4/6/20 - State Plan for Pandemic EBT (P-EBT)

Monday, April 6th, 2020

State Plan for Pandemic EBT (P-EBT)

The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.

1. Type of Request: Initial
2. Primary Citation: Families First Coronavirus Response Act
3. State: Illinois
4. Proposed Alternative Procedures:

The household allotment amount will be no less than the value of school meals at the free rate over the course of five (5) school days for each eligible child in the household. The value of the school meals is equal to the Federal reimbursement rate for breakfast and lunch at the free rate, as specified by USDA.

Verification of P-EBT Eligibility: [STATE MUST ADDRESS HOW THEY WILL OBTAIN ENROLLMENT DATA FROM LOCAL EDUCATIONAL ENTITIES, TO DETERMINE WHO THE CHILDREN ELIGIBLE TO RECEIVE P-EBT BENEFITS ARE, AND MATCH THEM TO THEIR EXISTING SNAP CASE, WHERE APPLICABLE.] See Below*

Release Of Information. Per Section 1101(e) of the Families First Coronavirus Response Act: Notwithstanding any other provision of law, the Secretary of Agriculture may authorize State educational agencies and school food authorities administering a school lunch program under the Richard B. Russell National School Lunch Act (42U.S.C. 1751 et seq.) to release to appropriate officials administering the supplemental nutrition assistance program such information as may be necessary to carry out this section.

Calculation of Household Allotments:

• [IN ORDER TO STREAMLINE THE ISSUANCE OF P-EBT BENEFITS, STATES MAY USE AN AVERAGE DATE FOR THE END OF THE SCHOOL CLOSURES AND/OR AN AVERAGE NUMBER OF CANCELLED SCHOOL DAYS FOR WHICH BENEFITS ARE ISSUED. March (7 days) April (22 days)
• P-EBT BENEFITS MAY BE PROVIDED ON A MONTHLY BASIS THROUGH THE END OF THE STATES CALCULATED AVERAGE DATE FOR THE END OF THE REGULARLY SCHEDULED SCHOOL YEAR.
• THE BENEFITS ISSUED SHALL BE EQUIVALENT TO THE DAILY REIMBURSEMENT FOR FREE BREAKFAST AND LUNCH IN THE STATE, AS SPECIFIED BY USDA, MULTIPLIED BY THE AVERAGE NUMBER OF DAYS SCHOOL WAS CANCELLED IN THE MONTH FOR EACH ELIGIBLE CHILD IN THE HOUSEHOLD. $3.50 lunch + $2.20 breakfast = $5.70
• THE STATE SHOULD INDICATE WHICH MONTH WILL BE THE FIRST MONTH OF ISSUANCE AND PROVIDE ESTIMATES FOR THE TOTAL FIRST MONTH.]
  • March (7 days) and April (22 days) will be combined for first month issuance:
  • SNAP eligible $95,057,913.90
  • New $90,260,412.00
  • Total $185,318,325.90

Issuing P-EBT Benefits to Households: [STATE MUST ADDRESS HOW THEY WILL ISSUE THESE BENEFITS TO EXISTING SNAP HOUSEHOLDS, E.G., IN A MANNER SIMILAR TO PROVIDING AUTOMATIC SUPPLEMENTS UNDER D- SNAP OPERATIONS, AND HOW THEY WILL SET UP NEW CASES AND ISSUE CARDS AND BENEFITS TO NON-SNAP HOUSEHOLDS.]

*For SNAP households States will use existing case information to issue the benefit. Therefore, the State could provide the P-EBT benefit without contacting a SNAP household.

For non-SNAP households, an application is required so that a P-EBT case may be set up in the States eligibility system and benefits can be issued. A non-SNAP household will need to provide household information in order to participate. A State may propose alternate procedures if the necessary data for non-SNAP households is readily available.

In instances where P-EBT eligible children are not part of an existing SNAP household, the State agency will obtain the following information prior to providing benefits:

• Name and signature of the head of household (which may be electronic).
• Number and names of eligible children in the household
• Address of household on record with the school district
• Mailing address if different than address on record with the school district

If available and practicable, States are encouraged to utilize existing household information from school meal applications in order to create P-EBT cases in their system.

Illinois will utilize the DSNAP coding and base module already in the eligibility system to create P-EBT households.

Existing SNAP Households:

Illinois will systematically identify all SNAP households that contain children attending school. We will multiply this number of children by the monthly allotment and create the P-EBT benefit for the household. These will be coded as a Supplemental DSNAP Issuance in our system. Our goal is to distribute April benefits to existing households between April 20th to April 30th. This staggering allows retailers to respond to the demand. And will begin after the EA allotments are distributed. Illinois is in direct contact with our Retailer association and will keep them informed of our approved distribution plan.

For new SNAP applications, we will complete a weekly process that reviews applications that were approved in the last week and create P-EBT benefits for any eligible households (contain children in school and havent already received a P-EBT benefit).

Non-SNAP Households:

• Applications

Illinois has developed a simplified application for P-EBT benefits for Non-SNAP households. Applications will be available in paper form as well as through our ABE Online Application portal. On the Online Portal, a new option will be listed right away to apply for only the P-EBT Benefits. The application is one page and collects the same data as the paper application.

