Report - Covid19 Fns Pandemic Ebt Interim Report
Summary
A USDA Office of Inspector General interim report on the Food and Nutrition Service's Pandemic Electronic Benefits Transfer (P-EBT), Inspection Report 27801-0001-23(1), dated June 24, 2022, from Gil Harden, Assistant Inspector General for Audit, to Cindy Long of the Food and Nutrition Service. It covers three of six objectives of an ongoing inspection: funding, outreach, and the criteria used to approve State plans. It found the Secretary authorized $37.1 billion to the States from March 18, 2020, through March 31, 2021, that the agency did outreach through webinars and phone calls, and that it used the legislative eligibility requirements to create State plan templates. It identified no issues and made no recommendations.
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“Report - Covid19 Fns Pandemic Ebt Interim Report.”
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OFFICE OF INSPECTOR GENERAL
U. S. DEPARTMENT OF AGRICULTURE
COVID-19―Food and Nutrition
Service's Pandemic Electronic
Benefits Transfer―Interim Report
Inspection Report 27801-0001-23(1)
June 2022
COVID-19—Food and Nutrition Service’s
Pandemic Electronic Benefits Transfer
Inspection Report 27801-0001-23(1)
Our ongoing inspection is reviewing P‑EBT—this report provides the results
on Objectives 1, 3, and 4 for P‑EBT funding and outreach activities, and the
procedures and criteria FNS used to approve State plans.
OBJECTIVE WHAT OIG FOUND
Our ongoing inspection has six The Pandemic Electronic Benefits Transfer (P-EBT),
objectives. This report addresses administered by the United States Department of
the following three objectives. Agriculture’s (USDA) Food and Nutrition Service (FNS),
Objective 1: What were the
provided benefits loaded on EBT cards for the purchase
P‑EBT budget authorities, and
what P-EBT funding amounts
of food in lieu of the meals that the children would have
did the Secretary authorize to received in school. The Families First Coronavirus
the States, as applicable through Response Act (FFCRA) authorized the establishment of
March 31, 2021?; Objective 3: P-EBT temporary assistance for households with children
What outreach activities did affected by school closures due to the coronavirus
FNS conduct to maximize State disease 2019 (COVID-19) pandemic.
participation in P-EBT assistance?;
and Objective 4: What procedures The Secretary authorized $37.1 billion to the States from
and criteria did FNS use to approve P-EBT’s March 18, 2020, inception through
State plans for the distribution of
March 31, 2021, with the Office of Management
P-EBT funds, including funds for
Supplemental Nutrition Assistance
and Budget’s (OMB) approval. We also found that
Program (SNAP) and non-SNAP during the period reviewed, FNS conducted outreach
participants? activities—such as webinars, phone calls, and written
documentation—to maximize State participation in
P-EBT assistance.
REVIEWED
Finally, FNS did not develop formal procedures to
We reviewed applicable laws, distribute P‑EBT funds because P-EBT provided
regulations, and informal temporary emergency assistance benefits. Instead, FNS
procedures; interviewed FNS used the legislative eligibility requirements to develop
officials; reviewed total P-EBT State plan templates and released guidance for State
funding amounts authorized agencies to submit their proposed plans to FNS for
to the States; and reviewed
approval.
apportionment reports from
OMB through March 31, 2021.
We did not identify any issues that would warrant
recommendations; therefore, we are not making any
RECOMMENDS recommendations in this report.
We did not make any
recommendations in this report.
OFFICE OF INSPECTOR GENERAL
United States Department of Agriculture
DATE: June 24, 2022
INSPECTION
NUMBER: 27801-0001-23(1)
TO: Cindy Long
Administrator
Food and Nutrition Service
ATTN: Melissa Rothstein
Director
Office of Internal Controls, Audits and Investigations
FROM: Gil Harden
Assistant Inspector General for Audit
SUBJECT: COVID-19—Food and Nutrition Service’s Pandemic Electronic Benefit Transfer
This report presents the results of the subject review. We do not have any recommendations in
the report and, therefore, no further response to this office is necessary.
We appreciate the courtesies and cooperation extended to us by members of your staff during our
inspection fieldwork and subsequent discussions. This report contains publicly available
information and will be posted in its entirety to our website (https://usdaoig.oversight.gov) in the
near future.
