May 26, Joseph Lazzaro Director, Accessibility Technology Group Information Technology Division Commonwealth of Massachusetts. Dear Mr.

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1 The Commonwealth of Massachusetts Executive Office of Health and Human Services Department of Public Health 250 Washington Street, Boston, MA DEVAL L. PATRICK GOVERNOR TIMOTHY P. MURRAY LIEUTENANT GOVERNOR JUDYANN BIGBY, MD SECRETARY JOHN AUERBACH COMMISSIONER May 26, 2010 Joseph Lazzaro Director, Accessibility Technology Group Information Technology Division Commonwealth of Massachusetts Dear Mr. Lazzaro: The purpose of this memorandum is to request a temporary waiver for the Department of Public Health s Women, Infants, and Children Nutrition Program (WIC) management information system known as Eos. We are requesting this waiver in accordance with the Commonwealth s Enterprise Information Technology Accessibility Standards, specifically as these standards pertain to the use of the WIC system by sight-impaired or mobility-impaired operators. The Department of Public Health is committed to providing our 600 employees and 140,000 clients with a state of the art system that is accessible to all who use it. To that end, we have outlined below our progress in meeting the accessibility standards and our aggressive timelines for doing so. Part of our rationale for requesting a waiver to roll this out as we implement the accessibility guidelines is that one of our public pledges has been to offer WIC clients even more nutritious food by giving them Farmer Market checks for this year. If we don t implement the system in early-summer, we will miss this opportunity for another year. As you know, wellness and obesity prevention is a cornerstone of the Governor s commitment and we are eager to implement this, keeping in mind our responsibility to develop an accessible system. In addition, we are currently out of compliance with some USDA regulations that will be resolved as the new system comes on line. Overview of WIC Program: Massachusetts WIC is a program within the Department of Public Health s Bureau of Family Health and Nutrition. WIC is a unique program which provides free healthy food to thousands of pregnant women and children every day. In addition, WIC links these low-income families to health, social and nutrition in critical stages of growth and development. More than 140,000 people benefit from WIC. The

2 most visible part of the WIC program is the food prescriptions which can be redeemed at 1,000 grocery stores or pharmacies.. Massachusetts WIC works with 35 local agencies at 130 sites to provide these benefits 12 hours per day, 6 days per week. In total, there are approximately 600 employees who use the WIC information system to directly provide WIC benefits to participants or to support these services at the back end. Legacy Information System: WIC services are currently provided via a distributed information system with independent applications operating at each of the 130 WIC site. Each site works entirely off-line and, at the close of business each day, transmits updates to its portion of the WIC database to DPH s central office. These updates are in turn sent to the mainframe at ITD in Chelsea for overnight processing. Upon completion of that processing, updated versions of the database are transmitted back to each WIC site. The WIC information system was developed in the 1980s and transferred from Illinois to Massachusetts in It is written in Clipper and runs on a DOS platform at local agency sites, and utilizes Natural and ADABAS at ITD. The overall system is obsolete and runs on outdated hardware at WIC sites. In order to replace this system, Massachusetts WIC must submit appropriate documentation to the U.S. Department of Agriculture (USDA). USDA is the funding agency for the WIC Program, and the preparation, filing, review, approval, and use of the USDA Advance Planning Document (APD) process and its related documents for project planning, management, and control purposes comprise the successive steps through which a State agency can meet Federal oversight requirements and subsequently receive Federal written prior approval for financial participation in information technology (IT) projects. Historical Timeline: The Massachusetts WIC Nutrition Program provided an Advanced Planning Document (APD), as required, to the Northeast Regional Office (NERO) of the USDA in mid The APD described the approach that Massachusetts would take to transfer a working WIC information system from another State and modify it to meet the requirements for integration into Mass.gov and the EOHHS Virtual Gateway. This approach is comparable to buying Commercial Off-The-Shelf software (COTS). USDA approved the Massachusetts WIC APD and its associated Functional Requirements Document in late With participation from the EOHHS architecture and Virtual Gateway teams, an RFR was prepared and posted in March Three proposals were received and evaluated, negotiations were completed, and a contract was signed with CIBER in early August 2005 to transfer a WIC system from Wisconsin. Modifications required for Massachusetts were expected to be completed by July Rationale for Temporary Waiver Request: The Enterprise Information Technology Accessibility Standards explain that a waiver may be granted when COTS is used as a technology solution, especially when: 2

