CTR067935 A3.pdf

INTERGOVERNMENTAL AGREEMENT (IGA)

Amendment

ARIZONA DEPARTMENT

OF HEALTH SERVICES

150 18th Ave Suite 530 Phoenix, Arizona 85007

Contract No.:

CTR067935 IGA Amendment No.: Three (3) Procurement Officer

Kailee Gray

1. Background

The Arizona Department of Health Services (ADHS) Bureau of Nutrition and Physical Activity (BNPA) administers funds provided by the United States Department of Agriculture (USDA) for the operation of the Special Supplemental Nutrition Program for Women, Infants and Children (WIC) and Breastfeeding Peer Counseling Program (BFPC) for the State of Arizona. The USDA nutrition programs are discretionary, and each provides a specific service to women, infants, and children who are low income and at nutritional risk. The overall goal of all the USDA Nutrition Programs is to increase food security and reduce hunger by providing eligible participants access to nourishing food and supportive nutrition education. ADHS is working with the counties to provide WIC services, and this opportunity is to provide additional community support as needed.

1.1. WIC Nutrition Services:

1.1.1. The WIC Program accomplishes this goal by providing participant-centered services (PCS) including nutrition and breastfeeding information and support, specific supplemental healthy foods through the issuance of food benefits that can be used at ADHS-approved grocery stores, and referrals to other health and human services as an adjunct to good health care during critical times of growth and development. Service population eligibility for the WIC Program is based upon federal regulations and includes participant category (pregnant and breastfeeding women, postpartum women, and infants or children under five (5) years of age), a household income at or below 185% of federal poverty guidelines, residence within the service area, and nutrition risks,

1.1.2. To be considered as a WIC Local Agency, the organization must be a local public or private non-profit organization, county health department, or tribal entity under contract with ADHS to provide WIC services according to the WIC Program federal regulations and state policies and procedures. The State awards a WIC Contract based on the ability of the organization to provide WIC services, potentially eligible population, need, response to the Scope of Work, information technology capacity, and available funds. The State determines and awards the WIC Contract amount based on a funding formula using several factors such as a base level for a program to function, the amount of caseload negotiated with each Local Agency, and quality of performance, and

1.1.3. Specific objectives for nutrition services (based on Healthy People 2030 Goals) are:

1.1.3.1. To increase the incidence of women initiating breastfeeding;

1.1.31.2. To increase the duration of women breastfeeding for the first six (6) months of their baby’s life;

1.1.3.3. To increase the duration of women breastfeeding for the first one (1) year of their baby’s life;

1.1.3.4. To increase the rate infants are exclusively breastfed at three (3) months and at six (6) months;

1.1.3.5. To reduce the proportion of adults who are considered obese;

1.1.3.6. To reduce the proportion of children ages two (2) to five (5) who are considered obese;

1.1.3.7. To increase the consumption and variety of fruits and vegetables by those age https://odphp.health.gov/healthypeople/objectives-and-data/browse-objectives/nutrition-and-healthy-eating two (2) and older;

1.1.3.8. To increase the consumption of whole grains by those age two (2) and older;

and

1.1.3.9. To reduce household food insecurity and hunger.

1.2. BFPC:

1.2.1. Breastfeeding peer counselors add a critical dimension to WIC’s efforts to help women initiate and continue breastfeeding. WIC breastfeeding peer counselors provide a valuable service to their communities, addressing barriers to breastfeeding by offering breastfeeding education, support, and role modeling. They are familiar with the resources available to WIC participants and the questions a new breastfeeding mother may ask, and recognize when to refer mothers to other resources when issues outside their scope of practice arise. In 2020 the USDA Food and Nutrition Service (FNS) released their new national breastfeeding campaign titled WIC Breastfeeding Support: Learn Together. Grow Together. As a part of this, FNS has developed training and technical assistance to equip WIC Programs with a framework for designing and maintaining peer counseling programs. Developing this training included formative research to understand barriers and motivators to implementing and sustaining peer counseling programs and develop training curricula. This Peer Counseling Training for WIC Managers, which is a training and technical assistance project that will be used as a model to aid WIC in designing, building, maintaining, and sustaining peer counseling programs that will improve breastfeeding initiation and duration rates. Arizona will be using this program to guide and develop the state peer counseling program,

1.2.2. The discretionary peer counseling services are considered an adjunct support to WIC breastfeeding services to help achieve the WIC Nutrition Services objectives regarding breastfeeding, and

1.2.3. Peer counseling has been a significant factor in improving initiation and duration rates of breastfeeding among women in a variety of settings, including disadvantaged and WIC populations representing diverse cultural backgrounds and geographical locations. Peer counselors are especially effective in communities where role models for breastfeeding behaviors, knowledgeable health care providers, and cultural practices that include breastfeeding as the norm, are scarce. Combining peer counseling with the ongoing WIC breastfeeding promotion and support efforts has the potential to significantly impact breastfeeding rates among WIC participants, and most significantly, increase the harder to achieve breastfeeding duration rates. WIC Local Agencies are strongly encouraged to provide peer counseling services in addition to the ongoing breastfeeding support to their WIC participants. Contractors must provide a breastfeeding friendly environment and have policies to accommodate participants and staff who are breastfeeding.

1.3. The subrecipient has the discretion to determine how the award amount is utilized and should provide a detailed outline of costs using a Budget Worksheet provided by ADHS The Grantee must adhere to the funding restrictions as outlined in the Arizona Policy and Procedure Manual.

