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Text Messaging Questions and Answers
The following are clarifications based on paraphrased questions sent by Local Agencies to their State Consultants about the new state use question and obtaining text messaging consent.
On this page: Overview | Transition | State use question | Text messaging | Forms | Docusign
Overview
On Oct. 1, a new state use question, Text Message Release Documentation, started displaying on the Demographics page in WINNIE. This is a required field specific to obtaining permission for the WIC Program (all local agencies and the state office) to communicate with a household using text messages. This field was added to standardize the way all local agencies collect text message communication consent. It allows households to sign only one consent and can be used by the State WIC Office and other WIC local agencies should the household transfer.
We added this field at this time to coincide with the roll-out of the Group Text Messages in Mobile Management (PDF) feature accessed within Mobile Management. Unlike individual texting available in Mobile Management, where the mobile app user opts in on their phone, using the Group Text Messages feature requires a signed consent for communication.
A memo, New Text Messaging Documentation (PDF), providing information about this new requirement was sent in the Sept. 23 Weekly Update, as well as discussed on the Sept. 16 WIC Local Agency Conference Call (PDF) and during the July 27, 2026, Advisory Group Meeting (PDF).
A list of some things that agencies can do now was sent in an email on Wednesday, Sept. 30 and was also included in the October WINNIE the Scoop.
Transition
Q: This is a very short time to transition agency processes and/or update our ROI form. What should we do if we can’t get everything updated by Oct. 1?
A: If the system requires you to select an answer, you can select RESPONSE NEEDED until your agency’s processes are in place.
Q: We are wondering how best to present this new form to families? We already ask about preferred methods to receive appointment reminders (text, phone, email).
A: Explain this is an updated form to get consent for the entire WIC Program (not just your agency) to communicate by text, covers all members, and is good for the duration of their time participating in WIC.
Q: If we choose NOT to have participants sign the Consent for Communication and select “NO – DO NOT TEXT” for all participants, what types of messages would they miss from the State?
A: This is not optional. The new state use question does not only address allowing the State Office to text participants. It also provides texting consent for other WIC agencies (in case of transfer), covers all household members, and is good for the duration of the family’s participation in the WIC Program.
You should NOT select NO – DO NOT TEXT unless you have asked the participant/representative for texting consent and they have declined. The expectation is that ALL agencies will collect this information, and obtain signed consent as appropriate, for use by the entire MN WIC Program.
Q: We already use a local use question to collect whether a participant opts in for texting and our own agency communication preference/consent form. This new required state use question is collecting the same information, which is going to be confusing. How can we make this transition easier?
A: The new consent language is more comprehensive, and includes the entire WIC Program, not just your agency. You can continue to use your current practice for documenting texting consent, but it would have to be in addition to also documenting consent in the state use question.
Despite already collecting consent, you must also ask each household again for their consent using the new broader language provided in Exhibit 1-C-1a: Consent for Communication (PDF).
Q: Agencies that use One Call Now use the email field to specifically indicate that a reminder should be sent via email. Exhibit 1-C and Exhibit 1-C-1a include email as an option. How should the agency document the email preference in WINNIE?
A: Other communication methods were included in each form so that all options were in one place. We do not expect or require you to document all preferred methods in WINNIE. The primary purpose of the form is to obtain written consent for text messaging.
Q: We currently have a texting platform that uses an Infoview report to pull system information. This is automatically integrated into the texting platform from a spreadsheet. Can we continue to use this?
A: You can if you want to continue to collect texting consent as you do now and in the state use field. If you choose to just use the state use question, please submit a Local Agency Reports & Data Request form and we will prioritize updating your report to use state use answers instead.
State use question
Q: When will the system require us to answer the new state use question?
A: If an answer has not been selected yet (the field is blank) and you try to save a change to the Demographics page, you will have to answer the question. You can use RESPONSE NEEDED to bypass this requirement at this time if the participant/representative isn’t available to complete the consent form or give you a verbal consent.
Q: If I create a new household, do I need to complete the new state use question right away?
A: No. If you simply prescreen a new participant/family and schedule an appointment, WINNIE will not require you to select an answer.
Q: Can we issue benefits if the state use question hasn’t been answered?
A: Yes. The system will not stop you from issuing benefits if the question hasn’t been answered.
Q: Staff can enter this in WINNIE at any time, but will they remember to do it?
A: Since it is required, if the question is blank and a change is made to Demographics, you will be required to answer it. We will also be creating an Infoview report template to identify participants who have answers requiring follow-up, as well as identify participants who do not yet have an answer.
Q: If we get verbal consent, and document this in the new state use question, do we still need to complete the Consent for Communication form?
