United States Government Accountability Office

GAO Report to Congressional Requesters

WIC PROGRAM 

More Detailed Price 

and Quantity Data 

Could Enhance 

Agriculture’s 

Assessment of WIC 

Program Expenditures

July 2006 

 

GAO-06-664 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

July 2006

WIC PROGRAM

More Detailed Price and Quantity Data 

Could Enhance Agriculture's Assessment 

of WIC Program Expenditures 

Highlights of GAO-06-664, a report to 

congressional requesters 

The Special Supplemental Nutrition

Program for Women, Infants and 

children (WIC), authorizes retail 

grocers, called regular WIC

vendors, to provide the food

benefit. Recently, some states have

seen an increase in vendors called 

WIC-only vendors, who stock only 

WIC food and accept only WIC 

vouchers. Both vendor types 

accept WIC vouchers in exchange

for a cash payment, or redemption, 

from WIC state agencies with U.S. 

Department of Agriculture (USDA) 

grant funds. To determine what 

effect WIC-only vendors’ growth 

would have on program

expenditures, in the absence of 

recent cost containment legislation, 

you asked GAO (1) what is known 

about WIC-only vendors’ growth 

and their share of the WIC market

in recent years, (2) to what extent 

do WIC-only and regular WIC 

vendors differ, and (3) what would

WIC-only vendors’ contribution to 

WIC program expenditures have

been, if their market share 

increased. GAO analyzed national

WIC vendor data, interviewed WIC 

state officials about vendors’ 

business practices, and analyzed

redemption data from California, 

Texas and Florida. 

What GAO Recommends

GAO recommends that the USDA 

Secretary require, if collecting 

detailed information on WIC food 

purchases is cost-effective through 

electronic benefits transfer, that

WIC state agencies collect data on 

the price and quantity of each food 

item purchased. USDA generally

agreed with our findings. 

The number of WIC-only vendors has tripled since 1999, with growth 

concentrated in a few states. However, WIC-only vendors’ share of the 

national WIC market was relatively small compared to that of regular WIC 

vendors in 2004. Nationally, WIC-only vendors increased in number from 394 

in 1999 to 1,180 in 2004, but 84 percent of these vendors are in California,

Texas, and Florida. Despite their growth, WIC-only vendors accounted for 3 

percent of all WIC vendors nationwide, and their market share, that is, their 

percentage of all WIC redemptions nationally, was on average 6 percent in 

2004. Because of limitations in the data, we were unable to calculate annual 

growth rates or analyze changes in market share over time. 

WIC-only and regular WIC vendors generally employed different business 

and marketing practices, largely in response to the two different customer 

groups they served, according to WIC state agency officials. Because WIC 

participants are not required to consider retail prices, WIC-only vendors 

competed for participants’ business by emphasizing customer service, which 

participants seemed to value. On the other hand, regular WIC vendors 

served non-WIC consumers as well as WIC participants. Because these nonWIC consumers are price sensitive, regular WIC vendors competed for their 

business based on price and competitors’ behavior. An important difference 

in these approaches was that because WIC participants were not price 

sensitive, they might choose the service offered by WIC-only vendors, 

regardless of price. Finally, WIC-only and regular WIC vendors used similar 

food purchasing practices, because the cost of food purchased for resale is 

related more to the volume purchased than to the type of vendor purchasing 

the food. Both WIC-only and regular WIC vendors were able to lower the 

average cost of food purchased for resale when they bought in volume, 

according to WIC state agency officials. 

If WIC-only vendors’ market share in 2004 had doubled in California, Texas, 

and Florida, either about 3 percent—about 136,000—fewer participants 

could have been served in each state, or program food expenditures would 

have increased about 3 percent—about $50 million—according to our 

scenario estimates. The average value of all vouchers redeemed by WIC-only 

vendors in 2004 was higher than the average value of all vouchers redeemed 

at regular WIC vendors. Thus, if the number of vouchers redeemed by WIConly vendors had increased and state food expenditures remained at 2004 

levels, fewer vouchers could have been issued, and fewer participants 

served. Conversely, if the number of vouchers issued remained at 2004 

levels, the higher average value of vouchers redeemed at WIC-only vendors 

would have resulted in increased program expenditures. However, the price 

and quantity of the individual food items that make up the vouchers were not 

available to us; therefore we could not determine if the higher average value 

of vouchers meant that prices for individual food items were higher at WIConly vendors. Making price comparisons would require food item price and 

quantity data for both WIC-only and regular WIC vendors, at a minimum. 

www.gao.gov/cgi-bin/getrpt?GAO-06-664.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cynthia 

Fagnoni at (202) 512-7215 or 

fagnonic@gao.gov. 
Contents 

Letter 1

Results in Brief 5

Background 8

WIC-Only Vendors Increased in Number during Fiscal Years 1999-

2004, although Their Market Share Remained Relatively Small in 

Fiscal Year 2004 15

WIC-Only Vendors and Regular WIC Vendors’ Business and 

Marketing Practices Differ in Their Approach to Customer 

Service and Price 23

We Estimated That Program Participation Would Have Decreased 

by about 136,000 WIC Participants or Expenditures Would Have 

Increased by About $50 Million if WIC-Only Vendors’ Market 

Share Had Doubled in 2004 32

Conclusions 37

Recommendation for Executive Action 38

Agency Comments 38

Appendix I Scope and Methodology 41 

Appendix II Number of WIC-Only Vendors, Fiscal Years 1999-2004 61 

Appendix III Average Monthly Redemptions per WIC-Only Vendor 

by State in Fiscal Year 2004 62 

Appendix IV WIC Vouchers Most Frequently Used at WIC-Only 

and Regular WIC Vendors in California, Texas and 

Florida 63 

Appendix V GAO Contacts and Staff Acknowledgments 68 

Page i GAO-06-664 WIC-Only Vendors 
Tables 

Table 1: Number of WIC-Only Vendors by State, Fiscal Years 1999

and 2004 17

Table 2: Estimated Change in the Number of Participants Served if 

WIC-Only Vendors’ Market Share Increased while Program 

Expenditures Were Held Constant at Fiscal Year 2004

Levels 33 

Table 3: Difference between the Average Value of WIC-Only and 

Regular WIC Vendor Food Vouchers in 2004 and the 

Market Share of WIC-Only Vendors in California, Texas, 

and Florida 34

Table 4: Change in Program Expenditures if WIC-Only Vendors’ 

Market Share Increases while Maintaining the Total 

Number of Food Vouchers at Fiscal Year 2004 Levels 36

Table 5: Time Periods Other than Monthly That WIC State Agencies 

Used in Reporting Fiscal Year 2004 Redemption Data to 

FNS 44 

Table 6: Example of Application of Model to Actual Data for 

California 52

Table 7: Example of Calculation of WIC-Only and Regular WIC 

Vendors’ Number and Average Value of Food Vouchers for 

California 53

Table 8: Example Calculation of Decline in Number of Participants 

for California 54

Table 9: Results of the Calculation of WIC-Only and Regular WIC 

Vendors’ Number and Average Value of Food Vouchers for 

California, Texas, and Florida 56

Table 10: Results of the Calculation of Decline in Number of 

Participants for California, Texas, and Florida 58

Table 11: Results of Allowing Program Food Expenditures to 

Increase for California, Texas, and Florida 59

Figures 

Figure 1: Sample Voucher from California 10 

Figure 2: National Total of WIC-Only Vendors 16

Figure 3: Share of Total WIC-Only Vendors Nationwide by State 

and the Top Three Metropolitan Areas in 2004 18

Figure 4: Percentage of Total WIC Vendors Represented by Each 

Vendor Type, Nationwide and in Select States 20

Page ii GAO-06-664 WIC-Only Vendors 
Figure 5: Average Monthly WIC Redemptions per Vendor in 2004, 

by Vendor Type 21

Figure 6: Share of Total Average Monthly WIC-Only Redemptions 

by State in 2004 23

Figure 7: Available WIC Food Items at WIC-Only Vendor in Texas 25

Figure 8: Interior of WIC-Only Vendor in California 25

Figure 9: Proximity of WIC-Only Vendor to WIC Clinic in Texas 28

Figure 10: Sample WIC-Only Vendor Promotional Flyer 29

Figure 11: Marquee of WIC-Only Vendor in Florida 30

Figure 12: Example of the Average Value of Food Vouchers 

Redeemed by a WIC-Only Vendor 48 

Figure 13: Example of Hypothetical Vouchers Specifying Price and 

Quantity 49

Figure 14: Average Monthly Redemptions per WIC-Only Vendor by 

State in Fiscal Year 2004 62

Figure 15: Most Frequently Used Vouchers for WIC-Only, Regular 

and State Total for California, 2004 63 

Figure 16: Most Frequently Used Vouchers for WIC-Only, Regular 

and State Total for Texas, 2004 64 

Figure 17: Most Frequently Used Vouchers for WIC-Only, Regular 

and State Total for Florida, 2004 66 

Abbreviations 

EBT electronic benefits transfer 

FNS Food and Nutrition Service 

GIS geographic information system 

IOM Institute of Medicine 

ITO Indian Tribal Organization 

MSA metropolitan statistical area 

TIP The Integrity Profile 

USDA U.S. Department of Agriculture 

WIC Special Supplemental Nutrition Program for Women, 

 Infants, and Children 

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page iii GAO-06-664 WIC-Only Vendors 
United States Government Accountability Office

Washington, DC 20548 

 

July 28, 2006

The Honorable Tom Harkin 

Ranking Democratic Member 

Committee on Agriculture, Nutrition and Forestry 

United States Senate 

The Honorable Herb Kohl 

Ranking Democratic Member 

Subcommittee on Agriculture, Rural Development and Related Agencies 

Committee on Appropriations 

United States Senate 

Each month, the Special Supplemental Nutrition Program for Women, 

Infants, and Children, better known as WIC, provides nutritious food, 

nutrition education, and referrals to health care to more than 8 million 

low-income women, infants, of Agriculture’s (USDA) Food and Nutrition 

Service (FNS) through WIC state and local agencies that implement the 

program and manage the food delivery system. WIC is a discretionary 

program, as Congress does not set aside funds to allow every eligible 

individual to participate, and was funded at a level of more than $5 billion 

in fiscal year 2005. 

In most states, WIC participants receive vouchers to exchange for food 

from authorized retail grocery stores that are known as WIC vendors in the 

program.1

 These vouchers provide participants with a prescribed type and 

quantity of supplemental WIC foods tailored to their health needs, such as 

infant formula, milk, and peanut butter. Participants generally are not 

required by the federal WIC program to obtain all items on a voucher. 

However, they may not use the voucher to purchase items that are not 

listed on it. Because participants receive food in exchange for their 

vouchers, without exchanging any cash, their purchasing decisions are not 

price sensitive, that is, they do not need to consider the prices WIC 

 1

WIC participants may receive benefits in the form of checks or vouchers, also called food 

instruments by the WIC program. We refer to both forms as vouchers for the purposes of 

this report. 

Page 1 GAO-06-664 WIC-Only Vendors
vendors charge for the items.2

 The vendors, which include independent 

stores as well as national and local chains, accept the vouchers and 

exchange them for a cash payment, or redemption, from the WIC state 

agency. Until recently, retail grocery stores that commonly carry a variety

of foods including supplemental WIC foods—or regular WIC vendors, as 

they are referred to in this report—represented 98 percent or more of the 

stores each WIC state agency authorized as WIC vendors. However, 

beginning in about fiscal year 2000, some WIC state agencies noticed an

increase in another type of authorized vendor in the WIC vendor market, 

one that sells only WIC-authorized food items to program participants and 

accepts only WIC vouchers. Prior to changes introduced by the Child 

Nutrition and WIC Reauthorization Act of 2004, these vendors were called 

WIC-only vendors.3

 With data reported by the WIC state agencies, FNS has 

tracked WIC-only vendors’ redemptions since 1998, but little else is known 

at the national level about the percentage of total WIC redemptions that 

WIC-only vendors are receiving, that is, their market share, or about their 

business practices. 

Questions have been raised about whether WIC-only vendors charge 

higher prices than other vendors and therefore will place a higher demand 

on overall program expenditures over time. If so, the WIC program may 

need to restrict program participation or seek additional funding. 

Concerned about the potential consequences of increasing claims on 

program funds, in fiscal year 2004, Congress established cost containment

provisions to ensure that the WIC program is not charged more for food 

items obtained at WIC-only vendors than it would be for the same items at 

regular WIC vendors.4

 Also, in fiscal year 2005, Congress prohibited the 

 2

While the WIC program generally does not require participants to pay attention to vendor

prices, some WIC state agencies, such as that of Texas, for example, require WIC 

participants to obtain the least expensive brand of certain items (e.g., juice) with their 

voucher. 

3

The Child Nutrition and WIC Reauthorization Act of 2004, Pub. L. No. 108–265 (2004), 

created a new category of vendors referred to as above 50 percent vendors, vendors whose 

revenue from the sale of WIC food is more than half of their annual revenue from food

sales, as part of an overall cost containment strategy. This new category includes WIC-only 

vendors. In this report, we used the definitions established by FNS prior to the changes

brought by the reauthorization because those definitions conform to the redemption data 

provided by FNS and WIC state agencies for our analyses. 

4

The Child Nutrition and WIC Reauthorization Act of 2004 established cost containment

provisions that require WIC state agencies to implement a vendor peer group system that 

groups stores according to similar characteristics in a way that ensures that all authorized

vendors are paid competitive prices for WIC food. 

Page 2 GAO-06-664 WIC-Only Vendors
payment of administrative funds to any state agency that authorized any 

new WIC-only vendors, unless deemed necessary to ensure participant 

access, for 2 years.5

 To determine what the effect of WIC-only vendors’ 

growth on WIC program expenditures would have been without the recent 

cost containment changes and the prohibition on authorizing new vendors, 

and to better understand how they do business, you asked us (1) what is 

known about WIC-only vendors’ growth and their share of the WIC market 

in recent years, (2) to what extent do the business and marketing practices 

of WIC-only and regular WIC vendors differ, and (3) what would WIC-only 

vendors’ contribution to WIC program expenditures have been if their 

market share increased.

To find out what is known about WIC-only vendors’ growth and their share 

of the WIC market in recent years, we analyzed data from FNS’s 

administrative data files on the national WIC vendor population—The 

Integrity Profile (TIP)—for fiscal years 1999-2004 to determine the number 

and distribution of WIC-only vendors. We focused exclusively on data

from the 50 states and the District of Columbia, and excluded from our 

analysis any vendor type other than WIC-only vendors and regular WIC 

vendors.6

 To determine WIC-only vendors’ share of the WIC market, we 

analyzed redemption data for an average month in fiscal year 2004 from 

FNS’s regional office files.7

 However, because TIP does not record when 

vendors enter or exit the WIC program, but instead records any vendor 

that participated in WIC during the fiscal year, it may overstate the number 

of vendors in operation at any point in time. As a result, we calculated the 

number of WIC-only vendors in the program each year, but we were 

unable to determine percentage-based growth from year to year. In 

addition, because national redemption data for fiscal years 1999-2004 did

not meet GAO’s data reliability standards, we could not use these data to 

 5

The Consolidated Appropriations Act of 2005, Pub. L. No. 108-447 (2004). The prohibition 

applied to those WIC vendors expected to derive 50 percent or more of their annual 

revenue from WIC vouchers. This prohibition was extended for fiscal year 2006, and the

President’s fiscal year 2007 budget proposal seeks a continuation of this prohibition 

through the fiscal year. 

6

Vendor types excluded from our analysis include military commissaries and pharmacies. 

See the background section for more information on these vendor types. 

7

Most redemption data from WIC state agencies were reported as average monthly 

redemptions in fiscal year 2004. According to FNS, this amount may represent either the

average monthly value of WIC vouchers over a 3-6 month period or a recent month that 

accurately reflects a vendor’s normal redemptions. See appendix I for additional 

information. 

Page 3 GAO-06-664 WIC-Only Vendors
analyze changes in WIC-only vendors’ share of the WIC market over time.