1.4. Based on program caseload and service area, funding will be allocated appropriately to all active subrecipients each Grant year for a five (5) year grant period. Budgets and work plans will be reviewed annually and may be decreased based on:

1.4.1. Changes to USDA funding allocation.

1.4.2. Changes to USDA caps on WIC services.

1.4.3. Failure to meet the goals and activities outlined in this Scope of Services.

1.5. The funds are awarded to ADHS and awarded to subrecipients through this Intergovernmental

Agreement (IGA) and the Contract Application process.

1.6. ADHS has the right to partially award based on the needs and areas being serviced.

2. Objective

The Subrecipient shall:

2.1 At a minimum, provide WIC services while allowing each Local Agency to provide, at their discretion, Breastfeeding Peer Counseling Services.

2.2 In the event the Arizona WIC Program funding is depleted (e.g. government shutdown) the Subrecipient may request permission to continue operating their program utilizing local funds. The Subrecipient shall contact the Arizona WIC Director to discuss the feasibility of sustaining clinic operations and participant food redemption at authorized vendor locations. The Subrecipient may transfer funds to ADHS to ensure continued operation.

2.3 Additional monies may be awarded under this contract for WIC Special Projects related to, but not limited to general infrastructure, breastfeeding promotion, nutrition services, information system enhancement efforts and client retention efforts.

3. Scope of Service

3.1. WIC Services:

The WIC Program Subrecipient shall perform all the work required to administer and provide WIC services to eligible participants according to the Arizona WIC Program Policies and Procedures Manual (WIC PPM). These include, but are not limited to, the following activities:

3.1.1. Perform WIC certification procedures such as categorical and income screening and health and nutrition assessments,

3.1.2. Provide participant centered nutrition and breastfeeding support services to WIC participants,

3.1.3. Provide the mandatory and appropriate additional referrals reflecting the needs of the individual WIC participants,

3.1.4. Issue WIC food benefits tailored to meet the needs of the participants,

3.1.5. Ensure the collection and recording of accurate information,

3.1.6. Provide professional training, mentoring and monitoring of WIC staff competencies necessary for delivery of required services,

3.1.7. Provide administrative functions for operation of the WIC Program, and https://www.azdhs.gov/prevention/azwic/agencies/index.php#manuals

3.1.8. Prepare and submit all required plans/reports in accordance with this contract and the WIC

PPM.

3.2. BFPC Services:

3.2.1. WIC BFPC Subrecipients shall perform all the work required to administer and provide additional breastfeeding support services to WIC mothers following the USDA WIC Breastfeeding Curriculum guidelines for peer counseling services and according to the Contractor’s proposal in order to increase the breastfeeding rate and duration of breastfeeding, and

3.2.2. Provide supervision, mentoring, monitoring, and evaluation of peer counselors, when appropriate.

4. Tasks

4.1. The WIC Program provides nutrition and breastfeeding support and information, supplemental nutritious foods, and referrals to other health and social services as an adjunct to good health care during critical times of growth and development, in order to prevent the occurrence of health problems and to improve the health status of eligible women, infants and children.

4.2. Nutrition education including breastfeeding promotion and support as part of the WIC program, shall be designed to achieve the following two broad goals:

4.2.1. Emphasize the relationship between nutrition, physical activity, and health with special emphasis on the nutritional needs of pregnant, postpartum, and breastfeeding women, infants, and children under five years of age, and raise awareness about the dangers of using drugs and other harmful substances during pregnancy and while breastfeeding.

4.2.2. Assist the individual who is at nutritional risk in improving health status and achieving a positive change in dietary and physical activity habits, and in the prevention of nutrition-related problems through optimal use of supplemental foods and other nutritious foods. This is to be taught in the context of the ethnic, cultural, and geographic preferences of the participants and with consideration for educational and environmental limitations experienced by the participants.

4.3. WIC Services Outreach, Retention, and Referrals:

The Subrecipient shall:

4.3.1. Conduct outreach activities targeting underserved populations by developing written and verbal presentations, or utilizing available materials, and/or promoting WIC on social media platforms to inform potentially WIC eligible individuals of the availability of the WIC Program and to explain the benefits of participation in accordance with the WIC PPM and this Contract,

4.3.2. Conduct retention activities to maintain and increase the participation of current WIC enrollees,

4.3.3. Establish community partnerships with, at a minimum, the mandatory referral agencies, local hospitals, OB/GYN and pediatricians offices, and provide regular contacts in accordance with the WIC PPM and this Contract,

4.3.4. Establish community partnerships with community organizations such as food banks, human and social services, school districts, etc. in accordance with the WIC PPM and this Contract,

4.3.5. Establish a referral system with breastfeeding/lactation specialists, including, but not limited to, International Board-Certified Lactation Consultants (IBCLC), Certified Lactation Counselors (CLC), Certified Breastfeeding Counselors (CBC), and Certified Lactation Educators (CLE) in accordance with the WIC PPM and this Contract.

4.4. Additional BFPC Outreach Tasks:

4.4.1. Develop and document an internal referral link between the WIC Program and WIC Peer

Counseling Program, when applicable. Interactions between the WIC Program and WIC Peer Counseling Program shall occur at least monthly and may be in the form of site visits from Peer Counselors, participation of Peer Counselors in WIC clinic meetings, and/or additional training for WIC clinic staff and Peer Counselors.

