Urban Wire Timing Is Everything for Students Needing Summer Food Support
Emily Gutierrez, Poonam Gupta
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Deborah Jendrasko prepares the free bag lunches for students at Deering High School on Friday

Millions of students may not receive the food assistance they need this summer.

Summer has long been recognized as a period of heightened food hardship for families with children who receive free or reduced-priced meals during the school year. Lawmakers acknowledged this by including in the Build Back Better (BBB) framework a summer electronic benefits transfer (Summer EBT) program that would provide funds to families with eligible children for the 2023 and 2024 summers, though passage of the bill looks increasingly unlikely. But even quick passage would not deliver a program for the summer of 2022. States have the option to provide summer 2022 Pandemic-EBT (P-EBT) benefits through the 2021 American Rescue Plan Act (ARPA), a program that provides emergency funds to families with children that would have received free or reduced-priced meals if not for school closures; however, states are required to have a school year plan in place before even considering providing summer benefits to students, and so far only 12 school year plans have been approved for 2021–22. As a result, there is a risk that millions of students may not receive food assistance this summer.

Insufficient lead time has plagued the P-EBT program since its inception, with benefits typically distributed retrospectively and often long after the initial need for support. Over the past two summers, families did not receive benefits until the end of summer or beginning of fall, and in at least one case, a state has yet to issue last summer’s benefits. Longer lead times allow states to plan for more effective implementation, but if the Food and Nutrition Service (FNS) of the United States Department of Agriculture does not simplify school year plan submission and put forth timely summer plan guidance, states cannot begin to consider providing summer benefits.

The pandemic heightened food insecurity awareness

Almost 30 million students receive free and reduced-price meals during the school year but have historically lacked food resources (PDF) when school is out for the summer. Yet, summer meal programs developed to address this need have not become standard practice across the US.

However, the onset of the pandemic created widespread school closures and limited access to school nutrition, raising awareness of rapidly growing child food insecurity. The USDA acted quickly to grant states waivers for school meal services to provide greater flexibility during school closures, including providing grab-and-go meals. But meal pickup proved difficult for many families and schools struggled with staffing capacity to maintain the program.

In March 2020, Congress acted to ameliorate some of the immediate shocks arising from the COVID-19 pandemic by passing P-EBT, a new federal child nutrition program, for the end of 2019–20 school year, which was ultimately extended through 2020–21. P-EBT operates through and alongside the Supplemental Nutrition Assistance Program to provide emergency funds to families with children missing school meals, and guidance requires states to collect an inordinate amount of data on student attendance and learning modes using systems that most states did not have in place. This made it and continues to make it difficult for states to respond to P-EBT without time to build capacity, contributing to issuance delays, and will manifest in any future emergency without efforts to simplify.

The ARPA extended P-EBT to include summer 2021, and any other summer following a school year with a public health emergency designation. Forty-seven states and territories were approved for summer 2021 benefits, though 23 of these were not approved until mid-July or later. This means many benefits either came at the end of the summer, or after the following school year had started, which was too late for many families. 

How many students could miss out on benefits?

If school year plan approval rates remain low, there could be an extensive gap in benefit coverage and ill-timed benefit disbursement for eligible students across the nation. As of the date of this publication, FNS has posted approved school year plans for 12 states, including Colorado, Delaware, Indiana, Michigan, Minnesota, New Mexico, North Carolina, Ohio, Rhode Island, Vermont, Virginia, and Wisconsin.

Using USDA P-EBT Summer 2021 student eligibility data (PDF) and assuming all states currently approved for school year P-EBT also submit a summer plan, it’s estimated that only 17.7 percent—about 1 in 5 eligible children—would receive benefits as current school year approvals stand, leaving more than 24 million children without summer food support. Even for those states that have approved school year plans and are on track to provide P-EBT, disbursing benefits on time (during the summer and not after) is contingent on receiving simplified summer plan guidance quickly enough from FNS for states to put together a plan. Last year, summer guidance was provided in April, leaving very little time for states to plan.

These estimates do not include some students and children younger than 6 years. In previous years, a pathway was made to provide benefits to children younger than 6 in the 2020–21 school year and summer. However, even if passed, the Build Back Better framework does not address this population, and because of the complexity of administering benefits to this population, FNS has instructed states not to submit plans for children younger than 6. Moreover, the pandemic prompted most states to create full-time virtual academies. But because students in virtual academies are not eligible for school year P-EBT, they are also ineligible for summer benefits

What states need so students don’t experience a gap in food benefits

  1. Simplification: States would be more likely to provide summer benefits if plan requirements for the current school year were simplified. The complexity (PDF) of administering P-EBT in the 2021–22 school year, with sporadic and near-constant uncertainty because of the omicron variant, is holding many states back from a meaningful response and making it challenging for states to plan for summer. Flexibility and simplified guidance would enable states awaiting school year approval or have yet to submit school year plans to focus on preparing for summer.
  2. Timeliness: An expedited guidance and approval process from FNS is the only way students can efficiently receive summer assistance. In previous iterations, the process from plan creation to implementation took months. Pandemic times are fast moving and ever changing, but providing Summer EBT guidance to states sooner than April (PDF), the timing of summer 2021 guidance, could result in food-insecure students receiving summer support when they most need it for the first time in the program’s existence.
  3. Advocate support: States would benefit from increased antihunger awareness, support, and mobilization from those interested in bringing more attention to the coverage gap children will experience this summer and the need for simplification, to ensure food-insecure students are provided for given the options currently available.


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Research Areas Education
Tags Secondary education Head Start and elementary education School breakfast and lunch
Policy Centers Income and Benefits Policy Center
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