Table of Contents
Background and Objectives ................................................................................... 1
Objective 1: What were the P-EBT budget authorities, and what P‑EBT
funding amounts did the Secretary authorize to the States, as applicable,
through March 31, 2021? ....................................................................................... 4
Objective 3: What outreach activities did FNS conduct to maximize State
participation in P-EBT assistance? ....................................................................... 6
Objective 4: What procedures and criteria did FNS use to approve State
plans for distribution of P-EBT funds, including funds for SNAP and non-
SNAP participants?................................................................................................. 7
Scope and Methodology ........................................................................................ 10
Abbreviations ........................................................................................................ 11
Exhibit A: SY 2019–2020..................................................................................... 12
Exhibit B: SY 2020-2021 ..................................................................................... 15
Background and Objectives
Background
The Pandemic Electronic Benefits Transfer (P-EBT), which is administered by the United States
Department of Agriculture’s (USDA) Food and Nutrition Service (FNS), provides households
with eligible children, benefits loaded on EBT cards 1 for the purchase of food in lieu of the
meals that they would have received in school. 2 (See Objective 4 for more detail on State
participation). The Families First Coronavirus Response Act (FFCRA) 3 authorized the
establishment of temporary P-EBT assistance for households with children affected by school
closures due to the coronavirus disease 2019 (COVID-19) pandemic. 4
FNS utilized State plans, as authorized by the FFCRA, 5 to approve specific details of a State
agency’s approach to distributing P-EBT funding. FNS developed State plan templates that
included information such as:
• date range covered;
• estimated monthly and total amount of P-EBT benefits the State plans would issue;
• estimated number of children the State would issue P-EBT benefits for, including the
number of children in Supplemental Nutrition Assistance Program (SNAP) households
and number of children in non-SNAP households;
• estimated amount of administrative funding the State would need to administer P-EBT
benefits; and
• estimated P-EBT benefit issuance schedule.
Furthermore, the FFCRA provides that—for each eligible child in a household—the Secretary
shall approve P-EBT benefits for no less than the value of meals that the child would have
received in school for 5 consecutive school days. 6 FNS determined P-EBT benefits based on the
following NSLP and SBP reimbursement rates. (See Table 1 and Table 2). The P-EBT benefit
amount was calculated by multiplying the free reimbursement daily rate by the number of days
that a child was eligible for benefits (i.e. they do not attend school in person and do not have
access to a meal service due to COVID-19).
1
State agencies were allowed and opted to provide P-EBT assistance through the EBT card system established
under the Supplemental Nutrition Assistance Program (Supplemental Nutrition Assistance Program: Pandemic
Electronic Benefit Transfer (P-EBT) Integrity, 85 Fed. Reg. 70043-70044, 214 (Nov. 4, 2020)). (See Objective 4
for more detail on State participation).
2
FNS’ National School Lunch Program (NSLP) and School Breakfast Program (SBP) provide nutritious meals to
children during each school day.
3
Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 179, Section 1101 (2020).
4
In January 2020, the Secretary of Health and Human Services declared the COVID-19 pandemic, a public health
emergency for the United States. COVID-19 is an infectious disease caused by a newly discovered coronavirus.
5
Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 179, Section 1101 (2020).
6
Ibid.
INSPECTION REPORT 27801-0001-23(1) 1
School Year (SY) 2019–2020 Free
July 1, 2019–June 30, 2020 Reimbursement
Daily Total
Contiguous United States $5.70
Alaska $9.16
Hawaii, Guam, Virgin Islands $6.66
Table 1: The table above is the daily total free reimbursement amount. 7
SY 2020–2021 Free
July 1, 2020–June 30, 2021 Reimbursement
Daily Total
Contiguous United States $6.82
Alaska $10.99
Hawaii, Guam, Virgin Islands, Puerto Rico $7.97
Table 2: The table above is the daily total free reimbursement amount. 8 (The daily benefit
for SY 2020–2021 includes the value of an afterschool snack). 9
Each school year, States must submit new plans for FNS’ review and approval before they can
issue P-EBT benefits to households with eligible children. Under FFCRA, a child was eligible
for P-EBT benefits if they met two conditions: (1) the child was eligible to receive free or
reduced-price meals at school; and (2) the child did not receive the meals because, due to
COVID-19, the school was closed for at least 5 consecutive days. Once a school met the
minimum 5-day threshold, children were eligible to receive P-EBT benefits for any additional
school closure due to COVID-19. In addition, children enrolled in a Community Eligibility
Provision (CEP) 10 school or a school operating under Provisions 2 or 3 11 were eligible to receive
P-EBT benefits if they attended a school closed for at least 5 consecutive days due to the public
health emergency. 12 Legislation 13 later expanded P‑EBT to account for reduced attendance or
hours for school children, children in child care facilities, any school year in which there is a
public health emergency designation, and any covered summer period. (See Objective 1 for
more details).
