WIC PROGRAM

Improved Oversight of 

Income Eligibility 

Determination Needed

Report to Congressional Requesters

February 2013

GAO-13-290

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-290, a report to 

congressional requestors

February 2013

WIC PROGRAM

Improved Oversight of Income Eligibility 

Determination Needed

Why GAO Did This Study

WIC provides nutritious foods and 

assistance to low-income pregnant and 

postpartum women, infants, and young 

children. Research has shown that 

WIC helps to improve birth and dietary 

outcomes and contain health care 

costs. USDA’s FNS oversees the 

program, which is administered by 

state and local agencies. While federal 

regulations define criteria that must be 

used to determine applicants’ income 

eligibility for WIC, state and local 

agencies are also given some 

discretion. In addition, since 1989, 

federal law has allowed families who 

participate in other assistance

programs, such as Medicaid, to be 

automatically income-eligible for WIC. 

GAO was asked to provide information 

on WIC income eligibility 

determination. GAO assessed: (1) How 

do state and local criteria for 

determining WIC income eligibility 

vary? (2) To what extent are 

individuals who would otherwise be 

ineligible for WIC deemed eligible due 

to their participation in other programs? 

(3) How does USDA assist and monitor 

state determination of WIC income 

eligibility? GAO reviewed federal laws 

and regulations; analyzed USDA’s 

national data from 2010, recent survey 

findings, and monitoring reports; 

reviewed WIC policy manuals from 10 

states chosen to provide population 

size and geographic diversity; and 

interviewed federal, state, and local 

officials. 

What GAO Recommends

GAO recommends that USDA develop 

a timeline for reviewing its monitoring 

reports to assess national program 

risks and target assistance. USDA 

agreed with GAO’s recommendation.

What GAO Found

The discretion granted by federal law, regulations, and guidance in certain areas 

of income eligibility determination for the Special Supplemental Nutrition Program 

for Women, Infants, and Children (WIC) has resulted in policy variation across 

states and localities. For example, while national survey data show that many 

states use an applicant’s current income to determine income eligibility, GAO’s 

review of 10 state policy manuals found that states differ in how they define the 

time period covered by current income, with some looking at income from the 

most recent 30 days and others using longer time periods. WIC administrators 

also have discretion in determining which members of an applicant’s household 

should be considered part of the applicant’s family, and both national data and 

state policy manuals suggest that states often provide local agencies with 

guidance in this area at the same time as they pass this flexibility to them. State 

policies also vary to some extent as to the sources of income that are included 

and excluded when determining an applicant’s income eligibility for the program, 

according to national survey data. 

GAO’s analysis of administrative data found that 2 percent of WIC participants in 

2010 were eligible solely because of their participation in another program, as 

they had incomes over the federal WIC income limit. Because income data were 

not available for an additional 7 percent of participants in 2010, GAO could not 

determine if these participants also had incomes over the federal WIC income 

limit. In recent years, some states have expanded Medicaid eligibility to pregnant 

women, infants, and children with incomes above the WIC income limit, and 

many WIC participants who are eligible for WIC due to their participation in 

another program receive Medicaid. However, the relationship between Medicaid

expansions and WIC participation is unclear. While studies generally find that 

Medicaid recipients are more likely to participate in WIC than others, some 

suggest that expanded Medicaid income eligibility has not had a substantial 

effect on WIC participation because eligible families with relatively higher

incomes are less likely to participate in WIC than lower-income families. 

The U.S. Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) 

regularly assists and monitors states’ administration of WIC, but it does not 

review monitoring results at the national level to target assistance to states. 

Although FNS regularly provides assistance to states in administering WIC, this 

assistance has generally not been focused on key income eligibility 

requirements, such as determination of family size and the time period of income 

assessed, in recent years. However, through its monitoring reports from the last 

few years, FNS has identified problems with or concerns about income eligibility 

determination policies or procedures in one-third of the states reviewed. Although 

FNS officials said that they plan to begin regularly reviewing monitoring findings 

at the national level to identify areas of program risk and target assistance to 

states accordingly, officials did not indicate when those reviews will begin. A 

timeline for reviewing monitoring reports to assess national program risks could 

better position FNS to show progress in completing its planned actions. 

View GAO-13-290. For more information, 

contact Kay E. Brown at (202) 512-7215 or 

brownke@gao.gov.
Page i GAO-13-290 WIC Program

Letter 1 

Background 4

The Exercise of Allowable Discretion Has Led to Some Variation in 

State and Local Income Eligibility Policies 8

At Least 2 Percent of WIC Participants Are Eligible Solely Due to 

Adjunctive Eligibility 12

FNS Assists and Monitors States’ Income Eligibility 

Determinations; However, It Does Not Currently Use Monitoring 

Results to Target Assistance 16

Conclusions 20

Recommendation for Executive Action 21

Agency Comments 21

Appendix I Other Datasets that Provide Information on WIC Participant 

Incomes 22

Appendix II GAO Contacts and Staff Acknowledgments 24

Tables

Table 1: Adjunctively-Eligible WIC Participants, 2010 13

Table 2: Number of States with Medicaid Income Eligibility 

Thresholds Greater than the WIC Eligibility Threshold, as 

of January 2012 15

Figure

Figure 1: WIC Participants and Federal Appropriations, Fiscal 

Years 1975-2011 5

Contents 
Page ii GAO-13-290 WIC Program

Abbreviations

FNS Food and Nutrition Service

SNAP Supplemental Nutrition Assistance Program

TANF Temporary Assistance for Needy Families

USDA U.S. Department of Agriculture

WIC Special Supplemental Nutrition Program for Women, 

 Infants, and Children

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Page 1 GAO-13-290 WIC Program

United States Government Accountability Office

Washington, DC 20548

February 28, 2013

The Honorable John Kline

Chairman

Committee on Education and the Workforce

House of Representatives

The Honorable Robert Aderholt

Chairman

Subcommittee on Agriculture, Rural Development, Food 

 and Drug Administration and Related Agencies

Committee on Appropriations

House of Representatives

The Honorable Larry Bucshon

House of Representatives

The Honorable Jack Kingston

House of Representatives

The Special Supplemental Nutrition Program for Women, Infants, and 

Children (WIC) provided food, nutrition education, and health and social 

service program referrals to approximately 9 million low-income pregnant 

and postpartum women, infants, and young children in fiscal year 2011. 

The 2 million infants who receive WIC benefits annually account for about 

half of the infants born in the United States. WIC is overseen by the U.S. 