A: A verbal consent is temporary and requires further follow-up. You must still complete either the Consent for Communication or an updated Release of Information (ROI) (state-provided or your own) that has the appropriate required language. Once signed, you must change the answer to YES – Signed Consent Obtained.
Q: If we get verbal permission, how do we show what it’s for (i.e. phone but not text or email)?
A: The option, YES – Verbal Consent Obtained, is specific to text messaging. A signed consent is not needed for phone or email communication.
Q: When are we expected to answer the state use question and get signed consent?
A: Ideally, you will answer the question and obtain signed consent (if applicable) at the next in-person contact with the household.
Text messaging
Q: Does this mean all participants need a new texting release?
A: Yes. The texting consent must contain the updated language found in Exhibit 1-C-1a: Consent for Communication (PDF).
Q: What text message platforms are allowed?
A: There is no specific texting platform that must be used. It is the local agency’s responsibility to ensure that whichever platform you use, the participants’ data is kept private and local agency IT and legal requirements are followed. The Group Text Messages feature available for use through Mobile Management is using Twilio.
Q: Are we expected to use the new Group Text Messages feature in Mobile Management to continue our current texting practices?
A: You can continue using your current texting platform and processes, but you must also document consent in the state use field and obtain a signed consent if the answer is Yes. At this time, Group Text Messages available through Mobile Management is just another optional method for communicating with multiple participants at once.
Q: Agencies using One Call Now/OnSolve texting use the Telephone 2 and Comment 2 field to indicate a text should be sent. Which telephone field will be used for the Group Text Messages in Mobile Management? Will we have to change our current procedures?
A: You do NOT have to change your current texting procedures. If your agency chooses to use the Group Text Messaging feature in Mobile Management, you can decide which phone number to use based on the Infoview report you use to pull your data. (NOTE: Currently, there isn't an Infoview template that pulls answers from the new state use question. One should be available mid-October.)
Q: Can we text with participants before having a signed consent or completing the state use question?
A: Yes. If you are already collecting texting consent, you can continue with your current practices. The next time you have contact with the participant/applicant, you should complete the state use question and have the participant sign the Exhibit 1-C-1a: Consent for Communication (PDF) with the updated language. You can also get temporary verbal consent if unable to collect a signature.
Q: If we use Mobile Management, do we need to have them sign a consent to send custom messages through the app?
A: Custom messages are not the same as text messages. Custom messages can be used to send information to registered app users regardless of whether they’ve opted in for texting. Custom messages are sent directly to the messages section of the app.
Q: If a participant does not want to receive text messages from the WIC Program and we have selected NO – DO NOT TEXT in the State Use field, but has opted in to texting via their app, can we text them back using Mobile Management?
A: Yes. App users must first opt-in to text messaging via their app for you to be able to text them using Mobile Management. Opting in via their app is considered consent. However, it only provides consent to text one-on-one using Mobile Management; this consent does not extend to other texting platforms, nor does it extend to the Group Text Messages feature.
Q: Can we use the WIC cell phone to send text messages?
A: Yes. You can use an agency-issued phone to send text messages, but never a personal cell phone. You must also never save a participant’s name to the phone contact list and if an agency-issued iPhone, you must ensure iMessage are turned off. (See MOM policy Section 9.6: Electronic Communications Security (PDF).)
Q: Why isn’t the state’s texting platform secure?
A: Although the actual platforms used for texting are considered secure, texting, in and of itself, is not considered secure because the message can potentially be interrupted at any point during the electronic transmission. Also, phone numbers can be reassigned, which can result in privacy issues.
Forms
Q: The use of “Release of Information” on the new Consent for Communication form is confusing. Would it be acceptable to use the statement “Confirm the methods you agree to for exchanging information”?
“I give my consent to the WIC Program to release and exchange information…” must be included on your consent for communication. This covers the WIC Program sharing a participant’s phone number with text message service providers. If you are updating your current ROI, you must include this statement.
Q: What participant information does the new form, Exhibit 1-C-1a – Consent for Communication, allow to be shared/released?
A: Verbiage on this form covers release of the participant’s phone number to WIC Program texting service providers.
Q: What if our county won’t allow us to use the generic verbiage and NOT specify our agency on our consent form?
A: If this is absolutely not allowed, an option when revising your form would be to include your agency name and also specify all local agencies and the state office. (Ex: County Name and text service providers used by Local WIC Agencies and the State WIC Office). If agency will not allow you to add the required language to your agency form, you will need to complete both your agency form and the state-provided Exhibit 1-C-1a: Consent for Communication (PDF) form.
Q: Is the Consent for Communication just for Group Text Messages in Mobile Management and other state text messages?
A: No. Although it is necessary for both local agencies and the state to use the Group Text Messages feature in Mobile Management, the purpose of the Consent for Communication is not just limited to these uses. It can be used as consent for your current texting practices as well.