4.5. Participant Records:

4.5.1. Document in Health and Nutrition Delivery System (HANDS) and maintain documentation of participant centered certification and administrative procedures as described in the WIC PPM, including, but not limited to, the following:

4.5.1.1. Eligibility and ineligibility determinations;

4.5.1.2. Nutrition assessments;

4.5.1.3. Nutrition and breastfeeding education and support;

4.5.1.4. Nutrition and breastfeeding counseling;

4.5.1.5. Facilitate behavioral goal setting;

4.5.1.6. Appropriate referrals;

4.5.1.7. Program fraud; and

4.5.1.8. Food Benefit Issuances.

4.5.2. Maintain inventory and accountability records, as set forth in the WIC PPM for Electronic

Benefits Transfer (EBT) WIC (eWIC) cards,

4.5.3. Maintain records in accordance with the PPM,

4.5.4. Assure participant confidentiality by obtaining written permission from affected program participant(s) prior to the release of participant information to any agency. The Contractor shall have a written agreement, completed in accordance with 7 CFR 246.26(d), and the Arizona WIC Policy and Procedure Manual, with any agency or program that will share participant information. The above federal regulation details the implementation of a written agreement and state plan to regulate use and disclosure of confidential applicant and participant information, https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246#p-246.26(d)

4.5.5. Staff shall only access the WIC Computer Data System and client files for business related reasons,

4.5.6. Ensure paper files containing confidential participant information are stored in a secure location in the clinic, archived when appropriate, and destroyed according to the retention schedule. All files should be destroyed in an appropriate manner,

4.5.7. The Subrecipient shall notify the State Agency immediately by telephone call and email upon the discovery of a breach of a participant’s confidentiality,

4.5.8. The Subrecipient shall immediately investigate such security incidents, breaches, or unauthorized use or disclosure of participant information. These investigations shall include:

4.5.8.1. These investigations shall include:

4.5.8.1.1. What data elements were involved and the extent of the data involved in the breach;

4.5.8.1.2. A description of the unauthorized person(s) known or reasonably believed to have improperly used or disclosed the protected information;

4.5.8.1.3. A description of where the protected information is believed to have been improperly transmitted, sent, or utilized;

4.5.8.1.4. A description of the probable causes of the improper use or disclosure; and

4.5.8.1.5. Whether Arizona Revised Statutes (A.R.S) § 18-552 or any other federal or state laws requiring individual notifications of breaches are triggered.

4.5.9. The Subrecipient shall provide a written report of the investigation to the Chief of the BNPA/WIC Director and Chief of the Office of Program Integrity within ten (10) working days of the discovery of the breach or unauthorized use or disclosure. The report shall include the information specified above, as well as a full, detailed corrective action plan, including information on measures that were taken to halt and/or contain the improper use or disclosure, and

4.5.10. The Subrecipient shall notify individuals of the breach or unauthorized use or disclosure when notification is required under state or federal law and shall pay any costs of such notifications, as well as any costs associated with the breach using non-WIC funds. The BNPA Chief/WIC Director, Chief of the Office of Program Integrity, and Assistant Attorney General shall approve the time, manner and content of any such notifications. The Local Agency shall arrange and pay for any mitigation (e.g. LifeLock) for participants at risk for identity theft because of breach of security of information.

4.6. Service Delivery and Program Rules:

4.6.1. Determine eligibility of persons requesting WIC services by screening individuals in accordance with procedures set forth in the WIC PPM.

4.6.1.1. Eligible program participants shall include the following categories whose household income does not exceed 185% of the current designated federal poverty guidelines, who have a nutritional risk as defined in the WIC PPM, and reside in Arizona as defined by the WIC PPM:

4.6.1.1.1. Pregnant women, breastfeeding women up to twelve (12) months post-partum, and non-breastfeeding women up to six

(6) months following the end of a pregnancy;

4.6.1.1.2. Infants from birth to age one (1); and

4.6.1.1.3. Children from age one (1) year up to five (5) years.

4.6.2. Provide complete nutrition assessment and document results and follow-up as outlined in the Arizona WIC Policy and Procedure Manual,

4.6.3. Provide participant-centered nutrition education to participants and appropriately utilize materials provided by the State,

4.6.4. Facilitate goal setting for behavioral change and follow-up on goals set,

4.6.5. Promote breastfeeding to WIC participants and provide breastfeeding education and support, and refer to and promote the Breastfeeding Peer Counseling Program, when appropriate,

4.6.6. Prescribe and tailor a food package appropriate to the participant's nutritional risk(s), the amount of formula consumed, and cultural preferences and issue food benefits as set forth in the WIC PPM,

4.6.7. Provide program participants with information about available health and social services to which the participant could be referred. The participant shall be provided with written information regarding community services and referrals in accordance with the WIC PPM and Local Agency referral procedures,

4.6.8. Coordinate WIC Services with other health and social services available within the service area, including but not limited to immunizations, voter registration, and breastfeeding support,

4.6.9. Provide information, check for understanding, and document instruction to participants on program rules, regulations, WIC approved foods, use of eWIC cards, and food benefit use and redemption. The program instruction shall be documented in the participant's record as outlined in the WIC PPM, and

4.6.10. Consider the impact of scheduling practices, hours of operation, and clinic closures on caseload and WIC applicants’ access to services.

