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P-EBT Plan Template Schools

Resource type
Technical Assistance
Resource Materials
State Plan for Pandemic EBT: Children in School
School Year 2020-2021

 

1.    State: _____________________________

2.    Primary Citations: Families First Coronavirus Response Act
                                                 Continuing Appropriations Act 2021 and Other Extensions Act

3.    Executive Summary:
Please provide the following data. In addition, please include a statement indicating
that you commit to informing USDA of any significant increase or decrease in these
data points during the date range 1 covered by this initial plan (or subsequent amendment).

a. The date range covered by this state plan or amendment.

b. Estimated monthly and total amount of P-EBT benefits the state will issue within this plan/amendment’s date range.

  • Estimated amount issued to school children in SNAP households.
  • Estimated amount issued to school children in non-SNAP households

c. Estimated total number of children to which the state will issue P-EBT benefits.

  • Estimated number of school children in SNAP households
  • Estimated number of school children in non-SNAP households

d. Estimated total amount of administrative funds the state needs to complete the work described in this state plan/amendment. 

e. Tentative P-EBT issuance schedule (the dates on which you will issue P-EBT benefits).

  • School children in SNAP households
  • School children in non-SNAP households
Response:

[please use as much space as needed]

 

4.    P-EBT for School Children

A. Eligible Children

Standard for P-EBT Eligibility

A child is eligible for P-EBT benefits if two conditions are met: 

  1. The child would be eligible for free or reduced-price meals if the National School Lunch Program and School Breakfast Program were operating normally. This includes children who are:
     a. directly certified or determined “other source categorically eligible” for SY 2020-2021, or
    b.  certified through submission of a household application processed by the child’s school district for SY 2020-2021, or
    c.  enrolled in a Community Eligibility Provision school or a school operating under Provisions 2 or 3, or
    d.  directly certified, determined other source categorically eligible, or certified by application in SY 2019-2020 and the school district has not made a new school meal eligibility determination for the child in SY 2020-2021.
     
  2. The child does not receive free or reduced-price meals at the 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. Once the minimum 5 consecutive day threshold is met, children are eligible to receive P-EBT benefits for closures or reductions in hours due to COVID-19. 
  • Describe how the state will identify eligible school children and confirm their eligibility for P-EBT. Also describe how the state will ensure that it does not issue benefits to school year 2019-2020 graduates and other non-students.
  • How will the state determine and/or confirm each child’s eligibility for free or reduced-price meals? Please describe separately for SNAP-recipient and non-SNAP-recipient children, children in public and non-public schools, new students (such as kindergarteners and transfer students), and children who become eligible during the school year.
  • How will the state confirm each child’s lack of access to meals at school?  Please describe separately for SNAP-recipient and non-SNAP-recipient children, and children in public and non-public schools.
  • Describe the process that the state will use to update and re-establish each child’s in-person and virtual schedules. How frequently will that information be updated? (Note that this information must be updated no less frequently than every other month.).
  • Describe the roles and responsibilities of each state agency or other partners involved in P-EBT (e.g., which agency is responsible for confirming eligibility).
    Response:

    [please use as much space as needed]

     

    B. School Status

    Standard for P-EBT Eligible School Status

    Children are eligible for P-EBT benefits if they are eligible for free or reduced price meals, but are unable to receive those meals at school due to the operating status of their schools as outlined below:  

    1.  The school is closed (including any delayed start or early closure to the school year), or the school is operating with reduced attendance or hours.
    2. School closures do not include weekends, or days when the school is closed due to a holiday or regularly scheduled break (Thanksgiving, New Year’s Day, Spring Break, etc.).
    3. The period of closure or reduced attendance or hours must meet the current school year minimum 5 consecutive day threshold before any child is eligible for P-EBT benefits. Once the minimum 5 consecutive day threshold is met, children are eligible to receive P-EBT benefits for closures or reductions in hours and/or attendance due to COVID-19.
    • Describe how the state will identify, confirm and monitor the status of individual schools. Also describe how the state will identify the period of duration of the closure, reduced hours, or reduced attendance of the state’s schools.
    • How will the state confirm that the child’s school has been closed or is operating with reduced attendance or hours for a minimum of 5 consecutive days?
    • Describe how this information will be obtained and how often the state will collect updated information from schools. (Note that this information must be updated no less frequently than every other month.).
    • Describe the state’s plan for monitoring changes in eligible school status between the state’s bi-monthly (or more frequent) collection of updated school data. Describe how the state will use this updated school information to revise issuance amounts.
    • Describe any simplifying assumptions the state proposes to use and the justification for using those simplifying assumptions. Please address both in detail. In addition, please describe any proposed measures that ensure program integrity when using the proposed simplifying assumptions.
    Response:

