The Families First Coronavirus Response Act of 2020 (FFCRA, PL 116-127), enacted March 18, 2020, included a general provision that allows the Department of Agriculture to approve state plans to provide temporary emergency Supplemental Nutrition Assistance Program (SNAP) assistance to households with children who would otherwise receive free or reduced-price meals if not for their schools being closed due to the COVID-19 emergency (also known as Pandemic EBT, or P-EBT). The authority for P-EBT under FFCRA expired on Sept. 30, 2020. The Continuing Appropriations Act 2021 and Other Extensions Act (PL 116-159), enacted Oct. 1, 2020 extended the authority for P-EBT through Sept. 30, 2021. This legislation also expanded the program to include child care facilities affected by the closures and schools with reduced attendance hours. The Consolidated Appropriations Act 2021 (PL 116-260), enacted Dec. 27, 2020, provided additional eligibility requirements and state flexibilities for both school and child care components of this program. The American Rescue Plan Act of 2021 (ARPA, PL 117-2) enacted on March 11 made several significant changes to P-EBT. Among these changes is the extension of P-EBT to the summer of 2021, school year 2021-2022, and summer 2022.
Per PL 116-159, and in order to operate P-EBT for Federal Fiscal Year 2021 and summer 2021, each state must submit a state plan to FNS regional office for approval. Once approved, in addition to administering P-EBT, each state SNAP agency will also be required to provide monthly reports via the FNS-292B (Disaster Relief) to the FNS regional office, regarding the number of eligible children receiving P-EBT benefits, number of households receiving such benefits, and the total value of the benefits. The state is expected to provide data that:
- Differentiates between non-SNAP and current SNAP households receiving P-EBT,
- within SNAP households, differentiate between base SNAP benefits and P-EBT benefits.
Each state is also expected to separately identify P-EBT participation and benefit issuance on the FNS-388 (State Issuance and Participation Estimates) and FNS-46 (Issuance Reconciliation Report) reports. There is no additional burden associated with this requirement, as the states already report participation data to FNS on the FNS-388 and FNS-46 on a monthly basis.
FNS will provide funding to each state's SNAP state agency for 100% of P-EBT-related administrative costs. Such funding will be available for the necessary, allowable, and reasonable state agency costs associated with the administration of P-EBT incurred during FY 2021. This includes administrative costs associated with the issuance of retroactive FY 2020 benefits incurred in FY 2021. States interested in the 100% funding will be expected to submit a P-EBT administrative cost plan for the intended period of operations for USDA approval using the FNS-366A (Program and Budget Summary Statement: Budget Projection). During the period of performance of the 100% funding, the SNAP state agency will be expected to aggregate obligation and outlay data from all state agencies utilizing the 100% funding and report quarterly to USDA using a P-EBT specific instance of the SF-425 (Federal Financial Report).
The current burden for a state agency to submit FNS-292B, FNS-388, FNS-46, FNS-366A and SF-425 reports is currently captured under the information collection for the Food Programs Reporting System (FPRS), OMB Control Number 0584-0594 (expiration date 7/31/23). The Food Programs Reporting System is the federal system state agencies use to report FNS program data to FNS. Therefore, this information collection estimates burden hours associated with P-EBT that are above the currently approved hours in 0584-0594 for forms FNS-292B, FNS-366A, and SF-425 for normal program operations.
In order to determine eligibility and benefit levels for P-EBT, state agencies must collect data from schools. To administer P-EBT during the school year, schools must provide the state with predominant learning model (fully virtual, hybrid, or fully in-person) used by the school for each month of the school year. States generally are collecting this information every couple of months during the school year. This information is used to determine the benefit levels children are eligible to receive. Schools that operated predominantly fully virtual or hybrid learning models must also provide a list of students that have been determined eligible for free and reduced price meals. States use these two pieces of information reported by the school to issue benefits to eligible households. Per PL 117-2, during the summer months all children eligible for free or reduced price meals that are enrolled in schools that participate in the National School Lunch Program are considered eligible for P-EBT. This requires all schools to provide the state agency with a list of children who have been determined eligible for free and reduced price meals.
FNS will provide funding to each state's SNAP state agency for 100% of P-EBT-related school level administrative costs. Such funding will be available for the necessary, allowable, and reasonable state agency costs associated with the administration of P-EBT incurred during FY 2021. In order to receive this funding, schools must report to their state agency on the school level costs incurred to administer P-EBT.
Eligibility and benefit levels for the child care portion of P-EBT are determined without needing to collect additional information. State agencies use SNAP enrollment status data to determine eligibility and school learning model data they are already collecting to administer the schools component of P-EBT to determine benefit levels.
This submission seeks OMB approval of this revision to an existing collection (OMB Control # 0584-0660, expiration 8/31/2021) for activities associated with administering P-EBT.