However, the fiscal year 1999-2004 TIP data on the number of vendors and

FNS regional office redemption data were sufficiently reliable for our 

purposes.8

To determine the difference in WIC-only vendors and regular WIC vendors’ 

business and marketing practices, we interviewed WIC state agency

officials in seven of the eight states that had authorized more than 10 WIConly vendors in fiscal year 2004: Alabama, Arkansas, California, Florida, 

Georgia, North Carolina, and Texas.9

 To complement these telephone 

interviews, we visited 4 WIC-only vendors and 4 regular WIC vendors in 

California, Texas, and Florida, for a total of 24 site visits. Our vendor 

selection criteria included urban and rural locations, years in operation, 

and redemption practices. WIC state officials’ accounts and the site visits 

to vendors provided insight into the distinctions in WIC-only and regular 

WIC vendors’ business behavior, but were not quantifiable or applicable

beyond the states and vendors they represented.

To calculate the contribution of WIC-only vendors to WIC program 

expenditures, we obtained administrative data from the California, Texas,

and Florida WIC state agencies on the redemption value for every voucher 

redeemed in those states in fiscal year 2004. We selected these three states

because they represent more than 80 percent of the national WIC-only 

vendor market. Because we needed data on both the price and the quantity

of WIC food items purchased from WIC-only and regular WIC vendors to 

isolate the effect of WIC-only vendors’ prices on program expenditures, 

and both of those data elements were not available from any existing data 

 8

See the discussion of our data reliability assessment procedures in appendix I. 

9

Because of Hurricane Katrina, Louisiana, one of the states with more than 10 WIC-only

vendors, was not included. 

Page 4 GAO-06-664 WIC-Only Vendors
source, we developed a scenario analysis that used redemption data.10 We 

used the redemption data to determine the actual number of vouchers 

redeemed and to calculate the average value of all vouchers redeemed in

each of the states by WIC-only and by regular WIC vendors. We applied the 

number of vouchers redeemed and the average value of all vouchers 

redeemed to the scenario analysis to estimate the effect on program 

participation and expenditures of successive increases in WIC-only 

vendors’ market share. However, because redemption data do not break 

out the price and quantity of the individual food items on each voucher, 

we could not determine whether prices of individual food items were 

higher at WIC-only vendors than at regular WIC vendors. Thus, even 

though we were able to calculate the average value of all vouchers 

redeemed by both types of vendors, we were not able to explain why the 

values may have been different. 

Appendix I provides a detailed description of our methodology and its 

limitations. We conducted our work from April 2005 through June 2006 in

accordance with generally accepted government auditing standards. 

The number of WIC-only vendors has grown substantially in recent years. 

However, their location is concentrated in a few states, and their share of 

the national WIC market remained small in 2004. The number of WIC-only

vendors in operation at any point during the fiscal year increased from 394 

in 1999 to 1,180 in 2004. WIC-only vendors are concentrated 

geographically: in 2004, 84 percent of all WIC-only vendors operated in 

California, Texas, or Florida, home to nearly a third of all WIC 

participants. Moreover, nearly half were located within three metropolitan 

Results in Brief 

 10The California, Texas, and Florida WIC state agencies periodically collect data on WIC

vendors’ shelf prices, but they do not collect data on both the price actually charged and 

the quantity of each WIC food item purchased with each WIC voucher. The California and 

Texas WIC state agencies maintain the shelf price data they collect during vendor 

monitoring visits in paper records and do not enter it into the automated management 

information systems they use to monitor vendors’ redemption claims. The Florida WIC

state agency transfers the shelf price data it collects during monitoring visits to an EXCEL

spreadsheet but does not incorporate these data into the state agency management 

information system. The California WIC state agency also sponsored a survey in fiscal year

2003 that collected shelf price data from a random sample of the state’s WIC vendors, but

this survey did not collect data on food item purchases. The Texas WIC state agency is 

currently conducting a pilot project for electronic benefits transfer (EBT) in selected areas

of the state that collects WIC transaction data, including the type of food item purchased, 

the quantity purchased and the price paid, and stores it electronically in the EBT system. 

These data may be useful for future research. 

Page 5 GAO-06-664 WIC-Only Vendors
areas: Los Angeles, California; Riverside, California; and Miami, Florida. 

Notwithstanding the increase in WIC-only vendors, in 2004 they 

represented only 3 percent of the approximately 45,000 WIC vendors 

nationwide. Although we could not determine the growth of WIC-only 

vendors’ market share over time, WIC-only vendors generated 6 percent of 

business in the WIC market on an average monthly basis in 2004, 

compared to the 94 percent generated by regular WIC vendors. However, 

on an individual store basis, WIC-only vendors redeemed about twice the 

monthly average redemption value of regular WIC vendors. 

WIC-only and regular WIC vendors used different business models, 

reflecting, for the most part, the different customer groups they served,

according to WIC state agency officials. Because WIC participants are not 

price sensitive, WIC-only vendors competed for their business by 

structuring their stores to emphasize customer service, which participants

seemed to value. For example, to simplify the WIC food purchase, 

officials pointed out that WIC-only vendors often gathered the food items 

listed on the voucher for WIC participants from food maintained behind a 

counter. This practice eliminated the stigma participants may feel because 

of backups in regular WIC vendors’ checkout lines when they select an 

unauthorized food item. WIC-only vendors, we were told, also tended to 

locate near WIC clinics, places that were very accessible to WIC 

participants. However, regular WIC vendors, who served non-WIC 

consumers as well as WIC participants, focused their businesses on their 

non-WIC customers, state officials told us. Because these non-WIC 

consumers are price sensitive, regular WIC vendors competed for their 

business based on price and competitors’ behavior. For example, regular 

WIC vendors made location decisions based on their broader customer 

base and often used price-based incentives, such as “buy-one-get-one-free”

offers, specials, or discount cards to appeal to their non-WIC, price 

sensitive customers. An important difference in these approaches was 

that because WIC participants were not price sensitive, they might take 

advantage of the service offered by WIC-only vendors, even if their prices 

were somewhat higher. In contrast to the vendors’ different customer 

service and marketing practices, state officials told us that both WIC-only 

and regular WIC vendors are able to lower the average cost of food they 

purchase for resale when they buy in volume, according to a majority of 

WIC state agency officials interviewed, by expanding from one outlet to a 

chain or forming consortia. However, we did not analyze the effect of 

decreasing food-purchasing costs on WIC-only and regular WIC vendors’ 

food prices.

Page 6 GAO-06-664 WIC-Only Vendors
If WIC-only vendors’ market share in 2004 had doubled in California, 

Texas, and Florida, either program participation would have decreased by 

about 3 percent—about 136,000 participants—or program food 

expenditures would have increased about 3 percent—about $50 million—

according to our scenario estimates. Our estimates showed that the 

average value of all vouchers redeemed by WIC-only vendors in 2004 was 

higher than the average value of all food vouchers redeemed at regular 

WIC vendors: $0.87 higher in California, $9.83 higher in Texas, and $4.42 

higher in Florida. As a result, if the number of food vouchers redeemed by

WIC-only stores had increased and total expenditures remained fixed at 

2004 levels, fewer vouchers could have been issued and fewer participants

could have been served. Conversely, if the total number of vouchers issued 

to participants remained at the 2004 level, the higher average value of 

vouchers redeemed at WIC-only vendors’ would have resulted in increased 

program expenditures. However, because we used the average value of all 

food vouchers in our analysis without knowing the price or quantity of the 

individual food items that made up the vouchers, we could not determine 

if the higher average value meant that prices for individual food items 

were higher at WIC-only vendors. WIC-only vendors’ higher average value

of redeemed vouchers could mean that they charge higher prices for WIC 

food but could also mean that WIC-only vendors’ customers are more 

likely to select all of the food items on their vouchers. Making price 

comparisons would require both food item price and quantity data for 

WIC-only and regular WIC vendors, at a minimum. 

To assist WIC state agencies in more effectively monitoring WIC vendors’ 

redemption practices, in implementing the new cost containment 

requirements, and in analyzing program expenditures, we are 

recommending that the Secretary of Agriculture require, if collection of 

more detailed information on WIC food purchases is cost-effective through 

electronic benefits transfer (EBT) implementation, that WIC state agencies 

collect data on both the price and the quantity of each WIC food item 

purchased, especially in each state that authorizes WIC-only vendors. In 

oral comments on a draft of this report, FNS officials generally agreed that 

our methodology was reasonable, given data limitations, and did not 

dispute our findings. However, officials did not believe that the smallscale study we recommended in the draft they read would be costeffective or necessary, because of the difficulty in collecting price and 

quantity data under the current system and because state agencies already 

are required to collect shelf price data and redemption data from 

authorized vendors. We acknowledged that USDA’s research funds are 

limited and that its research agenda is full. However, we maintained that

because the cost containment provisions are complex, it is important for 

Page 7 GAO-06-664 WIC-Only Vendors
FNS to monitor state agencies’ implementation of the provisions closely, 

to help ensure that program expenditures are in fact contained. In 

response, we removed our recommendation for further study and further 

clarified our recommendation for collection of data on both the price and

the quantity of WIC food items purchased under a cost-effective EBT 

system. 

WIC aims to protect the health of low-income women, infants, and young 

children who are at nutritional risk by providing nutritious foods to 

supplement diets, information on healthy eating, and referrals to health 

care at no charge to participants. Permanently established in 1974, WIC 

serves more than 8 million participants each month, including women who 

are pregnant, postpartum, or breastfeeding; infants under the age of 1; and

children under the age of 5, the largest category of participants. To 

participate in the program, eligible applicants must meet income 

guidelines, be deemed nutritionally at risk by a health professional (e.g.,

having a poor diet, low weight, or anemia), and must apply in the state in 

which they reside. 

Background 

In fiscal year 2005, the federal government spent over $5 billion on WIC. 

WIC is not an entitlement program that allows every eligible individual to 

participate; rather, it is a federal discretionary grant program for which 

Congress authorizes a specific amount of funds each year. At the federal 

level, WIC is administered by FNS, which provides grants to WIC state 

agencies for food and for nutrition services and administration. The 

nutrition services and administration grant covers the cost of certifying 

participants and determining nutrition risks; providing outreach and 

nutrition education services, including breastfeeding promotion; and 

printing vouchers and administering the food delivery system. FNS also 

determines WIC program policy and guidance, provides technical 

assistance to the WIC state agencies and sponsors research on program 

issues. In turn, WIC state agencies operate the program through thousands

of local agencies and clinic sites. The 90 WIC state agencies include 50

state health departments, as well as those of the District of Columbia, 34 

Indian Tribal Organizations, and five U.S. territories (Northern Mariana, 

American Samoa, Guam, Puerto Rico, and the Virgin Islands). 

Page 8 GAO-06-664 WIC-Only Vendors
In most WIC state agencies, WIC participants receive vouchers to 

purchase supplemental food in appropriate amounts tailored to their 

health needs from authorized retail stores, known as vendors in the WIC 

program.11 Vouchers prescribe food that is high in nutrients found to be 

lacking in a participant’s diet, such as milk, cereal, and eggs, and are 

adapted from a set of federally established food packages that differ 

according to participant type (e.g., infants or pregnant woman). Each WIC 

state agency designs its own vouchers and usually issues vouchers that 

contain a combination of WIC food items. For example, one frequently 

used voucher contains eggs, juice, cereal, cheese, milk, and beans. 

However, some vouchers contain only one food item, such as formula or 

cereal. (See app. IV.) Most participants receive multiple vouchers each 

month for all of the food they are prescribed. However they may not use 

the voucher to purchase items that are not listed on it. Figure 1 shows a 

sample voucher for food items from California’s WIC state agency. 

How the Retail Food 

Delivery System Works 

 11WIC state agencies may also operate other, less prevalent food delivery systems, 

including home food delivery systems, in which authorized supplemental foods are 

delivered to the participant’s home, and direct distribution food delivery systems, in which

participants, or their proxies, collect authorized supplemental foods from storage facilities 

operated by the state agency or its local agency. 

Page 9 GAO-06-664 WIC-Only Vendors
Figure 1: Sample Voucher from California

 

INDIVIDUAL NO. PARTICIPANT/ PARENT/GUARDIAN FIRST DAY TO USE LAST DAY TO USE SERIAL NO. 

113214683RR PAULA PARTICIPANT JUNE 12 04 JULY 11 04 476978438 

MILK/CHEESE /EGG 

WIC PROGRAM 

State of California 800-6229012572 

70-12-31 

1009 

EXACT PURCHASE PRICE: 

MUST NOT EXCEED 

$ 20 . 97 

Pay to the order of: 326476 

BOB’S QUICK SHOP # 119 

1661 SHORE ROAD 

WOOD CITY CA 95231 

VALID FOR WIC APPROVED FOOD ONLY. 

VOID IF NOT DEPOSITED WITHIN 45 DAYS OF 

 “FIRST DAY USE.” NOT VALID IF ALTERED. 

 Kind to buy: 

* MILK-COW, FLUID 

PASTEURIZED (GALLONS ONLY) 

* CHEESE-CHEDDER, JACK, 

AMERICAN, MOZZARELLA IN 

0.75 LB (12OZ.) OR LARGER 

* EGGS-AA WHITE, SM,MD,LG,UP TO: 

 How much to buy: 

2 GALLONS MILK, 2DOZ EGGS 

(DOZENS ONLY) 2 LBS CHEESE NOT NEGOTIABLE AUTHORIZED SIGNATURE (SIGN AT PURCHASE) 

1 2 

3 4 

5 

6 

7 

8 

9 

10 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

Each person’s ID number

The family name 

Name and address of the store 

First day voucher can be used 

Last day voucher can be used 

The kinds of food that can be purchased with voucher 

The actual price of purchase with voucher

(cashier fills in at checkout stand)

The price of food purchased can be only up to 

noted amount 

The amount of food participant can purchase with voucher

(Participant can purchase only up to this amount)

Participant signs name as cashier observes

Source: California Department of Health.

Unlike some other food assistance program models, WIC vouchers do not

provide an incentive for program participants to consider vendor prices 

for supplemental foods. For example, the Food Stamp and WIC Farmers’ 

Market Nutrition Programs generally provide electronic benefits or 

Page 10 GAO-06-664 WIC-Only Vendors
coupons that are used like cash at grocery stores or through farmers, and 

which encourage participants to make cost-conscious decisions regarding 

food choices. In contrast, because WIC participants purchase 

supplemental foods with vouchers that prescribe the type and quantity of 

foods a participant may receive, regardless of the prices charged by 

vendors to the WIC program, WIC participants are not price sensitive, that 

is, participants do not have an incentive to purchase their food benefit 

from lower-priced vendors.12

The approximately 45,000 vendors in the WIC program accept vouchers 

and exchange them for cash payment—or redemption—from their WIC 

state agency. Vendors are subject to price limitations, often in the form of 

an overall maximum, not-to-exceed amount for each voucher, determined

by WIC state agencies. As shown in figure 1, a state may clearly print the 

not-to-exceed amount for the total amount charged on the voucher. 

Like other retail grocery stores, WIC vendors sell to participants small 

quantities of food items that they typically purchase from manufacturers, 

wholesalers, or, on occasion, other retailers. The methods that grocery 

stores use to purchase food items are important business practices, 

because the cost of buying goods for resale is the largest single expense 

for an average grocery store, according to Food Marketing Institute 

research.13

How WIC Vendors Are 

Managed 

Through regulation and program guidance, FNS provides broad oversight

to WIC state agencies on cost containment and vendor management. FNS 

provides the food grant that state agencies use to reimburse vendors for 

redeemed vouchers, gathers program integrity data, supports upgrades to 

states’ management information systems, and sponsors research on 

vendor management issues. Because federal legislation grants primary 

responsibility for WIC vendor management to the WIC state agencies, WIC 

state agencies have considerable flexibility in designing and implementing 

their vendor management systems. FNS regulations require that WIC state 

agencies’ vendor management systems include six areas of activity: 

 12The total amount charged for a voucher is monitored and assessed for reimbursement by 

WIC state agencies. 

13Food Marketing Institute, Marketing Costs (Washington, D.C.),

http://www.fmi.org/facts_figs/superfact.htm (downloaded March 29, 2006).