7
USDA FNS, Pandemic EBT (P-EBT) Questions and Answers, Memorandum (2020).
8
USDA FNS, State Plan for Pandemic EBT: Children in School and Child Care, 2020-2021, Memorandum (2021).
9
On January 29, 2021, FNS issued a memo stating the daily P-EBT benefits, for both school children and children
in child care, included the value of the free reimbursement for an afternoon snack. The States could retroactively
apply the new, higher benefit back to the beginning of SY 2020–2021.
10
CEP is a non-pricing meal service option for schools and school districts in low-income areas. CEP allows the
Nation’s highest poverty schools and districts to serve breakfast and lunch at no cost to all enrolled students without
collecting household applications.
11
Congress incorporated into Section 11(a)(1) of the Richard B. Russell National School Lunch Act alternative
provisions to traditional requirements for annual determinations of eligibility for free or reduced price school meals
and daily meal counts by type.
12
USDA FNS, Pandemic EBT (P-EBT) Questions and Answers, Memorandum (2020).
13
Continuing Appropriations Act, 2021, and Other Extensions Act, Pub. L. No. 116-159, 134 Stat. 744,
Section 4601 (2020); Consolidated Appropriations Act, Pub. L. No. 116-260, 134 Stat. 1182 (2020); American
Rescue Plan Act, Pub. L. No. 117-2, 135 Stat. 4, Section 1108 (2021).
2 INSPECTION REPORT 28701-0001-23(1)
Objectives
Our objective was to review the key aspects of the FNS’ funding and administration of P-EBT
assistance. Specifically, we addressed the following three questions: 14
Objective 1: What were the P-EBT budget authorities, and what P-EBT funding amounts did the
Secretary authorize to the States, as applicable through March 31, 2021?
Objective 3: What outreach activities did FNS conduct to maximize State participation in P-EBT
assistance?
Objective 4: What procedures and criteria did FNS use to approve State plans for the
distribution of P-EBT funds, including funds for Supplemental Nutrition Assistance Program
(SNAP) and non-SNAP participants?
We did not identify any reportable issues for Objectives 1, 3, and 4.
14
During the course of our inspection, we plan to issue additional interim report(s) as we complete the remaining
three Objectives: 2, 5, and 6.
INSPECTION REPORT 27801-0001-23(1) 3
Objective 1: What were the P-EBT budget authorities, and what
P‑EBT funding amounts did the Secretary authorize to the States, as
applicable, through March 31, 2021?
The legislative history, as depicted below, outlines the budget authorities that established P‑EBT
for households with children affected by school or child care closures due to the COVID‑19
pandemic.
Figure 1: The legislative history of P-EBT and the changes enacted per legislation.
4 INSPECTION REPORT 28701-0001-23(1)
From P-EBT’s inception through March 31, 2021, the Secretary 15—with the approval of the
Office of Management and Budget (OMB)—authorized a total of $37.1 billion to the States. 16
From March 18, 2020 through September 30, 2020, the Secretary authorized $12.8 billion based
on the approval of 52 State plans for SY 2019‒2020 (See Exhibit A for approved State plans),
and 20 State plans for SY 2020‒2021. (See Exhibit B for State plans, approvals through
September 30, 2020). From October 1, 2020 through March 31, 2021, the Secretary authorized
$24 billion based on the approval of 36 State plans. (See Exhibit B for approved State plans). 17
Additionally, $300 million was approved for administrative costs. The figure below describes
the total funding authorized by each eligible category. 18
Figure 2: The history of P-EBT funding authorized by the Secretary, to the States, through March 31, 2021.
