The Summer Electronic Benefit Transfer (Summer EBT) program, also known as SUN Bucks, was launched nationwide in 2024, the first permanent federal nutrition program in over 50 years. In summer 2024, the state of Oklahoma chose not to participate, but three of Oklahoma’s tribal nations—the Cherokee Nation, Chickasaw Nation, and Muscogee (Creek) Nation—stepped in to provide benefits to children in both tribal and nontribal families in their service areas within the state. In this report, we dive into the challenges tribal nations faced and learnings gained in launching this program, explore how recipients and nonrecipients in the state experienced the benefit and food hardship, and reflect on considerations for the future.

Why This Matters

The Summer EBT program provides grocery benefits to low-income families with children during the summer months, filling an important gap in summer food assistance programs, and has been shown to effectively reduce food insecurity. However, Oklahoma’s lack of participation left half the state’s eligible families without access to the benefit. To combat childhood food insecurity during the summer, policymakers should be informed of how to ensure expanded and smoother implementation of the program, especially from the perspective of tribal nations whose perspectives are often overlooked.

What We Found

This study documents how tribal nations administered Summer EBT, challenges they encountered, and learnings gained in the first year of implementing the program in 2024. Some challenges stemming from program requirements and limited guidance included the following:

• Difficulty in acquiring the required administrative funding
• Limitations on flexibility of recipients’ benefit use due to requirement to purchase from prescribed food list, as specified under the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
• A lack of timely guidance, support, and institutional knowledge from Food and Nutrition Service (FNS)
• Lack of sufficient planning time
• Lack of cooperation from Oklahoma state agencies
• Untimely receipt of federal benefit funding

While tribal nations faced challenges launching Summer EBT, survey results showed that recipients reported significantly lower rates of food insecurity compared to nonrecipients, and were more likely to report having had enough access to fruits/vegetables, milk/dairy, protein, and whole grains.

In 2025, two more tribal nations will implement Summer EBT in Oklahoma, and more tribal nations in other states may choose to administer the program in future years to alleviate food insecurity in their state. To ensure tribal nations have fewer barriers to administering the program, and that benefit recipients experience the program as it is intended, we recommend the following:

• Provide timely and clear guidance for tribes implementing the program
• Ensure knowledge is transferred from the federal level to all regional offices, especially around the differences in implementation requirements for tribal nations and the WIC model
• Align distribution of funding from FNS with the fiscal year and provide partial administrative funding up front
• Ensure reporting processes from FNS are tailored to the WIC model of implementation
• Provide clear guidance on rules and roles for statewide collaboration to limit data-management burden for tribal nations
• At the statute-level, consider higher benefit levels, offering flexibility to tribal nations to choose to implement the SNAP model, which allows recipients to use benefits on any food items, rather than choosing from a prescribed list, or offering a more flexible food package under WIC

How We Did It

This study was developed as a research partnership between Hunger Free Oklahoma, an anti-hunger organization in Oklahoma and the Urban Institute. In the first part of this study, we documented Summer EBT implementation perspectives of tribal nations by conducting three interviews with representatives from Cherokee Nation, Chickasaw Nation, and Muscogee (Creek) Nation. We also held data walks with interviewees, a method of sharing preliminary data and research findings, to allow interviewees to react to and inform the analysis. In the second part of this study, we administered a survey to a sample of eligible Oklahoma households in both eligible and ineligible areas of the state to better understand household experiences with food access and household experiences with and without Summer EBT in summer 2024.