4.6.11. Additional BFPC Service Delivery Tasks:

4.6.11.1. Accept referrals generated from calls to the ADHS Pregnancy and Breastfeeding Hotline into the Peer Counseling Program, and

4.6.11.2. Provide peer counseling services, when appropriate. Services shall be made available outside of usual clinic hours and outside of the WIC clinic, but may also be available during usual clinic hours and in the WIC clinic.

4.7. Participant Centered Nutrition Education:

4.7.1. Provide and document participant-centered nutrition education to all WIC adult participants, and to parents or caretakers of participants according to the guidelines of the State Nutrition Services Plans. Nutrition education contacts shall be made available quarterly to all adult participants and the Authorized Representatives of infant and child participants certified.

Nutrition education contacts shall be scheduled on a periodic basis by the local agency, but such contacts do not necessarily need to take place in each quarter of the certification period,

4.7.2. Provide and document professional supervision, mentoring and monitoring of staff at the clinic level on a regular basis, in accordance with Local Agency Self-Assessment requirements and as often as necessary, to ensure competence,

4.7.3. Offer, as often as necessary, high- and medium-risk nutrition education/counseling by a

Registered Dietitian Nutritionist (RDN) to all participants deemed high-risk upon assessment.

As defined in the WIC PPM Local Agencies may designate a Bachelor's degree nutritionist or Nutrition and Dietetic Technicians, registered (NDTR) to serve as a WIC Nutritionist to provide medium-risk counseling to participants under the supervision of the RDN,

4.7.4. Expend a minimum of seven percent (7%) of the total amount the Subrecipient receives for provision of WIC services each contract year on salary, employee related expenses, travel expenses, continuing education, and training for one or more Registered Dietitian Nutritionists (RDN) providing high risk services. The agency may pay another Arizona WIC Local Agency or RDN contractor for RDN services as approved by the State WIC Director or the State WIC Director's designee. If the seven percent (7%) of the total amount the Subrecipient receives for provision of WIC services is not expended for employee related expenses, travel expenses, continuing education, and training expenses for RDNs, ADHS may request the Subrecipient to return an amount equal to the difference between the seven percent (7%) of the total amount the Subrecipient receives for provision of WIC services and the actual amount expended,

4.7.5. Expend for nutrition education activities an aggregate amount that is not less than the sum of one-sixth (1/6) of the amount the Subrecipient receives for provision of WIC services each contract year. If the one-sixth (1/6) amount is not expended for nutrition education activities, ADHS may request the Subrecipient to return an amount equal to the difference between the one-sixth (1/6) requirement and the actual amount expended if ADHS must pay a penalty to the Federal Government.

4.7.5.1. Costs that can be applied to meet the one-sixth (1/6) requirement for nutrition education include:

4.7.5.1.1. Salary and other costs for time spent on nutrition education, whether with an individual or group.

4.7.5.1.2. The cost of procuring and producing nutrition education materials.

4.7.5.1.3. The cost of training nutrition educators, including costs related to conducting training sessions and purchasing and producing training materials;

4.7.5.1.4. The cost of conducting participant evaluations of nutrition education, nutrition assessments and observations.

4.7.5.1.5. Breastfeeding Promotion Costs in excess of the targeted amount, currently four percent (4%) of NSA expenditures, may be added to other Nutrition Education costs to meet the one-sixth (1/6) of NSA expenditures target for other Nutrition Education.

4.7.5.1.6. Other ADHS-approved costs, including but not limited to items allowable per WIC federal regulations, the State of Arizona Accounting Manual, and the Arizona Policy and Procedure manual.

4.7.6. Coordinate nutrition education activities and messages. Wherever possible, the Subrecipient shall utilize USDA and/or AZ Health Zone materials and messages to ensure common nutrition messages, and

4.7.7. Provide documentation that a minimum of four percent (4%) of the annual WIC expenditures have been used to support breastfeeding promotion and education. If the four percent (4%) is not expended for breastfeeding promotion and education activities, ADHS may request the Subrecipient to return an equal to the difference between the four percent (4%) and the actual amount expended if ADHS must pay a penalty to the Federal Government.

4.8. Staffing

4.8.1. Designate a WIC Program Director/Manager who is an RDN, with previous WIC and/or community health experience to manage and administer the WIC Program and may provide high-risk nutrition counseling and/or formula authorization to WIC participants. If an RDN is on staff to provide the WIC RDN services and with prior approval from ADHS, the Contractor shall designate a Director with a minimum of an undergraduate degree from an accredited institution in nutrition (community nutrition, public health nutrition, nutrition education, human nutrition or nutrition science) or a related field such as home economics or biochemistry with an emphasis in nutritional science or public health administration. With prior approval from ADHS, number of years working in a WIC program may substitute for some years of education,

4.8.2. Identify an RDN to serve as the Local Agency Nutrition Coordinator as defined in the WIC

PPM. The Nutrition Coordinator shall oversee all WIC nutrition services for the Local Agency.

