Summary report : first national state directors meeting on program management

              A NATIONAL
~STATE~
DIRECTORS\lb/
I I I I MEETING ON
PROGRAM<~ ) ) )
MANAGEMENT@
Special Supplemental Food
Program for Women, Infants
and Children (WIC)
Commodity Supplemental
Food Program (CSFP)
United States Department of
Agriculture
Food and Nutrition Service
L
PROPERTY OF JHE ~
LIBRARY ~
APR 301980 ~-
'1 niversity of North Carolina
zt Greensboro
Depository
SUMMARY REPORT
FIRST NATIONAL STATE DIRECTORS MEETING
ON PROGRAM MANAGEMENT
Our appreciation is extended to the workshop
leaders who submitted reports on their sessions.
Printed in March 1980
Compiled and Edited by Diane Berger
Typed by Linda Clarke
Copies Available From:
Jennifer R. Nelson, Director
Supplemental Food Programs Division
Food and Nutrition Service
United States Department of Agriculture
Washington, D.C. 20250
TABLE OF CONTENTS
INTRODUCTION I I I I I I I I I I I I I I I I I I I I I 2
LETTER FROM RosALYNN CARTER. , , , , , , , , , , , , , 5
EXCERPTS FROM SPEECHES OF USDA OFFICIALS
CAROL TucKER FoREMAN, , , , I I I I I I I I I I I I
RoBERT GREENSTEIN , , , I I I I I I I I I I I I I I
QuoTATIONS FROM GENERAL SEssroNs , , ,
REPORTS oN WoRKSHOPS
I 1- I I I I I I
7
13
19
VENDOR MoNITORING I I I I I I I I I I I I I I I I I 21
LOCAL AGENCY ADMINISTRATIVE FUNDING I I I I I I I I
NUTRITION EDUCATION I
CIVIL RIGHTS. I I I I
I I I
I I I
I I I I I I I I I I I I
I I I I I I I I I I I I
DELIVERY OF SERVICES TO MIGRANTS. I I I • I • I I I
INDIAN STATE AGENCIES - IssuEs AND NEEDS .•• , , ,
AUTOMATED DATA PROCESSING SYSTEMS I I I I I I I I I
WAREHOUSING I I I I I I I I I I I I I I I I I I I I
INVOLVEMENT oF CoMMUNITY REsouRcEs. , . , , • I I I
35
45
55
61
71
81
89
99
CoNcLusION . . . . . . . . . . , , • , , . , , . . . . 105
MEETING ATTENDEES - NAMES AND ADDRESSES, I I I I I I
Programs o1 the U.S. Department o1 Agriculture are
available to all eligible persons without regard to
race, sex, creed, color, or national origin.
I 106
INTRODUCTION
In our Nation, malnutrition and inadequate maternal and infant health
care are two of the most serious problems affecting low-income pregnant
women and infants. During prenatal development and the first few years
of life, sufficient and appropriate foods and the availability of proper
health care are essential to healthy physical and mental development.
Denial of either proper nutrition or health care can have serious consequences
for the future growth of an infant. Such ·denial can make the distinct
difference between a healthy, productive life or an unhealthy, non-productive
existence. The United States Department of Agriculture (USDA)
provides funds for two programs specifically designed to attack nutrition
problems in children and in pregnant or postpartum women: The Commodity
Supplemental Food Program (CSFP); and the Special Supplemental Food
Program for Women, Infants and Children (WIG Program). Each is briefly
described below.
The CSFP provides supplemental foods to low-income pregnant and
postpartum women, and to children under six years of age. In fiscal
year 1979 the CSFP served approximately 100,000 needy individuals monthly.
The Program is administered by various State Departments and is operated
out of local health or service agencies. The foods provided under
the CSFP are purchased by USDA and distributed to the States. The food
package currently includes infant formula, evaporated milk, corn syrup,
powdered milk, dehydrated potatoes, cereal, egg mix, peanut butter,
canned meat or poultry, juice, and canned vegetables and fruit. The
commodities are stored at warehouses and distributed directly to partici­pants.
Many participants prefer the CSFP because it offers a wider
variety of foods than does the WIG Program. Nutrition education is
provided at the local agencies.
The WIG Program provides supplemental foods to low-income pregnant and
postpartum women, and to children under five years of age, who are
determined to be at nutritional risk. Ih fiscal year 1979 the WIG
Program served approximately one and a half million needy individuals
monthly. The WIG Program is administered by State Health Departments
and Indian tribes, and is operated out of local health and service
agencies.
Most WIG participants obtain foods at local grocery stores by presenting
a voucher for specified food products which are prescribed to meet their
nutritional needs. Foods provided through the WIG Program currently
include milk, cereal, juice, eggs, cheese, and infant formula. Health
services may be provided either by the local agency or by another agency
or physician under contract to the local agency. Nutrition education
is provided at the local agencies. The combination of supplemental foods,
health care and nutrition education make the WIG Program extremely
effective in the prevention of health problems.
2
Purpose of National Meeting
The administrative structures of the two programs are very similar.
At the national level, the Supplemental Food Programs Division of the
Food and Nutrition Service (FNS) has the responsibility for both programs.
Each program is administered by a division of State government and at
the local level by a health or service agency. Those of us at USDA
who work on these programs believe that greater coordination between
agencies at the State and local level would be extremely helpful in
improving administration and the delivery of benefits. Many of the
problems faced by the State agencies are similar, and knowledge of
innovative approaches developed by one State can be of enormous benefit
to other States. Many State agencies are knowledgeable about programs
in various parts of the country, and States within the same geographic
region do meet periodically to discuss common problems. However,
administrative personnel from different regions of the country benefit
from expanded opportunities for the mutual exchange of information among
the people involved in administering the Program at the State level.
Therefore, a national meeting was sponsored by USDA on December 3-5, 1979,
in Albuquerque, New Mexico. Attendees included the State Directors
of the WIC and CSF Programs, members of the National Advisory Council
on Maternal, Infant and Fetal Nutrition, Federal government personnel,
and representatives of Native American Tribes and of advocacy groups.
The purpose of the meeting was to enable the various State Directors
and others in attendance to learn more about the operations of programs
in other States. Workshops were held in which the participants could
exchange their experiences and ideas. Another goal of the meeting was
to give USDA personnel a better sense of the State agencies' concerns
and to listen to suggestions for improvements which could be made at
the national and regional levels.
This publication attempts to summarize the speeches given, the ideas
shared, and the recommendations made at the various workshops held at
the First National WIC and CSFP State Directors' Meeting on Program
Management.
3
4
THE WHITE HOUSE
WASHINGTON
November 28, 1979
This nation's children are our most precious resource.
The future of our country lies ultimately in their hands
and they shall be the final judge of our determination to
give them every opportunity to become healthy, competent,
caring members of our society.
But, as you all know too well, there are many children
who we have already failed, v7ho v1ill grow up in this
affluent nation permanently disadvantaged because of the
lack of proper nutrition or adequate health care at an
early age.
It is a great pleasure for me to recognize you who are
involved in programs which are on the front lines in the
fight to raise the nutritional status of young Americans.
The Special Supplemental Food Program for vlomen, Infants
and Children and the Commodity Supplemental Food Program
have denonstrated their success in improving the health
and nutrition of mothers and children in America.
I salute you for your outstandir:g accomplis:b.ments and urge
you to bring the same dedication that has rr~rked your efforts
in the past to the operation of these vital programs in the
years ahead.
Department of Agriculture
National State Directors Meeting
Supplemental Food Programs
Albuquerque, New Mexico
5
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6
EXCERPTS FROM SPEECHES OF USDA OFFICIALS
Carol Tucker Foreman - Assistant Secretary of Agriculture
for Food and Consumer Services
I am happy to be here today to express to you, in the strongest possible
terms, the Carter Administration's unwavering commitment to both WIC
and the Commodity Supplemental Food Program. Secretary Bob Bergland
believes that they are among the highest priorities in the entire
department. He believes, and I concur, that they should rate the same
high priority in the Federal government as a whole.
Ten or fifteen years ago all you had to do to get money for a social or
health program was to say, "it is needed for a good cause." That statement
made, everyone jumped. Today it is different. Many good programs go
unfunded and needy causes go unmet because we worship at the altars
of balanced budgets and cost/benefit analyses.
WIC and CSFP programs are good programs, meeting a great need. They
also meet the needs of today's budgetary concerns. They are demonstrably
health effective and cost effective.
A considerable body of evidence shows that WIC has significant and
positive effects on the outcome of pregnancy and that WIC favorably
influences infant development. The programs you administer reduce
infant mortality rates, and help prevent severe birth defects, chronic
ill health, and subnormal development.
Studies Cited on Effectiveness of WIC Benefits
The Center for Disease Control studies found:
I Children enrolled in WIC for one year showed considerable improve­ments
in blood values.
I Children with lowest hemoglobin and hematocrit values showed
the most improvement.
I Children with low weight for height grew significantly during
the first six months of participation.
I Strong evidence suggests that the incidence of low-birth weight
babies is substantially reduced if mothers participate in WIC.
Additional studies reported:
• In Michigan - Participation in WIC reduced the percentage of
anemic women in the caseload from 30 to 6 percent.
7
I In Oregon - Participation in WIC reduced the percentage of anemic
children in the caseload from 13 to 1 percent.
I In Pennsylvania - Participation in WIC reduced the caseload infant
death rate from 10.6 percent to zero. Immature birth rates
decreased from 12.8 to 1.6 percent. Pregnancies with complications
were reduced from 30.9 to 17.6 percent.
I In Montana on seven Indian reservations - Participation in WIC
reduced the infant mortality rate from 31.5 per thousand to 16.6
per thousand.
I In Arizona - WIC participants recorded an 81 percent reduction
in anemia, an 82 percent reduction in underweight, and a 64
percent improvement in stature. The Public Health Service Indian
Hospital in Tuba City treats far fewer children for severe
nutritional diseases than it did a decade ago.
A study by the Yale Medical School and the Waterbury, Connecticut Health
Department found dramatic reductions in infant mortality rates as a
result of WIC.
WIC Is Also Cost Effective. WIC does more than just meet health needs
effectively. A study conducted at the Harvard University School of
Public Health found that each $1 spent on pregnant women in the WIC
Program results in a $3 savings in later hospitalization costs for
low birth weight babies.
Dr. Eileen Kennedy, one of the authors of that Harvard study, and
Dr. Sandra Huffman, who was recently named Chairperson of the Subcommittee
on Nutrition and Fertility of the National Academy of Sciences, are
now employed by FNS on our Policy, Planning and Evaluation staff.
