WIC Program: Improved Oversight of Income Eligibility Determination Needed
Published: 2013-02-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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. 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.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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  Program (SNAP) 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, which we determined were  sufficiently reliable for the purposes of this report. 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, 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. 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. 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.
subsections: section_title: Background
paragraphs: Established as a national program in the mid 1970s, 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, 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.
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 sole- source 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.
subsections: section_title: Eligibility
paragraphs: 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  income eligibility threshold at a maximum of 185 percent of the federal  poverty guidelines, 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.
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 income- eligible for WIC. In practice, once WIC applicants provide proof of their  participation in one of these programs, they are determined income- eligible and do not need to provide proof of their incomes. 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. The  longest period for which any participant may be certified is 1 year. 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.
section_title: Program Oversight
paragraphs: 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.
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 non- compliant 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.
section_title: The Exercise of Allowable Discretion Has Led to Some Variation in State and Local Income Eligibility Policies
paragraphs: 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  national survey data, most states assess current income to determine  eligibility for all applicants. 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.
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  family size directly impacts income eligibility. 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. 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-by- case 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  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. 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. 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.
section_title: At Least 2 Percent of WIC Participants Are Eligible Solely Due to Adjunctive Eligibility
paragraphs: 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, with almost all of those participants eligible due to their receipt  of Medicaid. Further, in some states, pregnant women, infants, and  children with incomes greater than the WIC income eligibility threshold  are eligible to receive Medicaid. 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).
Although the national WIC administrative data are the best available for  examining the income of the entire population of WIC participants, 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. 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  records, and they are also not consistently reported by states. In 2010,  income information was not available for 7 percent of adjunctively-eligible  WIC participants. The share of participants with no reported income  information varied significantly by state, which may reflect differences in  state policy. 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  200 percent of the guidelines. 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.  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.)
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  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. 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. 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.
section_title: FNS Assists and Monitors States’ Income Eligibility Determinations; However, It Does Not Currently Use Monitoring Results to Target Assistance
paragraphs: 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.  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  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, and in one- third of the states reviewed since 2010, FNS found problems with income  eligibility determination policies and procedures. Specifically, in the  Management Evaluation reports we reviewed, 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. 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), the income  sources included or excluded (5 states), and the determination of an  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  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.  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. 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.
section_title: Conclusions
paragraphs: 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  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.
section_title: Recommendation for Executive Action
paragraphs: 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.
section_title: Agency Comments
paragraphs: 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.
section_title: Appendix I: Other Datasets that Provide Information on WIC Participant Incomes
paragraphs: 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 ½ 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. 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  have been found to be higher in the CPS and SIPP than in the  administrative data. 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.
section_title: Appendix II: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.