Wisconsin 2024 Summer Electronic Benefit Transfer (EBT) Plan for Operations and Management (POM)

Summer Electronic Benefit Transfer for Children (Summer EBT) Plan for

Operations and Management (POM) Template

Instructions

Each State and Indian Tribal Organization (ITO) that intends to administer the Summer EBT Program

beginning in 2024 must submit to the Food and Nutrition Service (FNS) regional office a final POM not

later than February 15, 2024.

In States with multiple Summer EBT agencies, the coordinating Summer EBT agency is the

primary point of contact for the Summer EBT Program and is responsible for the complete and

timely submission of the POM. However, the POM must be developed in cooperation with all State

Summer EBT agencies and be reflective of the plans and administrative funding needs of both. For ITOs,

the administering agency is responsible for its program’s POM. For the purposes of this document, the

term ‘Summer EBT agency’ includes all administering agencies within a State or ITO unless otherwise

specified.

The final POM must:

1. Address all the requirements in this template, and

2. Be approved by FNS before the Summer EBT agency may draw federal food benefit funds for

the fiscal year.

Amendments

At any time after approval, the coordinating Summer EBT agency may request to amend a final POM to

reflect proposed changes. The coordinating Summer EBT agency must submit any amendments to the

FNS regional office for approval. The amendments must be signed by the Summer EBT agency-

designated official(s) responsible for ensuring that the Program is operated in accordance with the POM.

Required Attachments – described in Sections 1 & 6

 A copy of the inter-agency written agreement(s) between the Summer EBT coordinating agency

and each partnering agency, if applicable [7 CFR 292.3(c), 7 CFR 292.8(e)(1), 7 CFR 292.8(e)(8)

]

 An FNS-366A expenditure plan for each agency within the State or ITO that will draw

administrative funds from FNS [7 CFR 292.8(e)(3)

], i.e., part of the administrative budget

 A budget narrative that corresponds with the 366A(s), which describes how costs within the

budget categories were derived, and demonstrates links between expenditures and specific

activities/tasks [7 CFR 292.8(e)(3)

], i.e., part of the administrative budget

 A copy of the fair hearing procedures for participants [7 CFR 292.8(e)(12); 7 CFR 292.26]

Section 1: Administrative Budget

1.1 Attach 366A expenditure plans(s) that reflect planned Fiscal Year 2024 administrative cost

requirements for each agency within the State or ITO that will draw Summer EBT administrative

funds from FNS [see 7 CFR 292.8(e)(3)]. See the policy memo SEBT 01-2024, FM 01-2024

Summer EBT Administrative Funding Process for FY2024, October 18, 2023 for further

information about the 366A.

1.2 A

ttach a budget narrative that corresponds with the 366A(s), describes how costs within the

budget categories were derived, and demonstrates links between expenditures and specific

activities/tasks. The budget narrative will include the administrative needs of all Summer EBT

agencies and local educational agencies [see 7 CFR 292.8(e)(3)

1.3 The Summer EBT agency attests that the attached 366A expenditure plan(s) and budget

comply with any standards prescribed by the Secretary for the use of these funds.

Section 2: Issuance [7 CFR 292.8(e)(10)

]

2.1 Provide an estimate of the number of children who will be served for the year this plan covers [7

CFR 292.8(e)(2)]:

Estimated number of children served in Summer EBT 2024: 450,000

Instructions: Provide an estimated number of children that will be served in Summer EBT during

the year this plan covers. A good starting point for calculating your estimate is the number of

children who are eligible for Free and Reduced-Price (FRP) meals in the National School Lunch

Program (NSLP) and School Breakfast Program (SBP) within your geographic State or ITO service

area. The number of free and reduced-price eligible children is reported annually each year on

the FNS-10: Report of School Program Operations. The number reported on this form can inform

estimates. Additionally, FNS’ Summer EBT toolkit provides estimates that may be used as a

