Specifications include, but are not limited to: During each compliance buy, the investigator will attempt a major substitution of an approved WIC item. The investigator will purchase foods that are not approved for the WIC program, but the food category is listed as part of the WIC benefits. If the WIC benefits specifies cereal and other foods, select a cereal high in sugar (i.e. Golden Grahams, Fruit Loops) If the WIC benefits lists 64 oz container of juice, select a sweetened juice (i.e. Hi-C, Hawaiian Punch). Special instructions for specific transactions may include: 1. Exchange Products – Attempt to exchange food or formula purchased with WIC benefits for other items in the store that are not approved by WIC (i.e. meat, diapers etc.) 2. Return Product for Refund - Attempt to get a cash refund for food or formula purchased with WIC benefits. Conducting a Compliance Buy - The State Agency will issue all benefits used in the compliance buys. The WIC card number and redemption dates of all benefits must be recorded on the compliance buy investigation report. The State Agency will record the card numbers and issued benefits to be used prior to providing them to the investigator. A shopping list will be provided to the investigator at the time the WIC benefits are furnished. Before entering the store, the investigator should take time to observe general activity in the store. It is also helpful to install the WICShopper app on a smart phone and register the WIC cards being used. The WICShopper app can be used to scan food items and identify what items are WIC approved and what items are not allowed. When selecting foods, the item price should be recorded on your shopping list. When ready, take all items to the checkout register and use the WIC card for payment. The compliance buy should be completed without entrapment. Entrapment is defined as the act of inducing persons to commit a crime not contemplated for the purpose of instituting a criminal prosecution. The mere act of furnishing the suspect the opportunity to commit a crime, where the criminal intent was already present in the suspect's mind, is not ordinarily entrapment. Generally, the entrapment forbidden by law depends on whether or not the activity leading up to the violation amounted to putting it in the mind of a person who had no prior inclination to violate and leading them to do it for the first time. If investigators merely provide an opportunity for a suspected violator to continue on a course of criminal conduct, this does not constitute entrapment. Investigators should make no appeals to sympathy and do nothing that could imply coercion. Do not give any kind of "sob story" to create sympathy. Although the object of the investigation is to determine whether or not the store is abusing the program, never demand that the clerk provide unauthorized items in exchange for WIC benefits. These behaviors could lead to findings of entrapment.