These two women and ot~ers on the policy staff have just completed an
analysis of cost-benefit ratios in the WIC program. Their analysis
shows that WIC's role in helping to prevent birth defects, chronic ill
health, and subnormal development, not only enables individuals to live
healthier, more productive lives, it also averts major medical expenditures
and reduces a later need for special assistance programs, such as Medicaid,
SSI, and Special Education. The analysis finds that the prenatal
component of the WIC Program will cost $150 million in fiscal year 1980.
That sounds like a lot of money. It is a lot of money. But the expenditure
of that $150 million will result in a~otal savings of $550 million in
medical and special assistance costs which will have been averted.
The $150 million spent on WIC also results in a federal savings of $260
million in reduced Medicaid, SSI, and Special Education costs. These
savings are probably understated since several benefits were not included
8
in the computations. Based on conservative estimates the savings from
the WIG Program -- in decreased medical costs, decreased assistance payments,
and increased earnings resulting in increased tax revenues -- are greater
than the costs of the entire WIG Program for 1980.
I don't believe there is any federal program that can equal WIG's record
for effectiveness, efficiency, and compassion -- all the things that
President Jimmy Carter, and, I'm sure, everyone in this room, believe
that government should be. These are also· the reasons why we are committed
to continuing WIG growth in the years ahead.
WIG Food Package Proposed Rules
After perhaps the longest pregnancy in history, the proposed regulations
for the food package have finally been delivered -- and published.
The gestation period was long and the birth was difficult for a number
of reasons. Every effort was made to get all the relevant issues and
opinions expressed in advance and as you know, on this subject there
are a lot of opinions. The task was further complicated by these three
factors:
I Nutrition is a complex and constantly changing science and there
are gaps in our nutritional knowledge.
I As a result, there is little agreement on answers to what should
be in the WIG food package. There isn't even unanimity on what
questions should be asked.
I People, especially people at high nutritional risk, are not
nutritional clones. There is not one perfect diet which will
ensure good health, long life, and an end to hives and the common
cold.
The new regulations attempt to deal with these problems. They propose
tailoring the amount of food issued to the different ages and nutritional
needs of participants. The three current food packages would be replaced
with seven. They divide infants and children into four age groups,
and then deal separately with children with special dietary needs, pregnant
and breastfeeding women, and postpartum women.
The food package proposals have six major objectives.
(1) They reflect more accurately the infant's developmental needs
and pediatric feeding recommendations.
(2) They correspond more closely to the recommended eating patterns
for pre-school children.
(3) They meet the additional nutritional requirements of pregnant
and breastfeeding women, and encourage breastfeeding.
9
(4) At the option of the competent medical professional, they reduce
the amount of iron required in cereals for participants who
are not anemic.
(5) They limit sugar in cereals.
(6) They explore the option of including vegetables and whole wheat
bread in the package in the future.
I want to emphasize that these are proposed regulations. We need to
hear from you about them. You are the people who are out there, every
day, living with the problems, and dealing with them. We want your
comments. We need your help to make the final regulations the very
best that can be devised. Better to take the time now than have an
administrative nightmare later.
Commodity Supplemental Food Program
I want to lay to rest, if I can, the perception that CSFP is a stepchild
of the supplemental food programs, and that we at USDA give it lip
service, but little else. It's true that we don't have the same data
for CSFP as we do for WIC. But that's not due to lack of interest.
It's due to lack of legislation. And we are very interested in hearing
the results of Dr. Al Mauer's evaluation of the CSF Program at St. Jude's
Hospital in Memphis during your evaluation panel session.
When the WIC legislation was enacted, some people thought CSFP would
die. That didn't happen and won't happen. And the reason it didn't
and won't, is because of the tremendous local support for the program
where it exists. I reaffirm to you our belief that both WIC and CSFP
have unique functions and both make unique contributions to the people
we are trying to help.
I'm sure you know that we are in the process of revising the CSFP
regulations. Again, we need to hear from you. Now is the time to
be thinking about where the program should go in the future. Do we need
additional legislation? Should the program be more structured? How
about connections to health care and nutrition education? How can CSFP
and WIC mesh better in areas where they exist cheek by jowl? Or should
they? How should CSFP administrative funds be calculated? Should they
be based on the value of the commodities? And if so, which value?
USDA's or the retailer's price? Or should they be allocated based on
a flat percentage of the funds allocated for the program? Your answers
to these questions, or your opinions on whether they are even the right
questions, are crucial to a sound, effective program.
10
Program Funding
The message I came to bring is one of strong unqualified support for
both WIC and CSFP. These programs have had the strong support of this
Administration. In a time of very tight budgets, when funding for many
programs is being cut back, President Jimmy Carter, Secretary Bob Bergland,
and FNS Administrator Bob Greenstein have found scarce dollars to expand
the CSFP and WIC Program. Those dollars have been there because the
programs are good. They are serving a needy constituency and serving
it well. But there is one overwhelming truth about federal programs --
the more praise and adulation they receive early in life, the greater
the temptation to live on those laurels, to assume that more support and
more money will always be forthcoming, and to perhaps assume it is not
necessary to run the program efficiently. Praise and adulation are
transitory in our business. The honeymoon is rapidly coming to a close
and hard-nosed, steely-eyed investigators from GAO and OIG are looking
to see if we're anywhere near as good as we think we are.
GAO has begun to look closely at WIC and the USDA Inspector General
has raised the problem, which I view as very serious, of retailers
charging the maximum amount on the voucher, instead of the regular
shelf price, to WIC participants. Our programs are good and they
are working but there is still a great unmet need for WIC and CSFP
services. The programs will never grow to meet those needs unless
the administration of the programs grows better as they grow bigger.
That job is up to you.
Public Relations
There is another task you must take on. We live in a time when government
and government programs generally are held in minimally high regard.
Some of that is deserved -- but much is not. I believe that the increasing
lack of faith in use of government action to resolve difficult social
problems undermines an important element of our system of government.
You are responsible for important government programs that are working
well and are reducing serious health problems. Tell people about them.
Tell the people in your communities about the good things WIC and CSFP
are accomplishing for them. They should know their communities are better,
that health costs are reduced, and retardation is diminished because
pregnant women and children are eating better. Tell your Congresspeople
and your Senators. If they know and understand the value of WIC and
CSFP, two important things may happen. First, there is a much better
chance that you will get the resources necessary to serve all of the
population in need. More importantly, your fellow citizens will know
that their tax dollars are being well spent in a good cause; that government
can work to solve social problems; and that there is reason to support
a system which will not let the poor live hungry and sick in the midst
of plenty.
11
12
Robert Greenstein - Admini~trator, Food and Nutrition Service
Budget Process
The title of this part of the agenda is .the "politics" of food
programs. Part of the politics are within the Department and the
Administration itself. Each year in mid-July, the Food and Nutrition
Service recommends a budget to the Department for the succeeding
fiscal year. During August, all of the top officials of the Department
the Secretary, the Assistant Secretaries, the Inspector General, and
the General Counsel -- get together and they go over all the competing
requests from various agencies within the Department, because, were they
to fund all the requests from all the agencies -- and this is true in
any department --you'd be billions of dollars over the Department's
total target.
Subsequently in September, those recommendations go to the Office of
Management and Budget, which in a similar fashion arrays the requests
from all the departments against the total federal budget. In January,
they go to the Congress, and at that point it's sort of like the iceberg
coming above water -- that's where all of you begin to see what happens
with the Congressional process, although for us it's really the second
part of a year-long process. In Congress, the various appropriations
committees go over the budget, and appropriate what becomes the funding
for that year.
I won't go into great detail here, but I will say that I have not seen
that many markups or debates on Capitol Hill that match the debate and
the intensity of the markup within the Department of Agriculture in
August, when our budget decisions are made. Congress has basically
reflected the funding requested by the Administration for WIC for the
past few years, and Carol Foreman's strong role in the USDA meetings
has made the difference of tens of millions of dollars for the support
of the WIC program.
WIC Audit Findings
Budget debates continue to go on year after year and one of the people
I mentioned who is an important player in that debate is the Inspector
General of the Department of Agriculture. Shortly after the Inspector
General came to the Department, I had a conversation with him in which
he described to me some of his audit and investigation plans
for the coming year -- this was a couple of years ago. The plans at
that time did not include anything on the WIC program. And he mentioned
an impression we all shared at that time, that the WIC program really
seemed different from many of the other agriculture and food programs.
There was little discussion of serious problems in the WIC Program
and given that he had to target his audit resources, he was not going
to target a great deal towards WIC. That has changed. The fact of
the matter is that the WIC Program does have problems.
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Retail Problems
One of the most serious problems is the retail side of the WIC program.
A major audit was completed by the Inspector General recently on
the operation of the WIC program in one State. I sat in on a
meeting on that audit where I was shown and personally went through
stacks of vouchers. Evidence of fraud on the part of some retailers
audited was irrefutable. In the State that was audited, some
grocers had been routinely completing vouchers for the maximum
value or sending vouchers to the bank without filling in the value.
When a blank voucher was received at the bank, the bank redeemed
it for the maximum value. Or, vouchers were being altered.
The Inspector General is now studying the retail aspect of the
program in a number of other States.
Retailer Monitoring
As we have said over the years, the WIC program works well at the local
WIC agency and at the clinics. But that is not the entire program.
I think we all have a little bit of a perception problem. Those of you
who are in health departments and in nutrition units tend to see your
role as getting better health care to people, better nutrition education,
and making the programs run better at the local agency level. Most of
us have not seen ourselves as investigators in retail stores or as throwing
stores out of the program or bringing charges against them. We haven't
spent enough effort in doing those things.
We cannot continue to run the program by concentrating just on one side
of it and ignoring the other side. There is a need in many States
for more visits, more monitoring, more enforcement, and yes,
disqualifications of retailers who abuse this program. We're not going
to get anywhere if we do not start using penalties -- and it's time
to do that.
Results of Program Abuse
Abuse or fraud in any program in and of itself regardless of the consequences,
is something that is never excusable. But in this circumstance, the
consequences go well beyond that. The funds for the WIC program are
limited. Every dollar lost through abuse on the retail side is another
dollar that does not go to someone who is on a waiting list or to another
local agency that is still waiting to open a program. The very State
in which an audit found the problems, in the month of September,
restricted benefits to the higher priority participants in the WIC
program.
Financial Management
In the area of financial management there are similarly significant
problems. Again, many of us in focusing on the health and nutrition
aspects, have seen our roles as health administrators, as physicians,
14
as nutritionists, as dieticians and have not focused on the nitty-gritty
of financial management. As a result, in some States there is difficulty
in knowing on a timely basis how much money is actually being used in
the program.
