• Program flexibility for maximum monthly allowance (MMA) requirements in Food Packages I and II (USDA, 2022b).
• Program flexibility for medical documentation requirements in Food Packages I and II (USDA, 2022c).
• Program flexibility for vendor formula substitutions during a transaction (USDA, 2022d).

17^th: FDA announces formula recall, Similac, Alimentum, and EleCare (FDA, 2022c).

18^th: Maine WIC notifies local agencies (LAs), WIC participants and vendors of recall with instructions on how to return formula. Maine WIC staff go to vendors to pull recalled product from the shelves. 2x weekly calls with LAs and 1x week NERO calls established.

21^st: Maine WIC applies and is granted waiver flexibilities on alternative formulas to provide, formula returns, medical documentation requirements, and the maximum monthly allowance (MMA) of formula. These waivers last until September 30, 2022. WIC updated the Approved Products List (APL). WIC holds twice weekly calls with LAs. Maine WIC attends weekly calls with NERO.

17^th: Abbott voluntarily recalls Similac, Alimentum, and EleCare powdered infant formulas manufactured at Sturgis facility in response to concerns about Cronobacter and Salmonella contamination (FDA, 2022b).

FDA issues advisory report recommending that consumers do not use recalled powdered infant formulas after investigating reports about Cronobacter infections linked to formula supplied by the Sturgis facility (FDA, 2022g).

18^th: CT WIC provided updates to internal staff and leadership; disseminated written guidance to LAs and authorized vendors on formula recall; shared information with key partners; and distributed participant communication via e-mail, WIC Shopper App, and the One Call Now text message system.

17^th: Abbott voluntarily recalls Similac, Alimentum, and EleCare powdered infant formulas manufactured at Sturgis facility in response to concerns about Cronobacter and Salmonella contamination (FDA, 2022b).

FDA issues advisory report recommending that consumers do not use recalled powdered infant formulas after investigating reports about Cronobacter infections linked to formula supplied by the Sturgis facility (FDA, 2022g).

18^th: USDA provides guidance for handling returns and exchanges of recalled product and the process for requesting WIC waivers related to infant formula shortages (USDA, 2022a).

FNS launches the new Infant Formula Safety webpage to provide public-facing, real-time, infant formula food safety updates to the public (USDA, 2024c).

17^th: Abbott Laboratories voluntarily recalls Similac, Alimentum, and EleCare powdered infant formulas manufactured at Sturgis facility in response to concerns about Cronobacter and Salmonella contamination (FDA, 2022b).^a

Around 4:30 p.m., Texas WIC contacted Abbott Laboratories, representative to discuss impacts. They also contacted USDA’s Southwest Regional Office and sent e-mail notification to LA directors of the recall.

18^th: Texas WIC sent text notification to all WIC clients receiving infant formula, informing them of the recall, instructing them to not use recalled product, and referring them to similacrecall.com.

17^th: Abbott voluntarily recalls Similac, Alimentum, and EleCare powdered infant formulas manufactured at Sturgis facility in response to concerns about Cronobacter and Salmonella contamination (FDA, 2022b).

FDA issues advisory report recommending that consumers do not use recalled powdered infant formulas after investigating reports about Cronobacter infections linked to formula supplied by the Sturgis facility (FDA, 2022g).

18^th: USDA provided guidance to WIC state agencies for handling returns and exchanges of recalled product and the process for requesting WIC waivers related to infant formula shortages (USDA, 2022a).

n.d.: Maine WIC issues a formula substitution graphic and texts it to all WIC participants. Maine WIC works with MaineCare on a provider notice. Maine WIC works with ITO in Maine to ensure formula for ITO WIC participants. Maine WIC direct-ships cases of formula to the LA clinics each week. Maine WIC is having trouble obtaining Nutramigen, Neosure, and Similac Sensitive.

Abbott issues rebate on all infant formulas WIC is purchasing. Rebate is extended to March 31, then changed to April 30, June 30, and currently rebate on all products go until August 31, 2022.

CT WIC convened meetings with LAs to provide updates and guidance. Attended meetings with USDA FNS NERO and NEATO state directors on formula recall. Daily meetings set with FNS NERO.

20^th: CT WIC applied for and was granted approval for three waivers through FNS NERO:

• 7 CFR § 246.10(d)(1)(i) which requires medical documentation for the issuance of non-contract-brand infant formula. Approval is granted to waive requirement for WIC participants receiving Food Packages I and II: medical documentation requirements in Food Packages I and II (USDA, 2022c).

20^th: USDA FNS begins issuing waivers to allow for product exchanges, non-contract brand of formula, and larger container sizes through September 30, 2022:^b

Program flexibility for MMA requirements in Food Packages I and II (USDA, 2022b).