    [please use as much space as needed]

     

    5. Benefit Levels

    Standard for Benefit Levels 

    1. The full daily benefit level for each eligible child is equal to the free reimbursement for a breakfast and a lunch for school year 2020-2021. The benefit is multiplied by the number of days that the eligible child’s status makes them eligible for P-EBT benefits. 

     

      pebt chart 11-16-2020
      • Describe the benefit levels proposed, including how days of eligibility will be determined. What simplifying assumptions does the state propose? Why must the state make those simplifying assumptions? Please address both of these questions in detail.
      Response:

      [please use as much space as needed]

       

      6. Implementation Timeline, EBT Processing, and Benefit Issuance

      Please provide an implementation timeline for SY 2020-2021 with estimated dates for major milestones in your plan.   

      •  States should develop their timeline cooperatively, including input from its EBT processor and all state agencies involved in implementing P-EBT. Instead of using specific dates, describe important milestones and realistic durations between them. USDA suggests that states build their timelines from the date USDA approves the state’s plan (Day #0).
      • The timeline must include the state’s tentative issuance dates. In SY 2019-2020, most states issued in phases, and on a rolling basis thereafter. For example: issuance to SNAP households Day #10, to non-SNAP households on Day #15, and to newly identified cases from Day #16 onward. This is a best practice, which we encourage states to continue.
      • Examples of other possible milestones include, but are not limited to:
        • State Education agency provides student data to SNAP state agency (Day #5)
        • P-EBT hotline becomes active (Day #9)
        • Public notice campaign begins (Day #10), etc.

      Please also address each of the following:

      • Will the state issue P-EBT benefits on a unique P-EBT card design? If so, who will receive these cards, non-SNAP households only? Or also SNAP households?
      • How will the state distinguish P-EBT from SNAP and D-SNAP issuances?  USDA strongly encourages the use of a sub-benefit type, even if your state did not do so in SY 2019-2020. This will greatly facilitate the states’ ability to report and USDA to maintain accountability for P-EBT.
      • What will be your draw/spend priority for P-EBT, SNAP, and D-SNAP? USDA suggests making P-EBT first on your draw/spend priority.
      • How will the state handle expungement of P-EBT benefits? USDA recommends that states follow the same expungement rules that the state currently follows for SNAP.
      • During SY 2019-2020, large numbers of P-EBT cards were returned to EBT processors via mail, due to incorrect addresses. How will you and your EBT processor handle returned P-EBT cards? How will you handle the need to issue replacement cards in these cases?
      • Will you issue new P-EBT cards to existing P-EBT households?
        • If so, who will receive these cards?  Non-SNAP households only?  Or also SNAP households?
        • If not, how will you handle cases where the P-EBT household no longer has their P-EBT card?
      Response

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      7. Customer Service

      Recommended Standard for Household Support 

      USDA strongly encourages states to develop a customer service plan that anticipates common questions from households of children that are eligible and potentially eligible to participate in P-EBT, and that ensures that all who are eligible are able to receive and use their P-EBT benefits. 

