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WIC Program: Improved Oversight of Income Eligibility Determination Needed

GAO-13-290 Published: Feb 28, 2013. Publicly Released: Mar 08, 2013.
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What GAO Found

The discretion granted by federal law, regulations, and guidance in certain areas of income eligibility determination for the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) has resulted in policy variation across states and localities. For example, while national survey data show that many states use an applicant's current income to determine income eligibility, GAO's review of 10 state policy manuals found that states differ in how they define the time period covered by current income, with some looking at income from the most recent 30 days and others using longer time periods. WIC administrators also have discretion in determining which members of an applicant's household should be considered part of the applicant's family, and both national data and state policy manuals suggest that states often provide local agencies with guidance in this area at the same time as they pass this flexibility to them. State policies also vary to some extent as to the sources of income that are included and excluded when determining an applicant's income eligibility for the program, according to national survey data.

GAO's analysis of administrative data found that 2 percent of WIC participants in 2010 were eligible solely because of their participation in another program, as they had incomes over the federal WIC income limit. Because income data were not available for an additional 7 percent of participants in 2010, GAO could not determine if these participants also had incomes over the federal WIC income limit. In recent years, some states have expanded Medicaid eligibility to pregnant women, infants, and children with incomes above the WIC income limit, and many WIC participants who are eligible for WIC due to their participation in another program receive Medicaid. However, the relationship between Medicaid expansions and WIC participation is unclear. While studies generally find that Medicaid recipients are more likely to participate in WIC than others, some suggest that expanded Medicaid income eligibility has not had a substantial effect on WIC participation because eligible families with relatively higher incomes are less likely to participate in WIC than lower-income families.

The U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) regularly assists and monitors states' administration of WIC, but it does not review monitoring results at the national level to target assistance to states. Although FNS regularly provides assistance to states in administering WIC, this assistance has generally not been focused on key income eligibility requirements, such as determination of family size and the time period of income assessed, in recent years. However, through its monitoring reports from the last few years, FNS has identified problems with or concerns about income eligibility determination policies or procedures in one-third of the states reviewed. Although FNS officials said that they plan to begin regularly reviewing monitoring findings at the national level to identify areas of program risk and target assistance to states accordingly, officials did not indicate when those reviews will begin. A timeline for reviewing monitoring reports to assess national program risks could better position FNS to show progress in completing its planned actions. GAO recommends that USDA develop a timeline for reviewing its monitoring reports to assess national program risks and target assistance. USDA agreed with GAO's recommendation.

Why GAO Did This Study

WIC provides nutritious foods and assistance to low-income pregnant and postpartum women, infants, and young children. Research has shown that WIC helps to improve birth and dietary outcomes and contain health care costs. USDA's FNS oversees the program, which is administered by state and local agencies. While federal regulations define criteria that must be used to determine applicants' income eligibility for WIC, state and local agencies are also given some discretion. In addition, since 1989, federal law has allowed families who participate in other assistance programs, such as Medicaid, to be automatically income-eligible for WIC. GAO was asked to provide information on WIC income eligibility determination. GAO assessed: (1) How do state and local criteria for determining WIC income eligibility vary? (2) To what extent are individuals who would otherwise be ineligible for WIC deemed eligible due to their participation in other programs? (3) How does USDA assist and monitor state determination of WIC income eligibility? GAO reviewed federal laws and regulations; analyzed USDA's national data from 2010, recent survey findings, and monitoring reports; reviewed WIC policy manuals from 10 states chosen to provide population size and geographic diversity; and interviewed federal, state, and local officials.


GAO recommends that USDA develop a timeline for reviewing its monitoring reports to assess national program risks and target assistance. USDA agreed with GAO’s recommendation.

For more information contact Kay E. Brown at (202) 512-7215 or

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Agriculture To improve WIC oversight and administration, the Secretary of Agriculture should direct FNS to develop a timeline for reviewing Management Evaluation reports to assess program risks at a national level and target assistance to states.
Closed – Implemented
In 2013, FNS staff developed a process to use an automated report to identify areas in need of correction or improvement that were found during WIC Management Evaluations conducted across the country. Using the output report, FNS will assess the frequency of Management Evaluation findings in each policy and program area nationwide and respond by providing policy clarification, training, or other corrective actions to states. The report went into production on November 1, 2013, and FNS reported that staff will review the reports quarterly.

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Child nutritionMedicaidChildrenInfantsFederal regulationsWomenFamily welfareTerritories and possessionsFederal lawEligibility criteria