Jan. 21, 2022
- Many states will calculate student-specific P-EBT benefits this school year rather than the uniform school-level benefits common in SY 2020-21. Under these student-specific plans, schools provide states with a separate count of absences and virtual learning days for each student, which are claimed as COVID-related. What reasonable quality-assurance measures should states take to ensure that benefits are only issued for COVID-related absence or virtual learning days?
In addition to providing clear written guidance to school and school district officials on what constitutes a COVID-related absence or virtual learning day, consistent with the state plan, USDA encourages states to develop additional standards to ensure the reliability of student-specific P-EBT issuances. USDA offers three examples below. In all cases, states must not issue P-EBT benefits to students for absence or virtual learning days that are not COVID-related. 1 States may adopt the following or propose their own measures, which must be approved in their P-EBT plans.
- The state will follow up with schools that report significant numbers of COVID-related student absences in months when the school does not report a mandatory quarantine for any students. Except for students' pre-approved virtual learning days, a state may question whether absences in a month when no student is quarantined at the order of the school are COVID related.
- The state will follow up with any school that issues P-EBT benefits in a month when the school district's absentee rate returns to pre-pandemic levels.
- The state will follow up with any school that proposes to issue P-EBT benefits at a rate that is clearly out of line with known community COVID incidence rates, the P-EBT benefits requested by nearby schools, or data collected through the state's school testing and contact tracing process.
- May states issue an average benefit for students with one or more COVID-related absences?
Yes. States may set an average benefit for students with one or more COVID-related absences. States would calculate such a benefit based on the average length of a COVID-related absence at the school, school district, county, or state level. States may propose this option in their state plan if they are able to confirm that an individual student had one or more COVID-related absences in a month but are unable to accurately count the student's number of COVID-related absences. This might be the case in states with limited student information systems, or in states where the transfer of student health-related data is limited by state law or local procedural hurdles.
Setting a fixed average benefit for these children is similar to a fixed benefit for children with hybrid learning schedules, which most states provided in SY 2020-21. Note that under any plan that distributes average benefits to students, it is the state's responsibility to ensure that the average reasonably reflects the actual distribution of students' COVID-related absences. FNS encourages states to monitor differences across the state or school districts and ensure those differences are limited. Significant differences call for region or school district specific averages to prevent discriminatory outcomes. 2 Given the constant change in state and local COVID case counts, USDA encourages states to re-calculate their school, county or state average using COVID-related absence data every month. At a minimum, however, states must recalculate their averages no less frequently than every other month. Please refer to P-EBT Q&As #20 and #22 for additional information on the calculation of average benefits.
- May states issue fixed benefit amounts for standard COVID-related incidents?
Yes, if schools are recording reason codes for student absences and have standard required absences for those reasons, then states may issue fixed benefits that are tied to mandatory isolation periods for pre-defined COVID-related incidents. Because different reason codes would indicate different lengths of required absences, the state would issue a fixed benefit for students who test positive, a different fixed benefit for students exposed to someone who tests positive, etc.
FNS will approve this option in state plans where a state mandates defined isolation periods of varying duration for multiple types of COVID-related incidents. 3 States must describe in their plan how this option delivers benefits that are reasonably consistent with the actual duration of individual students' COVID-related absences. Because this option is intended for schools that require different lengths of quarantine for pre-defined COVID-events, it is not intended for states that wish to issue a single fixed benefit to all students, regardless of the length of their actual absences. States that wish to issue a single P-EBT benefit to all children may calculate an average benefit that reflects the range of actual absences recorded over the course of the month (see Q&A Addendum #2).
- In most states, COVID-related incidents trigger absences of varying lengths. Rather than issue a unique benefit for the length of each student's COVID-related absence, may states issue a limited set of tiered benefits to simplify administration and communication with parents?
Yes, states may issue fixed benefits based on differences in the length of COVID-related absences without computing unique benefits for each student. A tiered benefit structure may be easier to administer and communicate to families. In addition, some states note that a tiered benefit may reduce administrative cost and present less risk to program integrity.
At a minimum, a tiered benefit must distinguish very short COVID-related absences from absences of greater length. As noted in Q&A Addendum #3, this benefit is intended for states that wish to use pre-determined lengths of COVID-related absences. States that wish to issue a single P-EBT benefit to all children should instead consider calculating an average benefit that reflects the range of actual absences recorded over the course of the month (see Q&A Addendum #2).