Page 11 GAO-06-664 WIC-Only Vendors
• authorization and reauthorization—The authorization process begins 

with a vendor’s application and an on-site visit by WIC state agency

staff to verify the information provided in the application. Authorized 

vendors must enter into a written agreement, which may be 

reauthorized, usually every 1-3 years.

• training—WIC state agencies train vendor staff on the purpose of the 

WIC program and program procedures such as accepting vouchers 

from participants at the point of sale. 

• representative monitoring—State agencies are required to conduct 

routine monitoring visits of at least 5 percent of their vendors annually 

to observe vendor and participant transactions and collect shelf prices 

to ensure they are within the required state limits. 

• voucher review and redemption—State agencies are required to 

develop and implement an edit system of the vouchers turned in for 

redemption to detect noncompliance with program regulations. The 

redeemed-voucher review includes checking that charges for food 

items do not go over the not-to-exceed payment amount for vouchers, 

set by the state, and other edits such as transactions or redemptions 

outside of valid dates. 

• high-risk vendor monitoring—WIC state agencies identify high-risk 

vendors through on-site monitoring visits or through the redemption 

system and must investigate a minimum of 5 percent of vendors 

meeting high-risk criteria, such as high rates of redemption at or near 

the not-to-exceed payment amount for vouchers.

• sanctions—State agencies may impose sanctions ranging from fines to 

disqualification on vendors that violate program requirements or may 

impose a civil money penalty when a disqualification would result in 

inadequate participant access. A temporarily disqualified vendor may 

reapply after the disqualification period has expired. 

How Vendor Management 

in the WIC Program Has 

Evolved 

In the past few years, the WIC program has initiated significant changes in 

vendor management practices to contain costs and maximize the number 

of eligible women, infants, and children that can receive benefits. Prior to 

fiscal year 2004, FNS characterized authorized WIC vendors that 

participate in the program as: 

Page 12 GAO-06-664 WIC-Only Vendors
• retail grocery stores—vendors that commonly stock a variety of foods, 

including supplemental WIC foods, and serve a wide variety of 

customers, referred to as regular WIC vendors in this report; 

• WIC-only vendors—vendors that stock only WIC-approved food and 

accept only WIC vouchers; 

• military commissaries—vendors located on military installations and 

designed for military families; and 

• pharmacies—vendors that only provide infant formula, exempt infant 

formula, or WIC-eligible medical foods.14

The Child Nutrition and WIC Reauthorization Act of 200415 established new 

cost containment provisions designed, in part, to ensure that the WIC 

program is not charged more for the same supplemental food items 

provided in exchange for vouchers that participants might use at WIC-only 

vendors instead of at regular WIC vendors. These cost containment 

provisions require state agencies to implement a vendor peer group system 

that groups stores according to similar characteristics, such as vendor size 

and geographic location, in a manner that ensures that the WIC program 

pays all authorized vendors competitive prices for supplemental foods. 

FNS expects to complete certification of states’ plans for cost containment 

by September 2006. 

One cost containment provision created a new category of vendors 

referred to as above 50 percent vendors, which include any vendor whose 

revenue from the sale of WIC supplemental food is more than half of its 

annual revenue from food sales.16 In addition, the Act prohibited above 50 

percent vendors from providing any incentive items, such as free diapers,

detergent, baby strollers, or bicycles, to participants unless the incentives 

are of nominal value or were obtained at no cost. On November 29, 2005,

USDA issued an interim rule, effective on December 29, 2005, that 

incorporated the cost containment provisions of the Act into program 

regulations that are applicable to WIC state agencies.17 To help ensure that 

 14Exempt infant formulas are designed for infants with specific medical or dietary 

problems. Similarly, WIC-eligible medical foods are considered medically necessary and 

are prescribed by a physician when conventional foods cannot be consumed by women or

children with special dietary needs. 

15The Child Nutrition and WIC Reauthorization Act of 2004, Pub. L. No. 108–265 (2004).

16However, we used the WIC-only vendor definition established by FNS prior to the

changes brought by the reauthorization because those definitions conform to the

redemption data provided by FNS and WIC state agencies for our analyses. 

1770 Fed. Reg. 71,708 (Nov. 29, 2005). 

Page 13 GAO-06-664 WIC-Only Vendors
vendors’ prices are competitive, these regulations require states to collect 

and review vendors’ shelf prices at least every 6 months after 

authorization. The regulations also require state agencies to compare the

average cost of each type of food instrument redeemed by WIC-only 

vendors against the average cost of the same type of food instrument 

redeemed by regular vendors. 

In December of 2005, attorneys representing an association of WIC-only 

vendors and three food companies, the plaintiffs, filed an action in federal

district court for the District of Columbia to stop implementation of FNS’s 

regulations. Arguing that the regulations were contrary to the Act and to 

congressional intent, the plaintiffs asserted that the cost containment 

provisions concerning above-50-percent vendors would reduce their WIC 

reimbursements to a level that would be unsustainable. In describing 

services that WIC-only vendors offered WIC participants, the plaintiffs 

characterized WIC-only vendors as small businesses and acknowledged 

that their cost of doing business was higher than that of large stores, 

referred to as box stores, that purchased food in high volume at discount 

prices. The plaintiffs estimated that WIC-only vendors’ prices were about 8 

to 15 percent higher than prices charged at box stores, on average. On 

February 23, 2006, the court dismissed the case, finding that the cost 

containment provisions of the interim rule were consistent with the plain 

language and purpose of the Act.18

Recent initiatives suggest that more changes to the WIC program are 

forthcoming. In 2003, FNS developed a plan to transform WIC from its 

paper-based food benefit delivery system to an electronic benefits transfer 

system. Through pilot projects in many states that are still under way, FNS 

is working toward a national model that is both technically and financially 

viable for implementation of EBT by 2008. In addition, in 2004 the Institute 

of Medicine (IOM) began examining WIC food packages to determine if 

modification could help participants eat a healthier diet. In its 2005 report,

IOM recommended revisions to the food packages that match current 

dietary guidance for infants and young children, encourage consumption 

of fruits and vegetables, emphasize whole grains, lower saturated fat, and 

appeal to diverse populations.19

 18National Women, Infants and Children Grocers Association v. Food and Nutrition 

Service, 416 F.Supp. 2d 92 (D.D.C. 2006). 

19See the Institute of Medicine, WIC Food Packages: Time for a Change, National 

Academies Press: Washington, D.C., 2006, for more information. 

Page 14 GAO-06-664 WIC-Only Vendors
Since 1999, WIC-only vendors have increased in number, with 

concentrated growth in a few states, but their share of the national WIC 

market stayed small in comparison to the share of regular WIC vendors 

during an average month in 2004. The number of WIC-only vendors 

nationwide tripled from 1999 to 2004, and the number of states with WIConly vendors also grew over this period. Notwithstanding these increases,

in 2004 the majority of WIC-only vendors were located in California, 

Texas, and Florida, and nearly half of all WIC-only vendors operated in a 

few metropolitan areas within these states. Nationwide, WIC-only vendors 

still accounted for about 3 percent of all WIC vendors in 2004 and 

generated about 6 percent of business in the WIC market during an 

average month that year, compared to regular WIC vendors’ predominant 

market share. On a store-by-store basis, however, WIC-only vendors’ 

redemption value was greater, on average, than regular WIC vendors’ 

during this period. 

WIC-Only Vendors 

Increased in Number 

during Fiscal Years 

1999-2004, although 

Their Market Share 

Remained Relatively 

Small in Fiscal Year 

2004 

WIC-Only Vendors Tripled 

from Fiscal Year 1999 to 

Fiscal Year 2004, and They 

Are Highly Concentrated 

Geographically 

The 1,180 WIC-only vendors in operation at any point during 2004 were 

three times the number in business at any point in 1999 (see fig. 2).20

 20TIP does not record when vendors enter or exit the WIC program, and therefore may

overstate the number of vendors in operation on any particular date. See appendix I for a 

more detailed explanation of the data limitations created by this issue. 

Page 15 GAO-06-664 WIC-Only Vendors
Figure 2: National Total of WIC-Only Vendors

0

200

400

600

800

1,000

1,200

1,400

1999 2000 2001 2002 2003 2004

WIC-only vendors

Source: GAO analysis of FNS 1999-2004 TIP files.

Fiscal year

394

523

621

779

961

1,180

Note: Vendor counts include any vendor in operation at some point during the fiscal year. 

Just as the total number of WIC-only vendors has increased, the number of 

states with WIC-only vendors has grown in recent years. Of the 50 states 

and the District of Columbia, 15 had WIC-only vendors in 2004, an increase 

from 12 in 1999 (see table 1).21

 21 States may have had WIC-only vendors in 1999 that they did not report in TIP. As one 

example, Georgia did not identify WIC-only vendors as a separate vendor type until 2004. 

Appendix II presents the number of WIC-only vendors by state for all fiscal years from 1999

through 2004. 

Page 16 GAO-06-664 WIC-Only Vendors
Table 1: Number of WIC-Only Vendors by State, Fiscal Years 1999 and 2004 

State 1999 2004

California 235 715

Texas 69 162

Florida 57 109

North Carolina 2 72

Arkansas 4 42

Georgia 0 22

Alabama 0 19

Louisiana 4 11

Oklahoma 5 8

New Mexico 4 7

Virginia 5 6

Kansas 0 3

Utah 2 2

District of Columbia 0 1

Tennessee 2 1

Oregon 5 0

Total 394 1,180

Source: GAO analysis of FNS 1999 and 2004 TIP data. 

Note: Vendor counts include any vendor in operation at some point during the fiscal year. Any state 

not listed had no WIC-only vendors authorized during either fiscal year. 

Even with the increase in recent years in both total WIC-only vendors and

the number of states with such vendors, in 2004 most WIC-only vendors 

were located in three states, and nearly half operated in three 

metropolitan areas. Figure 3 shows that, at the national level, 84 percent of 

all WIC-only vendors operated in California, Texas, or Florida. Moreover, 

approximately one out of every two WIC-only vendors nationwide 

operated in Los Angeles, California; Riverside, California; or Miami, 

Florida. In contrast, each of the remaining states with WIC-only vendors 

accounted for less than 7 percent of total WIC-only vendors in 2004. 

Page 17 GAO-06-664 WIC-Only Vendors
Figure 3: Share of Total WIC-Only Vendors Nationwide by State and the Top Three Metropolitan Areas in 2004 

Source: GAO analysis of FNS 2004 TIP file.

0 percent

More than 0 percent to less than 5 percent

5 percent to less than 10 percent

10 percent to less than 25 percent

25 percent or more

Miami

<1%

1%

<1%

2% 2%

6%

6%

9%

1%

4%

<1%

1% 1%

<1%

14%

61%

Los

Angeles

6%

Share of all WIC-only vendors

37%

Riverside

Note: Vendor counts include any vendor in operation at some point during the fiscal year. All figures 

have been rounded to the nearest whole number except for states that accounted for less than 0.5 

percent of all WIC-only vendors, which are marked as “<1 percent.” Metropolitan areas were 

determined using U. S. Census Bureau definitions for metropolitan statistical areas. 

Page 18 GAO-06-664 WIC-Only Vendors
The total number of WIC-only vendors in operation at any point in 2005 is 

not yet available, but may be lower than the 1,180 reported for 2004. For 

example, WIC state agency officials in Texas and Florida have indicated

that the number of WIC-only vendors in their respective states decreased 

after 2004. Both WIC state agencies continued to monitor and occasionally 

disqualify WIC-only vendors. At the same time, Texas WIC agency officials 

have indicated that a number of WIC-only vendors went out of business. 

Moreover, because the Consolidated Appropriations Act of 2005 

prohibited states from authorizing additional WIC-only vendors after 

December 8, 2004, WIC state agencies could not replace WIC-only vendors 

that departed the program with new WIC-only vendors during much of 

fiscal year 2005. 

Despite Recent Growth, 

WIC-Only Vendors 

Represent a Fraction of All 

WIC Vendors 

Notwithstanding the increase in the number of WIC-only vendors in recent

years, WIC-only vendors have remained a fraction of total WIC vendors. 

Nationally, the share of all WIC vendors accounted for by WIC-only 

vendors increased from approximately 1 percent in 1999 to about 3 

percent in 2004 (see fig. 4). During the same period, the number of regular

WIC vendors in operation at any point changed only slightly, from 43,712 

in 1999 to 43,463 in 2004. However, in California, Texas, and Florida, WIConly vendors have accounted for a larger proportion of all WIC vendors 

than in the nation as a whole. At the same time, these three states were 

home to nearly one-third of all WIC participants nationwide. 

Page 19 GAO-06-664 WIC-Only Vendors
Figure 4: Percentage of Total WIC Vendors Represented by Each Vendor Type,

Nationwide and in Select States

0 10 20 30 40 50 60 70 80 90 100

1999

2004

1999

2004

1999

2004

1999

2004

Percent

Source: GAO analysis of FNS TIP files, 1999 and 2004.

Regular WIC vendors

WIC-only vendors

Florida

Texas

California

Nationwide

Fiscal year

97 3

97 3

97 3

95 5

94 6

94 6

84 16

99 1

Note: Vendor counts include any vendor in operation at some point during the fiscal year. 

Page 20 GAO-06-664 WIC-Only Vendors
Nationally, as their numbers might suggest, WIC-only vendors had the 

smaller share of the WIC market during an average month in 2004, but on a

store-by-store basis, they redeemed about twice as much as regular WIC 

vendors.22 Whereas regular WIC vendors accounted for 94 percent of 

business in the WIC market, or about $784 million on an average monthly 

basis in 2004, WIC-only vendors redeemed about $47 million, or 6 percent 

of all WIC redemptions.23 However, WIC-only vendors nationwide 

redeemed nearly $40,000 per vendor during an average month that year, 

about twice the average monthly amount from WIC as regular WIC 

vendors that participated in the program (see fig. 5). 

WIC-Only Vendors Had the 

Smaller Share of the WIC 

Market in 2004 but 

Redeemed about Twice the 

Average Monthly Amount 

per Vendor as Regular WIC 

Vendors 

Figure 5: Average Monthly WIC Redemptions per Vendor in 2004, by Vendor Type 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

Reg

WIC-only vendor

ular WIC vendor

Dollars

Source: GAO analysis of FNS regional office 2004 TIP files.

39,852

18,310

 22 Because we were unable to calculate the growth of WIC-only vendors’ redemptions over

time, we reported redemptions on an average monthly basis in 2004. 

23 WIC business volume is defined as total redemptions from WIC, for the purposes of our 

report. 

Page 21 GAO-06-664 WIC-Only Vendors
Because these data represent simply the average monthly payments 

received per vendor from WIC state agencies, differences between WIConly vendors’ redemptions and those of regular WIC vendors could signify 

that a vendor type charges higher prices for WIC food, but could also 

reflect the number of participants that shop at each vendor type; the 

probability that a participant selected all or only part of the food items on 

a voucher; the amount of WIC business volume conducted, on average, by 

WIC-only and regular WIC vendors; or all of these practices.24 For example, 

a WIC-only vendor that serves a far greater number of WIC participants 

than a regular WIC vendor would tend to have higher redemptions for the 

same WIC items even if both vendors’ prices for those items were 

comparable.

At the state level, the three states with the most WIC-only vendors also 

produced the majority of total WIC-only vendor business volume during an 

average month in 2004. Though the average monthly redemptions per WIConly vendor in California, Texas, and Florida fell below the high of nearly 

$64,000 per vendor in Oklahoma, the three states accounted for 90 percent 

of all WIC-only redemptions during that period (see fig. 6).25

 24 The FNS data we analyzed did not allow us to make determinations about these 

differences. 

25See appendix III for the average monthly redemptions per WIC-only vendor in fiscal year 

2004 for all states with WIC-only vendors. 

Page 22 GAO-06-664 WIC-Only Vendors
Figure 6: Share of Total Average Monthly WIC-Only Redemptions by State in 2004 

7%

10%

12%

71%

Source: GAO analysis of FNS regional office 2004 TIP files.

