Federal Regulations vs State Plan Differences
Comments provided by local program staff.
A. Extra hemoglobin at 1 year.
B. Requiring an infant hemoglobin at 8 1/2-9 1/2 months, again at 12 months, again at 18 months, and again at 24 months. As opposed to sometime between 9-12 months, then 6 months later and then at 24 months.
C.
D Require hemoglobin to be entered into computer for certification while Federal regulations wants within 90 days.
E. Hemoglobin within 30 days of certification (as opposed to 90 days).
F. I’m not exactly sure on this but I think that MT WIC requires a hemoglobin test more often than the Feds require.
G. Requiring list all nutrition risk codes vs identifying and listing one nutrition risk code.
H. No “not to exceed” amount on the checks for participants who prefer organic and would like the option of organic and would be willing to abide by the price limit and choose which items they buy in order to not go over the limit.
I. Proof of pregnancy which is optional in the Federal regulations.
J. Proof of pregnancy (already required by MT Medicaid, participants do not lie about pregnancy.)
K. Recently adding need for proof of
pregnancy and what qualifies as proof of pregnancy vs. proof of pregnancy is
optional to State, if State chooses to require this it can be just visual, or
requested if the is suspected fraud.
“Proof of pregnancy is not a mandatory condition of eligibility for the
WIC Program”. Participants are asked to
bring a lot of information and staff are required to document a lot of
information; if this potentially creates a barrier to service, as has been the
philosophy in the past, and adds to administrative tasks and time for both participant
and staff, does the cost outweigh the benefit, especially as is not required by
Federal Register.
L. Having to
enter everything in both the computer and the paper chart. The computer system did not simplify the
work, just added to it.
M State CPA
requirements much more restrictive that Federal; we need uniformity and
consistency across MT about who functions as a CPA; requirements are a
barrier to finding qualified candidates to hire.
N. CPA
requirements (state vs. federal)>
O. Could we
have a person work as an aide for a year and pass a competency test to be a
“certifier of the participants? The RD
and RN could then do nothing but education contacts with each participant and
high-risk participant. It would be a
more efficient use of WIC dollars since the RD and RN could see at least twice
as many participants in a day.
P. The zero
income form requirements are not consistent with the Federal requirements. There is a 30 day leeway for income per
Federal vs immediate per
Q. No income
households must declare in-kind housing and benefits.
R. No income
households must sign a statement of no income.
S. Validating
Medicaid eligibility in SIS. (2 comments)
T. Residency
proof, does it have to be a “service into the home” or could we use the 1040,
driver’s license or something else that exists in the chart? (2 comments)
U. Requiring
monthly visits on all infants their first 3 months, and the bi-monthly visits
on certain identified risks (anemia, growth concerns) vs. minimum of quarterly visits.
V. Initial
certification for the infant is not automatic as an infant of a WIC mom. The newborn must come in to the clinic. Newborns are at risk for exposure to viral
and bacterial illnesses circulating in the community when required to report within
the first days/weeks of life. Also, it
is a hardship for WIC parents to comply with this requirement.
W. Checking
initial contact date on the computer screen and transferring the date to the
Certification Form and Eligibility Statement.
Do we always need it on paper? (2 comments)
X. Voter
registration, is keeping the registration cards on the reception desk adequate?
(2 comments)
Y. Release of
information form, can the Certification Form and Eligibility Statement be
adapted as a release, rather than adding another piece of paper? (2 comments)
Z. Duplicate
end of certification notices. (2 comments)
AA. Breast pump
release forms could be simplified. (2 comments)
BB. Breast pump
tracking forms, much of the information is redundant, like phone number and
participant ID. (2 comments)
CC. Void/Reissue
forms for formula (how about screen 302 plus brief documentation in the chart?
(2 comments)
DD. Breastfeeding
history on the Special Formula Approval Form. (2 comment)
EE. Formula
authorizations on the computer (eliminate either paper or computer approval).
(2 comments)
FF.
GG. Tracking
returned and donated formula. (2 comments)
HH. Interruptions
to change food packages for aides (would it be possible to divide
“how-many-pounds-of-cheese” type requests from “increasing-formula provisions”
type requests, and allow the aides to do the “grocery request changes”. In a hospital setting, aides take menu
request and the dietitians simply assure the diet assignment.) (2 comments)
II. Food
package options exponentially increasing.
How to simplify? (2 comments)
JJ. Only RDs
approving special formulas. Many states
allow RNs to approve special formulas.
Do we really want to take both RN and RD time by creating an extra
interface? (2 comments)
KK. RD contacts
with high priority participants, rather than referrals (not positive about this
one) etc.
LL. Require 12
continuing education credits each year.
Where we live it is almost always at least 6 hours of travel both ways
plus the classes.
MM. Time studies,
are they required?
NN. A lot of
administrative time is needed for the forms, classes, monitoring, etc., how can
we condense? (2 comments)
OO. Farmers’
market participant survey, way too many surveys expected. How about a focus group? (2 comments)
PP. Farmers’
market tracking sheet. Could the state
office hire a work study student to hand tally the hundreds of priorities and
categories? (2 comments) Chris’s note: They no longer have to separate out counts by
priorities, only categories (P,B, N, C).