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MI-WIC Vendor Policy Manual

5-02 High Risk Vendor Identification

5.02 High-Risk Vendor Identification

Effective Date: 08/01/2021

PURPOSE:

To describe how Vendors are selected for monitoring activities based on high-risk indicators.

DEFINITIONS:

High-risk Vendor means a Vendor identified as having a high probability of committing a program violation based on criteria established by the Department.

POLICY:

  1. The Department shall identify high-risk Vendors and refer them for compliance activities using the following criteria:
    1. System-Generated Reports. The Department uses statistically based reports to identify Vendors who are out of program compliance and/or have a high probability of having a Vendor violation.
      1. These reports are produced, reviewed, and analyzed at least annually and comply with USDA, FNS criteria for high-risk reports.
      2. Vendors identified on these reports may receive a warning notice, sanction, monitoring visit, compliance buy and/or inventory audit.
    2. Complaints. The Department receives information about Vendor noncompliance from a variety of sources, including WIC clients, other Vendors, local clinics, federal, state or local agencies (including law enforcement agencies) and interested citizens.
      1. Follow-up on complaints may include investigations by the Department, monitoring visits, compliance buys or referral to federal, state or local law enforcement agencies.
      2. Additional information on complaints is described in Policy 5.06 Vendor Complaints.
    3. Other Sources of Information. The Department may also identify high-risk Vendors through referrals from other units within the WIC Division regarding unusual WIC benefit redemptions or redemption patterns by Vendors.

References:

7 CFR Part 246.12 (j)

Cross-References:

5.06 Vendor Complaints

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