Department of Agriculture (USDA) and cost the federal government $7.2 

billion in fiscal year 2011. Federal WIC appropriations and participation 

have generally increased since WIC was established as a national 

program in the mid 1970s, primarily because of federal funding decisions 

but also due to policy changes that have expanded access to the 

program. For example, although federal law generally requires that 

families applying for WIC have incomes below 185 percent of the federal 

poverty guidelines, the 1989 federal enactment of adjunctive eligibility 

modified that requirement. Under adjunctive eligibility, families applying 

for WIC who receive benefits from Medicaid, Temporary Assistance for 

Needy Families (TANF), or the Supplemental Nutrition Assistance 

 
 

Page 2 GAO-13-290 WIC Program

Program (SNAP)1 are automatically income-eligible for WIC. When 

adjunctive eligibility was enacted, these programs had income eligibility 

thresholds for pregnant women, infants, and children that were equal to or 

less than 185 percent of the poverty guidelines, and therefore, this policy 

simply eased the WIC application process and increased coordination 

between related programs. However, since then, some states have 

expanded eligibility for these programs to include those with incomes 

above the WIC eligibility threshold, thereby potentially increasing the 

population eligible for WIC.

For families not adjunctively eligible for WIC, federal law and regulations 

define certain criteria that state and local agencies administering the 

program must use to determine applicants’ income eligibility. However, 

state and local agencies have some discretion in assessing applicants’ 

income eligibility. Because of this discretion, the characteristics of 

households determined income-eligible for WIC may vary across and 

within states.

This report is in response to your request for information on WIC income 

eligibility determination. We assessed: (1) How do state and local criteria 

for determining WIC income eligibility vary? (2) To what extent are 

individuals who would otherwise be ineligible for WIC deemed eligible for 

the program under adjunctive eligibility? (3) How does the USDA assist 

and monitor states’ processes for determining WIC income eligibility?

As criteria for our review, we examined relevant federal laws as well as 

USDA regulations and guidance related to WIC income eligibility 

determination and administrative oversight. To answer our research 

questions, we collected and analyzed information through several 

methods. At the federal level, we analyzed WIC administrative data on 

participant characteristics from 2010 and USDA’s national survey data on 

state and local WIC policy variation,2 which we determined were 

 

1 Medicaid generally provides health insurance coverage for low-income families and lowincome individuals who are aged or disabled, SNAP provides low-income families and 

individuals with benefits to purchase food, and TANF provides cash benefits and services 

to low-income families with children. 

2 USDA, Food and Nutrition Service, Office of Research and Analysis, National Survey of 

WIC Participants II: Volume 2: State and Local Agencies Report (Alexandria, VA.: 2012). 

This study collected data on WIC in 2008 and 2009.
 

Page 3 GAO-13-290 WIC Program

sufficiently reliable for the purposes of this report.3 We also examined 

USDA’s monitoring reports from all reviews conducted from fiscal years 

2010 through 2012 that assessed states’ certification policies and 

procedures and interviewed USDA officials. At the state level,4 we 

collected WIC policy manuals from a nongeneralizable sample of 10 

states that were selected to ensure diversity in population size and 

geography and reviewed sections related to income eligibility 

determination.5 We also interviewed state and local WIC administrators 

representing nine states, two Indian Tribal Organizations, and six local 

agencies, all of whom are members of the National WIC Association.6 To 

gather additional information on the effect of adjunctive eligibility on WIC 

participation, we conducted a literature review and examined six research 

studies that assessed the relationship between recent changes in income 

eligibility thresholds for Medicaid and WIC participation. We assessed the 

methodologies and findings of each of these studies and determined that 

they were sufficiently reliable for the purposes of this report.

We conducted this performance audit from October 2012 through 

February 2013 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

 

3 We assessed the reliability of the WIC administrative data on participant incomes by (1) 

performing electronic testing of required data elements, (2) reviewing existing information 

about the data and the system that produced them, and (3) interviewing agency officials 

knowledgeable about the data. We assessed the reliability of the national survey data by 

reviewing existing information about the data and the system that produced them and 

interviewing agency officials knowledgeable about the data. 

4 Throughout this report, our analyses of states reflect the 50 states, the District of 

Columbia, 34 Indian Tribal Organizations, and five U.S. Territories that administer WIC, 

unless otherwise noted. 

5 We selected California, Connecticut, Georgia, Idaho, Kansas, Michigan, Texas, Utah, 

Virginia, and Washington.

6 National WIC Association staff assisted us in contacting these officials, most of whom 

are Association board members. While the administrators we interviewed represented a 

range of geographic locations, the views they shared are not generalizable to all states. 
 

Page 4 GAO-13-290 WIC Program

Established as a national program in the mid 1970s,7 WIC is designed to 

improve the health and nutritional well-being of pregnant and postpartum 

women, infants, and young children by providing nutritious supplemental 

foods, nutrition education, and referrals to health and social service 

programs. Research has shown that WIC helps to improve birth and 

dietary outcomes and contain health care costs, and USDA considers 

WIC to be one of the nation’s most successful and cost-effective nutrition 

intervention programs. The program is available in each state, the District 

of Columbia, 34 Indian Tribal Organizations, and five U.S. Territories. 

USDA’s Food and Nutrition Service (FNS) oversees the program, which is 

administered by state and local agencies through approximately 10,000 

clinic sites.

Federal WIC appropriations and participation have generally increased 

since the program was established and totaled $7.2 billion and 9 million 

participants in fiscal year 2011 (see figure 1). WIC is almost entirely 

federally-funded. WIC is not an entitlement program; the federal 

government is not legally required to provide benefits to every eligible 

individual. Instead, WIC is a federal grant program for which Congress 

appropriates a specific amount of funds each year. In order to help inform 

budgetary decisions for the program, USDA annually estimates the 

number of people who are eligible for the program and the number who 

are expected to participate. Although federal funding has been sufficient 

to serve all eligible people who sought program benefits in recent years, 

some eligible people do not participate in WIC. Since 2000, WIC’s 

national coverage rate has been around 60 percent,8 but coverage rates 

vary by state and participant type. For example, in 2009, the coverage 

rate for children aged 1 to 4 was 51 percent, while the coverage rate for 

infants was 83 percent.

 

7 WIC began as a 2-year pilot program, the Special Supplemental Food Program, which 

was established in 1972. The program was renamed WIC in 1973, and legislation 

established WIC as a permanent national nutrition program in 1975.

8 USDA determines WIC coverage rates by dividing the number of program participants 

by the estimated number of people eligible for the program. Although WIC coverage rates 

have been estimated for many years, concerns that the estimates of people eligible for 

WIC did not reflect adjunctive eligibility and other eligibility factors led to recent changes. 