Program flexibility for medical documentation requirements in Food Packages I and II (USDA, 2022c).

Program flexibility for vendor formula substitutions during a transaction (USDA, 2022d).

24^th: NC submitted waiver request to FNS for additional flexibility during supply chain issues and 2022 Abbott recall—granted March 1, 2022.

• Texas WIC added an alert ribbon to Tex-asWIC.org notifying the public of the recall and referring them to similacrecall.com.
• Texas WIC discussed with Abbott Laboratories plans to implement contract provisions requiring the contract vendor to pay rebate on alternative brand products in the event of a shortage.

21^st: USDA FNS approved all waiver requests from Texas WIC, including:

• 7 CFR § 246.10(d)(1)(i), which requires medical documentation for the issuance of non-contract-brand, non-exempt infant formula.
• 7 CFR § 246.10(e)(9), which require MMA

FNS launched the new Infant Formula Safety webpage to provide public-facing, real-time, infant formula food safety updates to the public (USDA 2024c).

The New York State WIC program released “Vendor Bulletin #4: Infant Formula Public Health Advisory – Recall of Similac, Alimentum, and EleCare” to WIC vendors and Informational e-mail “Infant Formula Public Health Advisory – Recall of Similac, Alimentum, and EleCare” distributed to LAs. A follow-up informational e-mail was distributed to LAs to provide guidance on vendor exchanges, clarified all products affected, informed them of a planned mobile app

28^th: Abbott releases return formula instructions. Maine WIC issues packing materials and instructions to LA clinics.

• 7 CFR § 246.10(e)(9), which requires an MMA for infant formula. This includes 7 CFR § 246.10(e)(9) Table 1 footnote 7, which requires state agencies to issue containers that are all the same size of the same physical form. Approval is granted to waive the MMA for infant formula provided to healthy infant participants receiving Food Packages I and II only: MMA requirements in Food Packages I and II (USDA, 2022b).

28^th: Abbott recalls one lot of Similac PM 60/40 manufactured at the same facility (FDA, 2022d). FDA advises parents and caregivers not to feed their babies certain powder formulas including Similac, Alimentum, and EleCare.

for infant formula. This includes 7 CFR § 246.10(e)(9) Table 1 footnote 7, which requires state agencies to issue containers that are all the same size of the same physical form.

(WIC2Go) message, and notified agencies that a message about the recall was added to the Interactive Voice Response line.

• 7 CFR § 246.12(h)(3) (ii), which prohibits WIC authorized vendors from permitting exchanges for authorized supplemental foods obtained with food instruments beyond exchanges for an identical (exact brand and size) food item: vendor formula substitutions during a transaction (USDA, 2022d).

CT WIC disseminated additional information to authorized vendors and the WIC Vendor Advisory Council about recall instructions and published this information on the DPH website. (The WIC Vendor Advisory Council serves as a communication forum between WIC authorized retail stores, professional trade organizations, food distributors, WIC LAs, and the state

• 7 CFR § 246.12(h)(3) (ii), stating that vendor may not provide “substitution, cash, credit, refunds or exchanges.” A waiver to this requirement would allow grocers in the state of Texas to treat Texas WIC participants like other consumers impacted by this recall.

22^nd: Texas WIC began adding UPCs for non-contract alternative-brand products to the APL. Seventy-five products were made available by February 25, with a total of 125 products (non-exempt and exempt) added by the end of the supply crisis.

Program flexibility for MMA requirements in Food Packages I and II (USDA, 2022b).

Program flexibility for medical documentation requirements in Food Packages I and II (USDA, 2022c).

Program flexibility for vendor formula substitutions during a transaction (USDA, 2022d).

22^nd: The New York State WIC program requested a waiver to temporarily waive the requirement for medical documentation for Food Package III, specifically for the formulas affected by the Abbott recall which includes, Alimentum, EleCare, and EleCare Jr.

The New York State WIC program conducted a statewide call with LAs to provide

WIC Office. Members of this group include the Spanish American Merchants Association, the Connecticut Food Association, manufacturer representatives, and small, medium, and large chain stores).

Abbott approved rebate on non-contract and competitive formulas in a variety of sizes through March 31, 2022.

CT WIC began identifying and adding alternative formula products to the APL for participant purchasing.

• Texas WIC launched public-facing webpage on TexasWIC.org dedicated to communicating alternative redemption options to clients and vendors.
• Texas WIC sent notification to WIC-approved vendors of alternative redemption options being added to the APL.
• Texas Health and Human Services Commission (HHSC) published social media information about the recall.

information and answer questions. A broadcast message was added to the WIC2Go mobile shopping application to notify all participants issued Alimentum, EleCare, or EleCare Jr. of the recall.

