Specifications include, but are not limited to: It is the intent of ISDH to contract with a vendor that provides quality
Compliance Investigation Service for the WIC program.
The Contractor is expected to fulfill the following duties:
1. Provide investigative staff to perform compliance buys matching the Contractor's Compliance
Investigation Manual as approved by Indiana WIC. The Contractor's staff must be
representative of the racial makeup of the community where the identified suspect activity is
occurring. The following are the types of compliance buys that Indiana WIC expects the
Contractor to perform from most to least common:
a. Minor Substitution - Investigator attempts to substitute an unauthorized food item
within an approved category.
b. Trafficking Buy - Investigator attempts to sell a food instrument for cash or other form
of direct payment.
c. Major Substitution - Investigator attempts to substitute an unauthorized item clearly
outside the approved category. This includes substitutions of tobacco, alcohol,
d. Safe Buy - Investigator purchases foods listed on the food instrument that have a price
label, in the quantities, sizes, and types listed.
2. Conduct Compliance Investigations at selected WIC vendor locations utilizing WIC EBT
cards. The Compliance Investigation shall be conducted in accordance with the Contractor's
approved manual and under the instruction of Indiana WIC. All Compliance Investigations
shall be conducted in an appropriate manner so as not to appear threatening or intimidating or
insinuate entrapment and thus jeopardize the principles behind the Compliance Investigations.
If determined to be beneficial by Indiana WIC, an inconspicuous video recording device may
record the store visit by the compliance investigator. The Contractor can choose to require
additional fees for compliance buys involving video recording equipment.
3. Submit to Indiana WIC a completed Compliance Investigation Report with 100% accuracy for
each compliance buy within five (5) business days of completion of a Compliance Investigation
via email. The Compliance Investigation Report shall include proof of purchase for all food
items received from a vendor through one or more of the following: a receipt containing all
items purchased during the sales transaction(s), a picture of the sale transaction items, and/or a
video of the sales transaction(s).
4. Donate perishable foods to a charitable organization (e.g. food pantries or soup kitchens) as
quickly as possible. All refrigerated and frozen food items shall be stored in coolers until the
food is donated.
5. Maintain verifiable controls of the WIC EBT cards provided by Indiana WIC for use in
investigations. Upon inspection by the State, the Contractor must account for WIC EBT cards.
6. Participate and/or testify in pre-hearing conferences, administrative hearings, or court trials
when these events are directly related to the results of Compliance Investigations.