In 2003, the Committee on National Statistics of the National Research Council published 

a report outlining recommendations for improving WIC coverage rate estimates, and 

USDA has since modified its methodology based on those recommendations. 

Background 
 

Page 5 GAO-13-290 WIC Program

Figure 1: WIC Participants and Federal Appropriations, Fiscal Years 1975-2011

In enacting WIC, Congress intended the program to provide women, 

infants, and young children with supplemental foods during critical times 

of growth and development. WIC participants typically receive food 

benefits in the form of vouchers or coupons that they redeem at 

authorized retail vendors to obtain, at no cost to the participants, certain 

approved foods, including infant formula. State WIC agencies then 

reimburse the retail vendors for the food purchased by WIC participants. 

Since 1989, state WIC agencies have been required by law to contain the 

cost of infant formula using a competitive bidding process to award solesource contracts. Under these contracts, formula manufacturers agree to 

provide a rebate to the state WIC agency for every container of infant 

formula purchased under the WIC contract. Infant formula rebates have 

become an important source of funding for the WIC program, and in fiscal 

year 2011, infant formula companies provided more than $1.3 billion in 

rebates to states. As a result, while the average monthly WIC benefit cost 

to the federal government was $47 per participant in that year, the 

average monthly benefit value per participant was $59.

Pregnant and post-partum women, infants, and children up to age 5 are 

eligible for WIC if they are found to be at nutritional risk and have incomes 

below a certain threshold. Federal law and regulations set the WIC 

Eligibility
 

Page 6 GAO-13-290 WIC Program

income eligibility threshold at a maximum of 185 percent of the federal 

poverty guidelines,9 specify certain income sources that must be included 

and excluded when determining income eligibility, and require applicants 

to provide proof of income. However, federal regulations also provide 

state WIC administrators with discretion to further define income eligibility 

criteria. For example, federal regulations indicate that state agencies 

have the flexibility to decide whether to use an applicant’s annual or 

current rate of income, as well as the specific time period that equals 

current income, when determining applicants’ income eligibility. In 

addition, federal regulations broadly define the family or economic unit to 

be used for WIC income eligibility determination purposes, and federal 

guidance provides further clarification of this definition while also 

acknowledging that an answer is not available for every question that may 

arise in a specific case. Because of this, federal guidance also indicates 

that state and local agencies need to exercise discretion and use 

judgment in determining each applicant’s income eligibility within the 

general framework of regulatory requirements and basic program policy.10

Applicants may also be deemed income-eligible for WIC if they receive 

benefits from certain other federal assistance programs for low-income 

families—a policy known as adjunctive eligibility. Adjunctive eligibility was 

created by the Child Nutrition and WIC Reauthorization Act of 1989, and it 

makes recipients of Medicaid, TANF, and SNAP automatically incomeeligible for WIC.11 In practice, once WIC applicants provide proof of their 

participation in one of these programs, they are determined income-

 

9 States have the option of setting the WIC income eligibility threshold to equal either (1) 

the maximum income eligibility threshold specified in the National School Lunch Act for 

free and reduced price meals—185 percent of the federal poverty guidelines, or (2) the 

income eligibility threshold used for state or local free or reduced-price health care, as 

long as this guideline is at least 100 percent and no greater than 185 percent of the 

federal poverty guidelines. According to USDA, all states set the income eligibility 

threshold at 185 percent of the federal poverty guidelines. Federal poverty guidelines are 

determined annually by the U.S. Department of Health and Human Services. 

10 For example, when assessing eligibility, local agencies may review families’ income 

from the last 30 days, 12 months, or another time period, or include the income of all 

members of an applicant’s household or just the income of the mother and child. 

11 Adjunctively-eligible applicants are still required to meet other WIC program eligibility 

criteria. When adjunctive eligibility was created, it made Medicaid, Aid to Families with 

Dependent Children (AFDC), and Food Stamp Program participants automatically incomeeligible for WIC. However, TANF replaced AFDC in 1996, and the Food Stamp Program 

was renamed SNAP in 2008. 
 

Page 7 GAO-13-290 WIC Program

eligible and do not need to provide proof of their incomes.12 As a result, 

adjunctive eligibility streamlines the determination of income eligibility, 

easing the paperwork burden on both the applicant and the administrator. 

When adjunctive eligibility was enacted, income eligibility thresholds for 

Medicaid, TANF, and SNAP were below WIC’s income eligibility threshold 

of 185 percent of the federal poverty guidelines.

While WIC is not necessarily time-limited, because of the types of 

individuals it serves, it is generally a short-term program. WIC participants 

are certified as eligible for program benefits for time periods that vary 

based on the type of WIC participant—pregnant, post-partum, or 

breastfeeding woman; infant; or child—and state policy choices.13 The 

longest period for which any participant may be certified is 1 year.14 Once 

a participant’s certification period ends, the participant may reapply for 

benefits, at which time eligibility is redetermined. Between certification 

periods, WIC participants are generally not required to report changes in 

their circumstances—such as income or family size—that may affect their 

eligibility.15

Federal regulations require FNS to monitor state administration of WIC. 

To meet this requirement, FNS conducts Management Evaluations of 

states through its regional offices. The evaluations assess the 

accomplishment of program objectives and state and local agency 

compliance with federal requirements, including those related to income 

eligibility determination. FNS produces a report following each state 

evaluation that includes review findings and observations. If state or local 

program operations are found to be non-compliant with federal 

requirements, FNS identifies required corrective actions in the report. 

 

12 Although adjunctively-eligible WIC applicants do not need to provide proof of their 

incomes, FNS asks states to obtain self-reported income information from these 

applicants. 

13 Federal regulations establish timeframes for certification periods but also permit state 

agencies to make some limited policy decisions within the federal limits. 

14 For example, states may establish 1 year certification periods for certain breastfeeding 

women, infants, and children.

15 However, federal regulations require local agencies to reassess participant income midcertification if the agency receives information indicating the participant’s income has 

changed. 

Program Oversight
 

Page 8 GAO-13-290 WIC Program

States are then required to develop a corrective action plan and 

implementation timeframes.

Federal regulations also require states to monitor all local agencies 

administering WIC biennially and define the minimum number of clinic 

sites that states must review for each local agency. Income eligibility 

determination must be reviewed. Similar to federal reviews of states, local 

agencies must be notified of areas in which they are found to be noncompliant with requirements and must develop and implement corrective 

action plans to address these findings. States must also require local 

agencies to establish a system for reviewing their own operations, 

including those at clinic sites.