It now appears that there is at least $30 or $35 million dollars that
was available and was not spent in the WIC Program in fiscal year 1979.
While States across the country cut back the program in September, funds
were sitting around unused. Many states that cut back on the program
actually had funds that were unused, but because the financial management
systems weren't geared up to deal satisfactorily with this, they did not
know in time that the funds were there.
Financial management is the other major focus on this new multi-State,
across the country, Office of the Inspector General audit and survey. Some
very hard questions will be asked and I imagine that they will probably
lead to further audits. I also understand that in both the retail area
and the financial management area where further audits are forthcoming,
that based on the findings in those audits, the Inspector General may
be asking FNS to establish over-claims against States to recover funds
that have been lost through some sort of negligence or mismanagement.
Clearly all of us need to work together to address these problems.
And in FNS, we need to do more and we need to give more assistance
to you, to address these problems.
Enforcement Actions
In the WIC Program and in our child nutrition programs as well, health
departments and education departments have historically not focused on
financial management issues. Nor have they been in the situation that
social service and welfare departments have traditionally been in, where
claims, sanctions and things of this sort are a basic part of operating
life and need to be dealt with quickly or else severe consequences result.
For years, in various public assistance programs and in the Food Stamp
Program, there have been warnings and eventually sanctions and withholdings
of administrative funds where serious problems were involved. In one
State the problems were so serious that FNS has been withholding nearly
half a million dollars a month in administrative funds from the State
food stamp agency. Within 30 days after the withholding was started,
massive clean-up began in that State and tremendous progress has been
made. In another State, shortly before the funds were about to be withheld,
the most massive corrective action program in the history of the Food
Stamp Program was issued. In yet another State, $1.8 million dollars
was actually withheld, and again substantial actions were forthcoming.
We must do more to enforce our supplemental feeding program requirements.
Congress has indicated where it wants to go in the area of enforcement.
Within the past year or 18 months, it has specifically written into both
child nutrition and WIC laws, specific authorities and directives for
15
the Department of Agriculture to withhold administrative funds where
serious deficiencies have been identified and sufficient corrective
actions have not been taken after warning has been given.
The WIC regulations that came out this summer do contain performance
standards that tie into a warning and a sanctions system. I certainly
hope it will ~ be necessary to come to that end. But I do want to
be very clear in saying that it is our intention to enforce these performance
standards and take them where they lead if that turns out to be necessary.
Funding Issues
First as I mentioned before, when money is lost to the retailers,
people and clinics are waiting in line and are not in the program.
Secondly, in some financial management systems, States don't know
how much money they have, and then the money isn't spent. The
majority of the people in the country who are in need of the program
are still outside it and are not being fed. We do not want our
financial management system to discover 100 days after the end of
the year that we restricted participation or cut people off the
program and that we have lost funds that went unspent. That is
not where we want to take a Program when our intention is to reach
more people.
We need to clearly understand as well that the entitlement and automatic
funding period for the WIC Program is all over. For years this program
had an automatic appropriation through a mechanism known as the Section 32
fund. For fiscal year 1979 and the current fiscal year 1980 there was
an automatic entitlement. In previous years the appropriations
committees had no say over what the funding level would be for
the WIC Program. That's now changed. Starting in 1981, there is££
automatic funding. There is no Section 32 money. There is no entitlement.
Every single year it will be up to the appropriations committees to
determine how much money is to be available in the program. And the
appropriations committees, I can tell you, look extremely closely at
issues of program management.
Summaries of Other Issues Addressed by Mr. Greenstein
t Reallocations - FNS needs your 1979 fiscal year reports as soon as
possible to complete the reallocation process. We are aware that State
agencies have had difficulties with the reallocation process and we are
considering some restructuring of the process.
t WIC Food Package - FNS needs your comments on the recently proposed
regulations. Pay particular attention to the iron requirements for
cereals. We have proposed that persons certified for participation
due to iron deficiencies continue to be prescribed cereals with at least
45 percent of the RDA for iron. Persons not certified for iron deficiency
16
may be prescribed cereals providing 25 percent or more of the RDA for
iron, with the caveat that the competent professional authority can
restrict those persons to the 45 percent cereal if they think there is
risk. We have indications that the cereals offered are not always
being consumed. So, in the proposal we attempted to make certain that
people with iron deficiency get cereal with high iron content, but
that others get a broader variety. If the cereal isn't eaten at all
it does not do a whole lot of good. However, a cereal manufacturer
that will lose a portion of the WIC cereal market is doing a massive
and sophisticated lobbying campaign on Capitol Hill, claiming that the
reduced iron requirement undermines the entire health purpose of the
Department. You should draw your own conclusions and send us your
comments.
I Proposed WIC Income Requirements - Our earlier income proposal requ~r~ng
all States to use 195 percent of the poverty level as the uniform national
income requirement met with considerable opposition. In the near future
we will publish a proposal of several possible income alternatives.
In that proposal we will solicit comments on the original income proposal
and on two new alternatives that we believe alleviate problems State
and local agencies are having with the new definition of "health services."
Some of you have told us that you have serious problems with that definition
and that you're afraid some clinics may have to drop out of the program
or that some clinics in rural areas where you want to expand may not
be able to get into the program. We've got two competing goals here.
We really want to reach those underserved rural areas but, we want to
have the best health services we can available for the target population.
I think we have told all of you that no clinics currently in the WIC
Program should be removed under those regulations. Instead, they should
be worked with to improve health services. Also, the definition is not
as restrictive as some people have interpreted it to be. In a few
instances people have believed that they could not satisfy the health
services requirements until they checked with FNS and found that they
could. When you submit comments on the proposed income regulations let
us know which alternative you prefer, why you prefer it and whether
or not that proposed income alternative solves any difficulties you
have with the definition of health services. If, regardless of the
new income alternatives, you still have problems with the definition
of health services you should submit comments expressing exactly
where and what problems exist. The comments should be very specific.
I Migrant Farmworkers - Serving migrant farmworker families is an area
where all levels of administration of the WIC Program have done an
inadequate job. Although we've tried several approaches we have still
failed to reach enough migrants. I was very disturbed to see that a
number of States that received special WIC allocations for migrants
did not use a substantial amount of those funds, and did not reach the
number of migrants they had hoped to reach when they received the
allocations. WIC staff members have too often assumed that general
publicity and simply having the funds available would work for migrants
17
as it does for the main target population. What is needed is stronger
outreach networks between local agencies and migrant camps. I hope
those of you who were successful last summer will share your experience
in our migrant workshop at this meeting. The Field Foundation study
earlier this year found tremendous progress in improving the health
of low income people over the last ten years through the food assistance
programs. However, they did find that one of the few areas where
the progress was not so good was with migrant farmworkers. We've
got to do a better job there.
t Rural Transportation - The use of administrative funds to transport rural
participants into clinics is an issue I'm particularly interested in,
especially with the energy crisis. I understand that in recent years,
legislation was passed which provides rural transportation grants
through the Department of Transportation. It is designed to fund
rural transportation systems in which individual programs, such as
WIC and CSFP could contribute to the overall amount of money, but
where the amount each program contributes is much less, because there
are some federal funds and because it is a "shared" transportation system
to which many providers contribute. In rural areas, we think that this
is something that is certainly worth investigating.
t Outreach - A few weeks ago we published final Food Stamp Program outreach
regulations. Those regulations require Food Stamp Programs to refer
potential eligibles to WIC and CSFP in areas where there are clinics
and caseload space available. In the WIC regulations we require WIC
clinics to refer potentially eligible individuals to welfare and Food
Stamp Programs. A number of food stamp outreach materials are now being
developed and should soon be available to you through the State food
stamp office. We think it is particularly important to establish very
tight effective referral systems between these two programs. People
can't eat just on the WIC foods, people can't pay their rent, or pay
their energy bills if they don't have the other basic sources of support
they need. These programs have been established by Congress, they
are available. We believe people who are in need of program benefits
should receive them.
Conclusion
I would like to close by saying that these programs are among the best
programs anywhere in the federal government. I think that with all
the things one can do in this society, it is a great privilege for all
of us to have jobs in which we can spend the working part of our lives
making the lives of other people better through our programs. Most of
the people needing these programs are still outside them and many people
are still suffering serious nutrition and health problems. Given
that all of these things are the case, we all must dedicate ourselves
to cleaning up these programs as rapidly as possible to make
sure that the programs and our own associations with them flourish.
Thank you.
18
QUOTATIONS FROM GENERAL SESSIONS
Mark Hollis, Vice President, Publix Grocery Stores
"In your job, you have a responsibility far greater than
just managing programs -- you also have the responsibility
of managing people."
"Management is simply defined as getting work done through
people."
"Your people will be motivated in direct relationship to
the personal motivation that you demonstrate by your leader­ship
patterns. In other words, you deserve the people that
you have."
Sarah Short, Nutritionist
"You can spend lots of money for food for your clients •••
but, if the people don't eat your food then what good is
it? That's why nutrition education is important for all
of you, for all of us."
"To make nutrition education exciting, to make it come alive,
you've got to have enthusiasm and you have to make it relevant
to the people's lives."
"You know your subject. Know your people and start with
what they want to know. Throw in what you think that they
should know and if the whole thing turns out to be the pits,
then start again."
Bill Wood, "Franklin the Good Food Friend"
"Live arts is an exciting format to use - it can certainly
get a lot of attention and a lot of interest."
"When I do a show, I do a variety of things. Talking about
an attention span, everything I do lasts about 2 or 3 minutes.
My thinking is that if children don't like what they are
seeing now they're going to see something different in 2
or 3 minutes.
19
Eugene Crawford, Executive Director, National Indian Lutheran Board
"More programs are needed of this sort; but, not only the
bandaid type programs to feed people, I think we have to
go deeper than this, and look at the roots, or causes, of
hunger, the things that are causing these people not to
have an adequate diet."
"There is a common ground where we can all walk together
and in many of the areas we do walk together; but, we want
to walk closer and we want to walk further together."
Pete Lee, MTO and Associates
"Because groups believe that they are unique by virtue of
belonging to a particular group, it is important that you
recognize, in delivering services, that you must work with
them from the standpoint of that uniqueness."
Thomas McBride, Inspector General, USDA
"During the audit process ••• you should get feedback ••••
Ours is a system of alliance rather than an adversarial
relationship, and nothing makes me happier than to see a
final audit report filed in which all corrective action
has been taken during the course of the audit."
"For those of you who are administrating WIC at the State
and local level, I think it is very important that you fight
for the proper priorities •••• You are the kind of front
line fighters to make sure you get the kind of resources
you need to keep the program clean, keep the program popular,
and let it grow."