24^th: The New York State WIC program distributed an FAQ document that resulted from the February 22 statewide call. The New York State WIC program requested to waive exchanges of an identical authorized supplemental food item (7 CFR § 246.12(h)(3) (ii)(A)).

21^st: CT WIC distributed information to authorized vendors and the WIC Vendor Advisory Council about allowing exchanges and credit/cash refunds.

23^rd: CT WIC developed and distributed the first non-contract formula substitutes list to assist participants in purchasing non-contract formulas which was shared with LAs and authorized vendors. CT WIC developed “Breastfeeding Support During an Infant Formula Recall” guidance document and distributed it to LA staff.

CT WIC held call with LA staff to review substitutes and guidance.

23^rd: Texas WIC sent text messages to clients about alternative brand options based on the formula that was currently issued to their WIC card.

• Texas HHSC published on social media, including o content about alternative redemption option, with images, and content advising the public against making their own homemade formula.

24^th: Texas WIC posted formula recall guidance for LA staff (Texas WIC, 2022a).

25^th: The New York State WIC program requested to waive the maximum monthly allowance requirement for infant formula in Food Package III (7 CFR § 246.10(e)(9)) and of 7 CFR § 246.10(e)(9) to allow authorization and issuance of formula containers in sizes, that when added together, most closely provide the MMA. USDA FNS approved New York State’s waiver request for vendor exchanges.

26^th: The New York State WIC program distributed Vendor Bulletin #5: “Formula Recall – Vendor Exchange Waiver” notifying authorized vendors of the vendor exchange waiver approval.

CT WIC published substitutes list on website and shared it with participants through the WIC Shopper App and One Call Now text message system.

24^th: CT WIC updated the non-contract formula list with additional products and distributed it to LAs; also updated its website and distributed through communications channels for participant awareness.

• Texas HHSC published social media content promoting the WIC/DSHS Lactation Support Hotline for those needing assistance with breastfeeding.

25^th: Texas WIC launched FAQ section for health care providers that outlined Texas WIC’s response and how to support their WIC patients affected by the recall for both exempt and nonexempt formulas.

• Texas WIC sent e-mail to health care partner organizations notifying them of available resources.

28^th: Abbott recalls one lot of Similac PM 60/40 manufactured at the same facility. FDA advises parents and caregivers not to feed their baby certain powder formulas including Similac, Alimentum, and EleCare (FDA, 2022d).

Shared with the LAs and encouraged the use of social media posts that were planned to be posted daily on the DPH Facebook and Instagram pages, as well as the National WIC Association social media toolkit that highlighted the dangers of diluting formula or making homemade infant formula.

25^th: CT WIC updated the non-contract formula list with additional products and distributed to LAs; updated website and distributed through communications channels for participant awareness.

CT WIC distributed Abbott guidance to authorized vendors and the WIC Vendor Advisory Council on retail product return instructions and updated non-contract formula list.

28^th: Abbott Laboratories recalls one lot of Similac PM 60/40 manufactured at the same facility (FDA, 2022d).

• Texas WIC sent text message to all clients issued Similac PM 60/40 notifying them of the recall.

28^th: CT WIC attended the national FNS formula rebate call. FNS NERO calls changed to weekly.

4^th: CT WIC restarted food and formula reporting from LAs on a weekly basis to monitor issues.

5^th: CT WIC updated the non-contract lists to include store names for all store-brand products to help participants. Lists distributed to LAs, authorized vendors, and to participants through the website/WIC Shopper app.

11^th: Abbott extended rebate on non-contract formulas through May 31, 2022. Lists updated to reflect new date and add language to purchase Abbott products when available before a non-contract/competitor product.

12^th-14^th: CT WIC updated website with new list and shared with participants, LAs, and authorized vendors.

5^th: Posted on HHSC social media.

6^th: Texas WIC added store label and large can size options for multiple exempt formulas to its standard formulary to increase options. (These were added within the regulations for MMA for Food Package III.)

8^th: Texas WIC announced extension of authorization of non-contract alternative-brand formulas through May 2022: Notified LA staff and WIC-approved vendors.

11^th: Updated public and health care provider websites and WIC app.

12^th and 19^th: Sent text messages notifying WIC clients.

4^th: The New York State WIC program answered questions regarding the recall during the New York State WIC Association board meeting and regional WIC coordinator meetings.

5^th: Informational e-mail: “Lactaid Milk and Nutramigen Updates” distributed to WIC LAs notifying them that due to the Abbott recall, Nutramigen saw a 250% spike in demand, resulting in Mead Johnson only producing the powdered form and monitoring for overshipment to any WIC-approved vendor or geographic area.