The discretion granted by federal law, regulations, and guidance in 

certain areas of WIC income eligibility determination has resulted in some 

variation in policy across states and localities. As a result, a family may 

be correctly deemed income-eligible for WIC in one locality even though 

in another locality, the family would be considered ineligible. State and 

local WIC administrators we spoke to discussed the use of discretion in 

determining income eligibility and noted its importance because some 

WIC applicants have unique income and family situations that make 

income determination particularly difficult. Similarly, an FNS official noted 

that because of varied family circumstances, guidance cannot provide 

clarification on every situation that may arise. Federal guidance also 

states that discretion is necessary in part because the department does 

not intend WIC income eligibility determination to be a complicated and 

lengthy procedure.

The time period for which an applicant’s income is assessed is one area 

in which states are granted flexibility in federal regulations, and while 

there are some similarities in state policies, there are also some 

differences. Although federal regulations provide state agencies 

discretion to assess applicants’ current or annual income, the one 

example provided in regulations requires states to use current income 

when assessing the eligibility of unemployed applicants. According to 

The Exercise of 

Allowable Discretion 

Has Led to Some 

Variation in State and 

Local Income 

Eligibility Policies
 

Page 9 GAO-13-290 WIC Program

national survey data,16 most states assess current income to determine 

eligibility for all applicants.17 However, how states define current income 

differs. In 5 of the 10 state WIC policy manuals we reviewed, 2 define 

current income as income from the last 30 days, 1 defines it as income 

from the last 60 days, and 2 others do not clearly define it. In practice, this 

means families with a temporary drop in income—such as those in which 

a parent’s work hours have been reduced—may be found eligible for the 

program at the time of application, even if their annual incomes are above 

185 percent of the federal poverty guidelines. The 5 other state manuals 

we reviewed indicate that local agencies may assess an applicant’s 

current or annual income, depending on which most accurately reflects 

the applicant’s income situation. For example, one state’s manual

indicates that the decision of whether to use current or annual income 

should be made on a case-by-case basis. The policies of these 5 states 

indicate that these states chose to pass the discretion explicitly provided 

to them in federal regulations to their local agencies. This is consistent 

with national survey data, which show that about half of the states pass 

some of the federally-allowed discretion for WIC income eligibility 

determination on to their local agencies.18

Another area in which states are given flexibility is in determining an 

applicant’s family size. Because the family’s total income is assessed to 

determine income-eligibility for WIC, and total income must fall below 185 

percent of the federal poverty guidelines, determination of the applicant’s 

 

16 National Survey of WIC Participants II (2012). Throughout our report, references to 

national survey results are based on the state agency survey results from this study. All 

state agencies administering WIC were surveyed—representing 50 states, the District of 

Columbia, 34 Indian Tribal Organizations, and five U.S. Territories. Survey respondents 

included 49 states, the District of Columbia, 27 Indian Tribal Organizations, and five U.S. 

Territories. 

17 Sixty-two percent of states reported using current income for WIC income eligibility 

determination, 4 percent reported using annual income, and an additional 13 percent of 

states let local agencies define the income time period. Twenty-one percent of states 

responded “other” to this survey question.

18 Fifty-four percent of states give some discretion to local agencies regarding the 

determination of income eligibility. 
 

Page 10 GAO-13-290 WIC Program

family size directly impacts income eligibility.19 According to national 

survey data, 42 percent of states give additional discretion to local 

agencies in determining the WIC family or economic unit. In the 10 state 

WIC manuals we reviewed, 9 suggest that local agencies have discretion 

in defining the applicant’s family size, though all provide specific 

examples of family situations in order to assist local agencies with these 

determinations. For example, all 10 manuals clarify situations in which an 

applicant living in a household with other adults constitutes a separate 

economic unit from those adults.20 In such situations, a mother and infant 

living in a household in which total income is above 185 percent of the 

federal poverty guidelines may be found eligible for WIC if they are not 

receiving assistance from others in the household and if their own income 

is below that threshold. According to two WIC administrators we 

interviewed, determining a teenage mother’s economic unit can be 

particularly difficult if she is living with her parents or others. These 

administrators added that local staff ask these applicants many questions 

to try to determine whether the mother and her children are their own 

economic unit or whether they are part of a larger economic unit that 

includes the mother’s parents or other household members. Two 

additional WIC administrators echoed this statement more generally, 

noting that the varied household situations of WIC applicants sometimes 

require local agencies to make decisions about family size on a case-bycase basis. However, some added that discretion is generally not passed 

on to individual staff who determine eligibility. Rather, to facilitate 

consistent application of eligibility determination policies, all of the 

administrators we interviewed indicated that they provide specific 

protocols for staff to follow, and these protocols are often programmed 

into the computer system used for income eligibility determination. 

Additionally, two administrators noted that when staff encounter a unique 

 

19 Federal poverty guidelines are adjusted for the number of people within a family, and 

income that equals 185 percent of the poverty guidelines is greater as family size 

increases. For example, in 2012, a family of two with an annual income at or below 

$27,991 met the WIC income eligibility threshold in the 48 contiguous states, the District of 

Columbia, and the U.S. Territories, as did a family of three with an annual income at or 

below $35,317. 

20 Federal regulations define a family to be a group of related or nonrelated individuals 

who are living together as one economic unit. Federal guidance adds that the production 

and consumption of goods or services are related in an economic unit, and therefore, it is 

possible for two separate economic units to reside under the same roof. Guidance also 

notes that state and local agencies will need to exercise judgment regarding the economic 

dependence or independence of each applicant.
 

Page 11 GAO-13-290 WIC Program

case they are not able to resolve, they are instructed to seek supervisory 

review. Similarly, one of the state policy manuals we reviewed 

recommends supervisory review for all applicants who qualify as a 

separate economic unit within a household and notes that these 

applicants should be approved on an exception basis.

State policies also vary to some extent as to the sources of income that 

are included when determining an applicant’s income eligibility for WIC. 

