Policy: Reporting and Investigating Fraud and Abuse
Effective: 10/07
Policy
No: SO: 1
Revised: 10/07
The Nevada WIC program will investigate all allegations of fraud/abuse being
committed by WIC participants, WIC local agency employees, and WIC authorized
grocers.
Procedure
All
Reporting
Complaints can be filed by either:
 Calling the Nevada toll-free number 1-800-868-942
 Writing to:
Nevada State WIC Program
3427 Goni Road, Suite 108
Carson City, NV 89706
Examples of program abuse include but are not limited to:

Making false or misleading statements or misrepresenting, concealing, or
withholding facts to obtain Program benefits.

Exchanging food instruments or supplemental foods purchased with WIC
food instruments for cash, credit, non-food items, or unauthorized food
items.

Exchanging food instruments for more than the specified amount of
supplemental foods listed on the food instrument.

Theft of food instruments.

Physically harming, or threatening to harm WIC clinic or food vendor staff.

Redeeming more than the number of food instruments for which the
participant is eligible.

Altering the food instrument.

Redeeming food instruments at an unauthorized food vendor.

Redeeming food instruments before the issue date or more than 30 days
after the issue date.

Allowing WIC foods to be used by or giving away WIC foods for other than
the participants use.

Sale of WIC foods, WIC food instruments or exchange with other
individuals or entities.
Dual Participation means either:
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Policy: Reporting and Investigating Fraud and Abuse
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

