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New USDA Guidance Clarifies States’ P-EBT Flexibility to Mitigate Child Hunger

The U.S. Department of Agriculture (USDA) issued new guidance late last week to help states implement Pandemic EBT (P-EBT), which provides federally funded grocery benefits to replace the meals that children are missing when they’re not attending school or child care. It’s an important tool to reduce the staggering number of children not getting enough to eat.

Last spring, every state plus the District of Columbia and the Virgin Islands implemented P-EBT to provide benefits to replace school meals that children were missing. Yet roughly five months into this school year, only eight states and Puerto Rico have an approved plan in place to provide the benefits to school-age children — and no state is issuing benefits to younger children, as a P-EBT expansion of October allows.

To be sure, determining P-EBT eligibility and benefit levels is much more complicated this year. Schools vary widely in in-person versus virtual instruction (and, as a result, in how much children are getting free or reduced-price meals). Even within the same school, moreover, students have different schedules and receive different numbers of meals. Policymakers accounted for all this — when they extended P-EBT through fiscal year 2021 and made benefits available to certain children who were missing meals in child care settings — by letting states simplify how they can address information gaps and implementation challenges. In legislation they enacted just over a month ago, policymakers further simplified and clarified the rules in ways that states requested, particularly for children under 6. Yet not a single child under 6 has received benefits, in large part because USDA hadn’t issued guidance on how it would interpret this new flexibility for younger children.

Last week’s guidance clarifies the new state flexibilities and increases P-EBT maximum benefits to $6.82 a day to include the value of after-school snacks. While the guidance encourages states to provide benefits that align as closely as possible to children’s individual circumstances, it recognizes that some states can’t determine every child’s instructional schedule. The guidance clarifies states’ authority to make simplifications or use the best available data in order to issue benefits. Moreover, it encourages states to develop plans based on their specific circumstances and data limitations so long as they explain why they are taking their chosen approach.

With this guidance, every state should be able to design a benefit structure that it can implement. The information and materials that we and the Food Research & Action Center gathered about states’ P-EBT implementation approaches last spring also offer resources for states.

Now, states must develop plans and begin getting grocery benefits into the hands of families struggling to afford food. Up to 12 million children are living in a household where the adults said the children did not get enough to eat in the last seven days because they couldn't afford it, according to our analysis of the latest available data. That’s more than ten times the 1.1 million children in December of 2019 living in households where children didn’t get enough to eat at any point in the last 30 days. (See chart.) Up to 31 percent of children in Black households, up to 27 percent in Latino households, and up to 11 percent in white households (based on the race or ethnicity of the parent) live in households where children didn’t eat enough in the last seven days because the household couldn’t afford it. That means that any further delay in P-EBT benefits risks exacerbating longstanding racial inequities. Moreover, the delay for children under 6 is especially risky, given findings that deprivation in the first years of life can affect behavior and learning later.

Policymakers also can help prevent an increase in food hardship beyond this school year by extending P-EBT through the summer. Although it’s authorized through the end of September of 2021, its rules largely align with the school calendar, so program benefits will not be available over the coming summer. A summertime P-EBT benefit would create a bridge for families to the next school year, when students hopefully will return to their classrooms. This approach would be consistent with the Summer EBT demonstration program, a SNAP supplement that has been shown to reduce food insecurity and prompt healthier eating.

By implementing P-EBT expeditiously for the current school year and extending it through the summer, state and federal policymakers can reduce the alarming levels of food hardship among children and improve their health and developmental prospects for years to come. The risks of delay are significant, given the grip that food hardship has had on millions of children for nearly a year and the long-term consequences that even short periods of food insecurity pose for children.