Federal regulations include a list of income sources that must be included 

and excluded, but the list is not exhaustive, and some discretion is 

explicitly allowed. For example, national survey data show that only about 

one-quarter of states include energy, rental, or medical assistance 

(between 22 and 28 percent)—which are not directly mentioned in federal 

regulations—when assessing an applicant’s income.21 In contrast, there is 

significant consistency among states related to income sources that are 

included in federal regulations, as between 94 and 100 percent of states 

include wages, salaries, and fees; self-employment income; 

unemployment compensation; child support; or Social Security when 

assessing an applicant’s income. Federal regulations give states 

discretion regarding the exclusion of certain types of military 

compensation, and as a result, while 77 percent of states exclude the 

basic allowance for off-base and privatized housing in the United States, 

about half of states exclude certain other allowances for housing 

according to national survey data.22 As a result of the variation in income 

sources that are included when determining eligibility, one state could 

determine a family’s income to be under 185 percent of the federal 

poverty guidelines while another state could find that same family’s 

income to be over that level.

 

21 In addition, there is also notable variation based on the type of state agency. The states 

and the District of Columbia are more likely than Indian Tribal Organizations and U.S. 

Territories to include certain sources of income when determining income eligibility for 

WIC. For example, 90 percent of the states and the District of Columbia include federal 

Supplemental Security Income compared to 67 percent of Indian Tribal Organizations and 

40 percent of U.S. Territories. 

22 For example, 52 percent of states exclude Family Separation Housing provided to 

military personnel for overseas housing, and 55 percent of states exclude the Overseas 

Housing Allowance provided to military personnel living overseas. 
 

Page 12 GAO-13-290 WIC Program

Some adjunctively-eligible WIC participants have incomes greater than 

the WIC eligibility threshold and are therefore income-eligible for WIC 

solely because of their receipt of benefits from another program, though 

most adjunctively-eligible participants have incomes below the WIC 

threshold. In 2010, 69 percent of WIC participants were adjunctively 

eligible,23 with almost all of those participants eligible due to their receipt 

of Medicaid.24 Further, in some states, pregnant women, infants, and 

children with incomes greater than the WIC income eligibility threshold 

are eligible to receive Medicaid.25 According to national WIC 

administrative data, about 2 percent of all WIC participants were 

adjunctively eligible and had incomes over the WIC eligibility threshold of 

185 percent of the federal poverty guidelines in 2010. Because income 

data were not reported for an additional 7 percent of participants who 

were adjunctively eligible, we could not determine if these participants 

were also eligible for WIC solely due to adjunctive eligibility in that year. 

(See table 1).

 

23 For many years, a substantial portion of WIC participants have been adjunctively 

eligible due to receipt of Medicaid, TANF, or SNAP, according to national WIC 

administrative data. For example, in 1996, 59 percent of WIC participants were 

adjunctively eligible due to their receipt of one of these programs. 

24 Specifically, in 2010, 66 percent of WIC participants received Medicaid, either alone or 

in combination with SNAP or TANF. In addition to adjunctive eligibility linking Medicaid to 

WIC, federal law and regulations mandate coordination between the two programs. For 

example, WIC agencies are required to refer potentially eligible WIC participants to 

Medicaid. A 2007 report on coordination between the two programs found that 72 percent 

of state Medicaid agencies require their Managed Care Organizations to inform their 

members about WIC.

25 Each state operates its own Medicaid program within federal guidelines. Because the 

federal guidelines are broad, states have a great deal of flexibility in designing and 

administering their programs. Although certain mandatory populations must be covered by 

Medicaid for states to receive federal funding, states may choose to cover additional 

populations. As a result, Medicaid eligibility can and often does vary widely from state to 

state.

At Least 2 Percent of 

WIC Participants Are 

Eligible Solely Due to 

Adjunctive Eligibility
 

Page 13 GAO-13-290 WIC Program

Table 1: Adjunctively-Eligible WIC Participants, 2010

With Incomes Over 185 Percent

of the Federal Poverty Guidelines With No Income Data Reported

Number

Percentage of All WIC 

Participants Number

Percentage of All WIC 

Participants

Total Participants 166,289 1.7% 694,578 6.9%

Pregnant Women 17,731 1.7% 65,656 6.5%

Breastfeeding Women 10,464 1.6% 35,570 5.4%

Postpartum Women 9,686 1.4% 61,084 9.0%

Infants 35,621 1.5% 185,416 7.8%

Children 92,788 1.8% 346,852 6.5%

Source: GAO analysis of USDA data on all WIC participants in April 2010.

Notes: “Participants” include all persons on WIC master lists or persons listed in WIC operating files 

who were certified to receive WIC benefits in April 2010. Adjunctively-eligible participants with no 

income data reported include those for whom data on income, income time period, or size of the 

economic unit were missing or reported as zero. Because adjunctively eligible participants do not 

need to provide proof of income, these income data have not been verified.

Although the national WIC administrative data are the best available for 

examining the income of the entire population of WIC participants,26 both 

federal WIC requirements and the exercise of state discretion affect these 

income data. For example, federal regulations require that income data 

be collected from WIC participants at one point in time, which is the date 

of application. As a result, these data generally do not reflect increases or 

decreases in income that may occur during the time period for which a 

participant has been certified as eligible.27 In addition, federal regulations 

do not require states to assess income data for adjunctively-eligible 

participants, but rather, USDA requests that states submit self-reported 

income information for these participants to the department. 

Consequently, these data do not have to be verified either through 

participant-provided documentation or other means, such as state wage 

 

26 This statement reflects our assessment of the administrative data. See Appendix I for 

an overview of other datasets that may be used to assess WIC participants’ incomes. 

27 As previously noted, WIC applicants are generally not required to report changes in 

income that occur generally after a participant is determined to be eligible until the 

certification period ends. However, federal regulations require local agencies to reassess 

participant income mid-certification if the agency receives information indicating the 

participant’s income has changed. The longest time period for which a participant can be 

certified is 1 year. 
 

Page 14 GAO-13-290 WIC Program

records,28 and they are also not consistently reported by states. In 2010, 

income information was not available for 7 percent of adjunctively-eligible 

WIC participants.29 The share of participants with no reported income 

information varied significantly by state, which may reflect differences in 

state policy.30 The WIC director from one state that did not report income 

information for the majority of its participants told us that the state directs 

its local agencies not to enter income for adjunctively-eligible participants 

because self-reported income information does not reflect a full income 

assessment. The director explained that the state instead relies on the 

determination of income eligibility that has already been made by the 

program through which the applicant is adjunctively eligible, as that is the 

point of the adjunctive eligibility policy.

A review of state changes in income eligibility thresholds for the programs 

through which a WIC applicant can be deemed adjunctively eligible 

provides additional context for understanding the relationship between 

adjunctive eligibility and WIC participation. Since adjunctive eligibility was 

created, some states have increased the income eligibility thresholds for 

SNAP and Medicaid above the WIC income eligibility threshold of 185 

percent of the federal poverty guidelines. For example, according to 

USDA, 13 states have increased SNAP income eligibility thresholds to 

 

28 According to federal guidance, WIC administrators are not required to verify income 

information reported by adjunctively-eligible WIC participants because it is assumed that 

income was already verified by the program through which the participant is adjunctively 

eligible, such as Medicaid.