We will have three ways to return an application: Online, Mail, Central Email Address (DHS.FCS.PEBT@Illinois.gov)

• System Changes/Processing

Illinois has added a path through the existing DSNAP Module within IES to process P-EBT applications. This will allow for case and EBT account creation through the system and create an Initial DSNAP Issuance for any household that is found eligible for P-EBT and has not already received the benefit. Initially this processing will be available manually for staff to process applications. Illinois is working on automating the processing of Online P-EBT applications. Subject to approval, currently that automation is estimated to be available approximately April 21st, 2020. This automated process would still validate eligibility with ISBE and ensure child has not already received.

• Verification of Free or Reduced Lunch Eligibility

Illinois is establishing a Webservice call with the Illinois State Board of Education (ISBE) that will allow the State to send Name, DOB, Gender, and School District Code (obtained from a reference table based on the school district indicated on application). The webservice will return a value of Yes they are eligible, or no they are not. ISBE already began reaching out to School Districts to have them update indicators for Students that are eligible for free or reduced-price lunch to ensure we have accurate data to match upon. We have set a 2-week time for Districts to get this information updated. We will wait to process applications until this is considered complete to prevent any incorrect denials.

• Customer Education

Illinois will utilize our current Customer Education materials regarding EBT Benefits. Illinois has the LINK Brochure form 9203. We have coordinated with our EBT contractor to send this brochure with New LINK cards issued after our implementation date. The brochure provides the customer with the information needed to manage their account, redeem benefits and the store, and includes information about eligible items.

• Benefit Availability and Expungement

New Applications will follow the normal daily issuance schedule. A benefit becomes available to the customer the day following the next workday after processing. For Example, an application approved on Thursday, will have benefits available on Saturday. An Application approved on Friday, will have benefits available on Tuesday of the following week. Again, these will be Initial DSNAP benefits in our system.

The current assumption is that P-EBT benefits will follow our DSNAP expungement rules. All Supplemental issuances will have a normal 36- day expungement cycle, but Initial issuances will be limited to 90 days expungement. This can be changed if instruction from FNS indicates a different method should be used.

• Information Campaign

Illinois is partnering with ISBE to notify eligible households of the available benefit. DHS will provide ISBE with a copy of the blank paper application as well as a link to the online application. ISBE will provide a standard message along with the applications to the school districts who will distribute the information out to their families. We will encourage customers to use the online application to take advantage of automation and allow the quickest availability of benefits. School Districts will also assist in collecting paper applications of those who are unable to access the webservice and route those applications back to our central email for processing.

Additionally, our Communications department will use all platforms available to us, including social media, news outlets and our Website to promote the P-EBT Benefit and provide the methods to apply.

Reporting

Weekly reports will be produced that will detail the following:

• # of SNAP households issued a P-EBT Benefit
• # of SNAP Children issued
• Total Amount of P-EBT Benefits issued to SNAP Households
• Average amount of issuance to SNAP households
• # of Non-SNAP Households receiving a P-EBT Benefit
• # of non-SNAP children issued
• Total Amount of P-EBT Benefits issued to Non-SNAP Households
• Average amount of issuance to non-SNAP households.

Other Requirements: [If applicable, STATE SHOULD ADDRESS ANY OTHER STATE-SPECIFIC NEEDS THEY MAY HAVE.]

All P-EBT benefits will be delivered on an EBT card, and the State hereby confirms that it has sufficient card stock on hand to successfully begin operations for the number of households estimated below.

The State should conduct a public information campaign to alert those receiving benefits the purpose of P-EBT and how it is to be used.

The States SNAP agency also agrees to complete the FNS-292 form on a timely basis in accordance with requirements as well as all other normally recurring SNAP reporting included the FNS 46 and 388 reports, on a timely basis in accordance with requirements.

In addition, the State agency will submit monthly reports to FNS with the following information for the entire State:

• The value of the P-EBT benefits issued to SNAP and non-SNAP households, separately identified.
  • Within SNAP households, the data must differentiate between base SNAP benefits and P-EBT benefits
• The average P-EBT issuance amount per household for SNAP and non- SNAP households, separately identified.
• The number of SNAP households issued P-EBT and the number of non- SNAP households issued P-EBT

5. Justification for Request: Coronavirus COVID-19

Affected Caseload:

One month estimates for existing SNAP households under these procedures:

• Number of households receiving P-EBT benefits: 307,575
• Number of children receiving P-EBT benefits: 575,063
• Amount of P-EBT benefits to be issued: $95,057,913.90

One month estimates for those non-SNAP households/children who will receive P- EBT under these procedures:

• Number of households receiving P-EBT benefits: n/a
• Number of children receiving P-EBT benefits: 546,040
• Amount of P-EBT benefits to be issued: $90,260,412.00

6. Anticipated Implementation Date: [STATES SHOULD SPECIFY TWO DATES IF THE IMPLEMENTATION DATE WILL VARY FOR SNAP AND NON-SNAP HOUSEHOLDS] For active SNAP households, benefits will be made available beginning 4/20/2020 through 4/30/2020. Illinois estimates we will be able to begin processing new applications sometime between 4/14/2020 and 4/17/2020.

7. Signature and Title of Requesting SNAP and Child Nutrition State Agency Officials:

Grace B. Hou, Secretary - IDHS

Leslie K. Cully, SNAP Director

8. Date of Request: 04/06/2020