Confidentiality and Conflict of Interest Fall 2013

Terms of Agreement Vendor Responsibilities Vendor Provisions Incentive Items State Responsibilities Vendor Agreement

Routine Monitoring Visit Assess for program compliance Why State WIC Program representative Who Unannounced visit How

Routine Monitoring Visit Valid Health Permit Review invoices for formula purchases Review handling of food instruments Check inventory for MSR Document & discuss violations What

Handout

Compliance Investigations Federal program requirement Why State WIC Program representative Who Undercover buys or audit How

Handout

Formal Appeal Process Appeal an adverse action Why Vendor (business owner) Who Submit a letter Within 30 days of date of notice How

Formal Appeal Process Disqualification Application Denial Termination Peer Group Determination What WIC Vendor Agreement, Article I, Rule 13 Title 7 CFR, Part Title 22 CCR, Sections and Where

Vendor Information

Definition of Confidentiality Information collected by local WIC agencies about a specific WIC vendor or participant is confidential information and cannot be provided to anyone not directly connected with the administration or enforcement of the WIC program. Full text available at 7 C.F.R (d) and (e)

Vendor information that is Not Confidential… Vendor’s Name Store Name Store Address Store Telephone Number Store Website or Address Authorization Status

Vendor Confidentiality Confidential vendor information is any information about a vendor (whether it is obtained from the vendor or another source) that individually identified the vendor, except for vendor’s name, address, telephone number, website/ address, and authorization status. Full text available at 7 C.F.R (e)

Where do you find confidential information? Paperwork on file Notes

Maintain Security Paper Documents Follow document security instructions in WPM , item VI. Electronic Data CMB Chapter 2, I. Requirements, Section F. Information Technology and Technical Support Services

Proper Disposal Hardcopy  Shred and toss CD  Destroy and toss Electronic  Clean and sanitize hard drive

Local WIC Agency and Vendor

What is a conflict of interest? A conflict of interest (COI) occurs when the obligations of an employee to the WIC Program are influenced or compromised by self-interest, a prior commitment, competing loyalties, or an inability to be objective, and that which may or may not result in a financial gain.

Local WIC Agency Requirements (WPM ) 1. Establish a COI policy. 2. Ensure no COI exists. 3. Have staff sign a COI statement. 4. Make the COI policy and statement available to the State Agency. Local agencies may establish their own COI policy and statement.

LVL Responsibilities Train WIC staff on COI at least once per year (WPM ).

LVL Responsibilities Provide support to ensure your local WIC agency collects COI statements for all staff.

Example of COI You or any individual related to you by blood or marriage has a financial interest in any grocer authorized to accept WIC food instruments.

Testing Your Knowledge Conflict of Interest Scenarios

Is this a conflict of interest? An LVL provides a WIC participant the name and location of only a few WIC authorized vendors in the area.

Is this a conflict of interest? A WIC Authorized Vendor has a table set up at a community health fair sponsored by the county health department.

Is this a conflict of interest? A local agency WNA recommends large chain stores to a WIC participant because she believes these stores stock all the WIC foods and provide better customer service.

Is this a conflict of interest? A local agency site supervisor allows a WIC authorized vendor to place their weekly ad in the local WIC agency waiting area.

Is this a conflict of interest? A participant says they are new in town and would like a list of authorized vendors. The local agency front desk staff gives her a list of all the vendors in her neighborhood.

Is this a conflict of interest? A local agency Breastfeeding Peer Counselor encourages participants not to shop at a certain vendor because they are charging WIC shoppers high prices.

Is this a conflict of interest? An LVL makes arrangements to have a WIC outreach table at an event sponsored solely by a WIC Authorized Vendor.

Case Study

Primary State WIC Contacts Ruth Caldwell State WIC LVL Coordinator (916) Vendor Management Branch (855) Program & Business Integrity (800)

Your feedback is important to us! Scan and to fax to Ruth Caldwell at (916)

Thank you for joining us Such a full day of LVL training!