29 USDA officials told us that, over the years, they have worked with the states to increase 

the reporting of participant income data. The WIC administrative data show that this has 

improved. For example, while income information was not available for 16 percent of WIC 

participants in 2002, this percentage has steadily decreased since then. However, it is 

likely that there will always be some WIC participants with missing income information, as 

federal guidance provides states discretion to grant temporary benefits for 30 days to 

individuals who lack proof of income or adjunctive eligibility at the time of application. 

30 For example, of the 90 state agencies administering WIC, 57 states—37 states, 15 

Indian Tribal Organizations, and five U.S. Territories—reported income information for 90 

percent or more of their WIC participants. In contrast, 10 states—3 states and 7 Indian 

Tribal Organizations—reported income information for less than half of their WIC 

participants. If WIC participants’ incomes were distributed similarly across states that 

reported participants’ incomes and those that generally did not report incomes, the share 

of adjunctively-eligible WIC participants who had incomes above 185 percent of the 

federal poverty guidelines would have been about 2 percent. 
 

Page 15 GAO-13-290 WIC Program

200 percent of the guidelines.31 For Medicaid, some states similarly 

increased income eligibility thresholds to 200 percent of the guidelines, 

while others increased thresholds up to 300 percent of the guidelines.32

Specifically, infants in families with incomes greater than 185 percent of 

the federal poverty guidelines were Medicaid-eligible in 25 states, 

pregnant women in such families were Medicaid-eligible in 23 states, and 

children aged 1 to 5 in such families were Medicaid-eligible in 14 states, 

as of January 2012. (See table 2.)

Table 2: Number of States with Medicaid Income Eligibility Thresholds Greater than 

the WIC Eligibility Threshold, as of January 2012

Federal

Poverty Guidelines Infants Pregnant Women Children Aged 1-5 

186-200% 15 14 7 

201-250% 3 5 3 

251-300% 7 4 4 

Total 25 23 14

Source: Kaiser Family Foundation. Based on a national survey conducted by the Kaiser Commission on Medicaid and the Uninsured 

with the Georgetown University Center for Children and Families.

Notes: This analysis includes the 50 states and the District of Columbia. States included are those 

that have income eligibility thresholds for the specified groups set at levels above 185 percent of the 

federal poverty guidelines for Medicaid or Medicaid expansions funded by the Children’s Health 

Insurance Program. State income eligibility thresholds for separate state programs funded by the 

Children’s Health Insurance Program are not included in this analysis because recipients of these 

programs are not adjunctively eligible for WIC. We did not independently verify this information.

Although a number of states have expanded Medicaid income eligibility 

thresholds above the WIC threshold, the extent to which these 

expansions have increased WIC participation is unclear. While studies 

generally find that Medicaid recipients are more likely to participate in 

 

31 As of November 2012, 13 states had implemented broad-based categorical eligibility 

policies for SNAP that increased the SNAP income eligibility limit to 200 percent of the 

federal poverty guidelines, according to USDA’s “Broad-Based Categorical Eligibility” 

table, which is available on the department’s website. The difference between 185 and 

200 percent of the federal poverty guidelines was about $240 per month for a family of 

three in 2012. We recently reported on broad-based categorical eligibility for SNAP in 

Supplemental Nutrition Assistance Program: Improved Oversight of State Eligibility 

Expansions Needed, GAO-12-670 (Washington, D.C.: July 26, 2012).

32 The majority of states that increased SNAP income eligibility thresholds to 200 percent 

of the federal poverty guidelines also expanded Medicaid income eligibility above the WIC 

income eligibility threshold. 
 

Page 16 GAO-13-290 WIC Program

WIC than others, some studies suggest that expanded Medicaid income 

eligibility has not had a substantial impact on WIC participation because 

eligible families with relatively higher incomes are less likely to participate 

in WIC than lower-income families. For example, one study that focused 

on recent increases in WIC participation among children aged 1 to 4 

found that those increases were not related to higher-income families 

receiving Medicaid.33 Another study noted that the connection is unclear, 

but it added that increases in states’ Medicaid income eligibility thresholds 

did not seem to change the proportion of WIC participants who were 

determined eligible for WIC due to adjunctive eligibility.34 Two of the state 

administrators we interviewed were from states that had recently 

expanded Medicaid eligibility above the WIC threshold, and they similarly 

noted that they did not see an increase in WIC participation after 

Medicaid was expanded.

FNS regularly provides assistance to states in administering WIC, though 

this assistance has generally not been focused on key income eligibility 

requirements, such as determination of family size and the time period of 

income assessed, in recent years. While FNS headquarters’ staff are 

responsible for formulating WIC policy and guidance, FNS’s regional 

offices are the primary federal contact for states on WIC administration.35

Regional office staff are responsible for regularly reviewing changes to 

each state’s WIC State Plan of Operation to ensure it is consistent with 

federal requirements and providing states with technical assistance. 

However, in recent years, FNS’s assistance to states on income eligibility 

determination has been focused primarily on clarifications of particular 

situations that have arisen. For example, FNS guidance from the last few 

years has clarified the exclusion or inclusion of income sources such as 

combat pay, compensation payments made to certain veterans, and 

earned income of temporary Census workers. Although FNS 

 

33 M. Bitler and J. Currie, “Medicaid at Birth, WIC Take-Up, and Children’s Outcomes,” 

Institute for Research on Poverty, Discussion Paper no. 1286-04 (2004).

34 C.A. Swann, “WIC Eligibility and Participation: the Roles of Changing Policies, 

Economic Conditions, and Demographics,” The B.E. Journal of Economic Analysis & 

Policy, vol. 10, no. 1 (2010).

35 According to FNS headquarters’ officials responsible for WIC, their primary role is to 

formulate WIC policy and guidance and disseminate this information to FNS’s seven 

regional offices and the states. 

FNS Assists and 

Monitors States’ 

Income Eligibility 

Determinations; 

However, It Does Not 

Currently Use 

Monitoring Results to 

Target Assistance
 

Page 17 GAO-13-290 WIC Program

headquarters’ officials noted that questions regarding particular situations 

are frequently addressed, FNS has not recently clarified key income 

eligibility requirements. Rather, FNS’s primary policy guidance on those 

requirements was issued in 1988 and 1999. State WIC officials we 

interviewed indicated that FNS regional office staff are helpful and 

responsive to questions they raise regarding WIC administration, but 

none of the officials could recall asking FNS questions about key income 

eligibility requirements in recent years.

