FNS is aware that school food authorities and program operators may be operating NSLP, SBP, and other child nutrition programs, in a way that includes offering reimbursable meals and non-program foods (a la carte sales, catering, adult meals, etc.) using foods from popular franchise restaurants through a franchise agreement.
This policy memorandum is being issued in response to the fiscal year 2013 audit by USDA’s Office of Inspector General, state agencies’ Food Costs for the FNS WIC Program.
We have concluded that neither the authorization of vendors to accept WIC food instruments, nor the exchange of a WIC food instrument between a certified WIC participant and an approved WIC vendor represents a "covered transaction." Therefore, WIC vendors are not subject to the certification requirement.