According to the October 2023 National School Lunch Program reimbursement claims, the total number of FRPL-

enrolled students attending NSLP-participating schools at that point was 426,809. Wisconsin’s overall estimate of

students served by Summer EBT in 2024 has been increased to 450,000 for a few key reasons. First, there are a

handful of SFAs that had not had their FRPL-enrolled students counted in October 2023 due to being in withholding

as a result of noncompliance. Second, the population of FRPL income-eligible students who attend CEP schools

included in the 426,809 count is likely an underestimation according to DPI. CEP schools use a prescribed calculation

formula to report the proportion of their total enrollment made up of FRPL income-eligible students, and this

formula typically underrepresents the actual number of FRPL income-eligible students. Third, the 426,809 October

2023 total does not include school-age students who will be able to be directly certified but do not attend an

NSLP/SBP school.

narrative

Initial Here

reference point: Estimated Number of Summer EBT Eligible Children. ITOs may contact the FNS

regional office for assistance in determining the number of FRP children in their service area.

2.2 Provide the start and end dates of the summer operational period and an explanation for why

these dates were selected [7 CFR 292.2; 7 CFR 292.8(e)(10)(i)

First day of the summer operational period: _June 30, 2024

Last day of the summer operational period: _August 29, 2024

Explanation:

In Wisconsin, each school district determines its own operational calendar which means there is

no statewide standard summer period. In general, though, all schools complete the school year by

the end ofJune, and it is common to begin the following school year near the end of August.

Instructions: Summer operational period [7 CFR 292.2

] means the benefit period that generally

reflects the period between the end of classes during the current school year and the start of

classes for the next school year, as determined by the Summer EBT agency [

7 CFR 292.2]. The

summer operational period does not need to align with calendar months, nor does it need to be

3 months in duration (participants will get $120 per summer regardless of the number of days

that they’re out of school). The Summer EBT agency should review school calendars within the

State or ITO and select start and end dates that will allow students to access benefits when they

are not in school and not able to access school meals. Given the variation in school calendars

within States and ITOs, it is reasonable to designate a summer operational period that includes

days when some students are still in school, and does not include days when some kids are on

break. The objective is to select dates that are generally reflective of school calendars in the

State or ITO.

For example, if schools in a State or ITO generally start summer break the second week of June

and resume school the last week of August, the Summer EBT agency could select a summer

operational period that runs from June 15 – August 25. These dates cover the majority of

summer break for most children in the State or ITO. The Summer EBT agency could provide a

$120 benefits June 8 (7-14 days before the start of the summer operational period), or they could

provide benefits in multiple issuances. For example, issue $40 on June 8, July 6, and August 3, for

a total of $120 over the course of the summer.

Reminder: To the extent feasible in 2024, benefits must be issued and available for children to

spend at least seven calendar days and not more than 14 calendar days before the start of the

summer operational period. However, benefits expunge 122 days after issuance, so some

benefits will be spent after the end of the summer operational period. Children have until the last

day of the summer operational period to apply for benefits using a Summer EBT application. If

flexibility with timeframes for benefit issuance is needed in 2024, the State should indicate the

reason for the delay.

2.3 Provide the date(s) when benefits will be issued [7 CFR 292.8(e)(10)(ii)], 7 CFR 292.15(c)]:

First issuance: _6/22/2024

Second issuance (if applicable):

Third issuance (if applicable):

Additional information on schedule for benefit issuance, if any: _See below

The primary issuance of Summer EBT benefits in 2024 will take place on June 22

, 2024 – 8

calendar days before the start of the 2024 summer operational period. This issuance will include

the vast majority of eligible students, including those who are able to be streamlined certified as

well as those who apply via S-EBT application early enough

for the application to be processed

prior to early June. As part of this issuance, all children known to be eligible will receive their

benefits on the same date. Additionally, eligible children will receive the full $120 of Summer EBT

benefits at once as allowed by 7 CFR § 292.15(f)(1); the benefit amount will not be split across

multiple points in time.

For any children who do not apply early enough or are not known-to-be-eligible

in time for

inclusion in the June 22

issuance, DHS will facilitate continued issuances of Summer EBT benefits

throughout the summer operational period (and beyond as applicable). Following the June 22

major issuance, there will be ongoing issuances that take place approximately every two weeks

thereafter. These biweekly (twice per month) issuances will continue until mid-September. As the

deadline for submitting an S-EBT application for 2024 will be August 29

, the final biweekly

issuance will take place approximately two weeks after that deadline (ensuring that any students

who apply right at or before the deadline will be able to receive their benefits within the required

15-day window per 7 CFR § 292.15(c)(1)(i)(B), if eligible).