20
VENDOR
MONITORING
ELIGIBLE
GROCER
22
VENDOR MONITORING
Introduction
On the opening day of the national meeting, FNS Administrator
Bob Greenstein strongly emphasized the necessity of WIC Program
integrity and accountability. He cited recent audit findings
which indicate serious vendor abuse of the WIC Program. He pointed
out that when vendors abuse the program to receive payments for
which they are not entitled, it is the applicants and local agencies
waiting for admittance i~to the program who are cheated. It is,
therefore, imperative that the WIC Program exhibit sound management
in order to serve as many participants as possible.
Background
The WIC Program has grown at a rapid pace for the past three years.
During the first few years of operation, FNS emphasis was on
promoting program expansion and formulating administrative policies.
Recently, however, we have seen a move toward tightening guidelines
to strengthen program operations. Indicative of this trend is
the provision in Public Law 95-627 for establishing performance
standards, with violations resulting in monetary sanctions. In
response to this legislative mandate, FNS has established WIC
Program performance standards and incorporated these standards
into WIC Program Regulations. Three performance standards were
specifically established to monitor food delivery aspects of the
WIC Program. These standards were designed to ensure Statewide
vendor reviews by each State agency, prompt transaction of food
instruments, and one-to-one reconciliation of food instruments.
(Food instruments will be referred to as "vouchers" in the remainder
of this chapter). Also indicative of the need to strengthen vendor
monitoring procedures are audit findings and the numerous requests
FNS has received over the past few months for information regarding
prevention of fraud, abuse and waste in the program. These requests
have come from Congressional offices as well as from administrative
areas of the government and from the General Accounting Office.
Food Delivery Problems
WIC agencies using the retail purchase system give participants
food vouchers which may be redeemed at authorized grocery or drug
stores for prescribed WIC foods. As of December 1979, almost
90 percent of WIC Program participants were served through the
retail purchase system, as opposed to the direct distribution
or home delivery systems. Although the retail purchase method
has many advantages, it has the disadvantage of being particularly
susceptible to vendor fraud and abuse.
23
Recent audit reports have highlighted the potential for WIC Program
mismanagement where the retail system is utilized, and further
emphasize the need for stronger monitoring and better control of
vendors. Major problems being reported by Office of Audit are:
I Vouchers being redeemed at maximum amount regardless of
cost of food purchased.
I Vouchers being altered.
I Vouchers being honored although due dates have expired.
I Lack of or illegible endorsements.
I Omission of purchase price on vouchers, which in some
States results in overpayment for vouchers.
Additionally, State Plans and Management Evaluation reviews continue
to indicate weaknesses in food delivery systems. FNS collected
data in October 1979 regarding food delivery systems in every
State. That data indicated these major weaknesses in food delivery
systems:
I Inadequate reconciliation.
I Cumbersome food delivery systems.
I Lack of computer edits.
I Inadequate voucher security.
I Inadequate training, guidance and monitoring of vendors.
When designing and implementing a food delivery system, State
agencies should consider their ability to monitor the food delivery
system chosen. USDA auditors and FNS will evaluate State agencies to
ensure that vendor monitoring activities are adequate to reduce and/or
prevent abuse. State agencies are fully responsible for monitoring
their food delivery systems in order to effectively distribute WIC
Program benefits with minimal program abuse. It is understood that
cost may be a constraining factor and that, in some cases, funds
available for monitoring delivery systems may be limited. However,
State agencies should strive to achieve the most effective monitoring
system obtainable with funds available for that purpose.
24
Vendor Monitoring Workshop
The vendor monitoring workshop had the benefit of the experience
of two Food Stamp Program employees who are responsible for the
vendor compliance operations in that program. The remainder of
this chapter will describe the methods used in both the WIG and
Food Stamp Programs to reduce vendor abuse. According to the
Food Stamp Program experts, vendor abuse is effectively reduced
through proper management of the following sequence of events:
(l) Vendor selection and authorization.
( 2) Vendor education and guidance.
(3) Monitoring vendor compliance.
( 4) Investigating vendors.
(5) Imposing sanctions upon vendors.
WIG and Food Stamp experience has shown that when these steps
are properly executed most vendors do comply with program require­ments.
Each step is discussed in greater detail below.
Vendor Authorization
Uniform Eligibility Criteria - Each State agency should establish
written standards and procedures for authorizing vendors to accept
WIG food instruments. A useful tool is a vendor application form
on which pertinent information is supplied. WIG agencies should
identify criteria for selecting vendors, such as:
I Location
I Prices of WIG foods
I Availability of WIG foods
I Hours of business
I Reputable business practices
Concern was expressed during the workshops as to whether these
criteria, or others which would limit the number of vendors,
might be challenged as illegal restraint of trade. The informal
opinion expressed by FNS representatives was that use of these
criteria would not constitute such restraint of trade. It was noted
that a natural tension exists between the need to keep the number
of authorized vendors at a manageable level, and the need to provide
sufficient WIG vendors to meet the regulatory requirements and
to assure WIG participant accessibility to vendors.
25
Written Agreements - WIC regulations require that the State or
local agency enter into a written agreement with participating
vendors. Some States require in the agreements that vendors
meet conditions in addition to those stated in the regulations.
These include requiring the vendor to supply monthly a price list
of WIC foods, and requiring vendor attendance at WIC educational
sessions. The vendor agreement should be signed by someone who
has the legal authority to obligate the store.
Vendor Education and Guidance
The primary goals of vendor education are to promote an understanding
of the WIC Program and the importance of the food package, to
elicit voluntary compliance with program regulations, and to answer
any questions vendors may have. Vendor education should begin
with the agency's first contact, and continue throughout the vendor's
association with the WIC Program. The purpose of the WIC Program,
proper use of food vouchers, and vendor payment procedures should
be discussed before the vendor agreement is signed. Written informa­tion
should also be provided. Onsite training at the time.of vendor
authorization is very desirable. According to WIC Regulations,
education of food vendors is a State agency responsibility; however,
the State agency may delegate all or part of the vendor education
to the local agencies.
Experience has shown that in most instances the following ideas
and techniques should be stressed in educational contacts with
WIC food vendors. This is not an exhaustive list and may be supple­mented
or amended at the State's discretion to correspond to the
State agency's particular delivery system.
I Purpose of the WIC Program. The prescriptive nature of WIC
foods as necessary to provide adequate diets and improved health
to participants should be discussed with vendors. Vendors should
be made aware that abuses of the WIC Program may negatively affect
the health of WIC participants.
I Stock of WIC Foods. Vendors, regardless of the delivery system
used, must ensure that all WIC foods are adequately stocked.
This point should be given considerable emphasis, since failure
to stock all authorized foods may result in food substitution
which defeats the purpose of the program.
I Potential Areas of Abuse. The following categories of abuse
have been found to be prevalent and should all be discussed with
vendors:
I Food Substitution. Vendors should be reminded that
only the foods specifically designated by the State
agency may be issued to participants.
26
I Price Differential. WIC Program participants should
never be charged more than the customary selling price
for the WIC items.
I Technical Abuses. WIC Regulations, such as cut-off
date provisions printed on the vouchers, should be
discussed as part of vendor education. Other account­ability
requirements imposed by the State agency
such as maximum dollar values on the vouchers, counter­signature
provisions, endorsement of vouchers, and
presentation of ID cards should also be the subject
of discussion with vendors. Additionally, State
agencies should provide educational materials to
banks handling WIC vouchers, to minimize abuse and
fraud at that stage of WIC transactions.
I Cash in Lieu of Foods. Vendors must never give
participants cash in place of the food authorized
on the food instrument.
I Onsite Visits • . Such visits have proven to be an excellent
tool for encouraging compliance with program rules and to promote
effective performance. Usually onsite visits constitute interviews
with the store manager and/or owner.
I Cashier Training. It is absolutely essential for cashiers to
be well educated about program rules. Educational contacts with
vendors should always include a discussion of the training provided
to cashiers. Some States reported that they had to take copies
of problem vouchers to the store manager to demonstrate the need
for cashier training. With the cooperation of managing vendors,
the State agency may wish to undertake direct group training sessions
for cashiers. An approach that has been effective for the Food
Stamp Program has been the inclusion of one or more lessons as
part of the cashier training program of chain stores and community
colleges. Cashier turnover has been cited as a problem in many
States and demonstrates the need for ongoing training and education.
I Educational Visits to Grocery Association Meetings. State
level WIC Program officials may find that grocer association
meetings present opportunities to "pass the word" about the
WIC Program. This heightens the visibility of the State's WIC
Program and provides positive public relations. On a practical
level, such opportunities should leave grocers better informed
about the WIC Program so that they may return to their stores
more qualified to instruct their employees.
27
I Visits With District Managers of Chain Stores. Since district
managers are responsible for the overall operating efficiency
of a group of stores, their support is very helpful in ensuring
high standards of vendor performance. Furthermore, if problems
occur at a specific store, the district manager may be able to
help in solving problems. Moreover, contacts with the district
managers may reduce the number of onsite visits necessary to
the stores under their jurisdictions.
I Civil Rights. Vendors must extend courteous and respectful
treatment to WIC participants. Vendors should be made aware and
reminded that they may not discriminate against program participants
because of race, color, or national origin.
I Mailings. Written educational information and advice, as well
as new policies, should be mailed to participating vendors from
time to time as the need arises. This can be a very effective
tool to communicate the ongoing needs and policy changes of
Statewide programs. Mailings can include program information
materials sent to individual vendors, chain store groups, retail
clerk unions, trade associations, dairy delivery companies and
others as appropriate, for distribution within their organizations.
To ensure that materials are read, only important information
should be sent by mail (the outside of the envelope could be
marked "IMPORTANT WIC INFORMATION"). Mailings should not be so
frequent that they are ignored. When mailing educational material,
it is a good idea to ask for return information. This helps to
ensure that it is read and also serves as a check that the store
is still in business.
Monitoring Vendor Compliance
There are three principal activities for monitoring vendor compliance:
(1) Analyzing voucher redemptions.
(2) Making onsite visits to vendors.
(3) Handling complaints.
I Analyzing Voucher Redemptions. The reconciliation of vouchers
serves an important monitoring function. In addition, routine
reviews of redeemed vouchers should be performed to look for
irregularities or questionable practices.