15
The USDA Office of Budget and Program Analysis (OBPA) prepares estimates and other appropriations for
USDA. OBPA leads the USDA annual planning, budgeting, and execution process. The OBPA Deputy Director for
Budget Execution authorized FNS’ P-EBT funding before submitted to OMB.
16
The FFCRA authorized FNS to administer P-EBT through the approval of State plans. (See Objective 4 for more
detail on the process). FNS officials explained that the State plan was the State’s proposal for the implementation of
P-EBT and estimated program participation.
17
The $24 billion approved on February 24, 2021, was increased to a total of $44 billion, which was approved on
July 9, 2021. The increase in funding covered school children, child care facilities, and summer benefits through
September 30, 2021.
18
An FNS official stated that P-EBT operates on the SNAP EBT system and, therefore, functions under already
established SNAP agreements. As States issue P-EBT benefits, the funds are drawn against the total authorization.
INSPECTION REPORT 27801-0001-23(1) 5
Objective 3: What outreach activities did FNS conduct to maximize
State participation in P-EBT assistance?
The following figure illustrates the outreach activities that FNS implemented to maximize State
participation in P-EBT assistance.
Figure 3: Examples of outreach activities conducted by FNS headquarters.
FNS officials stated that a P-EBT team was assembled—including representatives from SNAP
and Child Nutrition program offices, and FNS’ Office of Financial Management—to perform
P‑EBT activities on a part-time basis. Additionally, FNS officials explained that the team was
responsible for conducting outreach for P-EBT, including the activities identified in Figure 3.
We recognize FNS’ outreach efforts to quickly issue memoranda to States, as the FFCRA
authorized the establishment of P-EBT on March 18, 2020, and, 2 days later, on March 20, 2020,
FNS issued a State Plan template. FNS developed State plan templates to approve details of a
State agency’s approach to distribute P-EBT funding. States were required to complete a State
plan to participate in P-EBT. For SY 2019‒2020, FNS approved 47 of the 52 (90 percent) State
plans for P-EBT within 3 months of FFCRA. Furthermore, all 52 State plans were approved
within 5 months of FFCRA. 19
19
In SY 2019-2020, all 50 States, the District of Columbia, and the Virgin Islands had approved State plans for
P‑EBT participation. (See Exhibit A). For SY 2020–2021, 33 States, the District of Columbia, Puerto Rico, and the
Virgin Islands, had approved State plans as of March 31, 2021. (See Exhibit B). The remaining 26 State plans for
SY 2020–2021 were outside the scope period of this review.
6 INSPECTION REPORT 28701-0001-23(1)
Objective 4: What procedures and criteria did FNS use to approve
State plans for distribution of P-EBT funds, including funds for
SNAP and non‑SNAP participants?
FNS did not develop formal procedures to distribute P-EBT funds because P-EBT provided
temporary emergency assistance. Instead, FNS used the legislative eligibility requirements to
develop State plan templates and release guidance for State agencies to submit their proposed
plans to FNS for approval. An FNS official stated there was uncertainty about both the school
closure and re-opening timeframes and whether P‑EBT was going to be extended beyond
SY 2019–2020. The FFCRA authorized the Secretary to distribute P-EBT through the approval
of State agency plans. 20 Within the State plan template, States were expected to provide the
number of estimated SNAP and non-SNAP households to receive P-EBT benefits. The figure
below illustrates FNS’ State plan approval process.
Figure 4: P-EBT process for State plan approval.
20
Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 179, Section 1101 (2020).
INSPECTION REPORT 27801-0001-23(1) 7
FNS used the legislative eligibility requirements to develop State plan templates and release
guidance for State agencies to submit their proposed plans to FNS for approval. Through
continuous legislative changes, 21 FNS provided guidance to State agencies in the form of
memoranda, State templates, and Questions and Answers (Q&A) to expedite the issuance of
funds to the States. For SY 2019–2020, FNS approved State plans from 50 States, the District of
Columbia, and the Virgin Islands. For SY 2020–2021, through March 31, 2021, FNS approved
State plans for 33 States, the District of Columbia, Puerto Rico, and the Virgin Islands. 22 The
figure below displays the month that FNS approved State plans.
