Research has shown that WIC helps to improve birth and  dietary outcomes and contain health care costs, and USDA considers  WIC to be one of the nation’s most successful and cost-effective nutrition  intervention programs. USDA’s Food and Nutrition Service (FNS) oversees the program, which is  administered by state and local agencies through approximately 10,000  clinic sites. In enacting WIC, Congress intended the program to provide women,  infants, and young children with supplemental foods during critical times  of growth and development. Federal law and regulations set the WIC  income eligibility threshold at a maximum of 185 percent of the federal  poverty guidelines, specify certain income sources that must be included  and excluded when determining income eligibility, and require applicants  to provide proof of income. For example, federal regulations indicate that state agencies  have the flexibility to decide whether to use an applicant’s annual or  current rate of income, as well as the specific time period that equals  current income, when determining applicants’ income eligibility. The Exercise of Allowable Discretion Has Led to Some Variation in State and Local Income Eligibility Policies

The discretion granted by federal law, regulations, and guidance in  certain areas of WIC income eligibility determination has resulted in some  variation in policy across states and localities. According to  national survey data, most states assess current income to determine  eligibility for all applicants. In 5 of the 10 state WIC policy manuals we reviewed, 2 define  current income as income from the last 30 days, 1 defines it as income  from the last 60 days, and 2 others do not clearly define it. This is consistent  with national survey data, which show that about half of the states pass  some of the federally-allowed discretion for WIC income eligibility  determination on to their local agencies. Another area in which states are given flexibility is in determining an  applicant’s family size. State policies also vary to some extent as to the sources of income that  are included when determining an applicant’s income eligibility for WIC. Because income  data were not reported for an additional 7 percent of participants who  were adjunctively eligible, we could not determine if these participants  were also eligible for WIC solely due to adjunctive eligibility in that year. While studies  generally find that Medicaid recipients are more likely to participate in  WIC than others, some studies suggest that expanded Medicaid income  eligibility has not had a substantial impact on WIC participation because  eligible families with relatively higher incomes are less likely to participate  in WIC than lower-income families. FNS Assists and Monitors States’ Income Eligibility Determinations; However, It Does Not Currently Use Monitoring Results to Target Assistance

FNS regularly provides assistance to states in administering WIC, though  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. FNS regularly monitors state and local WIC administration through  Management Evaluations conducted by its regional offices, and in one- third of the states reviewed since 2010, FNS found problems with income  eligibility determination policies and procedures. Although FNS plans to begin regularly reviewing Management Evaluation  findings at the national level to identify areas of program risk and target  assistance accordingly, officials had not previously done so because  findings were not easily compiled at FNS headquarters. In  the case of WIC and Medicaid, two-thirds of WIC participants are now  eligible for WIC benefits due to their receipt of Medicaid, and data show  that increases in Medicaid’s income eligibility thresholds have enabled  some women, infants, and children to receive WIC who would otherwise  have been found ineligible. Because officials have said they plan to do such reviews in  the future, a timeline for reviewing its monitoring results could better  position FNS to demonstrate progress towards completing its planned  actions. Recommendation for Executive Action

To improve WIC oversight and administration, we recommend that the  Secretary of Agriculture direct FNS to develop a timeline for reviewing  Management Evaluation reports to assess program risks at a national  level and target assistance to states. Appendix I: Other Datasets that Provide Information on WIC Participant Incomes

In addition to the national administrative data on participants in the  Special Supplemental Nutrition Program for Women, Infants, and  Children (WIC), two Census Bureau datasets have been used by other  researchers to examine WIC participant characteristics, including  incomes.
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.

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.

What GAO Recommends

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