Summer EBT Questions & Answers

The Consolidated Appropriations Act, 2023 (PL 117-328), established the permanent Summer EBT program beginning in summer 2024. We are aware that states and Indian Tribal Organizations (ITOs) are beginning to plan for Summer EBT and need certain information before the rule is published.

These Q&As provide additional information on program administration, eligibility, certification, verification, and EBT benefits. They expand upon previously released Summer EBT guidance and answer the most frequently asked questions of the Summer EBT program.

Program Administration

1. If a state or ITO submits a Notice of Intent but ends up being unable to implement in 2024, will there be any penalties or consequences?
2. If a state or ITO chooses not to operate Summer EBT in 2024, could they decide to operate the Program in future years?
3. [NEW!] If a state elects to forgo the opportunity to participate in Summer EBT can a school, community, or unit of local government within that state implement the program on their own?
4. Do states need to submit a management plan that covers Summer EBT and the SFSP?
5. Which agency is responsible for the Summer EBT Plan for Operations and Management (POM)?
6. [NEW!] What is the role of the coordinating agency?
7. How will Summer EBT operate in the territories?
8. Will eligible children in an ITO’s jurisdiction automatically be enrolled in the ITO’s Summer EBT Program?
9. What is the summer operational period?
10. Will there be appeals, fair hearings and/or overclaim procedures for Summer EBT?
11. How will FNS review state and ITO Summer EBT programs?
12. [NEW!] What should Summer EBT agencies do if schools and/or other agencies refuse to cooperate with Summer EBT implementation?
13. [NEW!] Are the POMs that states submit by February 15 binding documents? What if changes occur after the initial submission?

Eligibility and Certification

14. If a state or ITO opts to administer Summer EBT, do they have to serve all eligible children?
15. Are children who are not enrolled in NSLP/SBP schools eligible for Summer EBT?
16. Who can establish eligibility for Summer EBT with an application?
17. What is the age range for Summer EBT eligibility?
18. [NEW!] What does school-aged mean for Summer EBT?
19. [NEW!] Can children enrolled at NSLP/SBP schools who are older or younger than the age of compulsory school attendance participate in Summer EBT?
20. [NEW!] Can states and ITOs set an age threshold for streamlined certification of non-NSLP children that includes children older and/or younger than the state or ITO’s age of compulsory school attendance?
21. Will all children who attend special provision schools be automatically enrolled in Summer EBT (i.e., be issued benefits without the need to apply)?
22. Do Summer EBT agencies need to confirm that children on Summer EBT applications are enrolled in NSLP/SBP schools?
23. [NEW!] When should children on Summer EBT applications be checked against the NSLP-enrollment database in order to confirm eligibility?
24. Do children in special provision schools need current individual eligibility determinations to be eligible for Summer EBT?
25. What does it mean to have a statewide application requirement?
26. Can the Summer EBT application be used to establish eligibility for NSLP/SBP?
27. Can the NSLP/SBP meal application be used to establish eligibility for Summer EBT?
28. Does the Summer EBT application need to ask for the last four digits of a Social Security Number (SSN)?
29. [NEW!] Can applications that are collected and processed at the state or ITO level be used for both Summer EBT and NSLP/SBP?
30. Can Summer EBT agencies delegate the collection and processing of Summer EBT applications to Local Educational Agencies (LEAs)?
31. If LEAs collect and process applications that are used for Summer EBT eligibility and they participate in CEP, are they violating CEP program regulations?
32. [REVISED!] What are “alternative income applications” and can they be used to establish eligibility for Summer EBT?
33. How long do Summer EBT agencies need to accept applications? Can there be a submission deadline/cutoff?
34. [NEW!] What happens when USDA updates the income eligibility guidelines (IEGs) on July 1st? Must Summer EBT agencies change their Summer EBT applications mid-summer?
35. Are Summer EBT agencies permitted to use an online or mobile application, and can electronic signatures be accepted?
36. Do households need to provide documentation of eligibility at the time of application in order to be certified for Summer EBT benefits?
37. Is verification required for all Summer EBT applications?
38. [NEW!] What is the difference between a Summer EBT application, an NSLP/SBP application and an alternative income form. What program(s) can each be used for, and what are the verification requirements associated with each?
39. What is verification for cause?
40. Can the Summer EBT agency provide Summer EBT benefits to all children in CEP schools or only to directly certified children in CEP schools in the first years of program implementation?
41. What programs can be used to automatically enroll eligible children in Summer EBT through streamlined certification without matching against school enrollment?
42. [NEW!] Is a child who is enrolled in a Head Start program that participates in the NSLP and/or SBP eligible for Summer EBT?
43. For children who are not enrolled in NSLP/SBP-participating schools, but can be streamline certified through participation in SNAP, TANF, FDPIR, or Medicaid (as applicable), what is the timing of program participation to be eligible for Summer EBT?
44. If a state Child Nutrition Agency uses Medicaid to directly certify children for free or reduced price school meals, can Medicaid also be used to establish Summer EBT eligibility?
45. In states that have established their own higher income thresholds for eligibility for free school meals, will all students who receive free meals qualify for Summer EBT? For example, a state where students below 200% of the federal poverty guidelines are provided meals at no charge.
46. Are children who attend year-round schools eligible for Summer EBT if they meet all other eligibility requirements?
47. [NEW!] Can an eligible child participate in Summer EBT and another FNS program at the same time?
48. [NEW!] Is there any federal guidance on how to determine the head of household or address custody disputes?
49. [NEW!] Can a household request reconsideration if a child was not streamlined certified or was determined ineligible through a Summer EBT application?
50. [NEW!] Are all children in the household eligible for Summer EBT? For instance, an income-eligible household submits an application with two children; one is enrolled in an NSLP-participating school, and one attends a private pre-school that does not participate in the NSLP/SBP. Is the pre-schooler eligible for Summer EBT?
51. [NEW!] Are children eligible for Summer EBT benefits if the household applies for a program that is used for streamlined certification (e.g., SNAP) before the end of the summer operational period, but that application is not certified by the program agency until after the summer operational period ends?