Most of the States with computerized food delivery systems use
edit·checks for monitoring. Edit checks can be used to maintain
control over lost, stolen, or counterfeit vouchers. Also, obtaining
monthly printouts indicating stores redeeming vouchers at maximum value,
or outside a specified average range, is of assistance in identifying
program abuse. A variety of cost parameters are used by State
agencies to establish edit limits. Such systems need continual
updating to ensure the timeliness of the data used. Follow-up
based on the edit checks is extremely important. In some States,
28
it is done on an individual voucher basis, while in others it
is based on store trends. The following two store trends were
among those cited as indications of the need for further inspection
of the vendor's practices: (1) voucher redemption figures that
consistently end in .00 or .50; and, (2) voucher redemption
prices that are often the same, although the prescribed items
are different.
Some States contract with a central bank to screen redeemed vouchers
for such things as price, alteration, vendor identification, and
expiration dates. The cost for such services varies from State
to State, but is usually at least five cents per voucher.
I Onsite Visits. Onsite visits to vendors should include checking
shelf prices, observing the variety and quantity of WIG food items
available, observing check-out practices, reviewing WIG Program
purposes and requirements with the manager, and offering to answer
questions about the program. If any program violations are observed,
they should be brought to the attention of the manager.
Onsite reviews may be triggered by information received from
participants. The idea of training and involving participants
in the vendor monitoring process received strong support in each
workshop. Participants can be helpful in observing whether the
cashier checks countersignatures, whether anyone ensures that only
the authorized items are purchased, whether the price charged for
the items is accurate, and so on.
Food Stamp Program field staff who are performing vendor compliance
reviews for that program are another important resource to be
contacted. Those field staff employees are often knowledgeable
about local vendors and their business practices. Establishing
relationships with food stamp field staff may be very beneficial
to monitoring efforts. Although the monitoring of the WIG Program
vendors is a State agency responsibility and the monitoring of
Food Stamp Program vendors is a Federal responsibility, the individuals
performing the monitoring can exchange information and improve
the job done by both groups. Furthermore, the Food Stamp Program
field staff have developed innovative and effective methods of
monitoring vendors and can provide direction to State agencies.
I Complaints. When a WIG agency receives a complaint about a
vendor, a clear description of the problem should be obtained
from the complainant. The agency should then bring this to the
attention of the store manager. Depending upon the nature of
the complaint, redress should be sought from the vendor, and any
29
incorrect practices should be changed immediately. An onsite
visit may be necessary and should include observation of all
aspects of the vendor's performance, and a discussion with the
manager.
Warnings and Investigations
Investigating vendors suspected of Program abuse goes a step beyond
monitoring. As stated previously, most vendors will comply with
Program requirements when they are made clear. However, when
a vendor appears to be out of compliance, the problems should
be clearly pointed out to the vendor. If the problems are not
corrected, a clear warning should be made that failure to comply
with the terms of the vendor agreement can result in the withdrawal
of authority to accept WIC food vouchers. If an oral warning
does not result in elimination of the problems, a written warning
should be sent by certified mail. In these warnings reference
should be made to the vendor agreement and its provisions regarding
the vendor's responsibility to comply with Program requirements.
Many WIC vendors also accept food stamps, which usually represent
a great deal more monetary value to the ~endor. A vendor who
appears to be failing to comply with WIC rules should be made
aware that disqualification from participating in WIC can also
result in further investigation and possibly the loss of the authority
to accept food stamps.
If, after onsite visits and formal warnings, there is reason to
believe that the vendor is still out of compliance, steps should
be taken to investigate and, if necessary, to remove the vendor
from participation in the WIC Program. The Food Stamp Program
investigation techniques can be used to investigate many types
of abuse such as the sale of non-WIC foods·, giving participants
cash in lieu of WIC foods, and charging participants more than
the customary price for WIC foods. Food Stamp Program vendor
investigations usually involve an attempt to purchase unallowable
items by a person posing as a participant, since this is a
frequent and easily detected form of Program abuse. This approach
can be used to observe WIC Program abuse as well.
State or local organizations and agencies with investigative
expertise may be willing to assist in the investigation of WIC
vendors. State agencies should enlist the assistance of community
or State groups which have such expertise, for example, Welfare
fraud associations and investigators, police investigative units,
State agencies which regulate the sale of liquor, and State
prosecutors.
30
Throughout this workshop, it was emphasized that prevention,
through authorization, training, and monitoring, is the most
important aspect to concentrate on and that investigations and
sanctions should be resorted to only if absolutely necessary.
Imposing Sanctions Upon Vendors
When it is established that a vendor is out of compliance with
WIG Program rules, several courses of action are available to
WIG agencies. Section 246.10(d)(7)(i) of the WIG regulations
provides for up to a one year suspension of vendors who abuse
the Program. In addition, in the case of deliberate fraud, vendors
can be subject to the penalties outlined in Section 246.18 of the
regulations.
State agencies should develop specific warning and sanction procedures
to serve as guidelines in individual cases. Workshop attendees
recommended that such standards not be so rigid as to eliminate
human judgment in determining vendor intent.
The costs involved in pursuing claims against vendors were discussed
at several workshop sessions. Some States have been successful
in recouping vendor overcharges, but many States have experienced
difficulties. It was agreed by most workshop attendees that a
point of diminishing returns can be reached, when it becomes
more expensive to pursue a claim than the amount being sought.
In some cases, legal action against a vendor can be based upon
State laws. Rather than rely upon generally applicable laws for
dealing with problem food stamp vendors, many States have passed
laws specifically designed to deal with food stamp abuses. It
was suggested that WIG State agencies consider requesting similar
State laws.
Some States have had problems persuading prosecutors to take
cases against WIG vendors. However, prosecutors might be more
willing to accept such cases if they were involved in the early
stages of the investigation process. Some workshop attendees
believed that prosecutors would be willing to accept cases against
WIG vendors because of the political value of opposing white-collar
crime and the loss of taxpayers' money.
Action should first be sought through the administrative procedure
of vendor disqualification rather than through legal prosecution
because of the cost and difficulties of court action. Regardless
of the course of action taken, retailer disqualifications should
be advertised in local media and in retailer association journals.
Such negative publicity serves as a deterrent to future vendor abuse.
31
Workshop Recommendations
Many workshop attendees were enthusiastic about increasing their
efforts to curtail vendor abuse. The workshops provided an
opportunity for State agencies to exchange different ideas on
methods currently used to monitor vendors. The following recommenda­tions
emerged from the workshops.
I FNS Assistance and Guidance. FNS should provide guidance concerning
the proper means and legal ramifications of conducting investiga­tions.
Food Stamp Program employees and field staff experienced
in vendor compliance operations should train FNS Regional Office
staff and/or State agency staff about investigative techniques.
Some workshop attendees also recommended FNS participation in
the vendor monitoring activities. In addition, State agencies
should seek assistance from existing investigative units within
the State government.
I Participant Involvement. WIC participants should be encouraged
to assist in monitoring vendors, because they are in the optimum
position to observe vendors' business practices and to hear of
abuse. Participants are a valuable asset in the monitoring process
and should be trained to assist State agencies.
I Food Stamp Store Authorizations. FNS should provide the State
agencies with the Federal requirements retailers (grocers) must
satisfy prior to receiving authorization to accept food stamps.
I Clear Food Voucher Design. Food vouchers should be carefully
designed to avoid complications and confusion for the vendors
and participants. The layout and print size used on the voucher
can result in erroneous charges. For instance, if the maximum
value of the instrument is printed in very large type, and the
words "actual amount of sale" are in very small type, there may
be a greater likelihood that the instrument will be erroneously
redeemed for its maximum value.
I Claims. FNS should establish a minimum dollar amount below
which State agencies could disregard making claims against vendors.
This recommendation was made because the administrative costs
involved in pursuing a small claim can exceed the amount of the
claim.
I Hotlines. State or Federal hotlines should be established for
reporting vendor abuse.
32
FNS Actions
I Participant Assistance with Vendor Monitoring. A task force
is currently developing methods for encouraging participant
involvement in the WIC vendor monitoring process.
I Data Base on Food Delivery Systems. The available information
on data such as retail systems, store authorization procedures
and ADP systems for monitoring is being compiled into a format
which lends itself to an evaluation of strengths and weaknesses
in monitoring procedures.
I Training on Vendor Monitoring. An evaluation is underway to
determine ways in which the Food Stamp Program compliance staff,
which monitors vendors, can train WIC Program staff or possibly
assist State WIC staff with vendor visits.
I Vendor Education Materials. Vendor education materials and
ideas will be compiled from State Plans and other pertinent sources.
Assistance will be sought out from major retailing chains, cashiers'
unions and small retailers to determine the materials which should
be used or developed for effective vendor training. The material
will stress correct voucher redemption, but will also address
appropriate behavior toward WIC customers. The training materials
may include a short film or slide show, a manual and brochures.
I Vendor Authorization. FNS will study vendor authorizations to
establish guidance and criteria for store selection. They will also
determine: (1) If it is feasible or necessary to limit the number
of authorized vendors; and (2) If it is feasible to use vendor-specific
vouchers (redeemable only at one designated store) to improve accountability
or, if such vouchers would impose too many difficulties upon participants.
I Monitoring Systems. Efforts will be made to define the tolerances
in price and error rates on vouchers that States should strive
to achieve in their monitoring systems. Voucher systems will
also be evaluated to determine the systems and types of vouchers
that provide the best means to control voucher redemption.
I Federal Hotline. State agencies which do not have a telephone
number available for reports of vendor abuse may direct callers
to the toll free hotline number for the USDA Office of the Inspector
General: 800-424-9121. Suspected abuse of any USDA program
can be reported through that telephone number. Callers within
the Washington, D.C. metropolitan area should use the local
number for the Office of the Inspector General: 474-1388.
33
34
...
LOCAL
AGENCY
FUNDING
36
LOCAL AGENCY ADMINISTRATIVE FUNDING
The local agency is the delivery site for both the benefits and services
to the participant. Consequently, USDA is very concerned about the
local agencies' abilities to meet the needs of the service area and to
improve the delivery of benefits and services. In both the WIC and
CSF Programs, specific regulatory requirements have been established
regarding the distribution of administrative funds to the local agencies.
This chapter discusses those regulatory requirements and the different
methods State agencies use to distribute administrative funds to local
agencies as discussed in the National Meeting Workshop.
WIC PROGRAM
Background - Requirements of Public Law 95-627 and WIC Regulations
As a result of P.L. 95-627, State agencies are required to distribute
WIC administrative funds to local agencies under allocation standards
developed by the State agency in cooperation with several local agencies.
Distribution of Funds, Section 246.14 of the WIC Regulations, includes
provisions to incorporate this requirement. In addition, the law and
the regulations require that such allocation standards take into account
factors which identify the varying needs of the local agencies.