Figure 5: SY 2019–2020 and SY 2020–2021 maps show the month FNS approved P-EBT State plans.
FNS used the estimated P-EBT benefit amounts from approved State plans to determine the
estimated funding amounts that the Secretary would authorize to the States. During
SY 2019–2020, FNS approved estimated funds of more than $10.1 billion for 52 State plans.
(See Exhibit A). For SY 2020–2021, through March 31, 2021, FNS approved estimated funds of
more than $15.8 billion for 36 State plans. (See Exhibit B). 23
21
Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 179, Section 1101 (2020); Continuing
Appropriations Act, 2021, and Other Extensions Act, Pub. L. No. 116-159, 134 Stat. 744, Section 4601 (2020);
Consolidated Appropriations Act, Pub. L. No. 116-260, 134 Stat. 1182 (2020); American Rescue Plan Act, Pub. L.
No. 117-2, 135 Stat. 4, Section 1108 (2021).
22
Included in the 36 State plans, FNS also reviewed and approved 7 State plans for child care facilities. States and
territories had to submit State plans to participate in P-EBT.
23
Figure 2 depicts funding authorized by the Secretary to the States, including a total of $24 billion for
SY 2020–2021. Exhibit B includes the total of more than $15.8 billion authorized for SY 2020-2021, through
March 31, 2021. However, there were an additional 26 State plans approved totaling more than $14.3 billion
authorized that were outside the scope of our inspection.
8 INSPECTION REPORT 28701-0001-23(1)
Because the American Rescue Plan Act of 2021 24 eliminated the P-EBT’s September 30, 2021,
expiration, P-EBT benefits are available for the duration of the public health emergency.
24
American Rescue Plan Act, Pub. L. No. 117-2, 135 Stat. 4, Section 1108 (2021).
INSPECTION REPORT 27801-0001-23(1) 9
Scope and Methodology
We conducted an inspection to review key aspects of FNS’ funding for and implementation of
P‑EBT assistance. We performed our inspection remotely, with FNS headquarters officials. The
inspection scope covered P-EBT funding amounts authorized by the Secretary for
SY 25 2019–2020 and SY 2020–2021 through March 31, 2021. We conducted our fieldwork
from May 2021 through April 2022.
To accomplish our inspection objectives, we:
• Obtained and reviewed applicable laws, regulations, and informal procedures associated
with P-EBT;
• Interviewed FNS officials to determine the implementation of the P-EBT benefits;
• Interviewed FNS officials and reviewed documentation to determine how the agency
conducted outreach to stakeholders;
• Interviewed FNS officials to determine the budget authorities and reviewed total P-EBT
funding amounts authorized to the States; and
• Reviewed appropriation reports from OMB that identified the P-EBT funding amounts
approved for the program.
We conducted this inspection in accordance with the Council of the Inspectors General on
Integrity and Efficiency (CIGIE) Quality Standards for Inspection and Evaluation. 26 These
standards require that we obtain sufficient, competent, and relevant evidence to provide a
reasonable basis for our conclusions based on our inspection objectives. We believe that the
evidence obtained provides a reasonable basis for our conclusions based on our inspection
objectives.
25
A school year covers the months of July 1 through June 30.
26
Council of the Inspectors General on Integrity and Efficiency, Quality Standards for Inspection and Evaluation
(Jan. 2012).
10 INSPECTION REPORT 28701-0001-23(1)
Abbreviations
CEP ........................................Community Eligibility Provision
CIGIE .....................................Council of the Inspectors General on Integrity and Efficiency
COVID-19..............................coronavirus disease 2019
FFCRA ...................................Families First Coronavirus Response Act
FNS ........................................Food and Nutrition Service
NSLP ......................................National School Lunch Program
OBPA .....................................Office of Budget and Program Analysis
OIG ........................................Office of Inspector General
OMB ......................................Office of Management and Budget
P-EBT ....................................Pandemic Electronic Benefit Transfer
Q&A.......................................Questions and Answers
SBP ........................................School Breakfast Program
SNAP .....................................Supplemental Nutrition Assistance Program
SY ..........................................school year
USDA.....................................United States Department of Agriculture
INSPECTION REPORT 27801-0001-23(1) 11
Exhibit A: SY 2019–2020
This exhibit summarizes the amount of P-EBT funding authorized 27 to each State for eligible
school children during SY 2019–2020.