If a Local Agency has barriers to this staffing standard, they must be submitted in writing to ADHS with their plan for coordination of nutrition services within the Local Agency to be approved by ADHS,

4.8.3. Provide an appropriate number of RDNs, based on assigned caseload, to perform high-risk and medium-risk counseling, formula authorization, and as necessary, certification of participants. The Subrecipient shall provide the RDN services in a number proportional to the agency's high-risk caseload in accordance with the WIC PPM. The Subrecipient shall hire graduates with a minimum of a Master’s or Bachelor’s degree from an accredited institution in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition, or Home Economics with emphasis in Nutrition or Nutrition and Dietetic Technicians, registered to do medium-risk counseling, formula authorization, and as necessary, participant certification under the direction of an RDN. If a Local Agency has a barrier to having an RDN on staff, the agency shall submit, in writing, to ADHS with their plan for providing high risk nutrition services to participants,

4.8.4. Provide an appropriate number of adequately trained certification specialists, based on caseload, to provide categorical and financial eligibility screening, pre-certification and record required documentation, in accordance with the WIC PPM, as well as administrative support services when necessary. Such individuals shall have the minimum of a high school degree or equivalent and must complete the state training requirements and be certified by the Contractor as competent according to the competencies for the position. Previous nutrition or health related job experience is desirable. These individuals shall meet ADHS competencies as set forth in the WIC PPM prior to providing each service such as verifying applicant eligibility, collecting anthropometric and biochemical data for participants, instructing on Food Benefits in the Arizona WIC Program. Staff should be observed and certified by the supervising authority to be competent in an activity before being allowed to perform on their own without supervision,

4.8.5. Provide an appropriate number of adequately trained nutrition education specialists, based on caseload, to provide certification and nutrition education services to participants in accordance with the WIC PPM. Such individuals shall have the minimum of a high school diploma with nutrition experience, education, and training that have been certified by local or state agencies to be competent for the position. An Associate or Bachelor's degree is highly preferred. These individuals shall meet the ADHS competencies for Nutrition Education Specialists as set forth in the WIC PPM prior to certifying applicants for participation and/or providing nutrition services in the Arizona WIC Program. Staff shall be observed and certified by the supervising authority to be competent in an activity before being allowed to perform on their own without supervision,

4.8.6. Identify an IBCLC to serve as the local agency Breastfeeding Coordinator as defined in the

WIC PPM. The Breastfeeding Coordinator shall oversee all WIC breastfeeding services for the local agency to ensure all participants have access to breastfeeding promotion and support services. If a local agency has barriers to this staffing standard, they shall submit in writing to ADHS with their plan for coordination of breastfeeding services within the local agency to be approved by ADHS,

4.8.7. Identify a Training Coordinator as defined in the WIC PPM. The Training Coordinator shall oversee and facilitate both new employee and ongoing WIC training for the Local Agency including certifying that staff has met competencies prior to providing services without supervision. If a Local Agency has barriers to this staffing standard, they shall submit in writing to ADHS their plan for coordination of training services within the Local Agency to be approved by ADHS,

4.8.8. Identify an Outreach Coordinator who shall oversee and facilitate activities and efforts to retain current WIC enrollees and outreach to potentially eligible populations not currently enrolled in WIC, and participate in outreach-related workgroups. If a Local Agency has barriers to this staffing standard, they shall submit in writing to ADHS their plan for coordination of outreach activities within the Local Agency to be approved by ADHS,

4.8.9. Provide staff to conduct outreach activities targeting high risk and underserved populations, including but not limited to homeless and migrants, by developing written and verbal presentations or utilizing available materials to inform the potentially eligible individuals of the availability of WIC Program and explain the benefits of participation, and

4.8.10. Provide WIC Clerks to perform administrative support within WIC clinics, when applicable.

Such individuals shall have the minimum of a high school degree or equivalent and shall meet WIC Program competencies. Previous clerical or work experience is desirable.

4.9. Additional BFPC Service Staffing:

4.9.1. Employ a BFPC Program Manager to plan, direct and coordinate general operation of Peer Counseling Program. Ideal candidate is an IBCLC, have WIC experience, and be familiar with community resources,

4.9.2. Develop a support referral system for peer counselors with community Lactation Consultants, including IBCLCs, if the BFPC Program Manager is not an IBCLC or is unable to fulfill consultation duties for any reason, and

4.9.3. Employ Breastfeeding Peer Counselors to provide services. Qualifications for peer counselors shall be previous personal experience with breastfeeding, enthusiasm for helping others to succeed at breastfeeding, and similarities with the WIC population the program serves (including similar age, ethnic background, and language spoken). Exemptions to the peer counselor qualifications shall be approved by ADHS before hire. When possible, peer counselors should be current or previous WIC participants.

4.10. Staff Training:

4.10.1. Train new staff as outlined in the ADHS developed new employee training plan.

4.10.2. In addition to state requirements for competency training, Local Agencies must implement and adopt the state training standards as reflected in the ADHS WIC PPM. In addition, Subrecipients must participate in any mandatory training provided by ADHS due to changes in policy, procedures, and / or federal regulations,

4.10.3. Provide training for all new staff members regarding Civil Rights, Americans with Disabilities

Act (ADA), Conflict of Interest and Confidentiality, and Voter Registration during their orientation and, annually, provide all staff with training on Civil Rights, ADA, Conflict of Interest and Confidentiality, and Voter Registration by completing the ADHS LMS courses on Civil Rights, Conflict of Interest and Confidentiality, and Voter Registration or other courses or trainings that will be required by ADHS,

4.10.4. Provide, at a minimum, the Breastfeeding Coordinator, Nutrition Coordinator, Training

Coordinator and WIC Director of their representative for a three (3) day all WIC conference.