FNS regularly monitors state and local WIC administration through

Management Evaluations conducted by its regional offices,36 and in onethird of the states reviewed since 2010, FNS found problems with income 

eligibility determination policies and procedures. Specifically, in the 

Management Evaluation reports we reviewed,37 regional FNS reviewers 

found problems with or expressed concerns about income eligibility 

determination policies or procedures in 23 states (including 15 states, 6 

Indian Tribal Organizations, and 2 U.S. Territories), despite the flexibilities 

allowed in federal regulations in this area.38 The most common finding 

related to adjunctive eligibility was insufficient proof of adjunctive eligibility 

in participant case files (5 states). Concerning other aspects of income 

eligibility determination, problems were found related to a lack of required 

income information in participant case files (6 states),39 the income 

sources included or excluded (5 states), and the determination of an 

 

36 Similar to FNS assistance to states, FNS headquarters officials produce Management 

Evaluation guidance that is distributed to FNS regional offices and the states.

37 To analyze monitoring findings related to income eligibility determination, we reviewed 

FNS’s reports from all Management Evaluations of states conducted from fiscal years 

2010 through 2012 that addressed certification. These reports covered 68 of the 90 state 

agencies that administer WIC, though some states were reviewed more than once during 

this period. According to FNS officials, all states are to be reviewed at least once every 4 

years. Some FNS regions review states once every 4 years, at which time they review all 

required areas. In other regions, states are reviewed annually only on a selection of 

required areas. Certification, which includes income eligibility determination, is one of the 

required review areas. 

38 Some of these states had multiple findings related to income eligibility determination. 

39 In two of these six states as well as two additional states, FNS reviewers also noted 

problems related to a lack of income information in adjunctively-eligible participants’ case 

files. While USDA requests that states submit self-reported income information for 

adjunctively-eligible participants, they are not required to do so. Therefore, these 

Management Evaluation findings suggest that there may be inaccurate interpretations of 

federal requirements in this area by FNS reviewers.
 

Page 18 GAO-13-290 WIC Program

applicant’s family size (5 states). Other income eligibility determination 

policy and procedural issues were found in 13 states, such as a lack of 

procedures to follow when a participant’s income eligibility was in 

question and the provision of temporary certification without income proof 

for a period longer than the maximum 30 days. Because these 

Management Evaluations involve FNS review of state WIC administration, 

as well as administration in selected local agencies, some of the findings 

represent systemic problems within a state while others reflect more 

localized issues. For example, in some instances, FNS found that certain 

aspects of state income eligibility determination policies were not 

consistent with federal requirements, while in others, some local 

agencies’ procedures were not consistent with requirements.

FNS’s Management Evaluation reports also reflect that there are 

weaknesses in some states’ administration of WIC that may indirectly 

affect income eligibility determination. According to FNS headquarters’ 

officials, states have primary responsibility for overseeing and monitoring 

WIC administration through the dissemination of state policy and 

procedures and biennial reviews of all local agencies. However, the 

Management Evaluation reports we reviewed noted problems with staff 

training and state and local monitoring, which—while not directly related 

to income eligibility determination policy or procedures—are areas of 

weakness in the internal control system designed to ensure 

accomplishment of program objectives and compliance with federal 

requirements. For example, FNS reviewers found problems related to 

staff training in 16 states (including 9 states, 5 Indian Tribal 

Organizations, and 2 U.S. Territories). Although most of these findings 

related to insufficient training of state or local staff or a lack of 

documentation that staff had received training, in 2 of these 16 states, 

FNS reviewers noted that the state staff person responsible for monitoring 

local agencies had not received training on federal WIC requirements. 

The Management Evaluation reports we reviewed also included findings 

related to state or local monitoring of WIC administration in 17 states 

(including 12 states and 5 Indian Tribal Organizations). Within those 

states, a range of issues were found, such as state reviews of local 

agencies that did not assess all of the required review areas, states that 

did not review all local agencies within the required time period, and 

incomplete or missing local agency corrective action plans to address 

deficiencies found by state reviewers.

Although FNS plans to begin regularly reviewing Management Evaluation 

findings at the national level to identify areas of program risk and target 

assistance accordingly, officials had not previously done so because 
 

Page 19 GAO-13-290 WIC Program

findings were not easily compiled at FNS headquarters. Standards for 

Internal Control in the Federal Government call for management to 

comprehensively identify risks and indicate that methods to do so may 

include consideration of findings from audits and other assessments.40

Because Management Evaluations provide key information on WIC 

administration nationwide, upper management reviews of states’ actual 

performance cited in these Evaluations are essential to an effective 

internal controls system and FNS’s ability to take appropriate actions to 

address risks. However, FNS headquarters’ officials told us that, in the 

past, they have only reviewed regional offices’ monitoring findings on an 

ad hoc basis. Further, they have not reviewed findings on income 

eligibility determination, and, as a result, they have not focused their 

technical assistance in this area. Officials said that they plan to begin 

reviewing monitoring findings more regularly to help identify areas in 

which additional assistance may be needed, and the national 

Management Evaluation tool FNS implemented in 2010 will make this 

feasible. This electronic tool is accessible at FNS headquarters, and it 

includes findings from all Management Evaluations conducted by FNS 

regional offices nationwide. Officials said that they have been focused on 

ensuring that the tool is being implemented effectively, but they did not 

indicate when they plan to start using it to systematically analyze 

monitoring findings. A timeline for reviewing these evaluations, consistent 

with standard management practices for implementing programs, could 

better position FNS to demonstrate progress towards completing its 

planned actions.41 In addition, officials are also in the process of reviewing 

findings from the National Survey of WIC Participants II, which was 

released in April 2012, to determine areas in which additional clarification 

of federal requirements is likely needed.42

 

40 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 

41 Standard practices for project management established by the Project Management 

Institute state that managing a project involves, among other things, developing a timeline 

to reassess efforts underway. The Project Management Institute, The Standard for 

Program Management © (2008). 

42 Because FNS guidance is distributed by headquarters to both FNS regional offices and 

states, additional guidance clarifying federal requirements should improve both state WIC 

administration and the assistance states receive from FNS regional offices.
 

