State Agencies

State Plan for Pandemic EBT
Children in School and Child Care, 2020-2021
Issuing
Agency/Office:
Title of Document:
Document ID:
Z-RIN:
Date of Issuance:
Replaces:

Summary:

Disclaimer:

FNS / Child Nutrition Programs, Supplemental Nutrition
Assistance Program
State Plan for Pandemic EBT: Children in School and Child Care,
2020-2021
January 29, 2021
N/A
(1) This document is a template to assist States in the development
of State plans to operate Pandemic EBT for school children during
school year (SY) 2020-2021 and for children in child care during
federal fiscal year 2021. (2) This document relates to Section 4601
of the Families First Coronavirus Response Act (P.L. 116-127) as
amended by the Continuing Appropriations Act, 2021 and Other
Extensions Act (P.L. 116-159) and the Consolidated
Appropriations Act, 2021 (P.L. 116-260).
The contents of this guidance 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.

Additional context and background for this document can be found at:
https://www.fns.usda.gov/snap/state-guidance-coronavirus-pandemic-ebt-pebt

The P-EBT Assistance for Children in Schools and Child Care should be covered under an
Emergency Information Collection Request for the Pandemic EBT (Schools), to be adjusted as
appropriate, which is currently under review at OMB. Once OMB has approved the request and
assigned the OMB# Control Number, FNS will include the necessary information on the State Plan.

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State Plan for Pandemic EBT
Children in School and Child Care, 2020-2021
1. State:
2. Primary Citations: Families First Coronavirus Response Act (FFCRA);
Continuing Appropriations Act, 2021 and Other Extensions Act;
Consolidated Appropriations Act, 2021
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).
Note that P-EBT benefits for school children are available from the start of school year
2020-2021. P-EBT benefits for children in child care are only available from the start
of federal fiscal year 2021, or October 1, 2020.
a. The date range covered by this State plan or amendment
• for children in school
• for children in child care
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
• Estimated amount issued to non-school children in child care
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
• Estimated number of non-school children in child care
d. Estimated total amount of administrative funds the State needs to complete the work
described in this State plan/amendment. 2
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
• Children in child care
Response:

The date range covered by P-EBT State plan or amendment. For example: a State’s initial plan could cover August
31 through September 30, 2020; and a later amendment could cover October 1, 2020 through December 31, 2020.
2
Note that States may only claim 100% reimbursement for P-EBT administrative expenses incurred from October 1,
2020 forward.
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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.

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Describe how the State will identify eligible school children for P-EBT. Also describe
what measures the State will take to prevent the issuance of 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-SNAPrecipient 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 inperson 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).
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 the State will take to address program
integrity when using the proposed simplifying assumptions.

Response: [please use as much space as needed]

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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.
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.).
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.

2.
3.

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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]

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5. P-EBT for Children in Child Care
Standard for P-EBT Eligibility
A child enrolled in a covered child care facility is eligible for P-EBT if:
1.
2.

The child is a member of a household that received SNAP benefits at any time since October 1, 2020.
The child is enrolled in a covered child care facility. (Note that under the FFCRA, USDA deems all
children under the age of 6 to be enrolled in a covered child care facility.)
During a public health emergency designation, the child’s child care 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.

3.

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Describe how the State will identify eligible children and confirm their eligibility
consistent with the above standard.
How will the State determine and confirm the child’s receipt of SNAP benefits in
accordance with relevant SNAP privacy requirements?
How will the State determine that a child’s residence is in the area of one or more
schools that is closed or is operating with reduced attendance or hours?
For children whose residence is not in the area of one or more closed schools or
schools operating with reduced attendance or hours, how will the State determine that
child’s eligibility? Specifically, how will the State determine that:
o the child’s child care facility is closed or is operating with reduced attendance
or hours, or
o the child’s child care facility is in the area of one or more schools that are
closed or operating with reduced attendance or hours?
Are there any State or local public health ordinances that limit the capacity of child
care facilities in response to COVID-19 in your State? If yes, describe how you will
use those to find that all SNAP-participant children under age 6 are eligible for PEBT in those areas?
Describe the process that the State will use to update and re-establish each child’s
continued P-EBT eligibility and benefit level consistent with changes in the operating
status of the child care facility or area schools? 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).
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]

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6. 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, a
lunch, and a snack 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.

SY 2020-2021
July 1, 2020 - June 30, 2021
Contiguous U.S.
Alaska
Hawaii, Guam, Virgin Islands, Puerto Rico

Lunch
$3.60
5.79
4.20

Free Reimbursements
USDA School Meal Programs
Snack
(NEW)
Breakfast
$2.26
$0.96
3.64
1.56
2.64
1.13

Daily
Total
$6.82
10.99
7.97

Notes:
1. Lunch rates include the 7 cent performance-based reimbursement and the extra 2 cents per meal received by school food
authorities in which 60 percent or more of the lunches served during the second preceding school year were served free or at
a reduced price.
2. Breakfast rates are those received by "severe need" schools.
3. Snack rates are those for afterschool snacks served in afterschool care programs
Source: https://www.govinfo.gov/content/pkg/FR-2020-07-22/pdf/2020-15764.pdf

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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]

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7. 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.
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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:
o State Education agency provides student data to SNAP State agency (Day #5)
o P-EBT hotline becomes active (Day #9)
o Public notice campaign begins (Day #10), etc.

Please also address each of the following:
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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?
o If so, who will receive these cards? Non-SNAP households only? Or also SNAP
households?
o If not, how will you handle cases where the P-EBT household no longer has their
P-EBT card?

Response: [please use as much space as needed]

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8. 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.

2.
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USDA strongly encourages States to provide a means to resolve disputes and answer questions from
actual or potential P-EBT households.
USDA strongly encourages States to provide relevant program information to actual and potential PEBT 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 what information you will provide for households that do not want the P-EBT
benefit that is directly issued to them. How dispose of the card, etc.
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:
o 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)
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o 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, robo-call, and/or other electronic means?
Response: [please use as much space as needed]

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9. Over-issuance of P-EBT benefits
States should outline a process to recover or adjust P-EBT payments to correct errors on previous
issuances. States cannot simply apply their existing SNAP benefit claim process to P-EBT.
Accordingly, States should develop P-EBT-specific rules and procedures and include those in
their State plans. States must also consider the capability of their SNAP systems to
distinguish P-EBT from SNAP benefits.
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. Reclaiming benefits under those circumstances calls for a process that weighs the equity
of the claim, the burden on affected households, and the likelihood and costs of recovery.
Given those considerations, a State’s P-EBT plan should consider reasonable thresholds for
taking action to recover over-issued benefits. States that establish a process for benefit
recovery must provide clear notice to beneficiaries of the circumstances under which the
State may attempt to recover benefits or reduce a future issuance. Under no circumstances
may the State reduce a SNAP benefit to settle a P-EBT claim.
Finally, the States recognize that USDA is responsible for ensuring accountability of funds for PEBT 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: [please use as much space as needed]

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10. 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.
11. Administrative Funding
A separate grant to cover State level administrative costs associated with the administration of PEBT will be awarded to the SNAP State Agency within each State, for the period of performance
October 1, 2020 through September 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.

12. 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 U.S.C. 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.”
13. 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.
14. 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.

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Signature and Title of Requesting SNAP and Child Nutrition State Agency Officials:

Signature
Print Name and Title

Signature
Print Name and Title
Date of Request:

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