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Appendix F: Public Comment 2

Comment Number: FNS-2022-0015-1254-0026
All Sections: 5.2.10.1.1
Classification: Substantive
Commenter Type: WIC State Agencies/Indian Tribal Organization
Organization: PA Department of Health, Bureau of WIC
Excerpt Text: [Underline: Authorization and Reauthorization Processes]
Preliminarily, PA WIC notes that USDA’s estimate as to travel time to vendors is based on travel time
of WIC participant to vendor. In PA WIC, there are approximately 1,250 vendors throughout the
state. In comparison, in Pennsylvania, there are three centrally located offices [Footnote 3:
Harrisburg, PA (Central Office); Reading, PA (Eastern Office); Greensburg, PA (Western Office).]
from which PA WIC staff work out of. Naturally, the time it takes a WIC participant to travel to the
nearest vendor is significantly quicker than the time it takes a staff member to visit a vendor for a
review.
The below charts compare USDA’s time estimates for certain milestones with PA WIC’s data of it for
onsite vendor reviews and vendor application reviews.
[Underline: Table 1: Onsite Vendor Review – Comparison of USDA Estimate to PA WIC Data (1 Staff
Member) #]
Round Trip Travel to Vendor USDA Estimate: 20 minutes
Onsite Vendor Review USDA Estimate: 40 minutes
Vendor Training* USDA Estimate: Level 3 certification* USDA Estimate: [Bold: Total:] USDA Estimate: [Bold: 60 minutes]
Round Trip Travel to Vendor PA WIC Data: 60 minutes
Onsite Vendor Review PA WIC Data: 60 minutes
Vendor Training* PA WIC Data: 60 minutes
Level 3 certification* PA WIC Data: 20 minutes
[Bold: Total:] PA WIC Data: [Bold: 120 minutes minimum; 200 minutes including vendor training and
level 3 certification.]
* Due to safety concerns and for efficiency purposes, some milestones may require a second staff
member.

* Additional time in addition to round trip travel to vendor and onsite vendor review. Not all onsite
vendor reviews include vendor training or Level 3 certification.
[Underline: Table 2: Vendor Application Review - USDA Estimate to PA WIC Data (1 Staff Member)]
Application review new owner USDA Estimate: 40 minutes
Application review existing owner USDA Estimate: 40 minutes
State agency administrative procedures (e.g., generating correspondence, supervisory review, and
mailing) USDA Estimate: Local agency administrative procedures (e.g., schedule review, minimum inventory exception letter,
review announcement letter) USDA Estimate: [Bold: Total:] USDA Estimate: [Bold: 40 minutes]
Application review new owner PA WIC Data: 60 minutes
Application Review Existing Owner PA WIC Data: 30 minutes
State agency administrative procedures (e.g., generating correspondence, supervisory review, and
mailing) PA WIC Data: 30 minutes
Local agency administrative procedures (e.g., schedule review, minimum inventory exception letter,
review announcement letter) PA WIC Data: 30 minutes
[Bold: Total] PA WIC Data: [Bold: 90-120 minutes]