Improving Emergency Nutrition Response for Families: State Perspectives on P-EBT Implementation from the 2020-21 School Year

By Elaine Waxman and Poonam Gupta    October 28, 2021

This is the seventh of a multi-part blog series that will take a detailed look at the American Rescue Plan and the ways in which we can leverage it to strengthen the resiliency of our public health and human services infrastructure, and, in turn, substantially move the needle on social and economic mobility so families succeed for the long run.

Read Additional Posts from the American Rescue Plan Series:
Part 1   |   Part 2   |   Part 3   |   Part 4   |   Part 5   |   Part 6   |   Part 7   |   Part 8   |   Part 9

The Pandemic Electronic Benefits Transfer (P-EBT) program was first launched in spring 2020 as an effort to address the loss of access to free and reduced-price school meals due to widespread school closures at the onset of the COVID-19 pandemic. The goal was to provide timely benefits that would replace the value of school meals lost during the shutdown. All 50 states and territories ultimately implemented a P-EBT program in the spring of 2020, and these benefits were highly valuable to families in buffering the full extent of food insecurity they may have faced during this uncertain time.

While states generally assumed the P-EBT program would be a short-term temporary intervention, as fall 2020 drew near, hopes for a smooth transition to in-person learning faded. Schools “re-opened” across the country in a shifting mix of fully virtual, hybrid, and in-person formats and families lacked consistent access to school meals. However, a variety of implementation challenges, stemming from both delays in Congressional and USDA action and internal state barriers, resulted in many students going without the intended assistance until spring, and in some cases, summer 2021.

In order to understand the challenges states faced in delivering P-EBT benefits during school year 2020-21, the American Public Human Services Association (APHSA) and the researchers at the Urban Institute partnered to follow states’ decision-making process in real time as administrators navigated changing legislative and administrative environments and devised strategies to address the challenges they encountered. While much of the work on P-EBT assesses its impact on families and children, our research focused on the administrators themselves, providing a unique vantage point into the struggles of launching a new benefit program during a pandemic with limited guidance and immense pressure. In a newly released report, we dive into the challenges of launching this program during the 2020-21 school year and reflect on considerations and recommendations for future emergency situations.

In a series of conference calls, focus groups, and individual interviews with state administrators during fall 2020 and spring 2021, we found that states identified a series of external challenges arising from decisions and processes occurring at the federal level that prohibited administrators from having sufficient time to plan and administer benefits within the school year. These challenges included, but were not limited to:

  • Delays in congressional authorization for a full SY 2020-21 program. There was no Congressional authorization for a full school year 2020-21 program until October 2020, and when it came, the new parameters made it clear that states would need to devise an entirely new benefit approach based on the ability to track student attendance patterns and tailor benefits to different learning modes.
  • A lack of timely and clear guidance from FNS about how to implement P-EBT, which created challenges and delays when states sought to obtain approval for their plans. Initial guidance to states from USDA on how to implement the requirements lagged into mid-November and failed to fully resolve many state questions. By the time that Congress provided additional clarifying language in late December and new USDA guidance was issued in January, children across the country had been in school for almost half a year.
  • Untimely administrative funding, which impeded states’ ability to adequately staff their teams.

States also faced significant internal challenges emerging from a lack of infrastructure and capacity within their state, including:

  • Serious barriers to obtaining quality data needed to administer & physically issue benefits, including issues with data sharing between SNAP and education entities, assessing eligibility, and tracking constantly shifting school status;
  • Limited precedent for coordination between state and local SNAP and child nutrition stakeholders. States needed to establish an entirely new type of partnership between SNAP and DOE/child nutrition stakeholders in a very short time period. Two entities with limited preexisting relationships, very different methods of handling data, and no infrastructure to share the full range of required data had to rapidly develop a partnership to implement this program, which understandably led to a great deal of confusion and challenges.
  • Staffing constraints and limited resources to keep up with data infrastructure & customer services requests; and

However, the most challenging requirement encountered by states was USDA’s requirement to tailor benefits to the wide variety of student attendance modes that were emerging in the new school year.

This complicated mix of learning models for the school year was fundamentally different from the spring 2020 benefit issuing environment, which in some ways was easier as schools were essentially uniformly closed across the country. the need for accurate and timely data on individual school and student attendance patterns as the single largest obstacle to being able to launch a timely program.

Initial hopes that Congressional language providing for “simplifying assumptions” to develop state plans for administering P-EBT were not borne out by subsequent USDA guidance. As one state administrator observed, “simplifying assumptions were anything but simple.”

Many states did not have centralized databases that could track individual student attendance. In many cases, data on learning modes used by individual schools or school districts weren’t systematically available from state education agencies and often had to be collected through a time-consuming process using individual spreadsheets including tens or hundreds of thousands of students and a lengthy data-matching process. States were acutely aware that the absence of readily available data would lead to significant delays in not only plan submission but also plan approval and ultimately issuing benefits.

Ultimately, these delays in assistance occurred despite the collective best intentions of all stakeholders to assist families struggling with the loss of school meals.


Our new report includes several recommendations for how future iterations of these types of programs could more efficiently meet the intended goal: to ensure families receive timely resources during a national emergency. These recommendations can apply to programs operating either in emergency situations, or in building an infrastructure for wider use during the summer months to further the mission of reducing childhood food insecurity. Many of these recommendations are based on feedback from state agencies administering P-EBT based on their assessment of the strengths and weaknesses of the SY 2020–21 implementation process. These include:

  • Considering a standing authority for a P-EBT program that automatically kicks in during periods when in-person school learning is disrupted.
  • Providing timely, clear guidance, and establishing simple and feasible options for state implementation wherever possible.
  • Simplifying data collection requirements, and allowing for a national, standardized benefit for all eligible children.
  • Increasing flexibilities in allowable uses for administrative funding so states can build infrastructure.
  • Examining existing infrastructure around EBT card stock to shorten the time between benefit authorization and receipt and investing in infrastructure around digital wallet/mobile EBT.

Overall, states agree that any design of future iteration should consult with states on the administrative side of rolling out a new program before moving forward. This includes all relevant stakeholders—in this case, involving SNAP agencies, DOEs, and schools alongside the families receiving benefits in the program planning at the national level would have saved a great deal of time. While this report focused on the perspectives of states, more insights are needed to understand how barriers faced by states translated to the experiences felt by families and children. Building on existing insights rather than building a new program entirely will also be useful. As one state mentioned, the real tragedy would be if all their work was for nothing and that building off the existing framework would be critical.

Read Additional Posts from the American Rescue Plan Series:
Part 1   |   Part 2   |   Part 3   |   Part 4   |   Part 5   |   Part 6   |   Part 7   |   Part 8   |   Part 9

About the Author

Elaine Waxman is a senior fellow in the Income and Benefits Policy Center at the Urban Institute. Her expertise includes food insecurity, nutrition and the food assistance safety net, the social determinants of health disparities, and other issues affecting low-income families and communities.

Poonam Gupta is a research analyst in the Income and Benefits Policy Center, where she focuses on social safety net policies and issues related to nutrition, food access, and food insecurity.

Improving Emergency Nutrition Response for Families: State Perspectives on P-EBT Implementation from the 2020-21 School Year

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