Public Law 95-627 requires that State agencies develop a funding procedure
which furthers proper, efficient and effective administration of the
Program. State agencies must develop a funding procedure with the
cooperation of several local agencies which are a representative sample
and which take into account the varying needs of different types of
local agencies. This sample shall include a rural agency, an urban agency,
a small agency, a large agency and, where applicable, a migrant or Indian
agency. The procedure must use factors such as: the type and ratio of
staff needed to serve the estimated number of participants; the number
of participants served by the local agencies; the variation of salaries
of personnel; the types of equipment needed to be purchased for certifica­tion;
the expenses the local agency may incur for providing bilingual
services and material where the participant population contains a significant
proportion of non-English speaking persons; the cost of special services
needed to reach particular members of populations such as migrants and
Indians; costs related to rural and urban areas; and financial and in-kind
resources other than Program funds which are available to the local agency.
Need and Intent of Additional WIC Requirements - In the past, many State
and local agencies negotiated budgets mainly on the basic line item costs
such as salaries, supplies, etc. Sometimes, local agencies were not
able to comment on the budget authorized or on their operations. The local
agency was just informed of the funds they were to use to operate the
Program. In other States, locals were not provided with advance funds.
Expenditures were reimbursed as the costs were reported. As a result,
37
there was a lack of communication between the State and local agencies.
This lack of communication could also be found in areas other than funding
and caused many problems in the operation of the WIC Program.
Still, other State agencies employed the same method USDA used to
allocate funding, which was to allocate funds as a percent level of
the monies expended for food. As with the Department's method, when
State agencies allocated funds to local agencies on a straight percentage
of the food expenditures, the varying differences among local agencies
were not necessarily taken into consideration. The intent of both the
law and the regulations was to encourage State agencies, with input
from local agencies, to reevaluate their funding procedures to local
agencies and ensure that available administrative funds are distributed
in the most effective manner.
WIC Funding Procedures Presently in Use
The WIC Regulations issued July 27, 1979, required State agencies to
implement the requirement to develop a funding procedure for the alloca­tion
of fiscal year 1980 administrative funds to local agencies, and
to obtain input from the local agencies in this process. From a review
of the funding procedures submitted in the 1980 State Plans of Opera­tion
and Administration, and from discussion in the National Meeting
Workshop on Local Agency Administrative Funding, it was learned that
approximately one-half of the State agencies used a negotiated
budget, one-fourth used some kind of formula, and the remaining fourth
based funding mainly on a percentage of the food grant or on caseload.
The following is a discussion of those three methods State agencies
use to determine local agency funding and the issues that are of greatest
concern in each process.
I Negotiated Budgets
About half of the State agencies continue to use a negotiated budget
system for all or part of the local agency administrative funds. Some
States are using a straight line item budget which includes items such
as: salaries; fringe benefits; travel; equipment; supplies; automated
data processing; printing; telecommunication; indirect costs; rent; and
professional fees (audit). Several have developed other items of considera­tion
in determining the funds a local agency would be allocated. Some
additional items used are employment data, cost-of-living differences,
population density and the increased cost of serving certain clientele.
Monetary values are assigned to each item and the additional funds are
added to the proposed budget.
The negotiation process can be conducted in several different ways.
One method used is for the local agency to submit a budget to the State
agency. The State will then review the budget and either approve it
as submitted or discuss any changes with the local agency. The reverse
can also be employed. The State agency notifies the local agency of
what the State proposes as a budget for the local agency and the local
will either accept the proposed funding or make comment on it for further
negotiations.
38
Many State agencies find that negotiated budgets are the most flexible
and effective means of ensuring that each local agency's administrative
funding needs are met and in providing local agencies the opportunity
to participate in decisions. Other State agencies have encountered
problems in meeting the budgetary levels requested by local agencies,
verifying that costs listed are reasonable, ensuring that local agencies
allow sufficiently for future expenses and ensuring that small local
agencies obtain a fair share of funds.
To ensure the reasonableness of local agency budget requests, some
State agencies perform analyses of historical expenditures in various
cost categories. Other State agencies develop staffing standard guidelines
to use as a benchmark for staffing expenses (below is an example of
one standard) •
Number of Participants
Monthly
Under 50
51 - 150
151 - 300
301 - 400
401 - 500
501 - 600
601 - 800
801 - 1,000
1 '00 1 - 1,250
1 ,251 - 1 ,600
1 '60 1 -
Full Time Nutrition
Personnel
• 25
.5
.5
.5
1.0
1.0
1.5
1. 75
1. 75
1. 75
Other Full Time
WIC Personnel
.25
.5
1.0
1.25
1.5
2.0
2.5
3.0
3.5
3-75
Where State agencies encounter problems with local agencies expressing
concern that some other local agency is receiving a funding advantage,
some State agencies conduct budgetary meetings. At such a meeting
each local agency would present its budgetary request, justify the need
for the various cost categories and the group would reach a decision
on each budget. Generally, the local agency response is favorable to
this approach as it provides an opportunity to share in the decision making
process and learn the funding circumstances of other local agencies.
It is also helpful from the State agericy's perspective in that the
State is relieved of making subjective decisions on each budget independently
without the benefit of other local agencies input and expertise. This
system has also been found helpful in discussing the respective share
of funds and responsibilities to be assumed by the State agency and
local agencies.
I Percentage Funding
Many States still use a percentage method for all or part of the local
agency funding allocation. Most common is a funding method which
allocates funds on the basis of a percentage of the food grant or based
on caseload size. However, due to economics of scale and unique local
39
agency circumstances, most State agencies have introduced other elements
into this process. One system which uses a percent of the food grant
also brings into consideration the difference in urban and rural, and
large and small local agencies, by varying the percentage as the size
of caseload varies. For instance, if the caseload was 0-499, the local
would be allocated 20 percent of the funds allotted for food for administra­tive
costs. If the caseload was 500-999, the local would be allocated
17 percent. In this way, the higher costs of the smaller or more rural
local agency are taken into consideration.
Overall, it was found that this method is employed by State agencies
that believe the number 'of participants served is the single most
important factor in funding local agencies. However, it appeared that
State agencies are less inclined to use this method as the sole factor
in distributing funds due to other considerations not related to caseload
size.
I Formulas
Some State agencies select a formula for use in distributing allocations.
Many variations are used in the provisions and application of such
formulas. The formulas used pinpoint factors such as caseload, salary
levels and rurality as the most important measures of need among local
agencies. Some State agencies incorporate provisions such as those
used in the national administrative funding formula, including a minimum
grant and/or base grant, maximum grant, percentage guarantee, and
remaining funds distribution.
The formula is often a basis for allocating the largest portion of the
administrative funds and the remaining funds are distributed on a
negotiated basis. In some cases, a negotiated budget process is used
with a remaining funds portion distributed based on a formula.
In some State agencies, the formula is used as a starting point in the
budget preparation process. The State agency advises each local agency
of the funds allocated by the formula, then requests submission of a
line item budget. Some local agencies can justify an amount exceeding
the formula and others justify an amount of less than the formula.
Consequently, the end result is local agency budget requests that
eventually balance out within the State's administrative funds allowance.
A variation of this method is to use the formula as a base fund and
request a local agency budget which identifies activities or expenses
which cannot be funded within the formula-allocated level, but with the
requirement that all these activities or expenses be listed in order
of priority with the understanding that if the administrative funds cannot
cover all requests, only the highest priorities will be funded.
40
WIC Reallocation
In the course of discussion in the workshops, it was established that
as with administrative funding, reallocation is a multi-faceted issue
and has been dealt with differently among State agencies.
WIC Program regulations have established a policy of reallocation of
unspent funds in an effort to maximize Program growth and minimize unspent
funds. While this system has resulted in accelerated growth, it has
caused administrative problems (particularly with July allocations)
for State agencies which must amend contracts with local agencies.
One State agency dealt with this problem by designing a contract that
permits the State agency to increase or reduce the budgetary level in
a contract upon 30 days notice to the local agency. Understandably,
State agencies vary in the latitude permitted under State law and the
fiscal policy of each State, but generally, the greater the flexibility
in adjusting contracts, the easier it is to deal with the reallocation
process.
Aside from National reallocations, there are also many State agencies
that have a Statewide reallocation policy of some type to better ensure
utilization of funds. Other State agencies use an incentive system
to encourage growth. One incentive method is to incorporate in the
funding method a local agency's past performance in increasing participa­tion.
The incentive factor is based on the percentage of the eligible
population served by the local agency compared to the percentage of
the eligible population served which was set as a goal at the beginning
of the fiscal year.
COMMODITY SUPPLEMENTAL FOOD PROGRAM
Background of CSFP Regulatory Requirements
Until the passage of P.L. 95-113 in September, 1977, and the subsequent
issuance of the CSFP Regulations, the Program's appropriated funds had
only been used for purchasing the commodities while the cost of administering
the Program had been covered by State or local funds, or other third
party sources such as the Community Services Administration grants.
Since State involvement in the administration and funding of CSFP had
been minimal in most cases, local sponsors of CSFP had been most vocal
in demanding Federal assistance for administrative costs. The concerns
of the local agencies were particularly evident in the major metropolitan
areas served by CSFP. These local communities were suffering from a
tight funding situation in urban areas throughout the nation.
The Senate Select Committee on Nutrition and Human Needs had, over the
years, received very positive testimony with regard to the Program, and
as a result, wanted to preserve and improve it. The Committee, therefore,
submitted a questionnaire to Program Administrators soliciting recommen­dations
about the Program. Their response reaffirmed that the Program
41
had a very significant impact on the communities it served, but that
administrative funds were badly needed. Therefore, in September of
1977, P.L. 95-113 extended the authorization of the Program through
fiscal year 1981 and authorized USDA to provide each "State or local"
agency administering CSFP a certain share of administrative funds.
The final 15 percent level of funding administrative costs represented
a compromise position agreed upon by the Conference Committee on the
bill which became P.L. 95-113.
As stated above, since State involvement in the administration of the
Program was minimal in some cases, and local agencies were the ones
actively seeking the administrative funds, splitting the funds between
the State and local agencies would assure some funding for both parties.
Since both had some responsibilities, the approach provided USDA with
leverage for compliance and .corrective action at all levels.
After much deliberation, the Department decided upon the formula described
in the regulations published in March of 1978. Additionally, to further
ensure that the funds remaining after the State agency had received
its share were divided equitably among the locals, the regulations required
that those funds be allocated based on the need of the local agency.
After publication of the 1978 regulations, the Department received a
number of comments regarding the section on administrative funding.
Many of the comments requested changes in the method used by FNS for
computing State agency funding levels. The commenters also stated that
the burden of the cost of transportation of food within the State should
be borne by the local agencies rather than by the State agencies, or
that more monies should be given to the State agencies. Commenters
believed that State agencies were not able to retain sufficient administra­tive
funds to properly administer the Program. The Department agreed
that some changes were needed and as described below, revised the section
on administrative funding in the regulations published in March of 1980.
