Published July 31, 2025

The first year of Summer EBT implementation, 2024, saw two Indian Tribal Organizations (ITOs) join 37 states, the District of Columbia, and five U.S. territories in participating in the program. Together, these two Tribes — Chickasaw Nation and Cherokee Nation — issued benefits to a large number of children who resided in their respective Tribal service area and who otherwise would not have received benefits, as Oklahoma had opted out of the program.  

By providing families with approximately $120 in grocery benefits per summer per eligible child, Summer EBT addresses the gaps left by traditional summer nutrition programs. These programs work together with Summer EBT to ensure children remain fed during the summer months when they no longer have access to free and reduced-price school meals. This is especially critical for American Indian/Alaska Native households, which research shows face overall food insecurity rates that are more than double the national average. 

The Chickasaw Nation, which ran the Summer EBT demonstration projects for 12 years, including during the pandemic, reached nearly 150,000 students across both their service area and the Muscogee Nation service area in summer 2024. A new case study published this week by Indigenous Food and Agriculture Initiative (IFAI) and the Food Research & Action Center (FRAC) found that operating Summer EBT can increase the visibility of participating Tribal nations, allowing tribes to become a go to resource for families as well as draw down federal dollars that support the local and rural economy. Through implementation, Chickasaw Nation found that leveraging existing partnerships and relying on strong memorandums of understanding (MOUs) for data sharing with schools were best practices.  

Looking ahead, there are regulatory and statutory changes that could be made to the Summer EBT Program, which would make it easier for more Tribal nations to participate. Here are some recommendations: 

  • Expand Summer EBT eligibility criteria: For a Tribe to run Summer EBT, they must operate the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC). Only 33 ITOs operate WIC.  By opening Summer EBT eligibility to include Tribes successfully operating other nutrition programs, Congress could allow broader Tribal participation. 
  • Increase administrative funding: The 50 percent administrative match is a limiting factor for many Tribes that would like to operate the program. Allocating funding to cover this match would allow more ITOs to participate in the program. (See the Stop Child Hunger Act of 2025, S. 1622/H.R. 3217). 
  • Adapt requirements to ease implementation: Summer EBT Program requirements were designed with state agencies in mind, rather than Tribes. In addition, reporting requirements are based on a Supplemental Nutrition Assistance Program (SNAP) model and not a WIC model, which is a program that Tribes can operate. Burdensome requirements, such as submitting two “Plans of Operation and Management” each year and reporting requirements, stretch already overloaded staff. Requirements to utilize data-reporting systems that are not aligned with Tribal systems and access can also impose additional administrative burden on Tribes. By making slight adjustments in both statutory language and regulations, Tribes could more easily implement Summer EBT.  
  • Provide more federal technical support: Much of the available technical assistance for Summer EBT is focused on states. While ITOs have worked together to provide technical assistance for one another, greater support from the U.S. Department of Agriculture (USDA) would make the implementation process simpler for Tribes.  

Summer EBT is a key resource for filling the summer nutrition gap, especially among American Indian/Alaskan Native populations where food insecurity rates remain high. However, without changes to both the program’s statutory and regulatory requirements, many Tribes will remain unable to participate.