Beyond mid-September, benefits will only be issued semi-automatically (no major systematic

issuances) on an as-needed basis. Benefits that are issued past mid-September will only be issued

as a result of a correction or as ordered via a fair hearing appeal

Given this is a brand new program still being formulated and built, there is not sufficient time to

put the necessary systems in place, provide ample time for families and schools to submit

information as applicable, and issue benefits before June 22

. This is the earliest that Wisconsin

can begin issuing Summer EBT benefits for 2024 after identifying as many eligible children via

streamlined certification as possible while also maintaining program integrity and avoiding dual

participation and inaccurate issuances.

Wisconsin will lean on public communications to strongly encourage families to utilize the Summer EBT application

in March and April to ensure as many children as possible can receive their benefits as part of the June 22

issuance.

This will include school-age children who enroll in one of the applicable public assistance programs during the

summer months and, therefore, meet the criteria for streamlined certification.

Per IFR guidance, fair hearing appeal requests will be accepted for 90 days after the end of the summer operational

period. This means that households can submit an appeal request essentially through the months of September,

October, and November 2024.

As a clarification, in Wisconsin, benefits are loaded onto EBT cards and are available to spend as

soon as the participant receives, activates, and PINs the card. For recipients with existing EBT

cards in Wisconsin, benefits are loaded onto their EBT card automatically and are available to

spend right away (there is no delay between the loading of benefits and their availability to be

spent).

Instructions: Benefits are ‘issued’ when they are loaded onto EBT accounts and available for the

participant to spend. For example, if a Summer EBT agency loads benefits on accounts and mails

cards in early May, but sets the availability date on those benefits to June 1, the benefits are not

considered to be ‘issued’ until June 1 because that’s when the benefits are available to spend.

Issuance is not the same as loading benefits on EBT accounts or mailing EBT cards. Summer EBT

agencies may opt to provide households with their benefits in one issuance or in multiple

issuances. The first, or only, if applicable, issuance must be provided at least seven calendar days

and not more than 14 calendar days before the start of the summer operational period. Summer

EBT agencies have the flexibility to determine the timing of subsequent benefit issuances, e.g.

monthly issuances. If the Summer EBT agency plans to stagger issuances throughout the month

or otherwise modify that issuance schedule, an explanation should be provided under additional

information. If flexibility with timeframes for benefit issuance is needed in 2024, the State should

indicate the reason for the delay.

2.4 Does the State or ITO service area have Local Education Agencies (LEAs) operating on a

continuous school calendar [7 CFR 292.2

 Yes (complete the rest of this question)

 No (skip to question 5)

If yes, describe the school calendar(s) and break schedule(s) for LEAs operating on a continuous

school calendar [7 CFR 292.15(b)

Provide date(s) or timeframes when benefits will be issued:

First issuance:

Second issuance (if applicable):

Third issuance (if applicable):

Any additional information on the schedule(s) for benefit issuance:

Instructions: SEA instructions: Continuous school calendar means a situation in which all or part

of the student body of a school is (a) on a vacation for periods of 15 continuous school days or

more during the period October through April and (b) in attendance at regularly scheduled

classes during most of the period May through September.

Regardless of when benefits are issued, children attending schools operating on a continuous

school calendar must receive the equivalent of three months of benefits ($120 in 2024),

consistent with children who have a traditional summer break [7 CFR 292.15(e)(4)

2.5 Benefits will be provided using (select all that apply) [7 CFR 292.15(c)(2)

 An existing EBT account used to deliver other electronic benefits

Describe the existing account to which benefits will be added (e.g. SNAP or WIC) and how

they will be separately tracked in that account (e.g. a different benefit type or sub-type):

 A unique account for Summer EBT only

 Other payment instrument (provide explanation):

When the primary parent or caretaker of an eligible child already has an active EBT card

available, Summer EBT benefits will be issued onto that existing card. This existing EBT card

could be a QUEST card or a P-EBT card (the type of EBT card first created and utilized during

the COVID-19 public health emergency). When the primary parent or caretaker of an eligible

child does not already have an EBT card provided by the State (a QUEST or P-EBT card), a new

QUEST card will be issued/mailed to them with their Summer EBT benefits loaded onto it. In

Wisconsin, QUEST cards are the EBT cards onto which other types of food benefits (like SNAP

and Pandemic EBT) have been issued.