6^th: The New York State WIC program begins communication with contracted soy formula manufacturer regarding issuing competitive soy products as an alternative to Similac Soy Isomil.

18^th: Texas WIC held opening of proposals for the infant formula competitive contract invitation to bid. (The timing of this solicitation was unrelated to the recall and a result of the normal cadence of contracting, with Abbott Laboratories’ contract set to expire September 30, 2022).

20^th: Texas WIC announced intent to award the infant formula milk-based contract to Reckitt/Mead Johnson and soy-based contract to Abbott Laboratories as the responsive, responsible bidders offering the lowest total monthly net price for infant formula, respectively, consistent with 7 § CFR 246.16a(c)(5). Contracts were set to begin October 1, 2024.

7^th: Vendor Bulletin #7: “Addition of Neocate Syneo Infant 14.1 oz Powder” distributed to WIC authorized vendors to announce upcoming addition of Neocate Syneo powder.

8^th: New York State WIC added Neocate Syneo Infant 14.1 oz powder to the New York State WIC Formulary as an alternative product to recalled formulas. LAs were notified via LA Memo 04/22 #18: “Addition of Neocate Syneo Infant.”

22^nd: New York State WIC Central Office Staff began assisting the Vendor Management Agency with overflow calls from LAs requesting assistance in locating formula for participants.

1^st: Started weekly meetings with the Office of the Governor (OTG), CT Dept. of Social Services (DSS), OEC at OTG’s request to coordinate and gather data on impact of formula recall/shortages. Data were compiled and shared with stakeholders each week.

2^nd: USDA FNS issues waivers to allow formula imported under FDA’s enforcement discretion. CT WIC opted in.

6^th: Attended Formula Roundtable event convened by Rep. Joanna Hayes to discuss impact of infant formula recall/shortages.

10^th: Presented at the Medical Assistance Program Oversight Council Women & Children’s Subcommittee meeting.

2^nd: USDA FNS issues waivers to allow formula imported under FDA’s enforcement discretion. These initial approvals were superseded by extensions, starting on August 19, 2022.

3^rd: NC system changes complete; MMA waiver to expand can size availability implemented for families.

n.d.: NC worked to finalize statewide map of all vendors that could be filtered by retailer to ensure statewide access to formula. NC mapped larger retailer distribution centers and compared them to Gerber’s data to determine issues with some communities not having formula. Determined that there was a design change that was flagged incorrectly in the

6^th: Texas WIC opted into the waivers related to authorization of imported formulas under the FDA enforcement discretion, including:

• 2 USC § 1786(f)(15) (A), 42 USC § 1786 (h) (8)(ix)(II), 7 CFR § 246.10(g), and 7 CFR § 246.12(g)(10), which require that infant formula issued by WIC state agencies is only obtained from manufacturers registered with FDA.
• 7 CFR § 246.10(e)(12) minimum requirements and specifications for infant formula.

2^nd: USDA FNS issues waivers to allow formula imported under FDA’s enforcement discretion. These initial approvals were superseded by extensions, starting on August 19, 2022. New York State obtained contracted manufacturer support for implementation of the waiver. Under waivers for the MMA for Food Packages I and II and medical documentation for Food Packages I and II, New York State WIC temporarily added larger sizes and store-brand alternatives of Enfamil Infant, Enfamil AR, and Enfamil Gentlease to New York State WIC Formulary. The

14^th: CT WIC added the first foreign formula to APL, updated non-contract substitutions list, and added to website. Distributed new list to LAs, participants, and authorized vendors.

Gerber system (parent organization’s name vs. vendor’s name). In addition, a South Carolina distribution center was feeding some NC counties. We had to work to get system changes so these could be established to have priority.

6^th: USDA FNS implements ABFA provisions via a letter to WIC state agencies (USDA, 2022h).

55 additional standard products became available to NC families; 8 imported formulas were also added to the APL.

• USDA FNS implements ABFA provisions via a letter to WIC state agencies (USDA, 2022h). Texas WIC begins conversations with awarded manufacturer to incorporate expectations for a supply chain disruption action plan into their contract.

9^th: USDA approved Texas WIC’s request for waiver to 7 CFR § 246.10(e)(9) for Food Package III, which requires an MMA for infant formula. This includes 7 CFR § 246.10(e)(9) Table 1 footnote 7, which requires state agencies to issue containers that are all the same size of the same physical form.

New York State WIC program released Local Agency Memo 06/22 #25: Temporary Contract Formula Larger Sizes and Store Brands” to communicate this update to LAs and “Vendor Bulletin #12: Temporary Redemption of Formula Larger Sizes - No Action Required” to authorized WIC vendors.

