LVL Code of Conduct

Confidentiality

LVL Code of ConductConfidentiality and Conflict of Interest

Fall 2013Vendor Agreement2Routine Monitoring Visit3Routine Monitoring Visit4Handout

5Compliance Investigations6Handout

7Formal Appeal Process8Formal Appeal Process9ConfidentialityVendor Information10Definition of ConfidentialityInformation collected by local WIC agencies about a specific WIC vendor or participant is confidential information and cannot be provided to anyone not directly connected with the administration or enforcement of the WIC program.

Full text available at 7 C.F.R. 246.26(d) and (e)11

Vendor information that is Not ConfidentialVendors NameStore NameStore AddressStore Telephone NumberStore Website or Email AddressAuthorization Status

13Vendor ConfidentialityConfidential vendor information is any information about a vendor (whether it is obtained from the vendor or another source) that individually identified the vendor, except for vendors name, address, telephone number, website/email address, and authorization status.

Full text available at 7 C.F.R. 246.26 (e)14Where do you find confidential information?Paperwork on fileNotesEmail15Maintain SecurityPaper DocumentsFollow document security instructions in WPM 120-10, item VI.Electronic DataCMB Chapter 2, I. Requirements, Section F. Information Technology and Technical Support Services16Proper DisposalHardcopyShred and tossCDDestroy and tossElectronicClean and sanitize hard drive17Conflict of InterestLocal WIC Agency and Vendor18What is a conflict of interest?A conflict of interest (COI) occurs when the obligations of an employee to the WIC Program are influenced or compromised by self-interest, a prior commitment, competing loyalties, or an inability to be objective, and that which may or may not result in a financial gain. 19Local WIC Agency Requirements(WPM 150-10)Establish a COI policy.Ensure no COI exists.Have staff sign a COI statement.Make the COI policy and statement available to the State Agency.

Local agencies may establish their own COI policy and statement.20LVL ResponsibilitiesTrain WIC staff on COI at least once per year (WPM 190-00).

21LVL ResponsibilitiesProvide support to ensure your local WIC agency collects COI statements for all staff.

22Example of COIYou or any individual related to you by blood or marriage has a financial interest in any grocer authorized to accept WIC food instruments.23Testing Your KnowledgeConflict of Interest Scenarios

24Is this a conflict of interest?An LVL provides a WIC participant the name and location of only a few WIC authorized vendors in the area.25Is this a conflict of interest?A WIC Authorized Vendor has a table set up at a community health fair sponsored by the county health department.26Is this a conflict of interest?A local agency WNA recommends large chain stores to a WIC participant because she believes these stores stock all the WIC foods and provide better customer service.27Is this a conflict of interest?A local agency site supervisor allows a WIC authorized vendor to place their weekly ad in the local WIC agency waiting area.28Is this a conflict of interest?A participant says they are new in town and would like a list of authorized vendors. The local agency front desk staff gives her a list of all the vendors in her neighborhood.29Is this a conflict of interest?A local agency Breastfeeding Peer Counselor encourages participants not to shop at a certain vendor because they are charging WIC shoppers high prices.30Is this a conflict of interest?An LVL makes arrangements to have a WIC outreach table at an event sponsored solely by a WIC Authorized Vendor.31ActivityCase Study32Primary State WIC ContactsRuth CaldwellState WIC LVL [email protected](916) 928-8829Vendor Management [email protected](855) 942-7867Program & Business [email protected](800) 852-577033EvaluationYour feedback is important to us!

Scan and email to [email protected] OR fax to Ruth Caldwell at (916) 263-331234Thank you for joining us

Such a full day of LVL training!35