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Appendix I: Public Comment 5

Comment Number: FNS-2022-0015-1424-0005
All Sections: 5.2.10.1.1
Classification: Substantive
Commenter Type: Individual/Private Citizen
Commenter: Kim Hinnenkamp
Excerpt Text: We have concerns with the estimated amounts of time to complete the various tasks
identified in the rule. 45 minutes per vendor each year is grossly underestimated. This includes
reviewing the application, making the onsite store visit, reviewing the contract with the store, and
obtaining signatures which can take up to three to four hours depending on the location of the
store. We also need to come back to the office and update all the information in our MIS. 20
minutes to travel to a store is grossly underestimated. 30 minutes seems more reasonable one way,
so 60 minutes roundtrip is more realistic. This also does not account for stores that are an hour
away from our main WIC clinic, so this total time should account for stores farther away as well. 40
hours is listed as an estimated amount for virtually monitoring online stores. Since there is no
criteria or guidance given, it is difficult to estimate an amount of time needed as all of this will need
to be developed.