22^nd: USDA FNS provides a WIC Infant Formula Distribution Toolkit for state agencies and stakeholders (USDA, 2022i). It includes a list of state agencies authorizing imported formula, relevant USDA and FDA guidance, charts of the top retailers, and maps indicating the prevalence of retailers across each region.

12^th: Texas WIC began adding imported formulas to the APL.

The mobile shopping application (WIC2Go) broadcast message was updated to inform participants of the ongoing formula additions and referred them to the Temporary Shopping Guide, which was a pictorial guide informing participants what temporary formulas could be purchased based on the formula they were issued.

3^rd: The New York State WIC program opted in to Imported Infant Formula Under FDA enforcement discretion waiver.

6^th: USDA FNS implemented ABFA provisions via a letter to WIC state agencies (USDA, 2022h).

9^th: The New York State WIC program temporarily added larger sizes of Nutramigen powdered formula to the New York State WIC Formulary under the MMAs for Food Package III waiver.

Additional store brand alternatives to Enfamil Infant, Enfamil AR, Enfamil Gentlease, and Similac Soy Isomil were added. “Local Agency Memo 06/22 #26: Temporary Exempt Formula Larger Sizes and Additional Store Brands Walgreens, CVS and Target” was released to share this update with LAs and “Vendor Bulletin #13: Temporary Redemption of Formula Larger Sizes and Additional Store Brands—No Action Required” was distributed to WIC authorized vendors.

USDA denied medical documentation waiver Request: waive the medical documentation requirement to provide maximum flexibility for WIC clinic staff to ensure that participants have access to the necessary formula requested on May 24, 2022.

16^th: The New York State WIC program released “Vendor Bulletin #14: Temporary Redemption of Contract Formula Larger Sizes and Additional Brands—Week 3 Updates—No Action Required” to WIC authorized vendors.

17^th: The New York State WIC program added additional larger sizes and store-brand alternatives to Enfamil Infant, Enfamil AR, Enfamil Gentlease, Enfamil Reguline, and

Similac Soy Isomil to the New York State WIC Formulary. “Local Agency Memo 06/22 #29: Temporary Contract Formula Larger Sizes and Additional Brands Week 3 Updates” was released to communicate this update to LAs.

22^nd: USDA FNS provides a WIC Infant Formula Distribution Toolkit for state agencies and stakeholders. It includes a list of state agencies authorizing imported formula, relevant USDA and FDA guidance, charts of the top retailers, and maps indicating the prevalence of retailers across each region (USDA, 2022i).

23^rd: The New York State WIC program added additional larger sizes of Mead Johnson contract formulas and exempt formulas to New York State WIC Formulary.

Imported alternatives and additional store-brand alternatives to Mead Johnson contract formulas were also added. “Local Agency Memo 06/22 #31: Temporary Formula Larger Sizes and Additional Brands—Week 4 Updates” was released to communicate this update to LAs and “Vendor Bulletin #15: Temporary Redemption of Contract Formula Larger Sizes and Additional Brands “Week 4 Updates—No Action Required” was distributed to WIC authorized vendors.

19^th: USDA FNS extends flexibilities to allow formula imported under FDA’s enforcement discretion nationwide through November 30, 2022 (USDA, 2022j).

23^rd: USDA FNS extends most WIC waivers through December 31, 2022, to address the nationwide infant formula shortage under authority from the ABFA, previously under Stafford Act authority (USDA, 2022k).

9^th: Texas WIC updated Policy FD:19.0 with approval from USDA and in consultation with the Department of State Health Services to allow LAs, at their discretion, to reissue unopened containers of returned formula that had not been impacted by a recall to WIC participants during events that impact access to formula, such as natural disasters and supply chain disruptions (Texas WIC, 2022b).

10^th: Lyons Magnus expanded recall to include additional batches and formulations of Kate Farms products.

• Texas WIC: Updated website, notified WIC local agency directors by e-mail, and sent text messages notifying WIC clients issued recalled formula.

19^th: USDA FNS extends flexibilities to allow formula imported under FDA’s enforcement discretion nationwide through November 30, 2022 (USDA, 2022j).

23^rd: USDA FNS extends most WIC waivers through December 31, 2022, to address the nationwide infant formula shortage under authority from the ABFA, previously under Stafford Act authority (USDA, 2022k).

28^th: Abbott extended rebates of non-contract formulas through October 31, 2022.

29^th: CT WIC updated list to reflect new end date, updated website, shared update with LAs, participants, and authorized vendors

19^th: USDA FNS extends flexibilities to allow formula imported under FDA’s enforcement discretion nationwide through November 30, 2022 (USDA, 2022j).