EBT Benefits

52. Will Summer EBT agencies be allowed to load Summer EBT benefits on EBT cards used in other programs? Can Summer EBT agencies decide to issue one card per household or a card for each eligible child?
53. If Summer EBT benefits are co-loaded with SNAP benefits, should Summer EBT benefits be used before SNAP benefits?
54. [NEW!] How is opt-out supposed to be operationalized for SNAP households whose Summer EBT benefits are loaded onto SNAP cards?
55. When should states and ITOs issue benefits?
56. [NEW!] What is the summer operational period and what does it mean for when Summer EBT benefits can be issued and used?
57. [NEW!] How can Summer EBT agencies ensure that benefits will be available to spend between 7 and 14 days before the start of the summer operational period?
58. If a state or ITO is not able to issue benefits during the summer operational period in 2024, can the state or ITO still operate the program in 2024?
59. How many months of benefits can be provided each year?
60. When must Summer EBT benefits be expunged?
61. [NEW!] Do Summer EBT agencies have to ‘reset’ the expungement timeline for benefits that are not received by the eligible household before the benefit issuance date?
62. Will Summer EBT agencies be required to follow the Advance Planning Document (APD) process used in SNAP and WIC?
63. [Revised] Can Summer EBT agencies replace benefits that were lost as a result of a disaster?
64. [Removed]
65. Will the $40 monthly benefit be adjusted annually with inflation?
66. What foods can participants buy with Summer EBT benefits, and where can they buy them?
67. Will FNS assist Summer EBT agencies to negotiate modifications to their EBT service contracts?
68. Will FNS provide cost estimates to assist states and ITOs in developing budget requests for EBT development costs?
69. Do states and ITOs need to offer a process for families to decline benefits?
70. What are the requirements for Summer EBT retailers or vendors?
71. Can the Summer EBT agency hire contractors to administer parts of the Summer EBT Program?
72. Will Summer EBT funds go through the Account Management Agent (AMA)?
73. Which ITOs can administer Summer EBT?
74. Can an ITO administer Summer EBT if their geographic state doesn’t administer the program?
75. What vendors are eligible to accept Summer EBT benefit issues by an ITO?
76. What types of food instruments may ITO Summer EBT agencies offer?
77. Can ITO Summer EBT agencies provide the same foods that are authorized in their WIC programs?
78. If ITO Summer EBT agencies use a cash-value benefit (CVB) model, will they be limited to only providing fruits and vegetables like WIC?
79. What is the benefit level for ITO-administered Summer EBT programs?

Financial Management

80. Will there be new administrative funds reporting requirements for Summer EBT?
81. [NEW!] What is required to receive an initial allocation of funds in FY 2024?
82. [NEW!] Which activities do Summer EBT agencies need to reimburse Local Education Agencies (or LEA) for/not? Specifically, if a school collects alternative income applications regardless of Summer EBT, is it necessary to compensate schools for doing so?
83. [NEW!] Are Child Nutrition Technology Innovation Grants (TIG) permitted to be used for Summer EBT technology needs?
84. [NEW!] When Summer EBT administrative funds are sub-awarded to Local Education Agencies (LEAs), how should LEAs track and document these funds in their accounting system?
85. [NEW!] What are the matching requirements with respect to Summer EBT?
86. [NEW!] How can states and ITOs meet the matching requirement?
87. [NEW!] What is third party in-kind matching and is it allowed?
88. [NEW!] Can third-party donations of cash be accepted as the non-federal match?
89. [NEW!] How do I valuate in-kind costs to meet the match?
90. [NEW!] Are volunteer services allowable expenses for reimbursement purposes?
91. [NEW!] Can federal funding from other sources be used to meet the match?
92. [NEW!] Can a state or ITO meet the matching requirement with costs that would normally not be considered allowable?
93. [NEW!] Are the administrative costs incurred by WIC-administering ITO that are associated with implementing and operating Summer EBT considered allowable WIC costs?
94. [NEW!] Can WIC Nutrition Services and Administration (NSA) or Operational Adjustment (OA) Funding be used to support Summer EBT implementation?
95. [NEW!] Can the same staff work on WIC, SNAP, or child nutrition programs and Summer EBT programs?
96. [NEW!] Are Summer EBT administrative funds provided under a “reimbursement” model or “match” model?
97. [NEW!] Does the Summer EBT agency have to front 100 percent of Summer EBT costs with non-federal funds in order to get the 50 percent SEBT federal share?  
98. [NEW!] Do Summer EBT agencies have to meet the match on an expense by expense or category by category basis on the FNS-366A?
99. [NEW!] What documentation is required for third party contributions?
100. [NEW!] Is there a difference between the FY 2025 interim POM and FNS-366A which is due on August 15, 2024, and the FY 2025 interim POM required to receive FY 2024 administrative funds?
101. [NEW!] Does the February 15, 2024, deadline for final POM submissions apply to FY 2025 interim POMs submitted for the purpose of receiving FY 2024 administrative funding to support 2025 planning and implementation?
102. [NEW!] Can states and ITOs receive FY 2024 Summer EBT administrative funds for costs incurred in FY 2024 associated with planning for 2025 implementation after Feb. 15, 2024?
103. [NEW!] What does a state or ITO need to submit in order to receive FY 2024 Summer EBT administrative funds to cover costs associated with planning and implementation of Summer EBT in 2025?