June 22, 2023

The Summer Electronic Benefit Transfer (EBT) Program was permanently expanded in December 2022. In early June, the U.S. Department of Agriculture Food and Nutrition Service (USDA-FNS) released initial guidance on state implementation of the program and requested that stakeholders submit feedback to inform the interim rulemaking. Input is still requested as guidance was just issued this month. The guidance covers four areas of Summer EBT implementation: Program Administration, Benefit Funds, Summer EBT State Administrative Funds and Other Potential Sources, and State Agreement and Management and Administration Plans. The guidance also provides high–level details that states can use to prepare for Summer EBT implementation.  

  1. Program Administration
    -Encourages collaboration between state agencies to determine appropriate roles for each agency involved.
    -Urges stakeholders to work with their state legislatures to determine if laws must be changed to support effective program implementation.
    -Urges states to identify state-level funds to cover Summer EBT administrative costs. 
  2. Benefit Funds
    -Requires states to track Summer EBT funds, provided through a federal grant, separately from Supplemental Nutrition Assistance Program (SNAP) benefits. Asks state agencies to manage Summer EBT funds in a similar manner to SNAP benefits and subjects these benefits to the same oversight, restrictions, and requirements as SNAP benefits.
  3. Summer EBT State Administrative Funds and Other Potential Sources
    -Reminds states that they are required to cover 50 percent of all Summer EBT administrative costs without the use of other federal funds or federal SNAP funds.
    –    Suggests that states consider utilizing Federal State Administrative Expense funds for fiscal year 2023 implementation. 
    -Urges states to also consider additional funding sources, including Technology Innovation Grants. This funding can support projects that would benefit both school meals and Summer EBT, such as systems that allow states to gather and maintain eligibility information at a state level.  
  4. State Agreement and Management and Administration Plans 
    -Requires that one state agency take the lead of program administration and enter into a federal/state agreement with FNS.
    –    Urges state agencies to create interagency written agreements to define roles and responsibilities for each agency and administrative structure and authority. 
    –    Sets the deadline for notification of Summer EBT participation to USDA to January 1, 2024. 
    –    Reiterates that states must submit a State Management and Administration Plan by February 15, 2024.  This plan must include all administrative funds requested for the whole program. 

    FRAC applauds USDA for this timely initial guidance for Summer EBT implementation and for including language encouraging states to create interagency agreements and define agency roles. We believe that this guidance will help states begin their planning and maximize state uptake of Summer EBT. We also appreciate USDA noting other funding streams that may be used this fiscal year to help states prepare for the 50 percent administrative cost that begins next year. We look forward to the release of additional guidance on the Summer EBT Program, including customer access, acceptable application forms, and technical assistance.