23^rd: USDA FNS extends most WIC waivers through December 31, 2022, to address the nationwide infant formula shortage under authority from the ABFA, previously under Stafford Act authority (USDA, 2022k).

20^th: Texas WIC announced extension of authorization of non-contract alternative-brand formulas through September 2022 to the public. Updated public and health care provider websites and WIC app.

22^nd: E-mailed health care partner organizations.

24^th and 30^th: Sent text messages notifying WIC clients.

26^th: The New York State WIC program consulted with milk-based contract formula manufacturer to confirm support of the execution and extension of all USDA waivers to align with the expiration dates released by USDA FNS on August 23, 2022.

30^th: “Vendor Bulletin #17: Temporary Redemption of Formula” distributed to authorized WIC vendors announcing the addition of exempt formulas to the New York State Formulary.

14^th: Abbott announced a voluntary recall of certain lots of 2 fl oz/59 mL bottles of RTF liquid products for infants and children, including the brands Similac Pro-Total Comfort, Similac 360 Total Care, Similac 360 Total Care Sensitive, Similac Special Care 24, Similac Stage 1, Similac NeoSure, Similac Water (Sterilized), and Pedialyte Electrolyte Solution.

Abbott extended rebates of non-contract competitor products through December 31, 2022.

19^th: CT WIC updated list to reflect new end date, updated website, shared update with LAs, participants, and authorized vendors.

13^th: Correspondence received—FNS approved the use of WIC food funds for non-contract formula redeemed prior to December 31, 2022, as long as appropriate agreement in place.

1^st: Texas WIC transitioned the cost-containment contract for infant milk-based formula to Reckitt/Mead Johnson. The primary formula issued to client’s shopping list changes to Mead Johnson products, Enfamil Infant, Gentlease, AR, or Reguline.

However, with continued supply challenges nationwide and extension of federal waivers, Texas WIC continued to offer a variety of non-contract options, including alternative can sizes, at the point of redemption, as communicated on September 26.

8^th and 9^th: Posted on HHSC social media information regarding contract change and availability of alternatives.

18^th: The New York State WIC program released “Local Agency Memo 10/22 #51—Nutramigen Concentrate Supply Interruption” to notify LAs of Mead Johnson’s decision to prioritize manufacturing other products over Nutramigen Concentrate, resulting in limited supply.

17^th: Based on continued evidence of inadequate supply of contract formulas, Texas WIC announced extension of authorization of non-contract alternative-brand formulas through November 2022 and activated communication plan. Notified LA WIC staff.

18^th: Updated public and health care provider websites and WIC app and notified WIC-approved vendors.

25^th and 26^th: Sent text messages to client.

16^th: Abbott added products available for rebate to assist with shortages and extended rebates for non-contract and competitor formulas:

• For non-contract competitor formulas, through February 28, 2023.
• For Similac non-contract formulas and sizes, through April 30, 2023.

19^th: USDA FNS discusses unwinding and impacts of the infant formula shortage in a letter to WIC state agencies.

End of 2022 – Gerber sold formula line to Perrigo.

5^th: Posted on HHSC social media.

15^th: Based on continued evidence of inadequate supply of contract formulas, Texas WIC announced extension of authorization of alternative-brand formulas through January 2023 and activated communication plan. Notified LA WIC staff.

19^th: USDA FNS discusses unwinding and impacts of the infant formula shortage in a letter to WIC state agencies (USDA, 2022n). This guidance extended waiver authority for standard formulas to correspond with Abbott rebate extension dates announced on December 16, 2022, and extended two waivers related to special/exempt formulas through June 30, 2023:

• Imported infant formula under FDA’s Infant Formula enforcement discretion
• Issuance of certain imported specialty formulas only
• MMA for Food Package III—Infant Formula

23^rd: CT WIC provided guidance to LAs about the extended rebate and waiver authority dates.

16^th: Updated public and health care provider websites and WIC app and notified WIC-approved vendors.

19^th: USDA FNS announced plans for unwinding of formula flexibilities in a letter to WIC state agencies (USDA, 2022n). Waiver authority to provide non-contract alternative formulas would end February 28, 2023, along with a state’s authority to use federal food funds to pay for alternatives.

28^th and 29^th: Sent text messages to clients.

23^rd-28^th: CT WIC updated end dates on all products according to waiver/rebate extensions, updated substitutions lists, published updates to the website, and started participant communication messages.

28^th: CT WIC sent updated substitutes list with extension of rebate dates to authorized vendors.

1^st: USDA FNS publishes the “Unwinding of Infant Formula Flexibilities” in WIC policy memo to match the Abbott infant formula recall waiver expiration schedule (USDA, 2023a).