      1. USDA strongly encourages states to provide a means to resolve disputes and answer questions from actual or potential P-EBT households.
      2. USDA strongly encourages states to provide relevant program information to actual and potential P-EBT households. 
        • How will the state resolve disputes or issuance errors (incorrect benefit amount, denied benefits, etc.)? Based on the large number of such inquiries received by USDA, the states, and EBT processors, USDA suggests a phone number (hotline) staffed by personnel empowered to research and address such cases.
        • Please describe how the state will serve groups with potential access problems, for example: homeless children, foster children, children without social security numbers, children with limited English proficiency, households without internet access, and people living with disabilities.
        • Describe the state’s public information campaign. That is, the information you will provide to the general public (i.e., not directly to P-EBT participants), and how you will provide that information (i.e., print or broadcast advertising, social media, mailers to the general population).
        • Describe the information you will provide directly to P-EBT participants (this is different than the information you provide to the general public), and how you will provide that information. For example:
          • What will you provide to explain the purpose of P-EBT and how to use the benefit? Based on the large number and wide variety of public inquiries that USDA, states, and EBT processor call centers received regarding P-EBT in Spring and Summer of 2020, USDA recommends it include:
            • A description of P-EBT
            • Instructions for PINing a P-EBT card
            • Explanation of where benefits can be used
            • Explanation of how benefits can and cannot be used (i.e., eligible foods and non-eligible items)
            • Explanation of violations and penalties, such as trafficking
            • An indication that benefits are non-transferable
            • Instructions for destroying the card, if they want to decline benefits
            • Information regarding a hotline, helpdesk, or website/portal that participants can reach out to, if they have questions, need assistance (setting up a PIN, for example)
          • How will you provide P-EBT information to non-SNAP households?  How will you provide P-EBT information to SNAP households? 
            • Will you provide information via mailers?  Will the mailer(s) be a flyer/brochure, buck slip, letter, or some other alternative? USDA recommends flyers/brochures, because these can be used more flexibly than buck slips.
            • Will you provide information via e-mail, text messages, social media, website, robocall, and/or other electronic means?
        Response:

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        8. Over-issuance of P-EBT benefits

        States should outline a process to manage cases of benefit over-issuance. The process should take into consideration that many households received their benefits, without application, through an automated match process that relied on the state’s own administrative data. In no cases can states reclaim P-EBT benefits by reducing the household’s SNAP benefit.

        Finally, the states recognize that USDA is responsible for ensuring accountability of funds for P-EBT purposes. As part of its oversight responsibilities, USDA may hold state agencies liable for aggregate over-issuances or improper payments. USDA’s course of action is to pursue P-EBT over-issuance claims in the aggregate where USDA believes such action is merited, based on the nature of the error that gave rise to the over-issuance, the size of the error, and whether such action would advance program purposes.

        Response:

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         9.    Benefit Issuance Reporting
        The state agrees to complete the FNS-292 form as well as all other normally recurring SNAP reporting, including the FNS 46, 388, and 778 reports, on a timely basis in accordance with requirements.

        10.    Administrative Funding
        A separate grant to cover state level administrative costs associated with the administration of P-EBT will be awarded to the SNAP State Agency within each state, for the period of performance Oct. 1, 2020 through Sept. 30 2021. As the authorized grantee, the SNAP state agency will be granted access to the associated letter-of-credit in which the administrative grant funds will be placed. As P-EBT related state administrative costs may be incurred by state agencies other than the SNAP state agency, the SNAP state agency will be responsible for entering into interagency agreements in the form of a Memorandum of Understanding, or document of similar construct, with all other respective state agencies responsible for delivering P-EBT benefits. The SNAP state agency will be responsible for reimbursing the administrative costs of all associated agencies accordingly.

        Prior to USDA releasing the grant for administrative funding, each SNAP state agency will be required to submit a P-EBT budget plan using the FNS-366(a) Program and Budget Summary Statement. Funds will not be released to the SNAP state agency’s letter-of-credit until this plan is submitted and approved. The SNAP state agency’s budget plan should include the estimated administrative costs for all State agencies that will be handling P-EBT.

        As noted in Item 9 above, the SNAP state agency will be also responsible for reporting all administrative expenditures on a separate FNS-778, Supplemental Nutrition Assistance Program, Federal Financial Report designated specifically for P-EBT. The expenditures on the FNS-778 should align with those outlined in the FNS-366(a), Program and Budget Summary Statement. The forms associated with P-EBT will be modified accordingly.

        11.    Release of Information
        Per Section 1101(e) of the Families First Coronavirus Response Act: Notwithstanding any other provision of law, the Secretary of Agriculture may authorize state educational agencies and school food authorities administering a school lunch program under the Richard B. Russell National School Lunch Act (42 USC 1751 et seq.) to release to appropriate officials administering the supplemental nutrition assistance program such information as may be necessary to carry out this section.”

        12.    Civil Rights Statement
        The state will continue to comply with civil rights requirements, to include providing equal access to individuals with disabilities and individuals who are limited English proficient.

        13.    Administration of State P-EBT Plan
        The state will administer P-EBT according to the terms of its approved state plan. If the state wishes to change any of the terms of its plan, the state shall first notify USDA and will, if requested by USDA, submit a plan amendment for USDA review and approval.

        Response:

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        11/16/2020