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MI-WIC Vendor Policy Manual

5-01 Overview of Vendor Compliance

5.01 Overview of Vendor Compliance

Effective Date: 08/01/2021

PURPOSE:    

To describe the purpose and scope of Vendor compliance activities conducted by the Department.

 

DEFINITIONS:

Compliance activity means any monitoring, review, audit, investigation, or other action conducted by the Department to ensure Vendor compliance with WIC Program requirements.

 

Vendor violation means any intentional or unintentional action by a Vendor, its owners, officers, managers, agents, or employees that violates Federal or State WIC statutes, regulations, policies, procedures, or the WIC Vendor Contract.

 

POLICY:

 

  1. The Department shall conduct Vendor compliance activities to ensure compliance with Federal and State WIC Program requirements.

     

  2. Vendor compliance activities may include, but are not limited to:

     

    1. Monitoring visits;

       

    2. Inventory audits;

       

    3. Compliance buys;

       

    4. Complaint investigations; and

       

    5. Review of redemption and transaction data.

     

  3. Compliance activities may be conducted overtly or covertly and may be announced or unannounced.

     

  4. The Department may use the results of compliance activities to:

     

    1. Identify Vendor violations;

       

    2. Require corrective actions;

       

    3. Assess sanctions;

       

    4. Recover overpayments or claims; and

       

    5. Determine ongoing Vendor eligibility and authorization status.

     

  5. Vendors must cooperate with Department staff conducting compliance activities and provide requested documentation, records, invoices, and access to the store as required.

     

  6. Failure to cooperate with compliance activities may result in sanctions, termination, or disqualification from the WIC Program.

 

References:

7 CFR Part 246.12 (j)

 

Cross-References:

5.02 High-Risk Vendor Identification

5.03 In-store Monitoring Visits

5.04 Inventory Audits

5.05 Compliance Buys

5.06 Vendor Complaints

6.0 Vendor Sanctions

 

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