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Appendix L: Public Comment 8

Comment Number: FNS-2022-0015-1254-0030
All Sections: 5.2.10.1.3
Classification: Substantive
Commenter Type: WIC State Agencies/Indian Tribal Organization
Organization: PA Department of Health, Bureau of WIC
Excerpt Text: [Underline: Offline to Online Conversion and Online Ordering Implementation Costs]
It will take about 5 million dollars to convert Pennsylvania from an offline to online eWIC system.
The $90,000 estimate to implement an online ordering system is insufficient. It appears the $90,000
may not include all the associated costs to implement online ordering such as certification process
of the POS system.
USDA estimates the online ordering maintenance of $4,000 a month. PA WIC does not have a
context for this charge. PA WIC is unaware of any estimates or knowledge of associated online
ordering maintenance costs.
[Underline: New State Agency Positions]
The staffing cost estimate of $117,590 for each position seems accurate for the lowest level of
employee seniority at a Step 08 pay rate in Pennsylvania, inclusive of employee wages and state
paid benefits. The estimated cost does not factor in those entering the position at a higher seniority
level. An employee at the higher seniority level would significantly increase salary and state paid
benefits beyond the estimate of $117,590 for each position. It also seems the level of expertise the
position descriptions seek would be on the low end of the salary scale once the salary and state
paid benefits are factored in together.