No: SO: 1
Revised: 10/07
Simultaneous participation by the same person(s) in more than one WIC
local agency or more than one WIC clinic site within a local agency, or
Participant(s) receive benefits from both the WIC program and the
Commodity Supplemental Food Program (CSFP) during the same time
period.
Reporting and Documentation of Program Abuse
Once program abuse by a participant, alternate, proxy, parent, guardian,
caretaker, or representative of the participant is suspected or a complaint has
been received, the local agency is required to begin an investigation and is
instructed to:
1. Document the incident in the participants file (i.e. date, time, brief
explanation of facts, witnesses’ statement’s etc.) to the fullest extent
possible.
2. Obtain & document participant’s point of view. If the participant cannot be
contacted by phone, a letter will be sent instructing the participant to
contact the clinic. Document all attempts to contact the participant if they
are unreachable. When the participant contacts the clinic local agency
staff will clarify the issue with the participant and inform them that an
investigation is in process.
3. Local agency staff must complete the investigation within 120 days of any
incident.
4. If local agency staff determines that there are not sufficient facts for a
finding that the participant, proxy, parent, guardian, caretaker, or
representative of the participant, intentionally committed a program
violation, staff will document and provide a Warning(refer to explanation
below) using the “Notice of Ineligibility, Placement on Waiting List or
Disqualification” form. A copy of this form will be retained in the participants
file.
5. If the local agency has determined that an intentional violation has
occurred, they are to forward all supporting information to the State Office
within 2 working days of the completion of the investigation. This includes
but is not limited to:
 Family number
 Other family members on Program
 Length of time on Program
 Misrepresented information
 Copies of documented investigation including statement of
witnesses, etc.
 Any information pertinent to case
6. The State Office will apply sanctions if the intentional violation is confirmed
and report back to the local agency.
Disqualification Procedures for Dual Participation
Each month local agencies receive a copy of the Dual Participation report. If it is
discovered that a participant had dual participated the local agency will:
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Policy: Reporting and Investigating Fraud and Abuse
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Revised: 10/07
1. Complete the Dual Participation Report within 30 days and return to the
State Office(refer to RR:3)
2. Follow the procedures listed above for documentation of the investigation.
Dual Participation within the Nevada WIC Program:
▪ Ask the eligible participant to choose one clinic site from which to
continue to receive benefits, regardless of whether or not the dual
participation was intentional.
▪ The local agency will inform the second clinic site of the participant’s
decision.
▪ The local agency that the participant does not choose to participate
at will immediately terminate the participant without 15 days notice
and without benefits.
▪ The local agency the participant chooses to participate will determine
if the participant was informed of and understood that dual
participation is a program violation.
▪ The local agency will then take corrective action depending on the
outcome of the investigation.
Unintentional Dual Participation: Issue a Warning and place in
their file. A copy will also be placed in the “Participant-Vendor
Complaint Log” at each clinic.
Program Violation: Forward all supporting documentation to the
State Office within 2 working days of the completion of the
investigation.
Dual Participation with Commodity Supplemental Food Program
▪ Ask the participant which agency they wish to continue to receive
benefits.
▪ If they choose to participate with CSFP, immediately terminate the
participant without 15 days notice and without benefits.
▪ If the participant chooses to remain with the WIC program the local
agency will instruct the participant to obtain a notice of
disqualification from CSFP before issuing benefits. The local agency
may assist the participant with this matter by contacting CSFP and
requesting a fax confirmation.
▪ The local agency the participant chooses to participate or terminate
will determine if the participant was informed of and understood that
dual participation is a program violation.
Unintentional Dual Participation: Issue a Warning and place in
their file.
Program Violation: Forward all supporting documentation to the
State Office within 2 working days of the completion of the
investigation.
3. The State Office will apply sanctions if the violation is confirmed and report
back to the local agency. A copy of all sanctions will also be placed in the
“Participant-Vendor Complaint Log” at each clinic.
Examples of Possible Sanctions for Participant Abuse
Warning (Local Agency may administer)
A warning will be issued to a participant, alternate, proxy, parent, guardian,
caretaker, or representative of the participant if there is not sufficient evidence
for a reasonable person to conclude that the participant committed an act with
the intent to violate program rules or for participants that fail to properly
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Policy: Reporting and Investigating Fraud and Abuse
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comprehend the training of food instruments and unknowingly violates cashing
procedures.
Participants who are accused of violations but through investigation cannot be
verified should be informed of the close of the investigation and given a written
warning that if a violation was to occur again, the possibility of 1 year
disqualification and repayment of benefits.
All participants who are found to have committed a food instrument redemption
violation must receive and have documented in their file additional F.I. training.
Disqualification (State Office to administer)
Participants, alternate, proxy, parent, guardian, caretaker, or representative of
the participant found to have committed an intentional program violation may
be subject to:
 1 month disqualification if the violation (except dual participation) is a
first violation and results in a claim of less than $100.
 1 year disqualification if the violation resulted from dual participation
or a second violation (any amount) or a first violation resulting in a
claim of a $100 or more.
 Repayment of benefits from any participant violation regardless of
the amount of claim.
Intention
To qualify for a one year suspension, the Participant violation must be an
“intentional act of noncompliance committed by the participant.” There must be
a preponderance of evidence to show intent before a one year suspension
may be imposed.
Among the items that help show intent on the part of the participant includes:
 previous instances of dual participation
 making false or misleading statements or misrepresenting,
concealing or withholding information about themselves or their
family to obtain Program benefits
 previous warnings on dual participation
If there is any question as to whether intent has been established, the State
WIC Office will be consulted.
A warning will be given to a participant where an investigation of an alleged
violation shows that the participant committed an act described above, but
there is not sufficient evidence for a reasonable person to conclude that the
participant committed the act with intent to violate program rules.
Proxies
The State has the option for participants under the age of 18, infants and
children who face disqualification due to their own actions or the actions of
their sponsor to approve proxies in lieu of disqualification on a case by case
basis. To be approved the proposed alternate must be a responsible
adult(other than the individual who committed the program violation) who is
knowledgeable of the child’s eating habits and health status, capable of bring
the child to required WIC appointment, capable of redeeming food instruments
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Policy: Reporting and Investigating Fraud and Abuse
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at the grocery store, and willing to comply with program regulations. Local
agencies who feel participants qualify for this exception (violator no longer
living with family, social worker involved, etc) should include this information
within their documentation.
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