Count State State Plan Approval Approved State Plan Total Approved State
Date Estimated Funding Plan Estimated
Funding 28
1 Alabama 4/21/2020 $127,718,333 $131,850,000 29
5/22/2020 $4,100,000
9/8/2020 30 $50,000
2 Alaska 6/4/2020 $31,100,000 $46,100,000
2/12/2021 31 $15,000,000
3 Arizona 4/17/2020 $186,740,000 $220,500,000 32
5/28/2020 $33,800,000
4 Arkansas 5/21/2020 $96,695,280 $96,695,280
5 California 4/23/2020 $1,400,000,000 $1,448,000,000 33
5/15/2020 $43,000,000
6 Colorado 5/16/2020 $101,297,925 $101,297,925
7 Connecticut 4/24/2020 $72,300,000 $98,463,000 34
5/5/2020 $26,163,000
8 Delaware 4/30/2020 $37,050,001 $37,050,001
9 District of 5/19/2020 $26,400,000 $26,400,000
Columbia
27
For the purposes of this report, we used the term funding authorized to describe the estimated funding amounts
approved through the State plan approval process. An FNS official stated that the funding authorized amounts did
not represent actual funds spent for P-EBT and that the funding authorized amounts did not limit or prevent States
from requesting additional P-EBT funds.
28
The total approved State plan estimated funding amounts are listed as included in the approval letters. For
example, Arizona’s first approval letter included exact dollar amounts, but the amendment included an increase from
$186.7 million to $220.5 million. As a result, the total State plan estimated funding in the approval letter does not
equal the sum of the two separate estimated funding amounts.
29
The April 21, 2020 State plan approval letter included exact dollar amounts, while the subsequent amendment
approval letter included the amount of $127.7 million increased to $131.8 million. As a result, the total State plan
estimated funding in the approval letter does not equal the sum of the three separate estimated funding amounts.
30
Approval in September 2020 was an amendment to SY 2019–2020 State plans. When there was a change in their
P-EBT implementation process, States were required to submit amendments.
31
Alaska requested an amendment to its SY 2019–2020 State plan, which FNS approved in February 2021.
32
The April 17, 2020, State plan approval letter included exact dollar amounts, while the subsequent amendment
approval letter included $186.7 million increased to $220.5 million. As a result, the total State plan estimated
funding in the approval letter does not equal the sum of the two separate estimated funding amounts.
33
The April 23, 2020, State plan approval letter included $1.4 billion, while the subsequent amendment approval
letter included $1.405 billion increased to $1.448 billion. As a result, the total State plan estimated funding in the
approval letter does not equal the sum of the two separate estimated funding amounts.
34
The April 24, 2020, State plan approval letter included $72.3 million, while the subsequent amendment approval
letter included exact dollar amounts. As a result, the total State plan estimated funding in the approval letter does
not equal the sum of the two separate estimated funding amounts.