USDA suggests a tiered benefit similar to the following suggested by at least one state agency:
COVID-Related Absence Days P-EBT Benefit Days 1-5 3 6-15 The number of weekdays in the state's standard quarantine period. In the absence of a standard quarantine period, the state may issue the midpoint of this range, or 10 days. 16+ Full month (typically 18 days)
Note that the schedule above is only an example. The state may propose different ranges for its tiered benefits to match the most common types of COVID-related absences in the state. For example, if a single-day COVID-related absence is common in the state's school districts (perhaps for testing) then the state should include a fourth category for single-day absences rather than issue 3 days of benefits to all of those children. Similarly, the broad middle category is intended to capture the state's standard quarantine period. If the state has standard quarantines of multiple lengths, the state should split that category into more refined subcategories. And finally, states must review their fixed categories and make necessary changes through a plan amendment as state or school district policies on COVID-related isolation periods evolve.
- In some states, schools may not be able to distinguish COVID-related absences from other excused absences. How might those states use schools' excused absence data to determine children's P-EBT benefits?
FNS expects schools to report the best feasibly available data, such as students' individual COVID-related absences to their states. However, where that data is not feasibly available, a state may propose a plan to issue P-EBT benefits for a subset of student absences if the state can provide reasonable assurance that the adjusted absence days are COVID-related. States may consider the following option or suggest their own options with appropriate justification. USDA will not approve this option for states that can feasibly identify COVID-related reasons for students' absences.
- Establish a minimum block of consecutive absence days before issuing benefits for any absences.
Under this option, states would not issue P-EBT benefits for student absences that fall short of a pre-defined, presumptively COVID-related, block of consecutive days. A state that elects this option would not issue P-EBT benefits until a student's consecutive block of absence days reaches the state's standard quarantine for students with a positive COVID test. Such an approach sets an objective standard that may be easy to administer.
To protect children with COVID-related absences that fall short of the minimum, states must establish a process for families to submit documentation in support of their claim for benefits. In all such cases, the state must work with the school to confirm the length of the student's shorter absence.
Finally, states that elect this option would be responsible for following up with schools on any extended block of absences or recurring blocks of absences that suggest something other than a COVID-related reason.
- Establish a minimum block of consecutive absence days before issuing benefits for any absences.
- Are children eligible for P-EBT on days that school buses are not running, or on days that classes are canceled because of school staffing challenges?
No. The Families First Coronavirus Response Act (FFCRA) authorizes the issuance of PEBT benefits on days that students do not have access to meals at school due to a school closure or reduction in attendance or hours tied to “concerns about a COVID-19 outbreak.” Students are eligible for P-EBT benefits (consistent with the terms of a state's approved plan) if they are quarantined by the school or instructed to isolate in response to their possible exposure to COVID. 4 If that exposure takes place on a school bus or in class, the school may very well suspend bus service or temporarily close the school as part of the same emergency response. However, it is the COVID exposure that triggers the quarantine, the students' eligibility for P-EBT benefits, and the school's consequent decision to suspend bus service and temporarily close the school. By contrast, if a school suspends bus service or cancels classes due to its inability to fill staff positions for reasons that are not related to “concerns about a COVID-19 outbreak,” even if that inability has an attenuated connection to the pandemic-induced labor shortage, then any associated absences on those days are not P-EBT eligible. States are responsible for communicating this to their schools and confirming that they do not issue P-EBT benefits for non-COVID-related absences or virtual learning days.
- USDA will approve P-EBT plans for school children in SY 2021-22 that provide benefits when a COVID incident closes a school or requires the majority of students in the school to switch to virtual instruction. Must states supplement these plans with a process for families to claim benefits for children with isolated COVID-related absences and virtual learning days?
Yes. Given that most schools are committed to in-person instruction this year, a plan that limits benefits only to children affected by occasional school-wide closures may leave many eligible children without benefits. Accordingly, school year 2021-22 plans that issue benefits when a COVID incident closes a school or requires the majority of students in the school to switch to virtual instruction must provide an opportunity for families of eligible children affected by isolated COVID-related absences and virtual learning days to establish their eligibility and claim benefits.