The new required language also provides consent for other MN WIC agencies (in case of transfer), encompasses all members of the household, and extends the approval for the duration of their WIC participation.
Q: Does every household need BOTH a signed ROI and a Consent for Communication form completed and scanned into each member’s chart?
A: No, you do NOT need to complete both forms. If consent to text is given, you must have the participant/representative sign either a Consent for Communication OR a ROI that contains the appropriate required language and answer the state use question by selecting YES – Signed Consent Obtained for each household member. The form must then be saved to each household member’s folder (scan/import then use Copy Document to save to other members’ folders).
If the participant/representative does NOT consent to text messaging, this only has to be documented in the state use question by selecting NO – DO NOT TEXT for each household member.
Q: We currently get consent for text messages on our ROI. Is this no longer valid? Do we need to complete a NEW ROI for all participants? Do we need to advise our staff to select “No, do not text” in all folders for now?
A: Your current ROI is no longer valid, and all households will need to sign a new ROI that has been updated with the appropriate required language (or you can use the updated state-provided ROI – Exhibit 1-C: Authorization for Release of Information (PDF)). NOTE: Revised agency ROIs must be sent to your State Consultant for review.
You should NOT select the “NO – DO NOT TEXT” option unless you’ve confirmed with the family that they do not want the WIC Program to text them. This option does not require any follow-up and if selected, you will not know which participants still need to be asked for consent.
Q: If we are using the state ROI, do we still need to get a local ROI redone? I don’t understand why we would need a new local ROI.
A: Participants will need to have the new language for communication consent on their ROI. Whether you use the state-provided ROI that has been updated with the new language OR update your agency ROI with the new required language, participants will have to have a new ROI.
Some agencies asked for a separate communication consent as an alternate option (Exhibit 1-C-1a: Consent for Communication (PDF)). You can choose to:
- Use the updated state-provided ROI with the new required communication consent language.
- Keep the communication consent on your ROI and update the language as required (must be sent to your State Consultant for review before using).
- Collect the communication consent separately.
Q: What MUST we include if we choose to add communication consent to our agency ROI?
A: All the verbiage found on Exhibit 1-C-1a: Consent for Communication (PDF) must be included. The only optional content is whether you include Phone Call, Voice Message, and Email options.
NOTE: Revised agency ROIs must be sent to your State Consultant for review.
Q: Can a proxy sign the Consent for Communication form, or should it only be the parent/guardian or participant?
A: The form can be signed by anyone with rights to represent the household. This would include the participant, authorized representative, and alternate representatives.
Q: Can we help fill in the date and printed name if they aren’t completed when the form is signed?
A: Yes. The participant must sign the form and initial their communication preferences, but you can complete all other fields.
Q: Can the participant/representative indicate communication preferences with an “x” or check mark?
A: No. The participant/representative should write their initials next to their communication preferences.
Q: Do we have to write the email address on the ROI or Consent for Communication form if it’s already in WINNIE?
A: No. There are no requirements for documenting email addresses in writing or in the system.
Q: We already have consent to communicate in our ROI, and all participants should already have one scanned into their folders. All we need to do is select the correct option from the new state use question?
A: No. Previous consent cannot be used to meet this new requirement. Do not simply transfer the family's previous texting choice into the new state use question. All families will need to sign a new ROI that has been updated with the appropriate required language for consent to communicate. Whether they initial text messaging services or not must be documented in the new state use question.
If you do not want to collect new ROIs for participants or update the language you MUST then use the new Exhibit 1-C-1a: Consent for Communication (PDF) in addition to your ROI for all participants who consent to text messaging.
Q: Can we just use the Consent for Communication form for contacting participants by phone, VM, email, and text messages and if needed, complete the ROI for communication with other programs?
A: Yes. You can use Exhibit 1-C-1a: Consent for Communication (PDF) to document communication preferences if you do not need a ROI for any other reason. However, you only have to complete the form if they consent to text messages.
Q: If an agency uses a ROI with a consent to communicate and a participant transfers to another agency, can the other agency use the specific program referrals indicated in the ROI?
A: No. Program specific referral information is not transferrable between agencies. However, the consent for communication with the new appropriate required language is transferrable.
DocuSign
The revised Exhibit 1-C: Authorization for Release of Information (PDF) in English and Spanish and the new Exhibit 1-C-1a: Consent for Communication (PDF) in English, Spanish, and Somali have been added to DocuSign. For agencies using their own ROI, after your State Consultant has reviewed your revisions, please contact Blair Haesly (Blair.Haesly@state.mn.us) or Jamie Cooley (Jamie.Cooley@state.mn.us) if you would like it added to DocuSign.