Florida

Texas

California

All other states with WIC-only vendors

WIC-only and regular WIC vendors generally employed different business 

and marketing practices, largely in response to the two different customer 

groups they served and the nature of the markets they faced. Because WIC 

participants are not required by the WIC program to consider retail prices, 

vendors that served only WIC participants competed for their business by 

emphasizing customer service, which participants seemed to value. On 

the other hand, regular WIC vendors served non-WIC consumers as well as 

WIC participants. Because these non-WIC consumers are considered price 

sensitive, regular WIC vendors competed for their business based on price 

and competitors’ behavior. These differences in customer base also 

affected decisions on where to locate stores and how to advertise. WIConly stores tended to locate near WIC clinics, while regular WIC vendors 

considered their broader customer base when choosing locations. Also, 

WIC-only vendors used community-based media and word-of-mouth to 

advertise, while regular WIC vendors were more likely to use mass media. 

Finally, WIC-only and regular WIC vendors used similar food purchasing 

practices, because the cost of food purchased for resale by vendors is 

related more to the quantity of food purchased than the type of vendor 

purchasing the food. Both WIC-only and regular WIC vendors were able to

lower the average cost of food purchased for resale when they bought in

volume, according to WIC state agency officials. 

WIC-Only Vendors 

and Regular WIC 

Vendors’ Business and 

Marketing Practices 

Differ in Their 

Approach to 

Customer Service and 

Price 

Page 23 GAO-06-664 WIC-Only Vendors
WIC-only vendors employed a business model that allowed them to 

emphasize customer service for program participants rather than price, 

while regular WIC vendors focused on attracting a broader customer base 

by offering competitive prices. These differences have likely evolved 

because WIC shoppers need not be price sensitive. WIC-only vendors 

attracted WIC participants, who were not price sensitive, by emphasizing 

customer service. Because WIC participants were not price sensitive, they

responded to non-price inducements, like service, which they valued. As a 

result, they might take advantage of the service offered by WIC-only 

vendors, even if their prices were somewhat higher. In comparison, 

regular WIC vendors more often used price reductions to appeal to a 

broad customer base, most of whom were price-sensitive shoppers, 

according to WIC state agency officials. 

WIC-Only Vendors 

Emphasized Customer 

Service, while Regular WIC 

Vendors Focused on Price 

Although WIC-only vendors did not compete on the basis of price, WIConly vendors did compete with other WIC-only and regular WIC vendors 

on the basis of customer service, a central feature of their business model, 

according to WIC state officials. WIC-only vendors typically organized 

their stores in ways that emphasized service to their WIC participant 

customers. Because WIC-only vendors stocked only WIC-approved items 

(see fig. 7), they eliminated the need for WIC participants to identify WICeligible foods. Moreover, WIC-only vendors often kept food behind a 

counter, and employees gathered and bagged the WIC items customers 

requested, according to most WIC state agency officials we interviewed 

and our observations during site visits. (see fig. 8) As a result, customers 

did not need to spend time finding products in store aisles or face the risk 

or stigma of selecting an unauthorized food item and creating a delay in 

the checkout line. Several state officials thought that this feature of WIConly vendors’ business model was a prime attraction for WIC participants. 

Page 24 GAO-06-664 WIC-Only Vendors
Figure 7: Available WIC Food Items at WIC-Only Vendor in Texas 

Figure 8: Interior of WIC-Only Vendor in California

Source: GAO.

Source: GAO.

Page 25 GAO-06-664 WIC-Only Vendors
Some state officials told us they believe the customer service features of

WIC-only vendors’ business model, together with their use of only one or 

two checkout points, their limited customer floor area, and their location 

in low-income neighborhoods, would reduce their operating expenses. 

However, we were unable to obtain the data needed to confirm these 

views. 

Few WIC-only vendors used price-based incentives such as buy-one-getone-free specials, sale items, or discount cards to attract WIC customers. 

Because WIC participants purchase items with vouchers and are not price 

sensitive, price discounts would not induce them to go to a store with 

lower prices. However, for this same reason, WIC-only vendors would not 

risk losing WIC customers, even if their prices were higher.

In the past, WIC-only vendors also have given away food and non-food 

items, called incentives, to attract customers. For example, WIC-only 

vendors gave away strollers and diapers in California and North Carolina, 

cash in Arkansas, and gift certificates in Georgia, according to WIC state 

agency officials. Because WIC-only vendors’ main source of revenue was 

the WIC benefit, paid for by the WIC program, offering such incentives 

raised concerns about the use of federal funds. However, several WIC 

state agency officials noted that the use of incentives by WIC-only vendors 

has decreased as a result of rule changes required by the Child Nutrition 

and WIC Reauthorization Act of 2004.26 In fact, the WIC state officials we 

spoke with in California, North Carolina, and Arkansas said that WIC-only 

vendors no longer give away most of the items they provided in the past. 

None of the WIC-only vendors we observed on our site visits provided 

such incentives, with the exception of one in California that gave 

customers a small amount of free produce for purchasing a certain 

quantity of food items. 

In contrast to WIC-only vendors, the retail grocers that we define as 

regular WIC vendors targeted the population at large and did not focus on 

customer service, according to WIC state agency officials.27 Regular WIC 

 26Section 203(e)(14) of the law states, “A State agency shall not authorize or make 

payments to a [WIC-only] vendor that provides incentive items or other free merchandise,

except food or merchandise of nominal value (as determined by the Secretary), to program

participants unless the vendor provides to the State agency proof that the vendor obtained

the incentive items or merchandise at no cost.” 

27 Under the Child Nutrition and WIC Reauthorization Act of 2004, an unknown number of

these vendors we call regular WIC vendors will be reclassified as 50 percent WIC vendors. 

As such, they will continue to serve some combination of both WIC participants and pricesensitive non-WIC shoppers.

Page 26 GAO-06-664 WIC-Only Vendors
vendors served WIC participants, but their largest group of customers was 

non-WIC consumers, who are price sensitive. For the most part, regular 

WIC vendors targeted their business practices on their non-WIC customers 

and set prices in response to this group. The regular WIC vendors we 

observed on our site visits provided examples of their business practices 

that contrast with those of WIC-only vendors. Of the 12 regular WIC 

vendors we visited, none gathered the WIC food items listed on the 

voucher for WIC customers and only 3 had food items authorized by the 

WIC program placed together on an aisle shelf to assist participants in 

finding the items on their vouchers. Having to search store aisles and 

shelves for the correct food type, brand, and size listed on their voucher 

can make shopping for WIC food items at regular WIC vendors challenging 

or uncomfortable for WIC participants. 

WIC state officials told us that regular WIC vendors’ marketing practices 

are price-based, that is, they competed in the market based on price and

their competitors’ behavior. Regular WIC vendors commonly use buy-oneget-one-free specials, sale items, discount cards, and other price-based 

incentives to attract a broad client base that is price sensitive. Since the 

rule changes required by the Child Nutrition and WIC Reauthorization Act 

of 2004, regular WIC vendors, who have sources of revenue other than 

federal funds from their broad customer base, continue to provide higherpriced incentives to attract customers, according to several of the WIC 

state agency officials and WIC vendor employees whom we interviewed. 

Despite these differences, WIC-only vendors and regular WIC vendors 

used some similar business or marketing practices that did not involve

price-based incentives. For example, both employed checkout staff who 

spoke one or more languages other than English, according to the majority 

of WIC state agency officials interviewed, a practice we observed on our 

site visits. In addition, both vendor types in several states organized 

community outreach activities, ranging from baby clothes exchanges to 

barbecues. 

Page 27 GAO-06-664 WIC-Only Vendors
WIC-only vendors are often located in places readily accessible to WIC 

participants. All WIC state agency officials we interviewed stated that 

WIC-only vendors tend to locate their stores as close to WIC clinics as 

possible (see fig. 9), and several officials indicated that WIC-only vendors 

may also operate in low-income neighborhoods—geographic areas that 

are often one and the same. 

Figure 9: Proximity of WIC-Only Vendor to WIC Clinic in Texas 

In contrast, WIC state agency officials told us that regular WIC vendors 

typically make their location decisions based on their entire customer 

population, not just WIC participants. While WIC state agencies consider 

participant access when authorizing regular WIC vendors, they need not 

ensure that the vendor will be located near a WIC clinic. 

WIC-Only Vendors Tend to 

Locate near WIC Clinics; 

Regular WIC Vendors Base 

Location Decisions on 

Their Broader Customer 

Base 

Source: GAO.

WIC-Only Vendors Used 

Community-Based Media 

to Advertise; Regular WIC 

Vendors Use Mass Media 

WIC-only vendors generally advertise with publicity flyers, word-of-mouth, 

and community-based media. WIC officials in all seven states reported that 

WIC-only vendors tend to use publicity flyers to publicize their stores; 

figure 10 presents an example of this type of advertisement. Further, wordof-mouth is the most important advertising practice for some WIC-only 

vendors. In addition to using flyers and word-of-mouth, some WIC-only 

vendors in Alabama, Florida, and North Carolina advertise in local 

Page 28 GAO-06-664 WIC-Only Vendors
newspapers, and a few WIC-only vendors in California and North Carolina 

promote their stores via radio. 

Figure 10: Sample WIC-Only Vendor Promotional Flyer 

Source: Profile Unlimited.

Page 29 GAO-06-664 WIC-Only Vendors
In addition, most of the WIC-only vendors we visited post signs indicating 

that they accept vouchers. In California, the majority of the WIC-only 

vendors we visited post signs indicating that the stores accept vouchers. In

Texas and Florida, several stores have replaced the name of the store in 

the marquee over the front door with statements such as “WIC Checks 

Accepted Here” (see fig. 11).28 

Figure 11: Marquee of WIC-Only Vendor in Florida

Source: GAO.

In contrast to WIC-only vendors, which used community-based media, 

regular WIC vendors typically advertised to a broad client base through 

mass media such as newspapers, television, radio, and billboards, 

according to most WIC agency officials and regular WIC vendor employees 

 28Several WIC state agency officials noted that their states limit or do not permit WIC 

vendors to use the WIC acronym for advertising purposes. FNS policy states, “WIC State

agencies have the discretion to authorize WIC vendors to use the acronym ‘WIC’ and/or the 

WIC logo for the following purposes: 1) to identify the retailer as an authorized WIC food

vendor; and 2) to identify authorized WIC foods by attaching channel strips or shelf-talkers

stating ’WIC-approved’ or ‘WIC-eligible’ to grocery store shelves.” 

Page 30 GAO-06-664 WIC-Only Vendors
interviewed. However, most of the regular WIC vendors that we visited do

not post signs indicating that they participate in the WIC program, even 

though most WIC state agency officials whom we interviewed said that 

they provide regular WIC vendors with a state-authorized sign indicating 

that the store accepts vouchers. 

Officials Told Us That WICOnly and Regular WIC 

Vendors Lower FoodPurchasing Costs by 

Buying in Volume, 

although the Effect on 

Retail Food Prices Is 

Unclear 

Although their marketing and advertising practices differ, WIC state 

officials told us that WIC-only and regular WIC vendors use similar foodpurchasing practices. Wholesalers tend to offer WIC-only and regular WIC 

vendors lower prices for higher volume purchases, according to a majority 

of WIC state agency officials interviewed. Some vendors have lowered 

food-purchasing costs by expanding the number of outlets they operate or

forming consortia to buy in greater volume. For example, one WIC-only 

vendor in California operates a chain of 49 outlets. A few WIC-only chains 

in California and Florida have become wholesalers themselves because 

they are large enough to purchase food directly from manufacturers. WIC 

state agency officials in two states indicated that WIC vendors increase the 

amount of food purchased by forming a consortium with other vendors. 

For example, several WIC-only vendors in Florida purchase food 

collectively to earn volume discounts from wholesalers. 

In contrast to WIC vendors that form consortia or are large enough to 

purchase independently from wholesalers or manufacturers, some small 

WIC vendors—including both WIC-only and regular WIC vendors—

purchase food for resale from other retail sources. The small WIC vendors 

may not have the room to store large amounts of goods or may not be able

to buy on credit from wholesalers. Although several WIC state agency 

officials said that buying from other retailers leads to higher costs, a few 

officials noted that WIC vendors with a small purchasing capacity may in

fact pay less by buying food from other large retailers, such as Wal-Mart or 

Costco, instead of from wholesalers. 

Even though WIC vendors can reduce their average food-purchasing costs 

by buying food in greater volume, existing data did not permit us to 

determine the relationship between food-purchasing costs and retail food

prices. The retail price for food items reflects numerous store-operating 

expenses in addition to the cost of buying food for resale—such as 

employee salaries, rent, and insurance—and a decrease in average foodpurchasing costs over time does not necessarily result in a reduction in 

other business costs. 

Page 31 GAO-06-664 WIC-Only Vendors
If the market share of WIC-only vendors had doubled in California, Texas,

and Florida, either program participation would have decreased by about 3 

percent—about 136,000 participants—or program expenditures would 

have increased by about 3 percent—about $50 million—in those states, 

according to our scenario estimates using conditions present in 2004.29

These changes would have occurred because the average value of all food

vouchers redeemed by WIC-only vendors in 2004 was higher than the 

average value of all food vouchers redeemed at regular WIC vendors. 

However, even though the change would be a similar 3 percent of 2004 

levels across all three states, the reasons for the size of the change differ 

among the states, depending on WIC-only vendors’ market share and the 

difference in WIC-only and regular WIC vendors’ average voucher value. 

Because the average value of all food vouchers we calculated did not 

specify either the price or quantity of individual items that make up the 

voucher, we could not determine whether the prices for individual items at 

WIC-only vendors were higher than at regular WIC vendors. At a minimum, 

data on both the price a vendor charges for individual food items and the 

quantity purchased by participants are needed to make price comparisons. 

We Estimated That 

Program Participation 

Would Have 

Decreased by about 

136,000 WIC 

Participants or 

Expenditures Would 

Have Increased by 

About $50 Million if 

WIC-Only Vendors’ 

Market Share Had 

Doubled in 2004 

If WIC-Only Vendors’ 

Market Share Had Doubled 

in 2004 and Program 

Expenditures Were Held 

Constant, We Estimated 

That Program 

Participation Would Have 

Decreased by About 

136,000 WIC Participants 

The number of participants that could have been served would have 

decreased if the WIC-only vendors’ market share increased while holding 

total WIC food expenditures constant at 2004 levels, according to our first 

scenario.30

As shown in table 2, if redemptions at WIC-only vendors had doubled in 

each state, the decrease in the number of participants that could be served 

would be 136,202, or about 3 percent of 2004 levels for the three states. 

 29Our estimates are based on available data for WIC-only and regular WIC vendors, 

excluding pharmacies and commissaries, from 2004 and assume that all program 

characteristics other than those we manipulated did not change. See appendix I for 

additional information on our methodology. 

30We increased the market share of WIC-only vendors by increasing the number of food

vouchers redeemed at these stores. (See scenario 1 analysis in app. I.) 

