P-EBT FAQ for Schools

Updated Feb. 9, 2021

These frequently asked questions provide answers for school personnel on how to manage the P-EBT implementation in the 2020-21 school year. For basic questions on what P-EBT is, and how households will receive the benefit, please see FAQs About Pandemic EBT for Households. For more information about the process that schools are expected to follow, please see the Memo: Preliminary Guidance on P-EBT for School Year 2020-21 and Instructions for Determining Eligibility for P-EBT.


Q1: Should we send the customized letter to every household in our school district?

Yes, we are asking you to send this to every household for three reasons. First, we want to give households basic information about what to expect. Second, we want to give everyone who doesn’t currently qualify based on last year or this year a chance to submit an application.  Third, we learned from the Spring 2020 implementation that there were a lot of issues with incorrect Head of Household and mailing addresses, so we want to give households a chance to correct that prior to the cards being sent out.

It is a lot of work up front, but it will save you a lot of work processing unnecessary applications and fielding calls from parents who want to know where their cards are after they are mis-sent.  

To simplify the process of customizing the letters, we recommend setting up two mail merges: one for households who are already eligible, and one for households who need to submit applications. If you take the time to set up the mail merge, the customization should go fairly quickly. There is likely someone already experienced in setting up mail merges among your administrative staff. If not, see these instructions on how to set up a mail merge in Microsoft Word.


Q2: What is the timeline for this process?

Currently, we expect that DCF will begin asking for eligibility information for September – December 2020 in late February or early March. After that, likely in late March, they will ask for information for January and February. Starting in April, and each month after that, we will ask for information for the prior month to be reported by the 15th of the month.


Q3: When should we send the customized letters out? When should we ask households to respond?

The template letter asks households to respond to you by Feb. 15, 2021, if any updates are needed to their information. You may push this back a little if you are delayed in sending the letter out. Ideally you want to have your records updated with corrected information from households that are eligible for September-December by late February.


Q4. Can we email the letter to households or does it have to be sent via postal mail?
The letters may be sent electronically as long as you have emails for all of the households (or will send paper copies to those you don’t have emails for), and you are abiding by your district’s policies on how to safely email confidential student information.


Q5. Can we send a link to our electronic free and reduced meal application, or do we need to send paper copies of the application?

As long as you provide information to households on how to access a paper application (your electronic application should already do this), you may send a link to your electronic application and do not need to send a paper copy of the application.


Q6. We are a small school. Can we call households to verify information instead of sending them the letter?

Yes. However, the letter contains background information about P-EBT that may be difficult to convey over the phone. If you choose to call households to verify information and let them know their status, we suggest sending a generic version of the letter and FAQ for households as well.


Q7. We are running several different hybrid schedules with students having varying numbers of days of in-person and remote instruction each week. Do we need to calculate exactly how many days of in-person vs. remote instruction for each student to see how much the hybrid benefit will be for each student?

No. All hybrid students across the state will receive the same benefit for the month, regardless of the type of hybrid schedule they are on. The only calculation needed is whether the student was on a continuously remote status for the majority of the school days in the month. If the student is in a hybrid status for the entire month, there is no need to calculate exact number of days of in-person vs. remote instruction. These students should simply be listed as hybrid. Please see Instructions for Determining Eligibility for P-EBT for more information on how to determine whether students are eligible for the hybrid or remote benefit.


Q8. We have been 100% in person since the start of the school year for all of our students. Do we need to send this letter? Are our students eligible?

If you have been 100% in person for all of your students since the start of the school year, your students are not eligible, and you do not need to send the letter now. However, be prepared to send the letter later in the school year if you do end up needing to close or shift to remote status for any period of time. Your free and reduced-eligible students would then be P-EBT eligible for those months. Please also note that if any of your households opted to learn remotely from the start of the year, through VTVLC or other remote options, then they would qualify for this benefit even if the rest of the school was 100% in person. Please send the letter to these families to verify that you have their correct information.

In the event that no students at your school are eligible due to 100% in person learning, it would still be helpful to share some information with your households about what P-EBT is and why they are not eligible, as they will likely hear about it on the news or from friends and family. You can take language to share from the template letter or share a link to the FAQ for households.


Q9. How do we handle households with 50/50 split custody? Who should be listed as the Head of Household?

DCF needs to know who to mail the card to so that the child will benefit from the funds. It is up to the school to determine who this should be. This is one of the reasons for sending the customized letter to the households to confirm where they want their benefit sent. If there is a dispute about which parent/guardian should be listed as the Head of Household, the school could use the following factors to make the determination:

  • Which parent/guardian completed the application for free and reduced-price meals?
  • Which parent/guardian is listed first as the emergency contact in your system for that student?

In the event that the households disagree, you could ask them which parent/guardian will be claiming the child as a dependent on their taxes this year. That is likely something stipulated in the child’s custody agreement.

Ultimately, it is up the school to make the decision in the fairest way you can.


