This is to inform you of changes that will be made to the FMNP interim regulations. Because some aspects of this year's FMNP season have already begun, and the process of issuing regulations is long and complex, we wanted to offer state agencies the opportunity to implement the following provisions prior to publication of the final FMNP regulation.
This policy memorandum is simply a clarification of general WIC program confidentiality principals delineated in the Program Regulations and FCS Instruction 800-1 with special emphasis on provisions which affect immunization promotion activities.
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.
We have concluded that neither the authorization of farmers or farmers' markets nor the exchange of a FMNP coupon between a certified FMNP recipient and an approved farmer or farmers' markets in the FMNP represents "covered transactions." Therefore, farmers or farmers' markets in the FMNP are not subject to the certification requirements.