Page 32 GAO-06-664 WIC-Only Vendors
Table 2: Estimated Change in the Number of Participants Served if WIC-Only Vendors’ Market Share Increased while Program

Expenditures Were Held Constant at Fiscal Year 2004 Levels 

Percentage California Texas Florida Total for 3 states 

increase in

WIC-only

vendors’ 

market 

share 

Decline in 

number of 

participants 

serveda

Decline as 

a 

percentage

of 2004 

levelb

Decline in 

number of 

participants 

served

Decline as a 

percentage

of 2004 

levelb

Decline in 

number of 

participants 

served

Decline as 

a 

percentage

of 2004 

levelb

Decline in 

number of 

participants 

served

Decline as a 

percentage

of 2004 levelb

10 percent 

increase -6,277 0.29 -5,271 0.36 -2,072 0.31 -13,620 0.32

20 percent 

increase -12,553 0.59 -10,542 0.72 -4,145 0.61 -27,240 0.64

30 percent 

increase -18,830 0.88 -15,814 1.08 -6,217 0.92 -40,861 0.96

50 percent 

increase -31,383 1.47 -26,356 1.79 -10,362 1.53 -68,101 1.59

100 percent 

increase -62,766 2.95 -52,712 3.58 -20,724 3.05 -136,202 3.18

Source: GAO analysis of California, Texas, and Florida WIC state agency redemption data for 2004. 

a

We calculated the number of participants that would be affected by using the average number of 

redemptions per participant in each state. (See app. I) 

b

To develop our estimates for fiscal year 2004, we used our redemption data to calculate the number 

of people who redeemed a voucher that year: 2.1 million people redeemed vouchers in California, 1.5 

million in Texas, and 0.679 million in Florida. To avoid double counting, we used a unique 

identification number for each person that was available in our data and counted each person only 

once. Because we had data for every voucher redeemed in each of the three states, for every month 

in fiscal year 2004, our calculations of annual program participation likely exceeded FNS’s estimates 

based on average monthly participation. (See app. I) 

Because the average value of all food vouchers redeemed by WIC-only 

vendors in all three states in 2004 was higher than the average value of all

food vouchers redeemed by regular WIC vendors, more funds would have 

been needed to reimburse WIC-only vendors than regular WIC vendors for 

the same number of vouchers.31 As a result, when the number of food 

vouchers redeemed by WIC-only vendors increased and program 

expenditures were held constant in our scenario estimate, fewer food 

vouchers could be issued and fewer participants could be served. This 

 31These data should be treated with caution. A higher average value for all food vouchers 

does not necessarily mean that prices for individual food items at WIC-only stores are

higher than prices at regular WIC stores. Our average value of all food vouchers redeemed 

is the average value of all food vouchers redeemed in particular states, by type of vendor. 

(See app. I.) 

Page 33 GAO-06-664 WIC-Only Vendors
constraint was reflected in our analysis by a reduction in the number of 

vouchers redeemed by regular WIC vendors. 

The Reasons for the Size of 

the Decrease in Program 

Participation Differ among 

the Three States 

Even though the size of the decrease in program participation would be a 

similar 3 percent of 2004 levels across all three states, the reasons for the 

size of the decrease differ among the states. Two key factors would affect

the size of the decrease in each state: (1) the size of WIC-only vendors’ 

share of the total WIC vendor market and (2) the difference between the 

average value of food vouchers redeemed by WIC-only and by regular WIC 

vendors.32 As shown in table 3, in California, WIC-only vendors’ market 

share was 41.46 percent in 2004, and the difference in the average value of

food vouchers redeemed by WIC-only and regular WIC vendors was $0.87.

Because WIC-only vendors’ market share is 41 percent in California, 

doubling their market share means that WIC-only vendors would account 

for most of the WIC market in that state. 

Table 3: Difference between the Average Value of WIC-Only and Regular WIC 

Vendor Food Vouchers in 2004 and the Market Share of WIC-Only Vendors in 

California, Texas, and Florida 

State 

Average value of

WIC-only food

voucher

redeemed

Average value

of regular WIC 

food voucher

redeemed

Difference 

between WIConly and regular 

WIC

redemptions

WIC-only

vendors’ market 

share

Dollars Dollars Dollars Percent

California $13.15 $12.28 $0.87 41.47

Texas $31.55 $21.72 $9.83 7.93

Florida $22.92 $18.50 $4.42 12.8

Source: GAO analysis of California, Texas, and Florida WIC state agency redemption data for 2004. 

Conversely, in Texas and Florida, redemptions at WIC-only vendors 

accounted for a smaller market share than in California in 2004—8 percent 

in Texas and 13 percent in Florida. The difference between the average 

value of food vouchers redeemed at WIC-only and regular WIC vendors in 

2004, however, was higher than in California—$9.83 in Texas and $4.42 in

Florida. Therefore, although WIC-only vendors accounted for a larger 

 32Our scenario analyses assumed that all factors other than those we changed, including the

difference between WIC-only and regular WIC vendors’ average food voucher values, 

remained constant as we increased WIC-only vendors’ market share. 

Page 34 GAO-06-664 WIC-Only Vendors
portion of the WIC vendor market in California than in Texas and Florida, 

the smaller difference in WIC-only and regular WIC vendors’ food voucher 

values would have helped counteract the overall effect of an increase in 

California WIC-only vendors’ market share. Conversely, the smaller market 

share held by WIC-only stores in Texas and Florida would have partially 

offset the overall effect of the larger difference in average food voucher 

value in those two states. 

We acknowledge that we could have increased the market share held by

WIC-only vendors in Texas and Florida in 2004 further in our scenario 

analysis. However, our analysis is based on the relative market shares and 

the corresponding differences in average food voucher values in 2004. 

Over time, the differences in average food voucher values as well as the 

market share held by WIC-only vendors could increase or decrease with 

corresponding implications for program resources. 

If WIC-Only Vendors’ 

Market Share Had Doubled 

and Program Expenditures 

Were Not Held Constant, 

Program Expenditures 

Would Have Increased 

About $50 Million 

Program expenditures would increase if the market share of WIC-only 

vendors grew and all else remained the same, including the overall number 

of food vouchers redeemed by both WIC-only and regular WIC vendors in 

2004.

33 As shown in table 4, if redemptions at WIC-only stores doubled in 

each state, program expenditures would increase by about $50 million, or 

3 percent above the three states’ 2004 levels. As discussed previously, the

size of WIC-only vendors’ share of t See appendix IV for the range of 

vouchers in California, Texas, and Florida that we analyzed. The total WIC 

vendor market and the difference between the average value of food 

vouchers redeemed by WIC-only and by regular WIC vendors in part 

explain why the changes for the three states are similar. 

 33The overall number of food vouchers redeemed would remain constant as WIC-only 

vendors’ market share increases because the number of vouchers redeemed by regular WIC 

stores would go down. Because our estimates do not take into account savings from infant

formula rebates, the estimated dollar amounts in our scenario analysis do not reflect total 

cost to the program. 

Page 35 GAO-06-664 WIC-Only Vendors
Table 4: Change in Program Expenditures if WIC-Only Vendors’ Market Share Increases while Maintaining the Total Number 

of Food Vouchers at Fiscal Year 2004 Levels 

California Texas Florida Total for 3 states Percentage

increase in

WIC-only

vendors’ 

market 

share 

Change in 

WIC dollars 

Change as 

a percentage of

2004 

levelsa

Change in 

WIC dollars

Change as 

a percentage of

2004 

levelsa

Change in 

WIC dollars

Change as 

a percentage of 2004 

levelsa

Change in 

WIC dollars

Change as 

a percentage of

2004 

levelsa

Millions of

dollars 

Percent Millions of

dollars

Percent Millions of 

dollars

Percent Millions of

dollars

Percent

10 percent 

increase 2.52 0.29 1.78 0.35 0.69 0.30 4.99 0.31

20 percent 

increase 5.04 0.57 3.55 0.69 1.38 0.59 9.97 0.61

50 percent 

increase 12.60 1.43 8.89 1.73 3.45 1.48 24.93 1.53

100 percent 

increase 25.20 2.86 17.77 3.46 6.89 2.96 49.86 3.07

Source: GAO analysis of California, Texas, and Florida WIC state agency redemption data for 2004. 

a

In 2004, the value of redemptions was $880 million in California, $513 million in Texas, and $233

million in Florida. 

Data Limitations 

Prevented Us from More 

Fully Analyzing the Effects 

of WIC-Only Vendors on 

WIC Program Participation 

and Expenditures 

Although our two scenario estimates are based on the best available data

concerning WIC-only vendors’ contributions to expenditures and 

participation, they are illustrative only and have limitations. Because food

item price data and quantities of food items purchased were not available, 

we were unable to construct analyses that would have isolated the effect 

of actual prices charged by WIC-only and regular vendors on program 

expenditures or participation. For example, some food vouchers in our 

data were composed of a single item, but most of them contained multiple 

food items, such as milk, cheese, and cereal.34 Because most of the 

vouchers contained several types of WIC food and allowable quantities for 

each food item, the value of an individual voucher was not the price a 

vendor charged for an individual food item. The value of an individual food 

voucher was the sum of the price of each food item on the voucher times 

the quantity purchased. As a result, the difference in value between WIConly and regular WIC vouchers could be due to differences in prices for 

 34See appendix IV for the range of vouchers in California, Texas, and Florida that we

analyzed. 

Page 36 GAO-06-664 WIC-Only Vendors
individual items or differences in the quantities redeemed or both. For 

example, if some participant customers of regular WIC vendors select only 

a portion of the food items on a voucher, regular WIC vendors’ average 

redemption value would be lower than WIC-only vendors’, if their WIC 

customers received all of the items on the voucher. As a result, without 

these data, we could not attribute with certainty the changes in WIC 

program participation and expenditures we identified to WIC-only 

vendors’ prices. 

The growth in the number of WIC-only vendors in recent years, combined 

with our finding that individual WIC-only vendors generally had more than 

twice the business volume of regular WIC vendors in an average month in

2004, suggest that WIC-only vendors’ share of the WIC retail market was 

increasing before the 2004 legislation. Although in some states the number 

of WIC-only vendors has not grown, in others the number has grown 

quickly and the future effect of the new cost containment requirements on 

this growth is not known. Our scenario analyses suggest that continued 

WIC-only vendor growth could have resulted in either fewer participants 

being served or higher program costs. Moreover, given the current 

program model that focuses on ensuring participants receive prescribed 

foods without having to consider the costs of the commodities, 

participants would likely continue to take advantage of the customer 

service and convenient location offered by WIC-only vendors, even if 

prices are higher. 

Conclusions 

The lack of price and quantity data needed to explain the higher monthly 

average redemptions of WIC-only vendors and the higher average value of

vouchers redeemed by WIC-only vendors leaves important questions 

unanswered. We could not determine how WIC-only and regular WIC 

vendors’ prices differ. Our study was a first attempt to develop a national 

picture of WIC-only vendors, to inform policy initiatives and practice. 

However, absent a systematic analysis of vendor-level data, it is difficult to 

determine with more certainty how changes in market share between WIConly and regular WIC vendors would affect WIC program expenditures. 

The lack of price and quantity data on WIC food purchases also has 

broader program implications. Although WIC state agencies have used

routine and high-risk vendor monitoring and voucher review to promote 

accountability, for the most part they authorize and reimburse their WIConly and regular WIC vendors without knowing precisely which prescribed 

foods were purchased and in what quantities, what price the program was 

being charged for food, and whether participants were receiving the whole 

Page 37 GAO-06-664 WIC-Only Vendors
food package or only part of it. Collecting these data under the current 

system would be costly and burdensome to states. Under the new interim 

rule, WIC state agencies are required to collect vendors’ shelf price data 

but not the actual price charged the program or the quantity purchased. 

However, two recent developments in the WIC program—the 

implementation of electronic benefits transfer and the redesign of the WIC 

food package to include fruit and vegetables—may lead to changes in the 

WIC voucher and present WIC state agencies the opportunity to collect 

price and quantity data during the WIC transaction in a cost-effective way. 

This information could be used to determine whether the prices that both 

WIC-only and regular WIC vendors charge the program are reasonable and 

to analyze the effects of WIC vendors’ prices on program expenditures 

with greater certainty. 

To assist WIC state agencies in more effectively monitoring WIC vendors’ 

redemption practices, in implementing the new cost containment 

requirements, and in analyzing program expenditures, we recommend that 

the Secretary of Agriculture require, if collection of more detailed 

information on WIC food purchases is cost-effective through EBT 

implementation, that WIC state agencies collect data on both the price and 

the quantity of each WIC food item purchased, especially in each state that 

authorizes WIC-only vendors. 

We provided a draft of this report to the U.S. Department of Agriculture 

for review and comment. On June 14 and 16, 2005, FNS officials provided

us with their oral comments. The officials generally agreed that our 

methodology was reasonable, given data constraints, and did not dispute 

our findings on the recent growth of WIC-only vendors, the business 

model differences between WIC-only and regular WIC vendors, and the 

likely effect on the WIC program of further growth of WIC-only vendors’ 

market share based on 2004 data. However, they raised several concerns. 

They asked us to make clear that the 2004 data we used to determine the 

growth in the number of WIC-only vendors preceded the current 

moratorium on approving new WIC-only vendors, and the data we used to

calculate the effect of additional growth on the program were gathered 

before the full implementation of new cost containment provisions. These 

provisions, enacted when the program was reauthorized in 2004, are 

intended to help ensure that the program pays competitive prices to all 

authorized vendors. We incorporated additional references to these recent 

changes where appropriate. 

Recommendation for 

Executive Action 

Agency Comments 

Page 38 GAO-06-664 WIC-Only Vendors
FNS officials also commented on our finding that although the average 

value of all vouchers redeemed by WIC-only vendors in our three states in 

2004 was higher than that of vouchers redeemed by regular WIC vendors 

in these states, we could not determine with certainty whether prices 

charged by WIC-only vendors are higher than those charged by regular 

WIC vendors because we could not disaggregate price from quantity at the 

level of purchase. Officials acknowledged the ongoing challenges in 

collecting these data for foods provided under the WIC program. However, 

they expressed concern that this finding would be misinterpreted to mean 

there is no price difference between WIC-only and regular WIC vendors, 

and our finding on the likely effect on the program of continued growth of 

WIC-only vendors under 2004 conditions would be overlooked. We made 

some minor technical revisions to our report wording to clarify our 

findings and the limitations of available data on prices charged by WIC 

vendors. 

Further, in the draft these officials read, we recommended that FNS 

consider conducting a small-scale study to better understand how WIConly vendor prices and operations contribute to program expenditures. 

Officials did not believe this study would be necessary or cost-effective 

because of the difficulty in collecting price and quantity data on WIC 

purchases under the current paper-based system, and because program 

regulations already require monitoring of shelf prices and redemption data 

as a component of their vendor management. We understand that USDA 

has limited funds available for research, with multiple demands on these 

funds. Since the cornerstones of the new legislative requirements are that 

prices at above-50-percent vendors should be competitive with those 

charged by regular vendors and that vendors that derive more than 50 

percent of their revenue from WIC food instruments do not result in higher 

food costs to the program than do other vendors, officials are hopeful that

the new cost containment provisions will ensure the program pays 

competitive prices to all vendors. However, the cost containment 

provisions are complex and entail significant changes for some states. We 

believe it is important for FNS to closely monitor implementation of cost 

containment provisions to help ensure that program costs are in fact 

contained as intended. Moreover, as long as the program is structured so 

that participants need not pay attention to price, and given the current 

lack of available information on whether participants are actually 

receiving their prescribed foods and at what price, we believe FNS should 

proactively take advantage of all cost-effective ways of gathering data that 

will help contain costs and ensure the program is meeting its overall goals. 

In response, we have removed our recommendation for further study and 

further clarified our recommendation for additional data collection on the 

price and quantity of WIC food items purchased under a new EBT system. 

Page 39 GAO-06-664 WIC-Only Vendors
FNS also made additional technical comments, which we have 

incorporated where appropriate. 

As arranged with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after the 

date of this letter. At that time, we will send copies to the Secretary of 

Agriculture, relevant congressional committees, and other interested 

parties. We also will make copies available to others upon request. In 

addition, the report will be made available at no charge on the GAO Web 

site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me 

at (202) 512-7215 or fagnonic@gao.gov. Contact points for our Office of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff that made major contributions to this report are 

listed in appendix V. 

Cynthia M. Fagnoni 

Managing Director, Education, Workforce, and 

 Income Security Issues 

Page 40 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

Page 41 GAO-06-664 

Appendix I: Scope and Methodology 

This appendix discusses in detail our methodology for determining 

whether the vendors authorized by the Special Supplemental Nutrition 

Program for Women, Infants and Children (WIC) that are known as WIConly vendors contribute more to WIC program expenditures than do 

regular WIC vendors. The study was framed around three questions: (1) 

what is known about WIC-only vendors’ growth and their share of the WIC 

market in recent years? (2) To what extent do the business and marketing 

practices of WIC-only and regular WIC vendors differ?(3) What would 

WIC-only vendors’ contribution to WIC program expenditures have been if 

their market share increased? 