In this meeting, there will be opportunities for the Subrecipient to discuss issues regarding the WIC policies and procedures, federal rules and regulations, and nutrition standards,

4.10.5. Provide one (1) representative for a maximum of four (4) WIC Director teleconference meetings to receive information updates on WIC operations, policies and procedures, and other relevant materials being held in lieu of face to face meetings. This may include urgent meetings to discuss current events (e.g. government shutdown) and plan on managing the continuity of operations plan (COOP),

4.10.6. Maintain a record of training provided, monitoring and observation results of staff competencies in each staff file and/or the State LMS, and https://www.azdhs.gov/prevention/azwic/agencies/trainers/index.php#new-employee-training-plan

4.10.7. Document and maintain a record of any additional staff training that applies towards the annual Continuing Education Requirements for WIC staff in accordance with the PPM.

4.11. Additional BFPC Staff Training:

4.11.1. Send the WIC Director or designee and the Breastfeeding Peer Counselor Program Manager to a one (1) day virtual training during each Peer Counseling Program Grant term,

4.11.2. Provide training of Breastfeeding Peer Counselors using the ADHS provided Breastfeeding

Peer Counselor Mini Series within one (1) month of employment,

4.11.3. Provide continual education and adequate resources to peer counselors. Continual education shall include basic and continuing breastfeeding training, and may include opportunities to shadow lactation consultants, opportunities to meet with other peer counselors, and related training such as counseling skills, adult learning styles, and others,

4.11.4. Provide all WIC clinic staff the recorded presentation of the USDA WIC Breastfeeding

Curriculum at least once during each Peer Counseling Program Grant term.

4.12. Data Collection:

4.12.1. Utilize the hardware, software, and training provided by the Arizona WIC Program to operate the Subrecipient's portion of the WIC Computer Data System – HANDS,

4.12.2. Complete all data elements required on the WIC Computer Data System as outlined in the

WIC PPM,

4.12.3. WIC Computer Data System users are required to maintain integrity by keeping their username and password secure. Users shall not share their login information with others,

4.12.4. The Subrecipient’s IT that supports WIC shall coordinate with ADHS WIC IT to ensure immediate restoration of technical equipment (i.e. ADHS owned equipment) to include providing a temporary administrative account.

4.13. Administrative Services:

4.13.1. Obtain written approval from ADHS prior to implementing any policy or procedure that deviates from those set forth in the Arizona WIC PPM,

4.13.2. Update the Local Agency clinic information within ten (10) business days in HANDS. This information includes clinic names, addresses, phone numbers, days and hours of operations, closure days, and other pertinent information for public disclosure,

4.13.3. Provide the state agency with updated staff information, at a minimum, the names of Chief

Executive Officer (CEO)/Health Officer, WIC Director, Clinic Supervisors, Nutrition Services Coordinator, Breastfeeding Coordinator, Training Coordinator, and IT lead(s),

4.13.4. Provide, at a minimum, ten (10) weeks written notice when planning on opening, moving, or suspending WIC services at any location, https://www.azdhs.gov/prevention/nutrition-physical-activity/breastfeeding/index.php#wic-staff-counselors https://www.azdhs.gov/prevention/nutrition-physical-activity/breastfeeding/index.php#wic-staff-counselors

4.13.5. Read all ADHS provided documents and provide responses within the requested timeframe, if applicable,

4.13.6. The Local Agency Director shall ensure the ADHS WIC Program has the most recent contact information in an effort to maintain current and accurate information in the Master Contact List,

4.13.7. Maintain records of WIC services in WIC Computer Data System and electronic files of other WIC related operations and trainings, if applicable, according to the WIC PPM. These records include, but are not limited to:

4.13.7.1. Signed consent for hemoglobin screening and anthropometrics;

4.13.7.2. Signed Rights and Obligations for enrolled participant files (active and inactive);

4.13.7.3. Eligible participant files (active and inactive);

4.13.7.4. Ineligible applicant signature;

4.13.7.5. Monthly Participation Reports by Category and Ethnicity;

4.13.7.6. Outreach files;

4.13.7.7. Medical documentation;

4.13.7.8. Staff files, including trainings attended, skill observations, and Local Agency

Self Assessments;

4.13.7.9. Documentation of dual participation actions;

4.13.7.10. Waiting lists (when applicable);

4.13.7.11. Reconciliations of eWIC cards;

4.13.7.12. Civil rights files, including documentation and resolution of all civil rights complaints;

4.13.7.13. Documentation of annual civil rights and voter registration training of all employees; and

4.13.7.14. Documentation of annual Conflict of Interest and Confidentiality training of all employees and the WIC Confidentiality and Conflict of Interest forms.

4.13.8. Correct and resolve inappropriate or missing participant information, improbable assessment values, duplicate participation, and other quality assurance WIC Computer Data System issues identified in the report provided to the Subrecipient by ADHS within the timeframes specified in the WIC PPM,

4.13.9. Correct any regulatory deficiency or discrepancy noted during any of the program

Management Evaluations, Audits, Local Agency Compliance Investigations or Program Financial Management Reviews within sixty (60) calendar days of the date of the audit report unless an extension date is granted by the auditing/reviewing agency and documented. Any reimbursement dollars back to ADHS shall be done within thirty (30) days of receiving the Financial Management Review completion notification,

4.13.10. Adhere to the State of Arizona Accounting Manual (SAAM) travel rates. Travel rates reimbursed by the Local Agency cannot exceed the current Arizona State Reimbursement Rates located at https://gao.az.gov/travel/welcome-gao-travel,

4.13.11. Complete electronic copies of the Contractor's Expenditure Reports for each contracted program and submit the electronic and a signed copy to ADHS according to the instructions and requirements of the WIC PPM,

