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Appendix J: Public Comment 6

Comment Number: FNS-2022-0015-1549-0005
All Sections: 5.2.10.1.1, 3.3.2.3.3, 3.3.2.2.3
Classification: Substantive
Commenter Type: WIC State Agencies/Indian Tribal Organization
Organization: Maryland WIC Program
Excerpt Text: [Blue: Create Two New WIC State Agency Staff Positions to Reflect the Staffing Needs
of a Modern, Innovative Program (page 9)]
-- WIC Customer Service Coordinator
-- Description is not a customer service role but more a description for an IT developer.
-- This is handled by contractors, for which we are already paying.
-- These job functions are often divided between different staff.
-- New positions are going to affect each state and would be filled on a state-by-state basis:
-- The educational requirements are stiff. Maryland government is currently relaxing some degree
requirements in effort towards greater diversity and inclusion among its workforce.
-- Could the degree requirements be at the state’s discretion?
-- Our Program would need to request permanent positions from our Budget Management offices.
Maryland is not guaranteed to receive them when requested. It is a very rare occurrence.
-- Contracted positions are also not guaranteed by our Budget and Management office and not as
attractive to professionals of the proposed caliber.
-- We believe it will also be hard to fill part-time positions with the new educational requirements.
-- Currently, limited vendor positions are already at capacity and cannot be eliminated or
reclassified to cover these new positions without detrimental impact on overall service delivery.
-- The proposed positions are too heavily related to programming and development and most likely
be managed under IT departments/units.
-- We don’t believe that we would receive additional allotted funding from the state to fill these
positions.
-- No Additional Funding:
-- USDA calculated we will spend less time:
-- Performing Vendor Authorizations

-- 45 minutes to review an application for authorization is not an accurate depiction of a properly
processed application, especially since states have different application requirements.
-- Application processing times can span over days, more than 45 minutes when aggregated.
-- Travel time for monitoring
-- 20 minutes travel time is not an accurate depiction of travel time to most stores depending on the
state’s geography. Why is this based on participants’ travel time?
-- Travel time can take from 20 minutes to 2 or 3 hours.