6^th: CT WIC issued guidance and information to LAs, authorized vendors, and participants about infant formula transition and the end of non-contract competitor formulas effective February 28, 2023.

7^th: CT WIC attended USDA briefing webinar on “Unwinding of Infant Formula Flexibilities” in WIC policy memo.

9^th: CT WIC added Alimentum RTF 8-oz six-packs to increase availability considering shortages. Issued LA notification and guidance.

1^st: USDA FNS publishes the Unwinding of Infant Formula Flexibilities in WIC policy memo, which provided updates to the Abbott infant formula recall waiver expiration schedule published on November 8 (USDA, 2023a).

14^th: NC requested an extension of waiver for non-contract formulas and documented ongoing supply shortages.

19^th: Reckitt/Mead Johnson issued a voluntary recall of certain batches of ProSobee Simply Plant Based Infant Formula.

1^st: USDA FNS published the “Unwinding of Infant Formula Flexibilities” in WIC policy memo, which provided updates to the Abbott Laboratories infant formula recall waiver expiration schedule published on November 8 (USDA, 2023a).

4^th-6^th: Posted on HHSC social media.

16^th: Texas HHSC communicated with both Mead Johnson and USDA about inadequate supply of contract formula.

17^th: USDA FNS provided a process for states to request an extension of federal waivers on a case-by-case basis.

1^st: USDA FNS publishes the “Unwinding of Infant Formula Flexibilities” in WIC policy memo, which provided updates to the Abbott infant formula recall waiver expiration schedule published on November 8 (USDA, 2023a).

24^th: The New York State WIC program consulted with milk-based contract formula manufacturer to confirm support of New York applying for an extension to the USDA waiver of medical documentation for Food Packages I and II.

27^th: The New York State WIC program requested a 2-month extension of the waivers for medical documentation for Food Packages I and II and Imported Infant Formula under USDA FNS enforcement discretion.

15^th: CT WIC staff met to review infant formula transition and discuss prep for February 28, 2023 change to APL (removal of all non-contract competitor products).

16^th-17^th: CT WIC distributed information to key stakeholders (state agency and nonprofit partners, CT Chapter of the American Academy of Pediatrics, etc.) about the transition to normal formula operations.

21^st-22^nd: FNS NERO notified states of Mead Johnson Voluntary Recall of Prosobee 12.9-oz Infant Formula. CT WIC issued information and guidance to LAs, updated website with information for participants, and posted notice on WIC Shopper App.

19^th: Reckitt/Mead Johnson issued a voluntary recall of certain batches of ProSobee Simply Plant Based Infant Formula.

• Although Texas WIC’s soy-contract was with Abbott Laboratories, this still was potentially impactful to Texas WIC clients because redemption of non-contract alternative brands was still in effect. Therefore, Texas WIC initiated communication plans for this recall.

20^th: Notified LA WIC staff, WIC-approved vendors, and added information for clients and health partners on TexasWIC.org.

21^st: Sent text messages to all clients issued soy-based formula and e-mailed health care partner organizations.

27^th to March 1^st: USDA FNS approved Texas WIC’s request to extend waiver flexibility through March 31, 2023, for 7 CFR § 246.10(d)(1)(i), which requires medical documentation for the issuance of non-contract-brand infant formula.

• Texas WIC notified Mead Johnson of the plan to continue offering non-contract alternative formulas and

28^th: USDA (FNS) approved New York State WIC’s request to extend the waiver for medical documentation for Food Packages I and II and Imported Infant Formula until April 30, 2023. New York State WIC’s request to extend the waiver for imported infant formula was denied by USDA FNS. USDA FNS further required New York WIC to develop and implement a plan for transitioning to normal operations beginning May 1, 2023. Informational e-mail: “Revisions to New York State WIC Formulary” was distributed to LAs to notify them of these decisions.

27^th: Abbott requested that NEATO states share messaging on formula unwinding. CT WIC provided the information to Abbott as requested.

28^th: Initial flexibilities end (waiver and rebates for non-contract competitor products). CT WIC staff ensure initial transition is complete and all products are removed from APL.

invoice for rebates on these products.

• Texas WIC set all formulas imported as part of FDA enforcement discretion to end-date in the APL effective February 28, consistent with expiration of the waivers related to imported formulas.
• Texas WIC planned to continue offering a variety of larger can sizes despite the expiration of the waiver for MMA because it used the rounding-up method described in Table 1, footnote 8 of 7 CFR § 246.10(e)(9). Texas WIC’s formula food packages were established for the contract-brand formula to comply with MMA. Any alternative brands that exceeded MMA within each food package were removed, effective February 28, 2023.

