Cancellation of WIC Policy Memorandum #2017-1
|DATE:||March 11, 2019|
|POLICY MEMO:||WIC Policy Memorandum #2019-1|
|SUBJECT:||Cancellation of WIC Policy Memorandum #2017-1, New MIS Guidelines and Revised Procedures for EBT and MIS Grant Funding|
WIC State Agency
WIC Policy Memorandum #2017-1, New MIS Guidelines and Revised Procedures for EBT and MIS Grant Funding, dated Oct. 18, 2016, is cancelled.
The Healthy, Hunger-Free Kids Act of 2010 (PL 111-296) requires all WIC state agencies to implement electronic benefit transfer (EBT) by Oct. 1, 2020, unless granted an exemption by the Secretary.
When FNS issued Policy Memorandum #2017-1 in October 2016, the Agency determined there was no longer sufficient time for a WIC state agency to select a management information system (MIS) that was not EBT-functional or make modifications to an EBT-functional MIS. In the memorandum, FNS communicated it would no longer approve state agency technology projects adopting a system currently in EBT or MIS development, or a system that only issued paper checks. FNS transmitted letters to the limited number of state agencies for which the policy applied, i.e., state agencies that had not implemented EBT statewide, and did not have an approved Implementation Advance Planning Document. In the letters, FNS listed MIS providers with known EBT-functional systems.
In 2017, FNS revised the policy after further consideration based on comments from affected state agencies. The Agency revised its approach by recommending, not requiring, such state agencies use an EBT-functional MIS. FNS communicated this policy preference to applicable State agencies via follow-up letters. This option provided applicable state agencies with greater flexibility to determine the best path forward based on the needs of the state to fully implement WIC EBT by the Oct. 1, 2020 statutory deadline.
FNS, through technical assistance provided in review of MIS plans, will continue to recommend, but not require, the selection of an EBT-functional MIS. Regardless of approach, WIC state agencies remain responsible for meeting the statutory requirement to implement EBT statewide by Oct. 1, 2020.
If a WIC state agency chooses to select an MIS that is not already EBT-functional or make modifications to an EBT-functional MIS, please note that customized systems typically take longer to develop and implement. Choosing this approach may put your state agency at risk of not meeting the statutory mandate.
FNS continues to use its formalized oversight process to ensure WIC MIS and EBT projects, funded in part or in whole by federal funds, reflect sound design and costs, contain internal management controls, and are procured in a way that allows for fair and open competition.
Supplemental Food Programs Division
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.