P-EBT Guidance for Schools and Child Care

USDA is committed to providing nutrition assistance to hard-hit families across the country due to the coronavirus pandemic. On January 22, in support of President Biden’s call to action on hunger, USDA announced that it is increasing the Pandemic-EBT (P-EBT) benefit by approximately 15 percent, providing more money for low-income families and millions of children missing meals due to school and child care closures.

In addition, the Consolidated Appropriations Act, 2021 (PL 116-260) amended section 1101 of the Families First Coronavirus Response Act (PL 116-127), providing significant new flexibilities designed to ease the administration of P-EBT for states and territories. The Act makes changes to P-EBT for school children as well as children in child care.

This memo provides a high level summary of P-EBT that reflects these flexibilities and other changes. Accordingly, this memo supersedes USDA’s Nov. 16, 2020 memo.

USDA has also prepared a new P-EBT state plan template and a new set of Q&As. Both documents are available on USDA’s P-EBT website. These outline the standards that USDA will use in the review and approval of state plans. The Q&As provide answers to common questions and illustrate how states may apply the latest flexibilities in the development of their plans. USDA understands that states will propose alternative approaches, and USDA will consider those, in the context of statutory requirements. USDA asks that states review the latest documents on the P-EBT website and direct questions to their USDA-FNS regional offices.

P-EBT Benefit Levels
In accordance with the President’s Executive Order on Economic Relief Related to theCOVID-19 Pandemic, USDA has determined that the value of P-EBT benefits should be increased. The daily P-EBT benefit, for both school children and children in childcare, now includes the value of the USDA free reimbursement for an afterschool snack. The new, higher benefit is retroactive back to the beginning of SY 2020-2021.

USDA strongly encourages states to issue supplemental benefits to any child who has already received a P-EBT benefit under an approved SY 2020-2021 plan. For states in the contiguous U.S. the daily rate is now $6.82. The Q&As provide the full set of rates for Alaska, Hawaii, and U.S. territories.

Simplifying Assumptions and Best Feasibly Available Data
States may develop and use simplifying assumptions and use the best feasibly available data to identify eligible children, determine the operating status of schools and child care facilities, and establish state or regionally based benefit levels. The availability of simplifying assumptions and use of the best feasibly available data provided by the statute allows states and USDA to limit excessive administrative burden and cost and facilitate the delivery of P-EBT benefits to eligible children. USDA encourages states to make reasonable simplifying assumptions and offers examples in its latest Q&A document to help states achieve these complementary goals.

Eligibility:

P-EBT for Children in Schools
The basic P-EBT eligibility criteria for children in schools remains unchanged. Given that there is a Public Health Emergency designation in place, a school child is eligible for P-EBT benefits in school year 2020-2021 if the child meets the P-EBT conditions for eligibility:

1. The child would have received free or reduced price school meals under the NSLP and SBP if not for the COVID public health emergency; and
2. The child does not receive free or reduced-price meals at school because the school is closed or has been operating with reduced attendance or hours for at least 5 consecutive days in the current school year.

P-EBT for children in covered child care facilities
Given that there is a Public Health Emergency designation in place, a child is eligible for benefits under P-EBT’s child care component if three conditions are met:

1. The child is a member of a household that received SNAP benefits at any time since October 1, 2020,
2. The child is enrolled in a covered child care facility*, and
3. The facility is closed or is operating with reduced attendance or hours for at least 5 consecutive days, resulting in the child’s inability to attend the facility; or one or more schools in the area of the facility, or in the area of the child’s residence, is closed or is operating with reduced attendance or hours.

* Under the latest amendment to the FFCRA, USDA shall deem all children under the age of 6 to be enrolled in a covered child care facility. Accordingly, states may develop P-EBT plans that define a process for identifying and issuing benefits to all SNAP-recipient children under age 6 who live in the area of a closed school or a school operating at reduced attendance or hours, or whose child care facilities (if applicable)are closed or operating at reduced attendance or hours or are in the area of a school that meets those conditions. Note that P-EBT benefits for children in child care are only available back to Oct. 1, 2020, not the start of the current school year.

Administrative costs:
States may claim full reimbursement of necessary, allowable, and reasonable costs incurred in the development and execution of state P-EBT plans during federal fiscal year 2021 (Oct. 1, 2020, through Sept. 30, 2021). States may claim reimbursement for costs incurred by its SNAP agency, other state agencies that incur costs in the administration of P-EBT, and local agencies, including schools. USDA will work with states as they develop a Program and Budget Summary using the FNS-366a. All P-EBT Administrative grants will be provided in accordance with the applicable federal statutes, regulations, and terms and conditions of the Federal Award.

Additional information:
USDA recognizes that some states may be in a position to finalize and submit plans for school children before they are ready to submit plans for children in child care. USDA will review separate school and child care plans if that helps states deliver benefits to eligible children more quickly.

USDA looks forward to working with states in the coming weeks on their new and amended P-EBT plans.

Please be advised that the contents of this 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.

Attachments

• P-EBT Q&A – Jan. 29, 2021
• State Plan for Pandemic EBT - Children in School and Child Care, 2020-2021