Q10. We have some students who attend our school who live in other states. Are they eligible for this benefit?

Yes, if the student is attending a Vermont school, Vermont will issue the P-EBT benefits, regardless of the child’s state of residence.


Q11. Who should we list as Head of Household for State-placed foster students?

List the foster parent and mailing address where the student is currently placed. DCF will be comparing the list of eligible students to their most current information on state-placed foster children. DCF will update information for these students as needed so the cards will be mailed to the student’s current foster parent and address at the time of card issuance.


Q12. If we have students in-person in class for four days a week, and the fifth day is reserved for in-person callbacks, tutoring, or other services do we need to track which kids come in for services on the fifth day and consider those days as in-person?

We would consider everyone to be in a hybrid schedule in this situation. There is no need to determine which individual students are coming in for the callbacks each week.


Q13. How should we count students who are not in-person in class, but are present at the building for childcare or to attend classes remotely because they don’t have access to internet at home?

If the students aren’t formally offered a breakfast and lunch meal service at school during these programs, then they are eligible. Giving these students meals to take home doesn’t count as a meal service for this purpose. If these programs are an ad hoc situation where students aren’t specifically scheduled to be there, then you do not need to not count these as in-person days.


Q14. Are PreK students eligible for this benefit?

Yes, if your PreK students normally have access to your meals program, they are eligible for this benefit, subject to the same requirements as other students.


Q15. Pre-COVID, our PreK students normally only attended 4 days per week. Their schedule is unchanged. Are they eligible?

No. If the students are attending the same schedule that they attended prior to COVID-19, then we would consider them to be fully in-person and they would not be eligible.


Q16. Pre-COVID-19, our PreK students normally only attended 4 days per week, but they attended full days. Now, they are only attending 2 hours per day, but still 4 days per week. Are they eligible?

Yes. If the students schedule has been reduced due to COVID-19 and this is impacting their access to meals at school, then they are eligible for the hybrid benefit.


Q17. We have prioritized in-person learning for special education students. We are concerned that this means these students won’t have access to this benefit while their peers do.

AOE and DCF are also very concerned about this. We have proposed to USDA to allow these students to receive the same benefit as other children in their grade, based on what their attendance modality would have been if not for their special education status. We are awaiting word from USDA as to whether this will be approved and will update the field when we hear a response.


Q18. How should we handle students who were only enrolled in our school for part of this year? For example, students who unenrolled in order to switch to home study, or students who moved?

These students are eligible for benefits (assuming all other criteria are met) for the months that they were enrolled in your school. However, they are not eligible for benefits during which they were not enrolled in your school. Exclude them from your list of eligible students for months in which they were not enrolled.


Q19. Can we see the template for the file we will need to submit to DCF?

DCF is still developing their data submission system. They will share a template and provide training on this as soon as the system is finalized. You can expect the fields to be similar to those that were requested in Spring 2020. In addition, the template will contain a field to indicate if the child is directly certified due to SNAP/3SquaresVT. This is data that should be contained in your benefit issuance documentation already, as AOE CNP requires it for the verification report.


Q16. If we are in-person with only occasional remote days due to weather or contract tracing, do those occasional remote days make the students hybrid for that month?

Yes. Any remote day during the month that doesn’t meet the threshold for a fully-remote determination would make the students hybrid for that month, for the purposes of P-EBT.


Q20. When we conducted Verification, some households didn’t respond. Are these students eligible for P-EBT?
These households must submit the requested verification documentation in order to be eligible for P-EBT. If you are still in the process of conducting Verification due to this year’s extended deadline, it would be a good idea to let those households know that their response will impact their eligibility for P-EBT. If you have already moved the household into “Paid” status due to non-response, you could reach out to the household to let them know that they may reapply, but they will need to submit the documentation that was originally requested in order for them to be eligible for P-EBT. The documentation submitted must validate their eligibility for free or reduced-price meals.


Q21. Can our school opt-out of offering P-EBT?

No. This benefit must be offered to all students who are eligible. If your school normally participates in the National School Lunch Program and has students who are studying remotely or in hybrid status, you must provide the information so that we can offer this benefit to those households.


Q22. This is a ton of work! Does AOE realize how much work this is?

We do! We know this is a big ask, and we wouldn’t be making it if it wasn’t the only way to get almost $30 million in really critical assistance out to our most vulnerable families. We are committed to helping you in any way we can. In addition to ongoing training and support, we are working on providing funding to help with staffing, technology and mailing costs. We will provide guidance as soon as these funding streams are finalized. In the meantime, we recommend beginning to track any costs already incurred, and thinking about ways that investing funds in this project could help you accomplish this work. For example, you might be able to ask your Student Information System to create a new report for you that would make some of this easier. Or, you may be able to offer overtime hours to some additional staff to work on this project.

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Secretary Daniel M. French
1 National Life Drive, Davis 5
Montpelier, VT 05620-2501

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