4.13.12. Retain all evidentiary documentation (i.e. meal receipts) and submit to ADHS upon request for all expenses charged towards the WIC grant,

4.13.13. Prepare Final Closeout CER invoice for each contracted program reflecting the cumulative expenditures for a contract year,

4.13.14. Prepare WIC Local Agency Quarterly Cost Summary Reports that matches the amount of each quarter’s expenditures respectively in accordance with the requirements in the WIC

PPM,

4.13.15. Prepare an annual evaluation on the Contractor's Outreach Plan and a progress report on activities accomplished during the year,

4.13.16. Prepare an annual Amendment Application in accordance with the individual program requirements that will include budget breakdown of line items and budget justifications of any budget changes,

4.13.17. Adhere to the allowable and unallowable cost principles for WIC and BFPC as outlined in the

WIC PPM,

4.13.18. Conduct Local Agency self-assessments annually in the year that the Local Agency has a

Management Evaluation, and semi-annually in the year that they do not have a Management Evaluation,

4.13.19. Prepare all required plans, reports, and documents in accordance with the requirements in the WIC PPM, and

4.13.20. In additional to complying with the Guidance for Federal Grant Award Management (Blue

Book), the SAAM for Contractors of ADHS Funded programs, and the WIC PPM, the Subrecipient shall:

4.13.20.1. Control and monitor all State Agency provided WIC automation resources.

4.13.20.1.1. Report when WIC automation resources move physical locations by using the F4 Property Control Form. The form shall be completed in Microsoft Word including all required fields (Tag number, Serial number, Item and Make/Model), be signed, and then submitted to the WIC Service Desk via email at WICServiceDesk@azdhs.gov.

https://gao.az.gov/travel/welcome-gao-travel https://grants.az.gov/grant-manual https://grants.az.gov/grant-manual mailto:WICServiceDesk@azdhs.gov

4.13.20.1.2. In the event any WIC automation resources are lost, stolen, or damaged, the subrecipient shall report the information required to the State Agency following the details listed in the PPM.

4.13.20.2. Complete an annual physical inventory of all tagged WIC equipment, including

WIC automation resources, at both the state and local levels at all locations.

4.13.20.2.1. All equipment expenditures $10,000 or higher or computer equipment listed in Chapter 17 shall be purchased by ADHS.

The State Agency will tag WIC automation resources according to Arizona Department of Health Services (ADHS) policy with an ADHS property sticker with a unique identification number. The State Agency will tag all WIC automation resources that cost $250 and above.

4.13.20.2.2. Annually, the state office will send each subrecipient an inventory sheet of tagged equipment issued to them. The subrecipient shall verify the items listed on the inventory sheet, identifying what is present, if applicable what is missing, and any additional items that are present with a tag but not listed.

The state and local agency will work together to determine what happened to items marked as missing. Equipment lost or damaged due to negligence and/or a lack of internal control shall be the responsibility of the entity which last possessed the equipment.

4.13.20.2.3. The physical inventory must be completed annually in May and within one month. During the annual physical inventory, equipment moves at the Local Agency should be limited and only made if necessary.

4.13.20.2.4. The subrecipient is required to have all individuals that are conducting the physical inventory attend an ADHS-provided Annual Inventory Training.

4.13.20.2.5. During the physical inventory, the subrecipient shall:

4.13.20.2.5.1. Physically verify the location of all

equipment in the State Agency-provided inventory.

4.13.20.2.5.2. Account for WIC automation resources that

Local Agency staff use at home for teleworking by bringing the WIC automation resource into a Local Agency office or clinic.

4.13.20.2.5.3. Add WIC automation resources to the State

Agency-provided inventory that were found during physical inventory that was not included in the State Agency-provided inventory.

4.13.20.2.5.4. Indicate the WIC automation resources

that were on the State Agency-provided inventory, but could not be found during the physical inventory.

4.13.20.2.5.5. Update WIC automation resource physical

location changes (e.g., laptop on State Inventory was documented at clinic A, but was found at clinic B).

4.13.20.2.5.6. Verify that a WIC automation resource is in

a single location and not duplicated across multiple physical locations.

4.13.20.2.5.7. When inventory is completed at a specific

physical location, the Local Agency is required to have the individual who completed the inventory sign to verify the accuracy and be available to answer any State Agency questions.

4.13.20.3. Provide maintenance and upkeep for all equipment purchased with WIC funds.

Maintenance shall be provided through the Subrecipient’s own organization or the Subrecipient shall participate in State maintenance contracts where available, as specified in the WIC PPM.

4.13.20.4. Obtain written permission from ADHS prior to expending WIC funds to purchase equipment with a value of $10,000 or more;

4.13.20.5. Submit a request for all asset-related items to ADHS utilizing the process specified in the WIC PPM. ADHS WIC provides these items to local agencies.

Asset-related items include, but are not limited to,

4.13.20.5.1. Hardware including:

4.13.20.5.1.1. Computers.

4.13.20.5.1.2. Tablets.

4.13.20.5.1.3. Scanners.

4.13.20.5.1.4. Printers.

4.13.20.5.1.5. Card readers.

4.13.20.5.1.6. Pin pads.

4.13.20.5.1.7. Webcams.

4.13.20.5.1.8. Headsets.

4.13.20.5.1.9. Signature pads.

4.13.20.5.2. Certain telecommunications equipment necessary to access the web based WIC Computer Data System (e.g. MiFi’s).