Page 20 GAO-13-290 WIC Program

WIC provides essential nutrition and assistance to low-income families 

during pregnancy and in the important early years of a child’s 

development. Strong support for WIC over the years has led to increased 

federal funding that has enabled all eligible families who seek assistance 

from the program to receive benefits, but as the federal government 

continues to seek ways to manage with fewer resources, ensuring the 

program serves those it is intended to is critical. While state and local 

income eligibility determination policies for WIC differ to some extent and 

result in families’ eligibility for the program being somewhat dependent on 

where they live, the discretion granted in federal regulations and guidance 

suggests this result may be in line with program goals.

With adjunctive eligibility, however, whether program goals continue to be 

served is less clear. Adjunctive eligibility in WIC streamlines eligibility 

determination by allowing those eligible for another program that serves 

the low-income population to be deemed automatically income eligible for 

WIC—easing both administrative and client burden and improving 

program access. However, because programs change over time, it is 

important to continually assess the effect of these program interactions. In 

the case of WIC and Medicaid, two-thirds of WIC participants are now 

eligible for WIC benefits due to their receipt of Medicaid, and data show 

that increases in Medicaid’s income eligibility thresholds have enabled 

some women, infants, and children to receive WIC who would otherwise 

have been found ineligible. Given the current economic constraints, the 

impact of adjunctive eligibility may not be in line with program goals. 

However, if modifications to adjunctive eligibility are considered, because 

the policy currently eases administrative and participant burden for the 

majority of WIC participants, such changes should carefully weigh the 

potential benefits and costs.

Along with ensuring that WIC applicants’ income eligibility is determined 

consistent with program goals, it is important to ensure that the program 

operates effectively and in line with federal requirements. While federal 

regulations specify oversight and monitoring procedures aimed at 

ensuring requirements are met, as with any internal controls system, both 

the design and implementation of the system are key to its effectiveness. 

With WIC, FNS monitoring of states has identified areas related to income 

eligibility determination in which additional guidance and assistance may 

help improve WIC administration. To date, FNS has not taken advantage 

of available opportunities to improve program effectiveness by regularly 

reviewing monitoring results to identify and target assistance to states in 

these areas. Because officials have said they plan to do such reviews in 

the future, a timeline for reviewing its monitoring results could better 

Conclusions 
 

Page 21 GAO-13-290 WIC Program

position FNS to demonstrate progress towards completing its planned 

actions. Although little has changed in federal income eligibility 

determination policies in recent years, the existence of monitoring 

findings in this area suggest additional assistance and clarification would 

be beneficial in ensuring overall program integrity.

To improve WIC oversight and administration, we recommend that the 

Secretary of Agriculture direct FNS to develop a timeline for reviewing 

Management Evaluation reports to assess program risks at a national 

level and target assistance to states.

We provided a draft of this report to USDA for review and comment. In 

oral comments, USDA officials concurred with our recommendation. 

Officials also provided technical comments, which we incorporated into 

the report as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of it until 30 days from 

the report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Agriculture, and 

other interested parties. In addition, this report will be available at no 

charge on GAO’s website at http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-7215 or brownke@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in Appendix II.

Kay E. Brown

Director, Education, Workforce, and Income Security Issues

Recommendation for 

Executive Action

Agency Comments
Appendix I: Other Datasets that Provide 

Information on WIC Participant Incomes

Page 22 GAO-13-290 WIC Program

In addition to the national administrative data on participants in the 

Special Supplemental Nutrition Program for Women, Infants, and 

Children (WIC), two Census Bureau datasets have been used by other 

researchers to examine WIC participant characteristics, including 

incomes.

• The Current Population Survey (CPS), Annual Social and Economic 

(ASEC) Supplement is an annual survey that collects data on 

household income, participation in federal programs, and 

demographic characteristics of the household. Over 70,000 housing 

units are sampled. The CPS ASEC Supplement collects detailed 

information about annual income for the previous year, but it does not 

collect monthly income data. It also collects information on household 

participation in WIC, as well as programs used to confer adjunctive 

eligibility for WIC, including Medicaid, the Supplemental Nutrition 

Assistance Program (SNAP), and Temporary Assistance for Needy 

Families (TANF).

• The Survey of Income and Program Participation (SIPP) is a 

longitudinal household survey. The survey design is a continuous 

series of national panels, with sample sizes ranging from 

approximately 14,000 to 36,700 interviewed households. The duration 

of each panel ranges from 2 1⁄2 years to 4 years. The first SIPP panel 

was in 1984, and the most recent panel began in 2008. Households in 

the panel are interviewed every four months. The SIPP collects 

detailed information on each household’s monthly income, as well as 

information on participation in federal programs. Specifically, data 

about monthly participation in WIC, Medicaid, SNAP, and TANF are 

collected.

In 2003, the Committee on National Statistics of the National Research 

Council published a report that reviewed the use of CPS and SIPP data 

for estimating WIC eligibility and participation.1 The Committee found that 

WIC participation is underreported in both of these datasets. Despite this 

limitation, the Committee noted that research has shown that WIC 

participants’ characteristics are generally similar in the CPS, SIPP, and 

administrative data, with the exception of participants’ incomes, which 

 

1 National Research Council, Committee on National Statistics, Estimating Eligibility and 

Participation for the WIC Program: Final Report. The National Academies Press 

(Washington, D.C.: 2003).

Appendix I: Other Datasets that Provide 

Information on WIC Participant Incomes
Appendix I: Other Datasets that Provide 

Information on WIC Participant Incomes

Page 23 GAO-13-290 WIC Program

have been found to be higher in the CPS and SIPP than in the 

administrative data.2 The Committee concluded that this is not surprising 

given the flexibility that WIC administrators have in determining the time 

period for which income is measured to establish eligibility, as well as 

income variability over the course of a year, which has been found to be 

significant for the WIC-eligible population. As a result, researchers may 

reach different conclusions depending on the dataset analyzed.

 

2 M. Bitler, J. Currie, and J. Scholz, “WIC Eligibility and Participation,” Journal of Human 

Resources 38(S):1139-1179 (2003).
Appendix II: GAO Contacts and Staff 

Acknowledgments

Page 24 GAO-13-290 WIC Program

Kay E. Brown, (202) 512-7215 or brownke@gao.gov

Kathy Larin (Assistant Director), Rachel Frisk (Analyst-in-Charge), and 

Robert Campbell made significant contributions to all aspects of this 

report. Also contributing to this report were Carl Barden, Holly Dye, Chuck 

Ford, Ashley McCall, Sheila McCoy, Jean McSween, Dae Park, Kathy 

Peyman, Almeta Spencer, and Roger Thomas.

Appendix II: GAO Contacts and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(131212)
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