• Texas WIC announced extension of authorization of a modified list of alternative-brand formulas through March 2023. Notified LA WIC staff and updated public and health care provider websites and WIC app. Notified WIC-approved vendors. E-mailed health care partner organizations, sent text messages to clients, and posted on HHSC social media.

24^th: Based on continued evidence of inadequate supply of contract formulas in Texas, USDA FNS approved Texas WIC’s request to extend the waiver for 7 CFR § 246.10(d)(1)(i) for Food Packages I and II, which requires medical documentation for the issuance of noncontract-brand infant formula, through May 31, 2023.

• Texas WIC announced extension of authorization of a modified list of alternative-brand formulas through May 2023.

14^th: New York State WIC consulted with contracted milk-based formula manufacturer and confirmed support to request a 2-month extension of the waivers for medical documentation for Food Packages I and II and MMA for Food Packages I and II.

25^th: Updated public and health care provider websites and WIC app notified LA WIC directors and WIC-approved vendors, and sent text messages to clients.

30^th: E-mailed health care partner organizations.

20^th: The New York State WIC program requested a 2-month extension of the USDA FNS waivers for medical documentation for Food Packages I & II and MMA for Food Packages I and II to maximize access to contract formulas and comparable alternative products.

27^th: USDA FNS approved the New York State WIC program’s request to extend medical documentation for Food Packages I and II waiver until May 31, 2023 (1 month extension) and MMA for Food Packages I and II waiver until June 30, 2023.

28^th: “Local Agency Memo 04/23 #20: Infant Formula Waiver Update” released, notifying LAs that New York State WIC’s request to extend the medical documentation for Food Packages I and II and MMA for Food Packages I and II waivers were extended to May 31, 2023, and June 30, 2023, respectively. The program released “Vendor Bulletin #8: Discontinuation of Some Temporary Formulas” distributed. The bulletin notified vendors that currently approved alternative formulas would remain on the APL through May 31, 2023 and alternative can sizes of contract formula would remain through June 30, 2023.

9^th: CT WIC received Freedom of Information inquiry for all documents related to infant formula system. Referred inquirer to Massachusetts website on procurement and to the contract lead for followup if needed (MA is lead NEATO state).

14^th: USDA FNS provides information to WIC state agencies on infant formula flexibilities for Food Package III (USDA, 2023b).

30^th: Final waiver authority ends for infant formula flexibilities.

14^th: USDA FNS provides information to WIC State agencies on infant formula flexibilities for Food Package III (USDA, 2023b).

30^th: Infant formula waivers expired that allowed for non-contract-brand formulas and the MMA to be exceeded.

1^st: The New York State WIC program removed all of the store-brand formulas from the New York State WIC Formulary due to the medical documentation for Food Packages I and II waiver expiration. A WIC2Go broadcast message was added to notify participants of the formulas being removed.

10^th: “Vendor Bulletin #11: Discontinuation of Temporary Formulas” was distributed, notifying vendors of the list of temporary formulas that would be removed from the APL on July 1.

14^th: USDA FNS provides information to WIC state agencies on infant formula flexibilities for Food Package III (USDA, 2023b).

16^th: “Local Agency Memo 06/23 #29 Formula Updates Summer 2023” distributed to LAs. This memo notified LAs that some temporary hypoallergenic formulas would remain on the New York State WIC Formulary and reminded them that alternative container sizes would no longer be available July 1, 2023.

30^th: The New York State WIC program removed all temporary alternative formulas from New York State WIC Formulary due to expiration of waivers for MMA for Food Packages I, II, and III. A mobile shopping application (WIC2Go) broadcast message was added to notify participants of the formulas being removed.

8^th: USDA FNS provides technical assistance on the Requirements and Best Practices for Oversight of the Infant Formula Suppliers List in the WIC program (USDA, 2023c).

USDA FNS issues guidance on the oversight of infant formula purchase requirements in WIC, which discusses stolen infant formula which may be offered for resale to online platforms, warehouses, and retail stores and related WIC regulations (USDA, 2023d).

8^th: USDA FNS provides technical assistance on the Requirements and Best Practices for Oversight of the Infant Formula Suppliers List in the WIC program (USDA, 2023c). USDA FNS issues guidance on the oversight of infant formula purchase requirements in WIC, which discusses stolen infant formula which may be offered for resale to online platforms, warehouses, and retail stores and related WIC regulations (USDA, 2023d).

21^st: USDA FNS updated the Federal Actions to Support Access to Infant Formula webpage, which provides information on FDA’s infant formula strategies and USDA’s response actions (USDA, 2024b).

21^st: USDA FNS updated the Federal Actions to Support Access to Infant Formula webpage, which provides information on FDA’s infant formula strategies and USDA’s response actions (USDA, 2024b).