4.13.20.5.3. New technology will be evaluated for inclusion based on program needs.

4.13.20.5.4. For software purchases with WIC funds, the Local Agency may purchase software that is reasonable and necessary. The subrecipient is responsible for ensuring that new software will not impact the use of WIC applications on the WIC automation resource. The subrecipient may submit a request for testing new software that the subrecipient may want to purchase to ensure that the WIC applications are not impacted.

Subrecipients may submit software testing requests to the WIC Service Desk at WICServiceDesk@azdhs.gov.

4.13.20.6. Provide notification to ADHS for any asset-related resource items in need of transfer or disposition. The Subrecipient shall not directly dispose of any asset.

4.13.20.7. Adhere to WIC PPM procedures for transfer and disposals; and

4.13.20.8. Notify the Office Chief for the Office of Program Integrity (OPI) of the loss or theft of State-owned WIC automation resources within twenty-four (24) hours of the occurrence. The Local Agency must provide final documentation within ten (10) business days. Final documentation includes the F4 Property Control Sheet and police report. The Local Agency is only required to provide a police report for stolen WIC automation resources.

4.13.21. Additional monies may be awarded under this Grant for WIC Special Projects related to, but not limited to, general infrastructure, breastfeeding promotion, nutrition services, information system enhancement efforts, and client retention efforts.

4.14. Additional Peer Counseling Administrative Services:

4.14.1. Prepare and submit a Quarterly Report for the Peer Counseling services in the format provided by ADHS, and

4.14.2. Provide training and resources to assist the local agency in establishing and maintaining competency for new and existing staff.

4.15. Additional WIC & BFPC Tasks

The Subrecipient shall submit to ADHS each Contracted Program's amendment application by the specified deadline for the following year containing the following information:

4.15.1. Request for Caseload to be served.

4.15.2. Request for budget and budget justification.

4.15.3. Updated Outreach Plan for the upcoming FFY and an evaluation of the previous year’s activities.

4.15.4. Any additional services and other documents specified.

5. Reference Documents

5.1. CFR (Code of Federal Regulations) 246.26(d)):

5.2. Arizona WIC Program Policies and Procedures Manual:

https://azdhs.gov/azwic/local_agencies_policyManual.htm

5.3. Healthy People 2030:

https://health.gov/healthypeople/objectives-and-data/browse-objectives/nutrition-and-healthy-eating

5.4. WIC Specific Code of Federal Regulations:

https://www.ecfr.gov/current/title-7/part-246

5.5. General Accounting Office (Travel):

https://gao.az.gov/travel/welcome-gao-travel

5.6. Guidance for Federal Grand Award Management (Blue Book):

https://www.azdhs.gov/documents/operations/financial-services/bluebook-2018.pdf

5.7. Peer Counseling Training for WIC Managers:

https://wicworks.fns.usda.gov/resources/peer-counseling-training-wic-managers

5.8. State of Arizona Accounting Manual (SAAM):

https://gao.az.gov/publications/SAAM

6. State Provided Items

ADHS will provide:

6.1. Electronic copies of the Arizona WIC Program Policies and Procedures Manual;

6.2. Hardware and software necessary for operation of the WIC Computer Database System;

6.3. Training and resources to assist local agencies in establishing staff competency for new and existing staff;

6.4. AZHZ Collaborators Username and Password access to order.

https://azdhs.gov/azwic/local_agencies_policyManual.htm https://health.gov/healthypeople/objectives-and-data/browse-objectives/nutrition-and-healthy-eating https://www.ecfr.gov/current/title-7/part-246 https://gao.az.gov/travel/welcome-gao-travel https://www.azdhs.gov/documents/operations/financial-services/bluebook-2018.pdf https://wicworks.fns.usda.gov/resources/peer-counseling-training-wic-managers https://gao.az.gov/publications/SAAM

6.5. eWIC cards.

6.6. Nutrition Education Materials for participants.

6.7. Breast Pumps and kits.

6.8. Breastfeeding materials/resources for staff.

6.9. Required posters.

6.10. Clinic operations materials.

6.11. Outreach materials.

6.12. Financial documents:

6.12.1. Federal Funding Accountability and Transparency Act (FFATA) Form.

6.12.2. Direct Expenses Template.

6.12.3. Labor Activity Report (LAR) Template.

6.12.4. Contractor Expenditure Report (CER) Template.

6.12.5. Quarterly Cost Summary Report Template.

6.13. Technical assistance and support, as needed.

6.14. Required Breastfeeding resources for staff.

6.15. Assistance with IBCLC career track or advanced lactation consultant education, when appropriate.

6.16. Periodic redemption reports for issued benefits, as requested by the Local Agency.

6.17. Additional BFPC State Provided Items

6.17.1. Quarterly Report template (electronic) for Peer Counseling Program.

6.17.2. USDA WIC Breastfeeding Curriculum: Peer Counselors, which includes the PowerPoint presentation “Peer Counseling: Making a Difference for WIC Families,” when appropriate.

6.18. Interpreter Services. Local agencies have the option to use the State provided service or utilize their own paid for by their Local Agency.

6.19. Hemoglobin Screening Supplies. Local agencies have the option to use the State provided service or utilize their own paid for by their Local Agency.

7. Deliverables and Delivery Schedule

If applicable, any work plan or other documentation submitted to and accepted by ADHS regarding participation in WIC or BFPC shall be incorporated…