3 1. Application of Enterprise Information Technology Accessibility standards could compromise effective government operations and impose undue burden on the agency. 2. Functions are unlikely to involve an individual with a need for assistive technology. The application of Enterprise Information Technology Accessibility Standards at this time would further delay the implementation of a soon to be complete, state of the art WIC information system called Eos. Eos is a web-based transaction processing application. It enhances WIC s ability to integrate sharing of common data, improve reporting, meet state and federal security requirements, including those imposed by HIPAA, and support e-government initiatives of the Commonwealth. This new system allows Massachusetts WIC to better serve the families dependent on the program and provides major benefits to the WIC staff by offering the following improvements: Farmers markets With the new system, WIC clients will have access to fresh fruits and vegetables at farmers markets across the state. Compliance with USDA regulations WIC s funding from USDA is contingent on our ability to comply with current USDA regulations. WIC is currently out of compliance and implementation of Eos will correct this Immediate access to data - To comply with new regulations and update of data values for income, food packages, referrals, etc. Increased access - Ability to serve rural participants immediately Improved data quality and analysis - Integrated caseload and financial management capabilities that provide more accurate and up-to-date participant counts and enhance staff ability to track and predict caseload and expenditures. Better customer service State office staff will be able to walk local agency users through problems directly. The new system also includes on-line help to support and assist new service providers. Increased productivity The new system automates several activities currently conducted manually by Local agency staff such as appointment scheduling, noshow counts, preparation of financial and ad-hoc reports, nutrition risk determination, growth chart plotting and nutrition education tracking. The system also offers the ability to search and select participant records by name, improves correspondence capabilities, and provides other time saving features which will enable Local agency staff to devote more time to participant interaction and education. Cost savings The ability to tailor food prescriptions to meet participants consumption pattern avoids over prescription of WIC foods. Tighter security - The new system is secure and makes use of a more secure architecture for data transfer. Current Status and Plans: The initial projected completion date of July 2007 has been delayed in order to accommodate numerous changes in requirements. These include extensive requirements from USDA for WIC s new food package and changes for the 3

4 Virtual Gateway. The WIC Program is working closely with the EOHHS Virtual Gateway team to complete the conversion of the transferred system and roll it out statewide. The current projection for release to production is June Temporary Waiver Request: Based on our understanding of waiver criteria, as enumerated above, we are requesting that this WIC system receive a temporary waiver from ADA Section 508 in order to avoid placing an undue burden on local agencies that continue to provide WIC services through the use of an antiquated system, impacting productivity and quality of service delivery. Commitment to Accessibility: We recognize that accessibility issues are a critical component and must be addressed. We have, therefore, taken the following steps: 1. In an attempt to determine the level of effort necessary to satisfy the Massachusetts requirement to make all new systems accessible, the Massachusetts WIC Program investigated the feasibility of modifying this transferred system to make it fully ADA compliant. We received an amendment proposal to accomplish this effort during system development, but there was significant cost and schedule impact to the already approved project and no additional funding was available at that time. 2. Massachusetts WIC is fully committed to implementing a system that is ADA compliant and, to that end, requested federal funding from the USDA to build a web interface (GUI) which will be ADA compliant. The WIC Program requested ARRA funds for the project in June 2009, and received ARRA funds under a USDA Miscellaneous Technology Grant to be used specifically for the purpose of modifying Eos to be ADA compatible. The funds were awarded in October 2009 and are available through 30 September WIC has issued an RFQ under statewide contract ITS33 for implementation of changes to Eos to become ADA compliant. The evaluation previously referred to provides the basis for the statement of work to accomplish the changes. The contract for these services will be in place and fully funded prior to the promotion of the Eos system into production. 3. In order to assure that any user who is non-sighted, has low vision, or is mobilityimpaired can perform his or her work while we develop an ADA compliant interface, we will support such users by assigning other staff to assist the individual in performing functions where issues are being experienced. Other applications on the Virtual Gateway have used this buddy method while compliancy issues are being addressed. These duties include: Verification of written documentation pertaining to identity Verification of written documentation pertaining to residence Verification of written documentation pertaining to income Verification of written documentation pertaining to adjunctive eligibility (e.g., MassHealth ID card) Verification of written documentation pertaining to immunization records 4

5 Verification of written documentation pertaining to blood test results for hemoglobin, hematocrit, and lead levels Verification of prescriptions written by participant s doctor Observation of participant s visual cues during responses to questions Measurement of participant s height, weight, length Drawing participant s blood for testing Verification of WIC-prepared prescriptions prior to distributing to participant. As these tasks are completed, the results are entered into the WIC information system for record keeping and for use in calculating certification requirements, benefit issuance and referrals to other agencies. These tasks are required to be completed by WIC personnel. Thank you for your consideration of this request for a temporary waiver. Please let me know if you would like to discuss this or if we can answer any questions on this matter. Sincerely, John Auerbach Commissioner James Daniel Chief Information Officer 5