5-05 Vendor Complaints

5.05 Compliance Buys

Effective Date: 08/01/2021

PURPOSE:    

To describe the use of compliance buys to identify Vendor violations.

DEFINITIONS:

Compliance buy means an undercover investigation in which an investigator poses as a WIC participant or representative to determine whether a Vendor is complying with WIC Program requirements.

POLICY:

1. The Department may conduct compliance buys to identify Vendor violations and ensure Vendor compliance with WIC Program requirements.

    

2. Compliance buys may be conducted as part of:

    

   1. Routine compliance monitoring;

       

   2. Investigations;

       

   3. High-risk Vendor reviews; or

       

   4. Complaint follow-up.

    

3. Evidence obtained during compliance buys may be used to support sanctions, claims, disqualifications, or other adverse actions.

    

4. Compliance buys may be coordinated with federal, state, or local law enforcement agencies.

References:

7 CFR Part 246.12 (j)

Cross-References:

5.02 High-Risk Vendor Identification

5.06 Vendor Complaints

6.0 Vendor Sanctions