LVL Code of Conduct

1. LVL Code of Conduct Confidentiality and Conflict of Interest Fall 2013

2. Vendor Agreement

3. Routine Monitoring Visit

4. Routine Monitoring Visit

5. Handout

6. Compliance Investigations

7. Handout

8. Formal Appeal Process

9. Formal Appeal Process

10. Confidentiality Vendor Information

11. Definition of Confidentiality Information 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)

13. Vendor information that is NotConfidential… • Vendor’s Name • Store Name • Store Address • Store Telephone Number • Store Website or Email Address • Authorization Status

14. Vendor Confidentiality Confidential 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 vendor’s name, address, telephone number, website/email address, and authorization status. Full text available at 7 C.F.R. 246.26 (e)

15. Where do you find confidential information? • Paperwork on file • Notes • Email

16. Maintain Security • Paper Documents • Follow document security instructions in WPM 120-10, item VI. • Electronic Data • CMB Chapter 2, I. Requirements, Section F. Information Technology and Technical Support Services

17. Proper Disposal • Hardcopy • Shred and toss • CD • Destroy and toss • Electronic • Clean and sanitize hard drive

18. Conflict of Interest Local WIC Agency and Vendor

19. What 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.

20. Local 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.

21. LVL Responsibilities • Train WIC staff on COI at least once per year (WPM 190-00).

22. LVL Responsibilities • Provide support to ensure your local WIC agency collects COI statements for all staff.

23. Example of COI You or any individual related to you by blood or marriage has a financial interest in any grocer authorized to accept WIC food instruments.

24. Testing Your Knowledge Conflict of Interest Scenarios

25. Is 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.

26. Is 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.

27. Is 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.

28. Is 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.

29. Is 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.

30. Is 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.

31. Is 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.

32. Activity Case Study

33. Primary State WIC Contacts

34. Evaluation Your feedback is important to us! Scan and email to WICLVL@cdph.ca.govOR fax to Ruth Caldwell at (916) 263-3312

35. Thank you for joining us Sucha full day of LVL training!