Former State Agency Administrative Funding Formula
In fiscal years 1978, 1979 and the first half of 1980 the amount of
administrative funds provided to each State agency was determined by
FNS each quarter based on 15 percent of the estimated value of the total
commodities ordered by all State agencies for the quarter. After the
total amount of the available administrative funds for the quarter was
established, FNS determined each State's share as follows. Based on
the most current month's, participation reports, the number of participants
in each State was divided by the total number of participants nationally.
This produced each State's percentage of national participation and, that
percentage was then multiplied by the total amount of administrative
funds available for the quarter to arrive at the State's quarterly
administrative allocation.
Complaints about that formula were that: States could not properly
plan or budget for each year because they did not know at the beginning
of the year what their total annual admiP-istrative grant would amount
to; quarterly computation of the administrative grants based on estimated
42
food orders resulted in great fluctuation in the grants from quarter
to quarter; some States received less than 15 percent and others more
than 15 percent of the commodities ordered in their State; and, the
formula did not result in allocation of all available funds. Therefore,
the formula was revised to ensure a more stable and equitable allocation.
Current State Agency Administrative Funding Formula
Effective April 1, 1980, the amount of administrative funds provided
to each State is determined annually, based on 15 percent of the total
funds appropriated for commodities for the CSFP for the fiscal year.
As with the former formula, each State's share is based on its percentage
of the national participation figures. However, participation figures
are no longer based on the most current month's participation reports.
Instead, the number of participants both nationally and in each State
are based on the average participation over a~ year period.
At the beginning of each fiscal year, States will be advised of the
projected amount of their administrative funds for the year. However,
the grants will continue to be allocated on a quarterly basis and if
the State agency is not meeting projected expenditures, such as when
the number of participants served by a State agency decreases, there
is the possibility of up to 25 percent of the funds being recovered
and redistributed to new State agencies or to State agencies with increasing
caseloads.
State Agency Share of Administrative Funds
The State agency must distribute the majority of the administrative
funds to its local agencies. The past and current CSFP Regulations
provide a limit to the amount of funds a State agency may retain at
the State level as determined by the following formula:
State Share -- 15 percent of the first $50,000
plus 10 percent of the next $100,000
plus 5 percent of the next $100,000
Based on that formula, the previous regulations restricted the State
agency to a maximum of $22,500 per year in administrative funds. However,
the current regulations provide two new revisions in the distribution
of funds between State and local agencies. These revisions address State
agency warehousing costs and the costs of transporting commodities to
local agencies. Each of these changes from the 1978 regulations was
made in response to complaints that some State agencies were unable to
administer the CSFP with the amount of funds they were allowed to retain
rather than pass on to the local agencies.
Warehousing. As previously done, storage and handling costs at local
warehouses will continue to be paid for by local agencies. However,
now State agencies with their own warehousing facilities are permitted
to keep additional administrative funds to cover some of the expenses
of those warehouses. With FNS' approval, the State agency may now retain
funds in excess of the $22,500 annual limit to cover warehousing expenses.
43
Transporting Commodities. The previous regulations prohibited State
agencies from charging local agencies for any portion of the expense
of transporting commodities to local agencies. The State agency had
to bear such costs along with its other administrative costs. In some
States, that resulted in insufficient funds for other necessary administra­tive
expenses. Consequently, the current regulations allow State agencies
to charge local agencies for transporting commodities within the State.
Local Agency Share of Administrative Funds
All remaining funds from the total allocation to the State and any
unused funds at the State level must be distributed to the local agencies.
The State agency disbursing ,the administrative funds to local agencies
must ensure that the local agencies evidencing higher administrative
costs, while demonstrating prudent management and fiscal controls, receive
a greater portion of the administrative funds. In essence, the CSFP
State agencies should be looking at some of the same factors as WIC
State agencies in allocating administrative funds to their local agencies.
These factors include warehousing costs, caseload, rurality, staff needed,
and variation in salaries.
At the present time, many of the CSFP State agencies distribute administrative
monies to the local agencies by negotiating budgets. Usually, this includes
using line items such as salary, rent, etc. Since the State agencies
who operate CSFP have funding requirements similar to those of WIC
State agencies, the discussion of different funding methodologies addressed
in the WIC Program portion of this chapter are also applicable to CSFP.
NUTRITION
EDUCATION
46
NUTRITION EDUCATION
The requirement that nutrition education be provided to CSFP and
WIC participants, is strongly supported at Federal, State and local
levels of program administration. There is a growing recognition
that nutrition education is an essential part of CSFP and WIC Program
services. The provision of food may encourage women to seek health
care services earlier in their pregnancy, however, continued long
term improvement in participants' health and nutritional status
is achieved through nutrition education which encourages and teaches
participants to develop and maintain optimal nutritional status.
In addition, nutrition education improves the nutritional well­being
of other family members who cannot qualify for the direct
benefits of supplemental foods and health services.
Legislative Background
Nutrition education has always been an integral component of the
WIC Program although not mandated in legislation prior to 1978.
Regulations issued to implement Public Law 92-433 (1972) identified
nutrition education as an example of an activity that States could
conduct as an adjunct to the WIC Program. Federal funds were
specifically authorized for nutrition education with the passage
of Public Law 94-105 (1975). This law required States to submit
a description of plans on how they would spend administrative funds,
including the manner in which nutrition education services would
be provided. The 95th Congress further strengthened nutrition
education in the WIC Program by requiring in Public Law 95-627 (1978),
that annual nutrition education expenditures are at least equal to
one-sixth of the State agency's total administrative expenditures.
The legislative mandate for CSFP, Public Law 95-113 (1977), depicts
the cost of nutrition education as a component of overall program
administrative costs.
Regulatory Goals
One of the major thrusts of the current CSFP and WIC regulations
is an increased emphasis on the importance of nutrition education
in the two Programs. In both programs, the goals of nutrition
education are to emphasize the relationship between proper nutrition
and good health, and to help participants achieve a positive change
in food habits by utilizing supplemental and other nutritious foods.
This is to be done in the context of the ethnic, cultural, and
geographic preferences of the participants with consideration for
educational and environmental limitations experienced by the participant.
47
Nutrition Related Health Problems
I Trends of General U.S. Populations As we prepare for the 1980's
we see that the nutrition-related health problems of the u.s.
population are changing. Today there is less under-nutrition than
there was ten years ago and there is little in the way of deficiency
diseases. 11~111 However, even today many low-income people are
still not getting enough to eat. While under-nutrition is still
a real problem in low-income groups, there is also a creeping problem
of over-nutrition. The over-consumption of saturated fats, cholesterol,
salt, sugar, alcohol, and calories is beginning to show a strong
relationship between diet and chronic diseases.
I CSFP and WIC Target Population - The CSFP and WIC Program were
started in response to public concern about hunger in America and
the realization that pregnant and breastfeeding women and infants
and children from low-income families are at special risk for under­nutrition.
These groups have additional nutrient requirements
associated with growth and development.
I Pregnant Women - The HANES and the DHEW Ten-State Nutrition
Surveys found that there were no clinical signs of micronutrient
deficiency for pregnant women. 11~1 However, biochemical evidence
indicated that iron and folic acid levels were low, especially
for black and low-income women. Dietary data substantiated these
findings. For low-income black women, the lower intake of iron
was due to the inadequate intake of total calories rather than
the lower iron content of foods consumed. These findings are not
surprising since during pregnancy the requirements for iron and
folic acid approximately double normal values. It is very difficult
to meet the requirements for iron and folic acid from the food
in a regular diet. Dietary data also indicated low intakes of
vitamin A and C. Other studies have shown that low socioeconomic
status women have marginal to deficient intakes of zinc. 5/
The most recent USDA Food Consumption Survey (1977) indicates that
energy consumption is down by about 20 percent, with an average
value of 1500 calories for adult women. 4/ The RDA is 2,000 calories
per day with a range from 1600 to 2400.*- This means that the average
woman is consuming less than the lower limit of the RDA. Caloric
intake during pregnancy must ensure adequate weight gain throughout
pregnancy. Inadequate weight gain puts the woman at risk for having
a low birth weight baby.
A reduction in total caloric intake can also mean a reduction in
nutrients. Therefore, it is vitally important that pregnant women
eat more nutrient-dense foods. The problems of over-nutrition are
also important for pregnant women. Obesity, hypertension and diabetes
are examples of nutrition related problems which can contribute to
complications in pregnancy.
*Recommended Dietary Allowances, Ninth Edition (1979, in press)
for female age 23 to 50 years.
48
1 Infants - National health statistics indicate that infant mortality
and low birth weight continue to be primary health problems, espe­cially
among low socio-economic status populations. The 1979
Surgeon General's Report Healthy People has as major goals the
reduction of the infant mortality rate and the number of low
birth weight infants. Two thirds of the infants who die weigh
less than 5.5 pounds (2500 grams). 6/ Low birth weight babies have
more neurological and physical handicaps and mental retardation.
Inadequate prenatal nutrition is one of the major factors associated
with infant mortality and low qirth weight.
The Ten-State Nutrition S~rvey found that the dietary intake of
infants was adequate for all major nutrients except iron. However,
the intakes contained a wide range of values including low values
for calories and vitamins A and C. 1/ Other studies have shown that
low socio-economic status infants also have marginal to deficient
intakes of zinc. 5/
In addition to the problems associated with under-nutrition, some
infants also suffer from problems associated with over-nutrition.
Infant obesity has been associated with increased bottle feeding.
It has been hypothesized that mothers may coax their babies to
finish a bottle rather than take the baby's cue that she/he has
had enough. 11 The early introduction of solid food has also been
associated with obesity.
Many of the problems with the over-consumption of salt and sugar
by infants have been solved by the elimination of these additives
from commercial baby foods. However, there continues to be a problem
with home-prepared baby foods. In a recent study on the sodium
concentration of homemade baby foods it was found that samples of
homemade foods had two to three times the amount of sodium as
commercial products. 21
I Children- A preschool nutrition survey (1970) found that there
are minimal overt signs of nutritional deficiencies in the preschool
population. ~/ However, dietary and biochemical data showed that for
low socio-economic groups, the overall quality of the diet was
poor and there were particularly low values for iron. Low values
for iron were found to be due to an inadequate intake of calories.
The HANES and the Ten-State Nutrition Survey data also showed low
values for vitamin A for low-income blacks and Spanish speaking
children. The preschool nutrition survey found that a high percentage
of low-income children were being given vitamin supplements. All
three surveys found that among low-income children there was an
increased incidence of children of small size for their age.
