WIC Nutrition Risk Assessment Procedures to Expedite Service to Hurricane Katrina Evacuees
As part of the nutritional risk assessment, WIC regulations require at a minimum, height or length and weight measurements and a blood test for anemia. The blood test can be obtained within 90 days of certification for persons with a documented nutritional risk. Hurricane Katrina evacuees can be determined at nutritional risk since they are considered homeless. Therefore, the blood test can be deferred for 90 days. We will also allow the height or length and weight measurements to be deferred for 90 days, if necessary, to expedite the certification process. On a case-by-case basis the 90-day time frame may be extended based on the discretion of the State agency.

Every effort should be made to provide a full assessment at the time the individual seeks services to ensure that they are linked into the health and social services network in the State. This will ensure that WIC continues to serve as an adjunct to health care as it was designed.

Medical Documentation for Exempt Infant Formulas and WIC-eligible Medical Foods
WIC may provide, with appropriate medical documentation, exempt infant formula and WIC-eligible medical foods for participants with serious medical conditions. Due to the nature of the medical conditions of these participants, close medical supervision is essential for the continued monitoring of their health. WIC clinic personnel should refer individuals with serious medical conditions that require the use of an exempt infant formula or WIC-eligible medical food to local medical providers to ensure that the participant is linked to the health care system.

Section 246.10(c)(1)(v)(B) of the WIC regulations specifies the technical requirements for medical documentation. The medical documentation can be provided as an original written document, electronically, or by facsimile. Medical documentation also may be provided by telephone to a competent professional authority who must promptly document the information which must be kept on file at the local clinic. However, this method may only be used until written confirmation is received and only when absolutely necessary on an individual participant basis to prevent undue hardship to a participant or to prevent a delay in the provision of infant formula that would place the participant at increased nutritional risk. The local clinic must obtain written documentation of the medical documentation within a reasonable amount of time (i.e., one or two weeks’ time) after accepting the initial medical documentation by telephone. The written documentation must be kept on file with the initial telephone documentation.

In an effort to provide the best service to Hurricane Katrina evacuees, State agencies may exercise the following additional options:

1. Participants presenting at WIC clinics in a new State with a food instrument that specifies an exempt infant formula or WIC-eligible medical food may be issued food instruments for the specified item up to the end of their certification period.
2. Participants presenting at WIC clinics in a new State without a food instrument, but who can provide the name of the exempt infant formula or WIC-eligible medical food that the individual was receiving before relocating, may be issued a 1-month food instrument for that specific item.
3. Persons seeking WIC benefits who were not participants prior to Hurricane Katrina must obtain medical documentation prior to issuing the exempt infant formula or WIC-eligible medical foods.

Documentation of income, residency and identification
Per §246.7(d)(2)(v)(C) of WIC regulations, the income documentation requirement does not apply to an individual for whom the necessary documentation is not available or an individual such as a homeless woman or child for whom the agency determines the income documentation requirement would present an unreasonable barrier to participation. When using these exceptions, the State or local agency must require the applicant to sign a statement specifying why he/she cannot provide documentation of income. Such a statement is not required when there is no income.

Per §246.7(l)(2) of WIC regulations, the State agency may authorize the certification of applicants when no proof of residency or identity exists (such as when an applicant or an applicant’s parent is a victim of theft, loss, or disaster, a homeless individual, or a migrant farm worker). In these cases, the State or local agency must require the applicant to confirm in writing his/her residency and/or identity. Also, please keep in mind that there is no durational requirement. That is, length of residency cannot be a prerequisite to receiving WIC benefits.

Shorter Certification Periods
Section 246.7(g)(2) of the WIC regulations allows the establishment of shorter certification periods on a case-by-case basis. State agencies may want to consider this option for persons who may be temporarily residing within their jurisdiction.

Extension of Certification Period
Per Section 246.7(g)(3) of the WIC Program regulations, in cases where there is difficulty in scheduling appointments for breastfeeding women, infants and children who have not reached their fifth birthday, the certification period may be shortened or extended by a period not to exceed 30 days. This policy is available for clinics that are experiencing a shortage of competent professional authorities to perform certifications. In such cases, one month of food benefits can be issued to those participants until an appointment can be rescheduled.

Mailing WIC Food Instruments
We have received a number of inquiries regarding mailing of WIC food instruments due to the critical shortage of gasoline in some States. WIC Program regulations (246.12(r)(4)) allow mailing of food instruments to persons who are not scheduled for nutrition education or a second or subsequent certification. In light of the gasoline shortage, we will allow mailing of food instruments to those individuals who were scheduled for nutrition education, but not certification visits. The nutrition education visits should be rescheduled.

State agencies may not mail more than a 3-month supply of food instruments. If a State agency opts to mail food instruments it must utilize a system that ensures the return of food instruments if the participant no longer resides or receives mail at the address to which the food instruments were mailed. This policy is effective for food instruments issued between September and December 2005. In addition, we recommend the following policies with regard to the mailing of food instruments:

1. Use first-class mail with the following phrase added on the envelope "Do Not Forward, Return to Sender" or "Do Not Forward, Address Correction Requested."
2. Do not use window envelops as they can increase the incidence of stolen letters. Window envelopes provide an easy means of examining the content of the envelopes.
3. Do not identify the name of the WIC clinic or use the words "WIC Program" on the return address as this may increase the incidence of stolen mailed food instruments.