12 INSPECTION REPORT 28701-0001-23(1)
Count State State Plan Approval Approved State Plan Total Approved State
Date Estimated Funding Plan Estimated
Funding 28
10 Florida 5/27/2020 $743,800,000 $743,800,000
11 Georgia 6/5/2020 $264,400,000 $264,400,000
12 Hawaii 5/28/2020 $29,300,000 $29,300,000
13 Idaho 8/13/2020 $38,900,000 $38,900,000
14 Illinois 4/17/2020 $204,489,187 $383,417,226
5/4/2020 $178,928,039
15 Indiana 5/15/2020 $171,410,400 $171,410,400
16 Iowa 6/5/2020 $69,494,468 $69,494,468
17 Kansas 4/25/2020 $69,300,000 $69,300,000
18 Kentucky 5/19/2020 $163,020,000 $163,020,000
19 Louisiana 5/14/2020 $174,300,000 $208,700,000
6/4/2020 $34,400,000
20 Maine 5/5/2020 $16,900,000 $16,900,000
21 Maryland 4/28/2020 $68,600,000 $173,325,828
6/11/2020 $104,725,828
22 Massachusetts 4/17/2020 $100,707,800 $201,415,600
4/29/2020 $100,707,800
23 Michigan 4/9/2020 $336,699,000 $336,699,000
24 Minnesota 5/27/2020 $113,700,000 $113,700,000
25 Mississippi 6/1/2020 $91,400,000 $91,400,000
26 Missouri 5/15/2020 $138,316,008 $138,316,008
27 Montana 6/26/2020 $30,200,000 $30,200,000
28 Nebraska 6/16/2020 $43,900,000 $43,900,000
29 Nevada 7/9/2020 $99,000,000 $99,000,000
30 New 5/12/2020 $17,337,177 $17,337,177
Hampshire
31 New Jersey 5/8/2020 $248,400,000 $250,900,000
7/16/2020 $2,500,000
32 New Mexico 4/28/2020 $97,700,000 $97,700,000
33 New York 5/6/2020 $717,100,000 $885,820,000
5/8/2020 $168,720,000
34 North 4/16/2020 $238,260,000 $336,900,000 35
Carolina 6/19/2020 $98,600,000
35 North Dakota 5/1/2020 $10,853,711 $10,853,711
36 Ohio 5/11/2020 $254,500,000 $254,500,000
37 Oklahoma 6/25/2020 $111,000,000 $111,000,000
38 Oregon 4/29/2020 $134,300,000 $134,300,000
39 Pennsylvania 5/6/2020 $354,900,000 $354,900,000
35
The April 16, 2020, State plan approval letter included exact dollar amounts, while the subsequent amendment
approval letter included $238.2 million increased to $336.9 million. As a result, the total State plan estimated
funding in the approval letter does not equal the sum of the two separate estimated funding amounts.
INSPECTION REPORT 27801-0001-23(1) 13
Count State State Plan Approval Approved State Plan Total Approved State
Date Estimated Funding Plan Estimated
Funding 28
40 Rhode Island 4/10/2020 $14,187,129 $26,700,000 36
4/29/2020 $13,257,470
7/22/2020 $200,000
41 South 6/17/2020 $154,500,000 $154,500,000
Carolina
42 South Dakota 6/18/2020 $13,365,075 $13,365,075
43 Tennessee 5/19/2020 $180,100,000 $188,800,000
8/7/2020 $8,700,000
44 Texas 5/8/2020 $1,015,100,000 $1,015,100,000
45 Utah 7/7/2020 $67,100,000 $67,100,000
46 Vermont 5/4/2020 $14,700,000 $14,700,000
47 Virgin Islands 6/9/2020 $5,600,000 $5,600,000
48 Virginia 4/25/2020 $219,300,000 $219,300,000
49 Washington 5/22/2020 $191,200,000 $191,200,000
50 West Virginia 4/30/2020 $72,400,000 $72,400,000
51 Wisconsin 4/22/2020 $142,400,000 $142,400,000
52 Wyoming 5/16/2020 $6,056,250 $6,056,250
TOTAL 37 $10,164,419,949
36
The April 10, 2020, State plan approval letter included exact dollar amounts, while the subsequent amendment
approval letter included $26.5 million increase to $26.7 million. As a result, the total State plan estimated funding in
the approval letter does not equal the sum of the three separate estimated funding amounts.
37
In Figure 2, the Secretary authorized $12.8 billion in funding, from March 18, 2020 through September 30, 2020.
Exhibit A summarizes each State’s estimated funding approved through State plans for SY 2019‒2020. The
difference of more than $2.6 billion is the difference between the overall amount authorized by the Secretary and the
actual breakdown, by State, of SY 2019‒2020 State plan approvals.
