When conducting technology projects, WIC state agencies must comply with the Advance Planning Document (APD) requirements consistent with Section 17 of the Child Nutrition Act (P.L. 89-642, as amended), 7 CFR Part 246, and Federal procurement requirements at 2 CFR Part 200, Part 400, and Part 416.
On Aug. 10, 2011, we announced a time-limited, specific exception to the cost allocation requirements set forth in OMB Circular A-87 that requires benefiting programs to pay their share of the costs associated with building state-based information technology systems. This letter provides additional guidance on how states may take advantage of this exception to leverage these investments to serve multiple programs and needs.
In March 2007, WIC state agencies and regional offices received a memorandum that provided guidance on the process for State Agency Model (SAM) transfers. That guidance included: 1) the priority for funding, 2) the components of the streamlined Implementation Advance Planning Document (IAPD), and 3) examples of justification for non-SAM transfers.
FNS has become aware of a growing trend in states to consolidate or centralize some or all of the state's IT services across departmental lines. Because these organizational changes can have unintended consequences for our Food Stamp and WIC state agencies, we think it prudent to remind states of FNS requirements regarding such arrangements.
The purpose of the memorandum is to set forth policy in the APD process for the Special Supplemental Nutrition Program for Women, Infants, and Children. These policy changes and/or clarifications should lessen the burden of the current WIC APD process, and are effective immediately.
This policy memorandum outlines the requirements for the revised WIC Advance Planning Document process and provides additional guidance to state agencies that are interested in the transfer of a SAM system.
This memorandum presents FNS' position on Women, Infants and Children (WIC) Electronic Benefits Transfer (EBT) system development approaches and funding support.