The Surgeon General's Report (1979) states that the main problems
for preschool children are problems associated with the over-consump­tion
of calories, sugar and fat. ~/ The report states that "Obesity --
a risk factor for hypertension, heart disease and diabetes -- frequently
49
begins during childhood." About one-third of today's obese adults
were overweight as children. An obese child is at least three
times more likely than another to be an obese adult. The over­consumption
of fat is also a concern because there is evidence of the
development of coronary arteriosclerosis in teenagers. The reduction
of fat consumption by children may reduce the level of fat in the
blood and thus reduce the risk of heart disease. The over-consump­tion
of sugary materials greatly affects the dental health of children.
Tooth decay begins about age three with the appearance of primary
teeth.
Delivery of Nutrition Education
Nutrition education must be an integral part of the CSFP and WIC
Program to ensure that the foods which have been prescribed to
help the participant are actually used to promote his or her health,
rather than eaten by other family members . The participant is at
a critical stage of growth and development in the total life cycle.
Therefore, the short term goals of nutrition education must deal with
the immediate needs of adequate growth and development for the individual.
Long term nutrition education goals need to encompass the entire life
of the individual. For women this will serve to improve the outcome
of future pregnancies by increasing nutritional status and by reducing
certain risk factors which could complicate future pregnancies. For
infants and children long term benefits will help to establish good
eating habit~ which will continue to ensure adequate growth and develop­ment
throughout life and, will limit the development of diet related
diseases.
I WIC Requirements During each certification period, each partici­pant
is to have at least one basic contact plus either a secondary
contact or a high risk contact.
The basic contact includes the explanation of one or more of the
following topics: 1) Any special nutritional needs of participants
and ways to achieve an adequate diet; 2) The importance of supple­mental
foods being consumed by the participant rather than by other
family members; 3) The use of the Program foods as a supplement
rather than a total diet; 4) The nutritional value of the supple­mental
foods; and, 5) The importance of health care. In addition,
all pregnant women must be encouraged to breastfeed their infants.
Also, appropriate guidance should be provided to all parents to
assist them in meeting the dietary needs of their infants and children.
Secondary and high risk contacts are more individually oriented
sessions which may include a discussion of the participant's specific
nutritional needs and the relationship of one's diet to health.
The high risk contact formalizes development of an individual nutri­tion
care plan.
50
I CSFP Requirements The CSFP Regulations require that nutrition
education include all of the subject matter areas as listed above
for the WIC basic contact.
Focus of Workshop
A mass media extravaganza by Dr. Sarah Short and an innovative
live arts performance by Bill Wood (Franklin the Good Food Friend),
were presented at the initial general session of the national
meeting. These excellent nutrition education presentations served
to set the stage for the workshops. The workshops provided a forum
for workshop attendees to: 1) Discuss the general session presenta­tions;
2) Make recommendations concerning nutrition education issues
raised; and 3) Share their State's most innovative nutrition projects.
The two innovative methods of nutrition education were presented
at the national meeting in response to a recommendation made at
the September 1979 National Conference on Nutrition Education.
At that conference, the task force on pregnant women and children
recommended that "In order to promote and maintain the health of
pregnant women, infants and children, today's nutrition education
messages and their method of delivery must be substantially changed."
The task force stated that the nutrition education message must
grow out of a recognition of nutrition's role in total health and
lifestyle, taking into account the need for individual and social
responsibility in carrying out this role. The delivery system
needs to promote attitudinal and behavioral change rather than
merely disseminate information.
Traditionally, nutrition education for the CSFP and WIC Program
has been centered around the professional nutritionist who under­stands
that in order to improve the participant's dietary practices,
many factors must be considered. These include cultural, biological,
psychological and socioeconomic factors. The nutritionist acts
as a "change agent" by motivating the participant to gain the knowledge,
skills and self-assurance necessary to practice new behaviors and
experience the long term benefits.
As we move into the 1980's we need to strengthen this change agent
approach by using more effective techniques of bringing about behavior
change in the CSFP and WIC target population. These techniques
will expand the traditional context of nutrition education to include
teaching methods from social psychology, anthropology, economics,
marketing, and advertising. The principles of marketing will need
to be applied in the design of relevant messages. Approaches
will need to be aimed at specific diet related behaviors such as
exercise, self-awareness, and self-control. Nutrition education
messages will need to be reinforced in settings beyond the local
agency, such as in schools, in homes, in the market place, and
with mass media.
51
Workshop Recommendations
Workshop attendees were very enthusiastic about using mass media
and live arts for nutrition education in the supplemental food
programs. The following recommendations emerged from the workshops:
I FNS should develop innovative nutrition education materials
at the national level.
I FNS should develop slide-tape presentations, video-cassettes,
public service announcements, and commercials for distribution
to State and local agencies.
I A manual outlining how to implement live arts nutrition
education should be developed for local agencies. The
manual should include sample scripts.
I FNS should develop a system for the exchange of nutrition
education ideas and materials.
Nutrition Education Information
Innovative State and local agency nutrition education materials
can be sent to the Food and Nutrition Information and Educational
Materials Center, National Agricultural Library, Room 304, Beltsville,
Maryland 20705 in care of Robin Frank. Copies of these materials
can then be made available for loan. In addition, State and local
agencies wishing to share innovative nutrition education materials
are encouraged to forward copies of the materials to the Supplemental
Food Programs Division, Food and Nutrition Service, USDA 20250.
At the national office the materials will be useful in the development
of national nutrition education materials and to promote nutrition
education at conferences and meetings.
52
REFERENCES
1. Ten-State Nutrition Survey 1968-1970. U.S. Department of
Health, Education and Welfare, Center for Disease Control: Atlanta,
Georgia, 1973.
2. Health and Nutrition Examination Survey (HANES) conducted
by the National Center for Health Statistics. Advance Data Report,
No. 6, March 30, 1977.
3. Kotz, Nick. Hunger in America - The Federal Response. The
Field Foundation: New York, 1979.
4. Hegsted, D. Mark. What Americans Are Eating Now - Preliminary
Results of U.S.D.A. Food Consumption Survey. Paper presented at
3rd Conference on Nutrition and the American Food System, Washington,
D.C., October, 1979.
5. Stanstead, Harold. Zinc Nutrition in U.S., Am. J. Clinical
Nutrition. 26: 12511260, 1973.
6. Healthy People- The Surgeon General's Report on Health Promotion
and Disease Prevention. u.s. Department of Health, Education and
Welfare, PHS, Office of the Assistant Secretary for Health and
Surgeon General: Washington, D.C., 1979.
1. Committee on Nutrition: American Academy of Pediatrics. Breast­feeding
- A Commentary in Celebration of the International Year
of the Child. Pediatrics. 62(4), October, 1978.
8. Owen, George M. et al. A Study of Nutritional Status of Preschool
Children in the United States- 1968-1970. Pediatrics 53(4):597-
646, April, 1974.
9. Kerr, Clark M. et al. Sodium Concentration of Homemade Baby
Foods. Pediatrics. 62(3):3315, September, 1978.
53
54
CIVIL RIGHTS
56
CIVIL RIGHTS
Background of Title VI of the Civil Rights Act of 1964
In the early sixties, an increased awareness of individual rights
resulted in the Civil Rights Act of 1964 which was launched by
the Federal government as an attack against racial discrimination.
Title VI of the Act prohibits discrimination on the basis of race,
color or national origin. This title was designed to ensure that
Federal funds are spent in accordance with the Constitution. It
enunciates the basic principle that Federal funds should not be
used to subsidize discrimination.
Section 601 sets forth the basic national policy which controls the
other provisions of Title VI. By its terms, discrimination on the
basis of race, color, or national origin is prohibited in any program
or activity receiving Federal financial assistance.
Section 602 is the body of Title VI. Congress intended that the pro­cedures
set forth in this section would ensure fair, consistent and
flexible application of the principle of nondiscrimination. This
Section directs every Federal Department or agency providing financial
assistance to issue rules, regulations or orders of general applicability.
Where an agency receiving Federal funds fails to comply with such rules,
informal voluntary compliance must be sought. If this is unsuccessful,
the Federal agency may effect compliance by a termination of assistance
to the offending program or activity. Any action to terminate funds
must be based on an express written finding of noncompliance after
opportunity for a hearing.
Section 603 provides that any action taken pursuant to Section 602
is subject to judicial review.
Section 604 prohibits discrimination in employment practices when the
primary objective of the Federal financial assistance to the receiving
agency is to promote employment.
Section 605 provides for protection of existing authorities with respect
to Federal assistance extended by contract of insurance or guaranty.
General USDA Requirements
As a result of the Civil Rights Act of 1964 each Federal agency, including
USDA, prepared regulations defining how the Act is to be implemented.
The USDA regulations require the following:
I Written Assurance - Every State agency application for participation
in program benefits must be accompanied by a written assurance agreement
that the applicant's program will be operated in compliance with
all requirements of the USDA regulations.
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I Public Notification - The State agency is required to ascertain that
all eligible persons, and particularly minorities, are adequately
informed through specific action and encouraged to participate in
the program. The State agency is also required to provide informa­tion
on the USDA nondiscrimination policy and procedure for filing
a complaint.
I Complaints - The State agency is responsible for an awareness of
the proper handling of complaints and shall not intimidate, coerce,
threaten or discriminate against an individual because that person
has filed a complaint. The identity of complainants shall be kept
confidential.
I Participation Data - The State agency is required to have available
racial and ethnic data showing the extent of minority participation
and potential participation in the program.
I Records and Reports - Each State agency must keep complete and timely
records and must make this information available to personnel for
review purposes. Failure to furnish such information should be noted
in the report.
I Employment - The employment practices of a State agency must not
adversely effect the delivery of program benefits and services.
I Site Selection - In determining the site or location of facilities,
the State agency may not make selections with the purpose or effect
of excluding or denying participation in the Program benefits.
I Affirmative Action - The State agency must take affirmative and correc­tive
action to overcome the effects of past discrimination. Even
in the absence of prior discrimination, the State agency may take
affirmative action to eliminate conditions which could result in
discrimination.
I Non-English Language Provisions - Where a significant number or propor­tion
of the population eligible to be served needs service or informa­tion
in a language other than English in order to be informed of
or to participate in the program, the State agency shall take reasonable
steps to provide information in the appropriate language to such persons.
Specific USDA Requirements
The State agency shall not, based on race, color, or national origin:
I Deny an individual any service, financial aid, or
other benefit provided under the program.
I Provide any service, financial aid, or other benefit,
to an individual which is different or provided in
a different manner, from that provided to others
under the program.