14 INSPECTION REPORT 28701-0001-23(1)
Exhibit B: SY 2020–2021
This exhibit summarizes the amount of P-EBT funding the Secretary authorized to each State for
SY 2020–2021, through March 31, 2021. 38
State Plan Approvals
School Child
Children State Plan Care State State Plan Total State Plan
Count
State State Plan Estimated Plan Estimated Estimated
Approval Funding Approval Funding Funding
Date Date
1 Arizona 2/25/2021 $505,300,000 2/25/2021 $130,900,000 $636,200,000
2 California 09/21/2020 $654,200,000 $654,200,000
3 Connecticut 2/25/2021 $220,000,000 $220,000,000
09/25/2020 $12,300,000 $103,600,000
4 Delaware
2/17/2021 $91,300,000
District of 9/21/2020 $7,400,000 $101,400,000
5
Columbia 3/22/2021 $80,700,000 3/22/2021 $13,300,000
6 Florida 3/1/2021 $1,200,000,000 $1,200,000,000
09/15/2020 $27,300,000 $127,300,000
7
Hawaii 3/16/2021 $100,000,000
8 Idaho 3/23/2021 $65,500,000 $65,500,000
$200,000,000 $974,600,000
9 09/16/2020
Illinois 1/28/2021 $774,600,000
09/21/2020 $60,000,000 $331,700,000
10 Indiana
12/30/2020 $174,500,000 3/1/2021 $97,200,000
09/18/2020 $108,000,000 $698,000,000
11 Kentucky
2/24/2021 $590,000,000
12 Maryland 9/16/2020 $47,500,000 $47,500,000
09/16/2020 $60,600,000 $591,300,000
13 Massachusetts
12/15/2020 $412,400,000 3/3/2021 $118,300,000
14 Michigan 2/4/2021 $741,600,000 $741,600,000
15 Minnesota 2/8/2021 $372,800,000 $372,800,000
16 Montana 9/16/2020 $7,600,000 $7,600,000
9/17/2020 $945,000 $35,045,000
17 Nebraska
3/10/2021 $34,100,000
38
Exhibit B includes the total of more than $15.8 billion authorized for SY 2020–2021, through March 31, 2021.
However, there were an additional 26 State plans approved totaling more than $14.3 billion authorized that were
outside the scope of our inspection. In the report, Figure 2 depicts $37.1 billion in funding authorized by the
Secretary to the States, including $300 million in administrative costs, which will be reviewed in another inspection
objective.
INSPECTION REPORT 27801-0001-23(1) 15
State Plan Approvals
School Child
Children State Plan Care State State Plan Total State Plan
Count
State State Plan Estimated Plan Estimated Estimated
Approval Funding Approval Funding Funding
Date Date
18 New Jersey 9/18/2020 $40,400,000 $40,400,000
9/18/2020 $45,250,000 $100,850,000
19
New Mexico 1/28/2021 $55,600,000
North 9/14/2020 $111,500,000 $1,150,300,000
20
Carolina 2/1/2021 $860,000,000 3/24/2021 $178,800,000
21 North Dakota 3/10/2021 $9,800,000 $9,800,000
9/11/2020 $86,100,000 $578,300,000
22
Ohio 1/15/2021 $492,200,000
23 Oregon 9/23/2020 $35,600,000 $35,600,000
24 Pennsylvania 3/10/2021 $1,000,000,000 $1,000,000,000
25 Puerto Rico 1/14/2021 $390,700,000 $390,700,000
9/18/2020 $8,700,000 $49,900,000
26
Rhode Island 12/28/2020 $28,400,000 3/22/2021 $12,800,000
South $420,300,000
27
Carolina 2/5/2021 $420,300,000
6/03/2020 $36,300,000 $681,800,000
28
Tennessee 1/28/2021 $645,500,000
29 Texas 3/22/2021 $1,900,000,000 3/22/2021 $626,000,000 $2,526,000,000
30 Utah 3/25/2021 $45,100,000 $45,100,000
31 Vermont 1/28/2021 $29,600,000 $29,600,000
32 Virgin Islands 9/22/2020 $1,510,000 $1,510,000
9/16/2020 $76,200,000 $743,200,000
33
Virginia 3/2/2021 $658,000,000
34 Washington 2/23/2021 $590,500,000 $590,500,000
35 West Virginia 2/4/2021 $196,600,000 $196,600,000
36 Wisconsin 2/8/2021 $328,200,000 $328,200,000
TOTAL $14,640,705,000 $1,177,300,000 $15,818,005,000
16 INSPECTION REPORT 28701-0001-23(1)
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