Vermont Agency of Education

Congress has authorized Pandemic EBT (P-EBT) to continue through the end of the Public Health Emergency and the following summer. Currently, the PHE has been extended through Oct. 15, 2022, and is now likely to be extended until at least January. Vermont expects to have a P-EBT for schools plan approved for SY22-23 and for Summer 2023. However, as of Mid-August 2022, USDA has not yet allowed states to submit these plans, nor provided guidance to states on writing these plans. Barring new guidance from USDA, we are making some assumptions about how the plan will work for SY22-23 and Summer 2023 in order to provide preliminary guidance on what information schools participating in the federal school meals programs will need to collect from the start of the school year. Independent schools that are not participating in the federal school meals programs may disregard this email. 
 
New this Year: Schools Will Need to Track Each Instance of an Excused COVID-19-Related Absence for All Students
This year, benefits will be issued based on the actual number of excused COVID-19-related days of school missed for each student, so careful tracking of each absence day is critical. It is up to the LEA to decide how best to track this information. Here are some suggestions:

• One option to track excused COVID-19-related absences is to create a COVID-19-related excused absence attendance code in the Student Information System. This option was used successfully by a number of LEAs to track these absences during SY21-22, and these LEAs reported less difficulty in compiling P-EBT data than schools who attempted to compile the data separately.
• Schools could consider a consistent comment or other way of tracking COVID-19-related absences within the attendance system.
• Schools may also consider maintaining a separate list of these absences as they occur, rather than tracking them in through the attendance system.

The AOE has issued a list of types of absences that may be considered COVID-19-related for reference by school attendance staff. 
 
Please note that COVID-19-related absences are not limited to absences as a result of the student themselves being ill with COVID-19. Some schools have expressed concern that tracking COVID-19-related absences could expose private medical information. However, for the purposes of P-EBT, a COVID-19-related absence is any absence that would not have occurred if not for a concern about the spread of COVID-19. This includes students who are unable to attend school as a result of possible COVID-19 cases among other household members, or instances when classrooms are closed due to staffing shortages caused by concerns of a spread of COVID-19 among school staff. School closures for COVID-19-related reasons will also count towards P-EBT, but may need to be tracked separately to avoid errors with regular attendance data reporting to the AOE.
 
Initial Qualification for School (Building or Site) for Student Eligibility for P-EBT
As was the case in SY21-22, in order for any students in a school (building or site) to become eligible for P-EBT for SY22-23, the school will first need to have a COVID-19-related school closure or COVID-19-related reduced attendance for five consecutive days or more. Reduced attendance means one or more students is absent for a COVID-19-related reason. Different students may be absent over the 5 consecutive day period in order to meet this threshold. 

Once this threshold is met, students at the school are then eligible for P-EBT for the remainder of the year if the other P-EBT requirements are met. Schools will need to track COVID-related absences/closures from the start of the year to determine when each school meets this initial threshold. AOE will be asking School Food Authorities (SFAs) to report this date for each school within the SFA. The reporting method for this has yet to be determined, but will likely be a simple web-form. This requirement is unchanged from SY21-22. Prior to the school meeting this threshold, no students in the building will be eligible for P-EBT. The school eligibility date is the first day of the 5-day period of reduced attendance for a COVID-19-related reason.
 
All Students Eligible for P-EBT Once the Building is Eligible
Once the building is eligible, all students attending Community Eligibility Provision (CEP) or Provision 2 schools are eligible for P-EBT benefits for days when they have a COVID-related absence, or there is a COVID-19-related closure. In School Year 22-23, all public schools in Vermont will be operating CEP or Provision 2. Some independent schools will also be operating this option. 

This means that even though there will (hopefully) be fewer overall COVID-19-related absences in the upcoming year, schools may end up needing to report more students eligible for P-EBT benefits simply because all students will be eligible on days when they miss school for a COVID-19-related reason. 

Independent schools operating the NSLP/SBP but not participating in CEP or Provision 2 will continue to track student eligibility based on eligibility for free and reduced meals, in addition to COVID-19-related absences.

SY22-23 P-EBT Data Collections
At this point, the AOE and DCF expect to conduct two data collections for P-EBT. The first will likely be over the winter, and the second will likely be in June 2023. As we have over the past two years, we will likely have one final corrections window in August 2023. Once Vermont’s P-EBT plan is submitted to USDA later this fall, the AOE will provide template language to communicate to households about what to expect for P-EBT in SY22-23, and how households should provide the data needed to receive the benefits (head of household, mailing address and student date of birth).

If you have questions about P-EBT, please contact me or Denise Blankenship. Thank you for your continued work to make this benefit available to Vermont households. With your help, we have issued over $61 million in P-EBT benefits to Vermont households to-date, and another $16.3 million will be issued this month as a result of your efforts in June 2022.