Because existing research on WIC-only vendors consisted of a few singlestate studies or analyses of a small number of individual states, we sought 

to develop a national picture. To ensure comparability of costs and 

business practices, we focused on the WIC retail vendor market, excluding 

Mississippi, which operates a direct distribution system, and Vermont, 

which uses a home food delivery system. To prevent potential duplication 

of data, we limited the study to the geographically contiguous states, 

omitting the 32 Indian Tribal Organizations that authorize many of same 

vendors authorized by the geographic WIC state agencies in which they 

reside. Given the large size of the WIC retail vendor population, we used 

existing data sources for our national-level analyses of WIC-only vendors’ 

growth and market share. Because WIC food instrument and redemption 

systems are unique to each state, we focused our analyses of WIC-only 

vendors’ contribution to program expenditures at the state level, 

concentrating on California, Texas, and Florida, the states that authorize 

84 percent of WIC-only vendors. To examine WIC-only and regular WIC 

vendors’ business and marketing practices, we relied on the experience of 

WIC state agency officials who have managed a substantial number of 

WIC-only vendors, including officials from seven states that had 

authorized 10 or more WIC-only vendors in fiscal year 2004. 

We used separate sources of data for each study question, including 

national-level administrative data for the entire WIC vendor population, 

state-level administrative data for every WIC food instrument redeemed in

fiscal year 2004, telephone interviews with WIC state agency directors and 

vendor management staff, and on-site observations and interviews at WIConly and regular WIC vendor establishments. Before deciding to use the 

administrative data, we conducted a thorough data reliability assessment 

of each data base, including a review of the data collection and reporting 

system that produced the data, guidance on variable definitions and 

Scope 

Methodology 

WIC-Only Vendors
Appendix I: Scope and Methodology 

measures provided to entities that reported the data, and steps the Food 

and Nutrition Service (FNS) or the WIC state agencies took to ensure data 

reliability. Once we received the administrative data files, GAO’s 

methodologists conducted electronic tests to check for the accuracy and

completeness of individual data elements. We discuss our testing 

procedures and steps we took to mitigate any data limitations below, as 

part of the methodology for each study question. On the basis of these 

efforts, we believe the data are sufficiently reliable for our purposes. We 

conducted a descriptive analysis of WIC-only vendors’ growth and market 

share, a scenario analysis of WIC-only vendors’ potential contribution to 

WIC program expenditures, and a comparative analysis of WIC-only and 

regular WIC vendors’ business and marketing practices. 

Procedures for Analyzing 

WIC-Only Vendors’ Growth 

and Market Share 

To determine what is known about WIC-only vendors in recent years, we 

gathered various federal and other data sources. We collected copies of 

FNS’s The Integrity Profile (TIP) for federal fiscal years 1999 through 2004. 

TIP is a database that includes information on all vendors authorized to 

provide food benefits under the WIC program at any point during a fiscal 

year. For each vendor entry, TIP identifies vendor type, location, and WIC 

redemption amounts, among other data. TIP data is provided by 90 WIC 

state agencies, representing all 50 states, the District of Columbia, Indian

Tribal Organizations (ITOs), and U.S. territories. WIC state agencies 

submit electronic data to FNS on an annual basis in accordance with 

instructions provided by FNS.1

 To complement information provided by

TIP, we conducted a literature search to compile a list of all research 

conducted on WIC-only vendors in recent years, but found that few such 

studies exist. As a result, our analysis focused largely on TIP.

As one step in our data reliability assessment process, we evaluated the 

integrity of TIP data. This procedure revealed two primary limitations. 

First, TIP does not report the actual date when a vendor enters or exits the 

WIC program; rather, it only indicates whether a vendor was authorized by 

a WIC state agency at any point during a fiscal year. As a result, TIP likely 

overstates the number of vendors in operation on any given date. For 

example, the number of WIC vendors in operation on the first day of a 

particular fiscal year—October 1—is probably less than the number 

Data Collection 

 1

Through fiscal year 2004, WIC state agencies provided data in electronic files, using either

ASCII or delimited file formats, which FNS then converted into a consolidated file. For 

fiscal year 2005, WIC state agencies were able to upload data directly into the FNS 

database. 

Page 42 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

reported by TIP for the same fiscal year, as TIP includes all WIC vendors 

for that fiscal year that were authorized as of October 1, in addition to all 

vendors that entered the program after that date. Thus, we could not 

calculate a percentage-based growth rate from year to year using TIP. 

Instead, we could only calculate the total number of WIC vendors of a 

specific type in operation for at least 1 day during a particular fiscal year. 

The second limitation we identified was that national TIP redemption data 

did not meet GAO’s data reliability standards, based upon information 

provided by FNS. Although FNS had requested that WIC state agencies 

submit average monthly redemption data for all WIC vendors during fiscal 

years 1999-2003, FNS officials determined subsequently that not all WIC 

state agencies had followed these instructions. FNS officials concluded

that some WIC state agencies had submitted redemption data in formats 

other than average monthly amounts, such as annual or quarterly figures,

but they were uncertain about the time period used by any particular WIC 

state agency in reporting redemption data. In recognition of this problem, 

for fiscal year 2004, FNS requested that WIC state agencies specify the 

time period that their redemption figures covered when submitting TIP 

data. FNS then annualized all redemption figures not submitted as annual 

amounts by multiplying the figures that were other than annual by the 

appropriate number of months. However, this process may have resulted

in overstated redemption figures for certain WIC vendors in fiscal year 

2004, as FNS annualized the redemption figures for all WIC vendors that 

did not have annual redemption amounts—including those vendors that 

were not authorized to participate in WIC for the entire fiscal year. As a 

result of these issues, we determined that we could not use FNS’s national 

TIP data to report trends in redemption amounts over time, or to calculate

average annual redemption amounts by vendor type for any particular 

fiscal year. However, because FNS had requested that WIC state agencies

specify the time period used in reporting redemption data for fiscal year 

2004, we concluded that we could use the original state data files from that 

year to calculate average monthly redemption figures. 

We converted redemption figures for all WIC-only and regular WIC 

vendors with valid redemption data into average monthly redemption 

amounts for any state that reported redemptions in a form other than 

monthly (see table 5 for these other time periods reported by states to FNS 

for fiscal year 2004).2

 For example, for any state that reported redemption 

 2

The majority of WIC state agencies provided redemption data over an average monthly 

period in fiscal year 2004. 

Page 43 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

amounts using quarterly figures, we divided each WIC vendor’s 

redemption total by three to create an average monthly figure. In 

converting redemption amounts, we excluded vendors that were not 

authorized to participate in the WIC program but that were sometimes 

included in the state files. When such vendors appeared, they were clearly 

identified as being unauthorized. 

Table 5: Time Periods Other than Monthly That WIC State Agencies Used in

Reporting Fiscal Year 2004 Redemption Data to FNS 

State Redemption data reporting period used

Alaska No valid redemptions reporteda

Delaware Quarterly

District of Columbia Annual 

Kentucky Annual, specifying the number of months in operation 

Maine Annual, specifying the number of months in operation 

Maryland Quarterly

Mississippi Not applicableb

New Hampshire Annual, specifying the number of months in operation 

New Jersey Quarterly 

New Mexico Annual 

Ohio Annual

Oregon Annual

Pennsylvania Annual

Rhode Island Annual, specifying the number of months in operation 

Vermont Not applicablec

Virginia Annual

West Virginia Annual 

Source: FNS regional office 2004 TIP files. 

a

Alaska’s WIC state agency did not report valid redemption data for fiscal year 2004; therefore, we 

excluded Alaska from our redemption analysis. However, Alaska was included in our analysis of 

national WIC vendor numbers. 

b

Mississippi did not authorize any WIC-only or regular WIC vendors during fiscal year 2004. 

c

Vermont did not authorize any WIC-only or regular WIC vendors during fiscal year 2004. 

In addition to eliminating specific analysis procedures due to data 

reliability issues, we narrowed the focus of our analyses to certain 

geographic areas and WIC vendor types. Because TIP includes data from 

ITOs and U.S. territories in addition to the 50 states and the District of 

Columbia, some WIC vendors may have been listed in more than one state 

Page 44 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

agency TIP file. For example, both a state and an ITO located within that 

state may have authorized, and thus included in their data file submitted to 

FNS, the same WIC vendor. To eliminate these potential data-reporting 

redundancies, our analysis of TIP focused exclusively on the 50 states and 

the District of Columbia. Concerning our vendor focus, TIP includes some 

vendor types and additional food delivery systems that are not directly 

comparable to WIC-only vendors. The noncomparable vendor types 

include military commissaries, usually located on military installations, 

and pharmacies, which often only provide infant formula and WIC-eligible 

medical foods. In addition, some state agencies authorize other food 

delivery systems, such as home food delivery and direct distribution. We 

eliminated from our analysis these noncomparable vendors and alternate 

food delivery systems, and defined our total WIC vendor population as 

consisting entirely of WIC-only vendors and regular WIC vendors. 

Our findings are the result of two primary analyses. First, we generated

frequency statistics concerning the number and location of WIC-only 

vendors and regular WIC vendors for fiscal years 1999 through 2004, and

used geographic information system (GIS) software to map the location of 

WIC-only vendors in fiscal year 2004. Second, using the original state data

we received from FNS’s regional offices for fiscal year 2004, we analyzed 

average monthly WIC redemption amounts by vendor type, both nationally 

and by state. 

Data Analysis 

Procedures for 

Determining the Extent to 

Which WIC-Only and 

Regular WIC Vendors’ 

Business and Marketing 

Practices Differ 

To identify WIC-only and regular WIC vendors’ business and marketing 

practices, we used two data collection strategies: group telephone 

interviews with WIC state agency directors, vendor management staff, and 

local agency staff that participate in vendor monitoring in selected states, 

and site visits to three of the states selected for telephone interviews. We 

developed criteria and selected states and officials for the telephone 

interviews and the site visits. 

Because we were relying on WIC state officials’ experience managing their 

WIC-only and regular WIC vendors to identify their business and 

marketing practices, we selected states for the telephone interviews that 

had authorized a substantial number of WIC-only vendors and specified 10 

as the minimum number of vendors. Using TIP data for fiscal year 2004 to

determine the number of vendors in operation, we selected states that had 

at least 10 WIC-only vendors that year. During fiscal year 2004, the number 

of WIC-only vendors in the 16 states that authorized them varied from 1 to 

715, but eight states—California, Texas, Florida, North Carolina, Arkansas, 

Alabama, Georgia, and Louisiana—had 10 or more. We treated Puerto Rico

Sample Selection 

Page 45 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

as a separate case and, because of Hurricane Katrina, excluded Louisiana, 

leaving seven states for interviews. To select telephone interview 

respondents, we asked the WIC state agency director to identify staff who 

had observed WIC-only and regular WIC vendors’ business and marketing 

practices directly through representative monitoring and compliance 

investigations. 

To ensure that we visited establishments with a range of key 

characteristics, we selected states for site visits from among those with 

the greatest number of WIC-only vendors—California, Texas, and Florida. 

We selected vendor establishments to visit in consultation with the WIC 

state agency director. Our selection criteria included urban and rural 

locations, years in operation, food price range, and vendor size, measured 

by WIC redemption volume. The California and Texas WIC state agencies 

provided us with a list of vendors from which we chose vendors according 

to our selection criteria. The Florida WIC state agency provided us with a 

list of vendors that met our criteria. We visited four WIC-only and four 

regular WIC vendors in each of the three states. 

We developed an interview guide with a standard set of questions for the 

telephone interviews and data collection instruments for the site visits. As 

a first step, we compiled a list of business and marketing practices from an 

interview with WIC state agency directors and vendor managers; 

interviews with representatives of vendor associations, such as the 

National Grocers Association, the Gulf Coast Retailers Association, and 

the California Independent Grocers Association; and existing studies of 

WIC-only vendors. These practices include selling shelf space to 

manufacturers; location of stores near clinics or military bases; advertising 

methods such as announcing weekly specials in newspaper ads or placing 

flyers on windshields in parking lots; incentives offered to participants at 

no cost, such as strollers, diapers, and bicycles; reduced price offers, such 

as buy one item, get one free; and transportation for participants to and 

from the vendor’s establishment. For the telephone interviews, we 

converted the list of practices to a separate set of questions about WIConly and regular WIC vendors. The site visit data collection instruments 

covered the same topics as the telephone instrument to permit 

comparisons of the information provided by WIC state agency staff and 

our observations of vendor establishments and interviews with store 

managers. However, the site visit instrument was designed with fixedresponse questions in a checklist format to facilitate completion during 

observation. To complement the observational and interview data, we 

obtained digital cameras and, with the WIC vendors’ permission, took 

interior and exterior photographs of the vendor establishments we visited. 

Data Collection 

Page 46 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

For all of the seven states we interviewed by telephone, we prepared a 

state-level table that synthesized the interview responses separately by 

vendor type and key business and marketing practice categories. We also 

prepared summary tables that further aggregated the business and 

marketing practice data within vendor type for each state. We used the 

summary tables to make cross-state comparisons. For the site visit 

interview responses, we created a matrix to summarize key findings on 

store characteristics, illustrative price data, and selected business and 

marketing practices. 

Data Analysis 

Scenario Analyses of WICOnly Vendors’ 

Contribution to WIC 

Program Expenditures, if 

Their Market Share 

Increases 

In order to assess WIC-only vendors’ contribution to WIC program food 

expenditures, if their market share increased, we developed two 

scenarios, based on available data for 2004 (the latest data available). In 

these scenarios we asked: 

• Scenario 1: What would have happened to the number of food 

vouchers that could have been issued and the number of WIC 

participants that could have been served in 2004, if we increased the 

number of food vouchers redeemed at WIC-only vendors while holding 

program food expenditures constant at fiscal year 2004 levels?

• Scenario 2: What would have happened to program food expenditures 

in 2004 if we increased the number of food vouchers redeemed at WIConly vendors while program expenditures were not held constant and 

the number of food vouchers issued to program participants remained 

at the 2004 level? 

We obtained copies of administrative data files from WIC state agencies’ 

management information systems in California, Texas, and Florida. These 

data included information on every food voucher that had actually been 

redeemed—that is, submitted for payment and paid—in these states. The 

unit of measure in our data was the value of a redeemed food voucher, and 

the data consisted of values for more than 100 million vouchers. 

Data Collection 

Using these data, we could determine the actual number of food vouchers 

redeemed at WIC-only and regular WIC vendors for each of the three 

states, as well as the average value of all food vouchers redeemed at WIConly and regular WIC vendors in each state. For example, figure 12 depicts 

the information available on three representative food vouchers and how 

we combined the values for these individual vouchers (e.g., $17.95, $13.07, 

and $12.55) to determine the average value of all vouchers redeemed (e.g., 

Page 47 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

$14.52). We did this for all vouchers for WIC-only and regular WIC vendors 

in California, Texas, and Florida. 

Figure 12: Example of the Average Value of Food Vouchers Redeemed by a WIC-Only Vendor

 

INDIVIDUAL NO. PARTICIPANT/ PARENT/GUARDIAN FIRST DAY TO USE LAST DAY TO USE SERIEL NO. 

113214683RR PUAL PARTICIPANT JUNE 12 04 JULY 11 04 476978438 

MILK/CHEESE /EGG 

WIC PROGRAM 

State of California 800-6229012572 

70-12-31 

1009 

EXACT PURCHASE PRICE: 

MUST NOT EXCEED 

$ 20 . 97 

Pay to the order of: 326476 

VALID FOR WIC APPROVED FOOD ONLY. 

VOID IF NOT DEPOSITED WITHIN 45 DAYS OF 

 “FIRST DAY USE.” NOT VALID IF ALTERED. 

 Kind to buy: 

* MILK-COW, FLUID 

PASTEURIZED (GALLONS ONLY) 

* CHEESE-CHEDDER, JACK, 

AMERICAN, MOZZARELLA IN 

0.75 LB (12OZ.) OR LARGER 

* EGGS-AA WHITE, SM,MD,LG,UP TO: 

 How much to buy: 

2 GALLONS MILK, 2DOZ EGGS 

(DOZENS ONLY) 2 LBS CHEESE NOT NEGOTIABLE AUTHORIZED SIGNATURE (SIGN AT PURCHASE) 

 

INDIVIDUAL NO. PARTICIPANT/ PARENT/GUARDIAN FIRST DAY TO USE LAST DAY TO USE SERIEL NO. 

