P-EBT State Plans for SY 2020-21

The Continuing Appropriations Act 2021 and Other Extensions Act (PL 116-159) extends Pandemic EBT (P-EBT) through the end of September 2021. That means that P-EBT is now available for all of school year (SY) 2020-2021.

The Act also makes several significant changes to P-EBT. These include:

• expanding P-EBT to cover certain children in childcare,
• provisions to simplify state administration of the program,
• providing full administrative funding, and
• making P-EBT available to eligible children in Puerto Rico, American Samoa, and the Commonwealth of the Northern Mariana Islands.

To facilitate the development of state plans for SY 2020-2021, USDA created a new plan template and a set of Q&As. Both are now available on USDA’s P-EBT website.

Please note that this memo, the P-EBT plan template, and the Q&As only address the development and approval of P-EBT plans for school children. At this time, USDA is not accepting state plans to issue P-EBT benefits for children in childcare. The extension of P-EBT to childcare raises several complex operational issues. USDA is working to resolve those issues now and will issue childcare-specific materials as soon as possible.

The state P-EBT plan template and Q&As discuss the recent changes to P-EBT for school children as well as the standards that USDA will use in the review and approval of state plans. Several of the Q&As suggest options that states may adopt when structuring particular elements of their plans. However, USDA understands that states may propose alternatives, and USDA will consider those, in the context of statutory requirements. We ask that you review those documents and contact your USDA-FNS regional office with specific questions.

The discussion immediately below provides a high level summary of several critical points covered in greater detail in those documents.

Correcting errors from already approved P-EBT plans for children in school:

States with approved P-EBT plans for SY 2019-2020 or the beginning of SY 2020-2021 can issue P-EBT benefits to children who were covered by the states’ approved plans but did not receive benefits due to state error. States should contact USDA before making such corrections.

Amending previously approved plans for children in school:

States with approved plans for the period from the start of SY 2020-2021 through September 30 may amend those plans in order to apply a consistent standard for benefit calculation and issuance for those months and the period from October 1 through the rest of SY 2020-2021. USDA will no longer accept amendments to states’ approved SY 2019-2020 plans.

New and amended SY 2020-2021 plans for children in school:

Changes to P-EBT’s authorizing statute provide states with new flexibility to make simplifying assumptions and use the best feasibly available data in the development and execution of their P-EBT plans. While this flexibility will reduce burden on states and help ensure the delivery of benefits to eligible children, it does not allow USDA or the states to sidestep the basic eligibility criteria for P-EBT benefits. USDA looks forward to working with states on practical plans that deliver benefits to eligible children and respond to changes in schools’ instructional models and children’s eligibility over the course of the 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). The template and Q&A provide more detail on allowable costs and the development of an administrative cost plan.

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

• SY 2020-21 Memo for States on Pandemic EBT
• SY 2020-21 P-EBT Questions & Answers
• SY 2021-21 P-EBT Plan Template Schools
• P-EBT/EA Reporting Questions & Answers