|DATE:||February 7, 2007|
|SUBJECT:||WIC Policy Memorandum # 2007-2 State Agency Model (SAM) Systems Transfers|
Supplemental Food Programs
This policy memorandum outlines the requirements for the revised WIC Advance Planning Document (APD) process and provides additional guidance to state agencies that are interested in the transfer of a SAM system.
We ask that you send this memo out to all WIC state agencies upon receipt.
In June of 2006, this office sent state agencies and regional offices a memorandum that provided an overview of the state agency model (SAM) project, the benefits of adopting a SAM model, and the changes to the APD process in light of the SAM efforts. That letter was intended to provide a high level overview and more specific information was promised at a later date. This letter provides that additional guidance, to include: 1) the priority for funding, 2) the components of the streamlined Implementation APD (IAPD), and 3) examples of justification for non-SAM transfers. A timeline is also provided for special SAM funding should it become available.
The June guidance presented the revised APD process that went into effect October 1, 2006. The guidance laid out the steps that needed to be taken for all state agencies that are planning a new information system (IS). Please note that the steps have been slightly modified, as we no longer require a Letter of Interest be submitted by the WIC state agency to the national office. This step has been replaced with a requirement that the RO send a copy of the state agency transmittal letter that accompanies the Planning APD. We have also removed the requirement for a Letter of Commitment, as this will be accomplished de facto by the submission of a grant application. Also, references to the alternatives analysis have been changed to feasibility study because it would be very difficult to submit a complete alternatives analysis without completing the other components of a feasibility study. Attached to this memorandum are the feasibility study guidelines as defined in the FNS Handbook 901.
Step 1. The state agency submits a Planning APD (required) to the regional office.
Step 2. The RO submits the transmittal letter from the Planning APD to the national office.
Step 3. The state agency submits for regional review either a planning Request for Proposal (required for state agencies utilizing contract services) or a detailed statement of work or narrative description of work for state agencies using in-house resources. The in-house narrative should follow the same guidelines that are outlined for RFP’s in FNS Handbook 901.
Step 4. The state agency conducts a System Feasibility Study and provides results to the Regional Office (RO). The results are required prior to submission of an IAPD. The alternatives analysis must include the analysis of technical and programmatic merits of possible system transfers to include one or more SAM models. If the results of the feasibility study support a non-SAM transfer, the state agency must submit justification and proceed with the full ADP process, as outlined in FNS Handbook 901.
Step 5. An IAPD is required for approval if total system cost exceeds $500,000. For those state agencies that are taking a SAM transfer, a streamlined IAPD is acceptable. However, steps 1 through 4 must be completed before submission of an IAPD.
The following documents are required for a streamlined SAM IAPD. The APD Handbook 901 will be revised accordingly and will provide further details on each document.
- Executive Summary
- Funding Request
o Proposed Budget
o Budget Narrative
- Project Management Plan and Resource Requirements
- Schedule of Development Activities, Milestones and Deliverables
- Cost Allocation Plan (if appropriate)
- Waiver of Depreciation
- Modifications Required to SAM transfer software (if known)
- Commitment to do a Security Plan (to include system access and physical, personnel, and information security)
- Commitment to do a Continuity of Operations/Disaster Recovery Plan
This is a streamlined process as it does not require a cost benefit analysis, the full general system design, or the Functional Requirements Document. We cannot justify any additional streamlining given the complex risks and costs associated with a system transfer development effort.
Acceptable Justification for a Non-SAM Transfer
The results of the alternatives analysis should clearly support any justification for a non-SAM transfer. The following are examples of why a state agency might not be able to take a SAM transfer:
- None of the SAM systems meet the software or hardware requirements of the state agency or will not run on the state agency supported architecture (e.g., open source, Linux, Java, 64-bit, etc.). Costs to replace existing infrastructure necessary to support a SAM system are prohibitive to both the state agency and to the Food and Nutrition Service (FNS). This should be supported by documentation denoting the state agency's hardware and software standards.
- The state agency mandates an implementation date that is prior to the thorough testing and acceptance of the SAM system that best fits the needs of the state agency’s WIC Program.
- The state agency requires that the WIC component be developed as part of a larger, integrated health system that is not compatible with any existing SAM.
- The WIC state agency plans on becoming a sub-state, such as the case of the VIWoW system in the Virgin Islands that is being run by the Maryland system.
SAM Grant Process
Funding for the SAM transfers will be awarded through the grant process. FNS plans to release a solicitation package in the second quarter of the federal fiscal year. This package will request system information from the state agencies that are interested in the transfer of a SAM system. The state agency will submit the requested information to the RO. The RO will forward the information, along with recommendations for funding to the national office. Based on the information provided, FNS HQ will prioritize the funding requests. Input from the RO and other sources may also be considered. Final grant awards will be announced in the 3rd or 4th quarter of the federal fiscal year, depending on funding availability and the SAM project schedules.
Priority for Funding
Limited funding may become available to assist state agencies with the costs of a SAM system transfer. For funding and resource planning purposes, it is that the RO submit the PAPD transmittal letter to FNS Headquarters (HQ) as soon as the PAPD is received (regardless of when the state agency began the planning phase). This will alert HQ that additional technical assistance and dialog may be needed to assist the state agency through the new APD process and that funding may be requested in the future.
First priority for funding will be to those state agencies most in need of a new IS based on a number of criteria, including, but not limited to, the following:
- The level of critical functions performed by the current system, as defined in the Functional Requirements Document for a Model WIC Information System (FReD).
- The age of the current system.
- The level of modernization of the current system as compared with the stated objectives of a SAM system, i.e., web-based; fully functional; EBT-ready; modern and state-of-the-art technology; and ease of software upgrades and mandated enhancements.
- The state agency’s flexibility and willingness to adapt to new business rules (to fit a SAM system).
- The ability of the current system to facilitate operational efficiency and Program effectiveness.
Any questions concerning the process outlined above should be directed to your regional office.
PATRICIA N. DANIELS
Supplemental Food Programs Division
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.