113214683RR PUAL PARTICIPANT JUNE 12 04 JULY 11 04 476978438 

MILK/CHEESE /EGG 

WIC PROGRAM 

State of California 800-6229012572 

70-12-31 

1009 

EXACT PURCHASE PRICE: 

MUST NOT EXCEED 

$ 20 . 97 

Pay to the order of: 326476 

VALID FOR WIC APPROVED FOOD ONLY. 

VOID IF NOT DEPOSITED WITHIN 45 DAYS OF 

 “FIRST DAY USE.” NOT VALID IF ALTERED. 

 Kind to buy: 

* MILK-COW, FLUID 

PASTEURIZED (GALLONS ONLY) 

* CHEESE-CHEDDER, JACK, 

AMERICAN, MOZZARELLA IN 

0.75 LB (12OZ.) OR LARGER 

* EGGS-AA WHITE, SM,MD,LG,UP TO: 

 How much to buy: 

2 GALLONS MILK, 2DOZ EGGS 

(DOZENS ONLY) 2 LBS CHEESE NOT NEGOTIABLE AUTHORIZED SIGNATURE (SIGN AT PURCHASE) 

 

INDIVIDUAL NO. PARTICIPANT/ PARENT/GUARDIAN FIRST DAY TO USE LAST DAY TO USE SERIEL NO. 

113214683RR PUAL PARTICIPANT JUNE 12 04 JULY 11 04 476978438 

MILK/CHEESE /EGG 

WIC PROGRAM 

State of California 800-6229012572 

70-12-31 

1009 

EXACT PURCHASE PRICE: 

MUST NOT EXCEED 

$ 20 . 97 

Pay to the order of: 326476 

VALID FOR WIC APPROVED FOOD ONLY. 

VOID IF NOT DEPOSITED WITHIN 45 DAYS OF 

 “FIRST DAY USE.” NOT VALID IF ALTERED. 

 Kind to buy: 

* MILK-COW, FLUID 

PASTEURIZED (GALLONS ONLY) 

* CHEESE-CHEDDER, JACK, 

AMERICAN, MOZZARELLA IN 

0.75 LB (12OZ.) OR LARGER 

* EGGS-AA WHITE, SM,MD,LG,UP TO: 

 How much to buy: 

2 GALLONS MILK, 2DOZ EGGS 

(DOZENS ONLY) 2 LBS CHEESE NOT NEGOTIABLE AUTHORIZED SIGNATURE (SIGN AT PURCHASE) 

Total value 

of individual 

food voucher 

redeemed 

Average value 

of food 

voucher 

redeemed 

$17.95 

$13.07 

$12.55 

$14.52 

Source: GAO analysis.

Even though we were able to calculate the average value of all redeemed 

food vouchers for WIC-only and regular WIC vendors, we were not able to

determine whether prices for individual food items were higher at WIConly vendors than at regular WIC vendors. In order to answer that type of 

detailed question, we would have needed additional information that was 

not available because of the way data are collected by the states. 

Specifically, we would have needed the price of the individual food items 

Page 48 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

listed on the voucher and the quantity of each food item purchased, in 

addition to the total redeemed value. Figure 13 shows hypothetical 

vouchers from two vendors that include the type of information that 

would have been needed for such an analysis. It specifies that 2 gallons of 

milk were purchased at $3.57 per gallon for a total expenditure of $7.14. 

However, the data files we received did not contain either the price or the 

quantity purchased for individual vouchers. 

Figure 13: Example of Hypothetical Vouchers Specifying Price and Quantity 

WIC voucher 1

Product Quantity Unit price Total price

Milk

Eggs

Cheese

Total

2 gal.

2 doz.

2 lbs.

$ 7.14

$ 2.62

$ 8.18

$ 17.95

$ 3.57

$ 1.31

$ 4.09

WIC voucher 2

Product Quantity Unit price Total price

Milk

Eggs

Cheese

Total

2 gal.

2 doz.

2 lbs.

$ 14.00

$ 0

$ 0

$ 14.00

$ 7.00

Source: GAO analysis.

-

-

Without information on the quantity and price of the items on food 

vouchers, WIC participants would not know the value of the items they 

received and could not be price sensitive. WIC agencies would also not be

able to determine the prices of the items they redeemed or whether 

participants received the total quantity of products specified on the 

voucher. Without this information, it is difficult to know why average 

redemption values differ. 

Page 49 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

Figure 13 illustrates why it is important to know the quantity actually 

redeemed by the participant. For example, as shown in voucher 1 in the

figure, the participant received the full quantity of food specified on the 

voucher. The average value of all items is $17.95. In voucher 2, the average

value of the voucher at $14.00 is less expensive. The participant, however,

did not buy eggs or cheese and did not receive the full quantity of food 

specified on the voucher. If the voucher represents a prescription designed

to fulfill shortfalls in the participant’s nutritional needs, the partial 

fulfillment suggests that although the average value of voucher 2 is less 

than in voucher 1, the actual delivery of the food has not been achieved. 

Voucher 2 in figure 13 also demonstrates why it is necessary to know the 

price of individual items on the voucher. Without this information, it is not

possible to know whether the prices at one vendor are higher than prices

at another vendor. In voucher 2, the total value of the voucher is less than 

in voucher 1, yet the price charged for a gallon of milk is significantly 

higher. Use of the average value of the voucher of $14.00 clearly does not 

prove that prices at the second vendor are less than prices at the first 

vendor with the higher average value of $17.95. 

In addition, it is important to collect the actual price of the sales 

transaction—collected at the point of sale—rather than a shelf price. This 

is because the price listed on the shelf may not be the actual price of the

transaction. For example, if milk is being sold as a loss leader at the 

vendor represented by voucher 1, it is possible that the price on the shelf 

is actually $7.00 per gallon even though the price on the voucher is $3.57

per gallon. 

We also would have needed information on such things as the size and 

location of stores to further determine why prices and average values may 

have varied between WIC-only and regular WIC vendors in the states. 

To answer the questions presented in these two scenarios, we used the 

following equation for the sum of WIC-only and regular WIC retail vendor 

food expenditures: 

The model 

1) (program food expenditures for WIC-only vendors) + (program food 

expenditures for regular WIC vendors) = total WIC program food 

expenditures, or: 

2) qw xw + qr

xr = F04

Page 50 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

Where, 

qw xw = program food expenditures for WIC-only vendors where 

qw= number of vouchers redeemed by WIC-only vendors 

xw = average value of vouchers redeemed by WIC-only vendors 

qr

xr = program food expenditures for regular WIC vendors where 

qr

 = number of vouchers redeemed by regular WIC vendors 

xr

= average value of vouchers redeemed by regular WIC vendors 

F04 = total WIC program food expenditures for fiscal year 2004 

Table 6 shows the actual data for 2004 for California and can be used to 

demonstrate the application of the model. The number of vouchers 

redeemed by WIC-only vendors (qw) equaled 28,866,000, the average value

of vouchers redeemed (xw ) equaled $13.15.

3

 Conversely, the number of 

vouchers redeemed by regular WIC vendors (qr

) equaled 40,745,000, the 

average value of vouchers redeemed (xr

) equaled $12.28. Total WIC 

program food expenditures for California for fiscal year 2004 (F04 ) equaled 

$880,096,000. These data can be used in the formula to obtain the 

following: 

3) (28,866,000* $13.15) + (40,745,000 * $12.28) = $880,096,0004

 3

For each state, we computed the number of redeemed vouchers as the total count of

records in each state data file excluding vouchers redeemed at commissaries and 

pharmacies. In addition, we removed, on the advice of and in consultation with state 

representatives, any record that appeared to contain an anomaly such as missing 

an instrument ITEM number code, missing a vendor TYPE code, having a redeemed

amount greater than the maximum allowable amount, or having a negative redeemed

amount. 

4

Numbers may not add because of rounding. The total is the result of numbers and

calculations carried out using more significant digits than shown and is accurate. 

Page 51 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

Table 6: Example of Application of Model to Actual Data for California

WIC-only vendors Regular WIC vendors Total

Number of 

vouchers 

redeemed

Average value of

food vouchers 

redeemed

Number of 

vouchers 

redeemed

Average value of

food vouchers 

redeemed

Total number of

food vouchers 

redeemed

Total WIC 

program food 

expenditures

California Thousands Dollars Thousands Dollars Thousands Thousands

2004 Actual 28,866 $13.15 40,745 $12.28 69,611 880,096

Source: GAO analysis of California WIC state agency redemption data for 2004. 

In the first scenario, we wanted to see how participation would change in 

California, Texas, and Florida in 2004 if the number of vouchers redeemed 

at WIC-only vendors increased while holding total WIC program food 

expenditures constant at 2004 levels. We did this by increasing the number 

of vouchers redeemed at WIC-only vendors in the states in 2004 by a 

hypothetical 10, 20, 30, 50, and 100 percent. Because we increased the 

number of food vouchers redeemed at WIC-only vendors, and do not allow 

total WIC program food expenditures to increase, the total number of 

vouchers for WIC-only and regular WIC vendors that can be issued 

depends, in part, on whether the average value of redeemed vouchers is 

higher for WIC-only vendors. If the average value is higher, fewer food 

vouchers could be issued under this scenario and thus fewer participants

could be served. This would be reflected in our scenario by a reduction in 

the number of vouchers redeemed by regular WIC vendors. We calculated 

this change in the number of vouchers redeemed by regular WIC vendors 

by using equation 2a, which is equation 2 transformed.5

 We calculated the 

number of vouchers that would have been redeemed at regular WIC 

vendors qr

 for each hypothetical increase. All else was held constant at 

2004 levels. 

Scenario 1: 

2a.) qr

 = ((F04 - qw xw/)/xr ) 

We then used these new quantities calculated for WIC-only and regular 

WIC vendors under each of the hypothetical increases to determine the 

program food expenditures for each of the vendors. Examples of the 

 5

 Equation 2 is transformed to 2a in the following manner: 

 qw xw + qr xr = F04 

 qr xr = (F04 - qw xw) 

 qr = ((F04 - qw xw)/xr ) 

Page 52 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

scenario results for California are presented in table 7. In the case of a 100 

percent increase in WIC-only vendor redemptions, we increased the 

number of WIC-only redemptions from the actual value in 2004—

28,866,000 by a hypothetical 100 percent to 57,732,000. The resulting 

number of redemptions for regular WIC vendors, as calculated in formula 

2a, decreased from the 2004 value of 40,745,000 to 9,827,000. All else—the 

average value of redeemed vouchers for WIC-only ($13.15) and regular 

WIC vendors ($12.28), as well as total WIC program food expenditures 

($880,096,000)—is held constant. 

Table 7: Example of Calculation of WIC-Only and Regular WIC Vendors’ Number and Average Value of Food Vouchers for 

California

WIC-only vendors Regular WIC vendors Total

Number of food 

vouchers 

redeemed

Average value of

food vouchers 

redeemed

Number of 

food vouchers 

redeemed

Average value of

food vouchers 

redeemed

Total number of

food vouchers 

redeemed

Total WIC 

program food 

expenditures

California Thousands Dollars Thousands Dollars Thousands Thousands

100% increase 57,732 $13.15 9,827 $12.28 67,560 $880,096

Source: GAO analysis of California WIC state agency redemption data for 2004. 

This decline in the number of vouchers redeemed at regular WIC vendors 

results from the restriction in the analysis of keeping total WIC program 

food expenditures constant at 2004 levels. This decline occurs because 

according to our calculations based on all food vouchers for the state, the 

average value of food vouchers redeemed at WIC-only vendors is 

somewhat higher than the average value at regular WIC vendors. 

We calculated the number of participants who might be affected by the

change in the scenario. We did this by adding together the number of 

vouchers redeemed at WIC-only and regular WIC vendors in 2004 and 

under each hypothetical increase in the scenario for each of the three 

states. For example, in California, a total of 69,611,000 vouchers were 

redeemed in 2004 (table 6). As shown in table 7, for a doubling in the 

number of vouchers redeemed by WIC-only vendors, we estimated a total 

of 67,560,000 vouchers. 

Calculating the Number of 

Participants 

In the absence of more specific information on participation, we simply 

divided the total number of vouchers redeemed by the average number of 

vouchers redeemed per participant for each of the states. For example, in 

Page 53 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

California we estimated 32.69 vouchers per participant.6 We used that 

information to estimate that there were 2,130,000 participants in 2004, 

(69,611,000 / 32.69). Conversely, as shown in table 8, if the redemptions of 

vouchers by WIC-only vendors doubled, we estimated that 2,067,000 

participants (67,559,000 / 32.69) would be affected. 

As shown in table 8, in California, the difference between the number of 

participants in 2004 and the estimated number of participants if WIC-only 

vendor redemptions increased 100 percent (2,067,000-2,130,000) indicated

a decline of 63,000 participants that could be served. In California, this 

represented about 3 percent of the number of participants in 2004, ((63,000 

/ 2,130,000)*100). 

Table 8: Example Calculation of Decline in Number of Participants for California 

Total number of vouchers 

redeemed, all vendors

Average number of vouchers 

redeemed per person

Number of 

participants

California Thousands Number Thousands

2004 actual 69,611 32.69 2,130

100 percent increase in vouchers 

redeemed at WIC-only vendors 67,560 32.69 2,067

Decline in vouchers and participants -2,052 0 -63

Source: GAO analysis of California WIC state agency redemption data for 2004. 

Note: Numbers may not add because of rounding. 

In the second scenario, we wanted to see how expenditures that had been

held constant in the previous scenario would have to change in order to 

maintain the level of program participation constant at 2004 levels when 

the market share of WIC-only vendors increased. As in the previous 

scenario, we increased the number of redeemed food vouchers for WIConly vendors (qw) by a hypothetical 10, 20, 50, and 100 percent. While 

Scenario 2: 

 6

The number of vouchers per participant is based on the number of unique people who

redeemed a voucher, that is, people who are counted only once even if they came back

multiple times. For California, we computed the number of participants as a count of all 

unique INDIVIDUAL_ID values. This was defined in the California data documentation as a 

“system generated 11 character identifier unique to an individual”. The Individual ID can 

remain constant throughout the participant’s entire eligibility period with WIC. For Texas,

we computed the number of participants as a count of all unique CID (Unique Number 

Identifying A Client) values in the file. For Florida, we asked the state agency for “the

number of unique people who redeemed any type of food instrument in FY2004”. Florida

provided us with an “Unduplicated count for FFY04”. The number of vouchers per 

participant was computed as the number of vouchers/number of participants. 

Page 54 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

keeping the total number of vouchers redeemed constant at 2004 levels, 

we again used equation 2a to calculate the number of redeemed vouchers 

for regular WIC vendors (qr

). We allowed total expenditures to increase 

(F04). We then looked at the difference between that new level of 

expenditures and 2004 levels and then calculated what that change

represented as a percentage of 2004 levels. 

The results of the analysis for scenario 1 are presented in the next two 

tables. As shown in table 9, if the number of food vouchers redeemed in 

California at WIC-only vendors doubled, the number would increase from 

28.8 million to 57.7 million, while the number at regular WIC vendors 

would decline from 40.7 million to 9.8 million. 

Results of the Analysis for 

Scenario 1 

Page 55 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

Table 9: Results of the Calculation of WIC-Only and Regular WIC Vendors’ Number and Average Value of Food Vouchers for 

California, Texas, and Florida 

Actual and WIC-only vendors Regular WIC vendors 

scenario

increases in

vouchers at WIConly vendors 

Number of food 

vouchers 

redeemed

Average value of food

vouchers redeemed

Number of food 

vouchers redeemed

Average value of

food vouchers 

redeemed

Total WIC 

program food 

expenditures

California Thousands Dollars Thousands Dollars Thousands

2004 actual 28,866 $13.15 40,745 $12.28 880,096

10 % increase 31,753 13.15 37,653 12.28 880,096

20% increase 34,639 13.15 34,561 12.28 880,096

30 % increase 37,526 13.15 31,470 12.28 880,096

50 % increase 43,299 13.15 25,286 12.28 880,096

100% increase 57,732 13.15 9,827 12.28 880,096

Texas 

2004 actual 1,808 31.55 20,988 21.72 512,976

10 % increase 1,989 31.55 20,726 21.72 512,976

20% increase 2,170 31.55 20,463 21.72 512,976

30 % increase 2,350 31.55 20,201 21.72 512,976

50 % increase 2,711 31.55 19,675 21.72 512,976

100% increase 3,616 31.55 18,362 21.72 512,976

Florida

2004 actual 1,562 22.92 10,641 18.50 232,709

10 % increase 1,719 22.92 10,447 18.50 232,709 

20% increase 1,875 22.92 10,254 18.50 232,709 

30 % increase 2,031 22.92 10,060 18.50 232,709 

50 % increase 2,343 22.92 9,673 18.50 232,709 

100% increase 3,125 22.92 8,706 18.50 232,709 

Source: GAO analysis of California, Texas, and Florida WIC state agency redemption data for 2004. 

