Finding Text
Statement of Condition: During eligibility testing, we selected a sample of 60 WIC participant files for the period July 1, 2024 through June 30, 2025. We identified 6 instances (10% deviation rate) in which the certification file did not contain a signed WIC Agreement of Rights and Responsibilities for the applicable certification period. All other eligibility attributes tested (WIC category, categorical determination, proof of residency, income determination, and nutritional risk documentation) were properly documented without exception. Criteria: Eligibility is a direct and material compliance requirement under the OMB Compliance Supplement for Assistance Listing 10.557. Pursuant to 7 C.F.R. § 246.7, WIC applicants (or parents/caretakers, as applicable) must read and sign a statement of Rights and Responsibilities as part of the certification process in order to receive benefits. The signed agreement documents that: the information provided is true and accurate, the participant understands program rules, and the participant accepts responsibilities under the program. Additionally, the State of Maine WIC contract requires that each applicant/participant sign the Department-provided WIC Agreement of Rights and Responsibilities annually. Effect: Failure to obtain and retain signed WIC Agreements of Rights and Responsibilities represents noncompliance with federal regulation (7 C.F.R. § 246.7) and state contractual requirements. Although other eligibility elements were properly documented, the absence of required participant signatures results in certification files that are technically incomplete. This increases the risk that benefits may be issued without proper participant acknowledgment of program rules and responsibilities. Cause: Based on inquiry with management, the absence of signed agreements appears to be the result of procedural oversight during the certification or recertification process. Controls designed to ensure required documentation is obtained and retained were not operating effectively in all instances. Questioned Costs: No questioned costs are reported. While the absence of required documentation represents noncompliance, food benefits are issued and administered through the State-level EBT system. The dollar amount of benefits associated with the affected participant files cannot be readily determined at the local agency level. Accordingly, questioned costs are not reported. Recommendations: We recommend that management strengthen procedures to ensure that signed WIC Agreements of Rights and Responsibilities are obtained and retained for all initial certifications and annual recertifications. This may include implementing supervisory review controls, system-based prompts, or periodic internal file reviews to verify completeness of certification documentation.