WIC-only vendors account for a much smaller share of the WIC market in 

Texas and Florida than in California. In Texas, for example a doubling of 

the WIC-only vendors’ market share would result in an increase in the 

number of food vouchers redeemed from 1.8 million to 3.6 million—with 

the number of food vouchers redeemed at regular WIC vendors decreasing 

from 20.9 million to 18.3 million. 

For Florida, the doubling of WIC-only vendors’ market share would result 

in an increase in the number of food vouchers redeemed from 1.6 million 

Page 56 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

to 3.1 million—with the number of food vouchers redeemed at regular 

WIC vendors decreasing from 10.6 million to 8.7 million. 

In all the states, the average value of vouchers redeemed at WIC-only 

vendors was higher than the average value of vouchers redeemed at 

regular WIC vendors. The value for California was calculated as $13.15, 

while the value for regular WIC was $12.28, with a difference of $0.87

between the two types of vendors. In Texas, the average value of vouchers 

redeemed at WIC-only vendors was calculated to be $31.55, while the 

value for regular WIC vendors was $21.72—a difference of $9.83. In 

Florida, WIC-only voucher redemptions averaged $22.92 in value, while the 

value for regular WIC was $18.50—a difference of $4.42. In addition, 

according to our analysis, the average value of vouchers redeemed at 

regular WIC vendors was lowest in California, at $12.28, followed by 

Florida at $18.50 and Texas at $21.72. The difference in the average value 

of vouchers redeemed should be treated with a great deal of caution. 

Because we used the average value of all food vouchers in our analysis 

without knowing the price or quantity of the individual food items that 

made up the vouchers, we could not determine if the higher average value

meant that prices for individual food items were higher at WIC-only 

vendors. As described earlier, the data represent the average value of the 

vouchers, not prices for specific food items. These data do not enable us 

to make price comparisons between the two types of vendors. In addition, 

this analysis does not allow us to determine why the average values in 

vouchers redeemed may be higher. To do that, we would need enough 

data on the costs vendors incurred in obtaining the food items as well as 

an understanding of the factors affecting those costs, such as store size, 

store location, marketing conditions and business practices, and any other 

factors affecting food item prices, to identify the factors affecting voucher 

values. 

The results of our calculation of the decline in the number of participants 

due to the increase in WIC-only vendors’ market share are presented in 

table 10. The number of redemptions as reported to us by each of the 

states was 33 per participant in California, 16 in Texas, and 18 in Florida. 

The decline in the number of participants ranged from less than 1 percent 

for a 10 percent increase in the number or redemptions at WIC-only 

vendors to about 3 percent for a 100 percent increase. 

Page 57 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

Table 10: Results of the Calculation of Decline in Number of Participants for California, Texas, and Florida 

Actual and

scenario

increases in food 

vouchers at WIConly vendors 

Total number of

vouchers, all 

vendors 

Average number 

of vouchers per 

person

Number of 

participants

Decline in number of

participants 

Decline in number of

participants as a 

percentage of 2004

California Thousands Number Thousands Thousands Percent

2004 actual 69,611 33 2,130 -

10 % increase 69,406 33 2,123 -6 0.29

20% increase 69,201 33 2,117 -13 0.59

30 % increase 68,996 33 2,111 -19 0.88

50 % increase 68,585 33 2,098 -31 1.47

100% increase 67,560 33 2,067 -63 2.95

Texas 

2004 actual 22,796 16 1,469 - 

10 % increase 22,715 16 1,464 -5 0.36

20% increase 22,633 16 1,458 -11 0.72

30 % increase 22,551 16 1,453 -16 1.08

50 % increase 22,387 16 1,443 -26 1.79

100% increase 21,978 16 1,416 -53 3.59

Florida

2004 actual 12,203 18 679 - 

10 % increase 12,166 18 677 -2 0.31

20% increase 12,129 18 675 -4 0.61

30 % increase 12,091 18 673 -6 0.92

50 % increase 12,017 18 669 -10 1.53

100% increase 11,831 18 658 -21 3.05

Source: GAO analysis of California, Texas and Florida WIC state agency redemption data for 2004. 

The results of our analysis for scenario 2 are shown in table 11. 

Expenditures for WIC-only vendors in California increased from $380 

million for a 10 percent increase to $759 million for a doubling of their 

market share. Expenditures changed by $2.5 million for the 10 percent 

increase to $25 million for a 100 percent increase in WIC-only market 

share. 

Results of the Analysis for 

Scenario 2 

Page 58 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

Table 11: Results of Allowing Program Food Expenditures to Increase for California, Texas, and Florida 

Program food expenditures 

 by vendor type Total program food expenditures Actual and

scenario increases 

in vouchers at WIConly vendors 

WIC-only

vendors 

Regular WIC 

vendors

Total food 

expenditures

Change in food

expenditures under 

scenarios 

Change in total 

program food 

expenditures as a 

percentage of 2004

California Thousand dollars Thousand dollars Thousand dollars Thousand dollars Percent

2004 actual 379,704 500,392 880,096

10 % increase 417,674 464,942 882,616 2,520 0.29

20% increase 455,644 429,491 885,135 5,039 0.57

50 % increase 569,555 323,139 892,694 12,598 1.43

100% increase 759,407 145,885 905,292 25,196 2.86

Texas 

2004 actual 57,046 455,930 512,976

10 % increase 62,751 452,002 514,753 1,777 0.35

20% increase 68,455 448,075 516,530 3,554 0.69

50 % increase 85,569 436,292 521,861 8,885 1.73

100% increase 114,092 416,654 530,746 17,770 3.46

Florida

2004 actual 35,801 196,907 232,709

10 % increase 39,382 194,016 233,398 689 0.30

20% increase 42,962 191,125 234,087 1,378 0.59

50 % increase 53,702 182,452 236,154 3,446 1.48

100% increase 71,603 167,997 239,600 6,891 2.96

Source: GAO analysis of California, Texas, and Florida WIC state agency redemption data for 2004. 

In Texas, program food expenditures in the scenario increased from $1.8 

million to $17.8 million, while expenditures increased from $689,000 to

$6.9 million in Florida. In all three states the increase represented from 

less than 1 percent to about 3 percent of 2004 values. 

The scenarios presented are based on the best data available at the time of 

the analysis. The results, however, are illustrative and leave unanswered 

some fundamental questions, including whether WIC-only vendors charge 

higher prices for food items and if so why the prices would be higher and

what is the overall effect on total program food expenditures and 

participation. In order to more fully answer these questions, we would 

have to know more about the actual prices and quantities of individual 

food items on the redemption vouchers. Any price comparison would have 

to be for similar products of similar quantity and quality. In addition, we 

Limitations 

Page 59 GAO-06-664 WIC-Only Vendors
Appendix I: Scope and Methodology 

would also have to know the factors that may be influencing prices. This 

would include such things as the costs for obtaining the product, as well 

as the difference between that cost and price. In addition, even if price 

differences exist, certain factors affecting the store’s costs—the size of the 

store, the location of the store, and the general market structure in which 

the store operates—may help explain the price differences. In the case of

the WIC market, the role of the program itself cannot be ignored; for 

example, that participants are not price sensitive. Thus to fully understand

the price difference between WIC-only and regular WIC vendors, we would 

need not only additional data but a different framework of analysis that 

would allow us to hold various factors constant while changing others. 

This type of detailed analysis would require significant resources to gather 

the data and, in addition, would probably be limited in scale to cover local 

rather than national WIC markets. 

Page 60 GAO-06-664 WIC-Only Vendors
Appendix II: Number of WIC-Only Vendors, Appendix II: Number of WIC-Only V Fiscal Years 1999-2004 endors, 

Fiscal Years 1999-2004 

State 1999 2000 2001 2002 2003 2004

Alabama 0 0 0 3 4 19 

Arkansas 4 4 9 0 0 42 

California 235 303 378 516 653 715

District of Columbia 0 0 0 1 1 1 

Florida 57 78 90 106 109 109 

Georgia 0 0 0 0 0 22 

Kansas 0 0 0 0 1 3

Louisiana 4 5 4 6 13 11

Maryland 0 0 0 1 1 0

Missouri 0 1 0 0 0 0

New Mexico 4 4 4 4 4 7 

North Carolina 2 11 18 29 44 72 

Oklahoma 5 6 6 6 6 8

Oregon 5 7 7 0 0 0 

Tennessee 2 2 2 3 2 1 

Texas 69 89 86 81 116 162 

Utah 2 1 1 1 1 2 

Virginia 5 12 16 22 6 6 

Total WIC-only vendors 394 523 621 779 961 1,180

Source: GAO analysis of FNS 1999-2004 TIP data. 

Note: Vendor counts include any vendor in operation at some point during the fiscal year. States not 

listed did not authorize any WIC-only vendors at any time during any of the fiscal years listed. 

Page 61 GAO-06-664 WIC-Only Vendors
Appendix III: Av

per WIC-Only V

20

erage Monthly Redemptions 

endor by State in Fiscal Year 

04 

Page 62 GAO-06-664 

Appendix III: Average Monthly Redemptions 

per WIC-Only Vendor by State in Fiscal Year 

2004 

The figure below shows the average monthly redemptions per WIC-only 

vendor and the number of these vendors in the 15 states (including the 

District of Columbia) with them in fiscal year 2004. 

Figure 14: Average Monthly Redemptions per WIC-Only Vendor by State in Fiscal Year 2004 

Dollars

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

Tennessee (N = 1)

DC (N = 1)

Utah (N = 2)

Kansas (N = 3)

Virginia (N = 6)

New Mexico (N = 7)

Oklahoma (N = 8)

Louisiana (N = 11)

Alabama (N = 19)

Georgia (N = 22)

Arkansas (N = 42)

North Carolina (N = 70)

Florida (N = 109)

Texas (N = 162)

California (N = 715)

Source: GAO analysis of FNS regional office 2004 TIP files.

46,339

36,128

30,200 29,209 30,107

32,757

63,751

42,759

15,055

8,287

15,761

46,182

36,909

20,965

25,490

Note: N = number of WIC-only vendors with valid redemption data in fiscal year 2004. States are 

listed from left to right with decreasing numbers of WIC-only vendors. 

WIC-Only Vendors
A

Used at WIC-Only and

in C

ppendix IV: WIC Vouchers Most Frequently

 Regular WIC Vendors 

alifornia, Texas and Florida 

Page 63 GAO-06-664 

Appendix IV: WIC Vouchers Most Frequently 

Used at WIC-Only and Regular WIC Vendors 

in California, Texas and Florida 

The figures below show the most frequently used vouchers for WIC-only 

and WIC regular vendors as well as the state total. We defined “most 

frequently” used as those that accounted for more than 1 percent of the

total. The figures indicate that both WIC-only and regular vendors are 

redeeming the same type of vouchers. 

Figure 15: Most Frequently Used Vouchers for WIC-Only, Regular and State Total for California, 2004 

Percentage of total

Source: GAO analysis of California WIC state agency redemption data for 2004. 

Type of voucher 

 California–all 

 California–regular WIC 

 California–WIC-only 

0 

5 

10 

15 

20 

25 

30 

Formula-16 cans

Similac Advance (conc.) 

Peanut butter-1 jar 

Formula-3 cans

Similac Advance (powder) 

Milk-2 gallonflu

Cereal-36 ounce

id/dry/evaporated 

s

Milk-1 gallonfluid/dry/evaporated 

Juice-3 containers

Milk-1 1/2 gallonfluid/dry/evaporated 

Cereal-36 ounces 

Juice-4 containers

Formula-4 cans 

Similac Advance (powder) 

Formula-5 cans 

Similac Advance (powder) 

Formula-9 cans 

Similac Advance (powder) 

Milk/cheese/egg

WIC-Only Vendors
Appendix IV: WIC Vouchers Most Frequently

Used at WIC-Only and Regular WIC Vendors 

in California, Texas and Florida 

Figure 16: Most Frequently Used Vouchers for WIC-Only, Regular and State Total for Texas, 2004 

Percentage of total

Source: GAO analysis of Texas WIC state agency redemption data for 2004. 

Type of voucher 

Texas–all 

Texas–regular WIC 

Texas–WIC-only 

0 

5 

10 

15 

20 

25 

30 

Formula Formula 

Gerber infant cereal 

w/o fruit, juice

Formula 

Eggs, juice, cereal, 

cheese, milk, beans

Eggs, juice, cereal, cheese, 

milk, peanut butter 

Eggs, juice, cereal, 

cheese, milk, beans

Form

Milk 

ula 

Formula 

Milk 

Milk 

Eggs, juice, milk, 

cheese

Formul

, cereal 

a 

Eggs, juice, cereal, 

cheese, milk, beans

Milk 

Formula 

Eggs, juice, cereal, cheese, 

milk, peanut butter 

Eggs, juice, cereal, 

cheese, milk, beans

Formula 

Page 64 GAO-06-664 WIC-Only Vendors
Appendix IV: WIC Vouchers Most Frequently

Used at WIC-Only and Regular WIC Vendors 

in California, Texas and Florida 

[This page left blank intentionally.] 

Page 65 GAO-06-664 WIC-Only Vendors
Appendix IV: WIC Vouchers Most Frequently

Used at WIC-Only and Regular WIC Vendors 

in California, Texas and Florida 

Figure 17: Most Frequently Used Vouchers for WIC-Only, Regular and State Total

for Florida, 2004 

0 

2 

4 

6 

8 

10 

12 

14 

16 

18 

20 

Milk/juice/eggs

16-GoodStart Supreme

(conc.) 

Milk/cheese/juice/eggs

Milk/cheese/juice/eggs

4-GoodStart Supreme

(powder) 

Milk/cheese/juice 

3-GoodStart Supreme

(powder) 

Milk/cheese/juice/cereal/ 

eggs/peanut butter 

Milk/cheese/juice/ 

cereal/eggs/beans

Percentage of total

Source:GAO analysis of Florida WIC state agency redemption data for 2004. 

Type of voucher 

Florida–all 

Florida–regular WIC 

Florida–WIC-only 

Page 66 GAO-06-664 WIC-Only Vendors
Appendix IV: WIC Vouchers Most Frequently

Used at WIC-Only and Regular WIC Vendors 

in California, Texas and Florida 

15-GoodStart Supreme Soy

DHA and ARA (conc.)

4-GoodStart Essentials

(powder)

Milk/cheese/juice

16-GoodStart Supreme Soy

DHA and ARA (conc.)

3-GoodStart Essentials

(powder)

2-Similac Alimentum Advance

(powder)

Juice/cereal (infant)

3-12.9 oz GoodStart Supreme Soy

DHA and ARA (powder)

Milk/cheese/juice/

cereal/eggs

Milk/juice

Milk/juice

15-GoodStart Supreme Soy

DHA and ARA (conc.)

Page 67 GAO-06-664 WIC-Only Vendors
A

A

ppendix V: GAO Contacts and Staff 

cknowledgments 

Page 68 GAO-06-664 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

Cynthia M. Fagnoni (202) 512-7215, fagnonic@gao.gov 

Kay Brown,(Assistant Director), Sara Edmondson, (AIC), Carol Bray, 

Casey Hanewall, Avani Locke, Luann Moy, Jennifer Popovic, Mark 

Ramage, Tovah Rom, and Dan Schwimer also made significant 

contributions to this report. 

GAO Contact 

Acknowledgments 

(130464) WIC-Only Vendors
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