In order to differentiate the multiple different types of benefits that may be on the same EBT

card/account, a new benefit type has been created specifically for Summer EBT. This means

that a single card/account could contain benefits of up to three unique types: SNAP benefits,

Pandemic EBT benefits, and Summer EBT benefits. This also allows for compliant

expungement, warning letter generation, and report generation.

Instructions: Summer EBT benefits may be loaded on an existing EBT account associated with an

existing EBT card (e.g. SNAP for State or WIC for ITOs), or a new EBT account and card may be

issued for Summer EBT only. A Summer EBT agency that opts to co-load Summer EBT benefits on

existing EBT accounts will need to also issue new Summer EBT accounts/cards for eligible

children who are not a member of a household with an existing EBT account. Check the box(es)

that corresponds to your planned method for providing benefits. If ‘other’ is selected, provide an

explanation. Use of EBT cards is the industry standard for SNAP and WIC, and FNS expects that

Summer EBT agencies will issue Program benefits on EBT cards in a similar manner to SNAP or

WIC. However, Section 13A(b)(2)(B) of the Richard B. Russell National School Lunch Act

allows

benefits to be issued through another electronic means, as determined by the Secretary. In the

event a Summer EBT agency wants to adopt a new method of Summer EBT payment, such as

payment with a mobile phone, USDA will work with the Summer EBT agency to determine

whether and how this can best be executed while still meeting other program requirements.

Some Territories operating the Nutrition Assistance Program (NAP), including American Samoa

and the Commonwealth of the Northern Mariana Islands, do not currently issue Program

benefits electronically. For these agencies, Summer EBT benefits may be issued in the same

manner as NAP benefits.

2.6 Summer EBT agencies will need to issue new accounts/cards for children who are not associated

with an existing EBT account, or for all children if the Summer EBT agency does not choose to

co-load benefits on existing accounts for children who have them (see question 5) [7 CFR

292.15(c)(2)]. Benefits that are not loaded on existing EBT accounts will be issued:(select all that

apply):

 On one account/card to heads of households, to the extent States and ITOs have contact

information and can determine which children are in a household

 To each eligible child on account/card

As is the case for SNAP and Pandemic EBT benefits issued in Wisconsin, Summer EBT benefits are

issued to the primary parent/caretaker of an eligible child. Any child determined to be eligible

whose primary parent/caretaker does not already have a QUEST or P-EBT card will be issued a

new QUEST card (See Section 2.5 for more information). Further, if one adult is the primary

parent/caretaker for more than one eligible child in their household, the benefits for each eligible

child will be issued onto the same EBT card whenever possible. The State of Wisconsin is not in

the practice of issuing benefits to eligible children directly

nor of issuing benefits onto separate

cards/EBT accounts for members of the same household.

Other Issuance Logistics (Explained):

- Each student determined eligible for 2024 benefits will be issued a one-time lump sum of

$120

- S-EBT benefits will be issued onto existing EBT cards when possible (and onto new QUEST

cards when not possible).

o The QUEST card is the EBT card Wisconsin (DHS) uses for all issuances of SNAP

benefits. P-EBT benefits have also historically been added onto QUEST cards when

available. The P-EBT card is the EBT card Wisconsin (DHS) used for issuances of P-

EBT benefits when an eligible household did not already have a QUEST card.

 For students that are part of a household that already has an active QUEST

or P-EBT card, S-EBT benefits will be added onto their existing EBT card.

 For students that are part of a household that does not already have an

active EBT card, S-EBT benefits will be added onto a new QUEST card and

mailed to the household. In this case, a custom informational mailer

will be

The only exception to this occurs when an eligible child is their own primary caretaker and has documented legal

authority to receive benefits on their own behalf.

DHS will write/design a custom mailer that will be sent along with QUEST cards issued to households who are

receiving a new card due to their Summer EBT eligibility. This mailer will differ from the one that usually accompanies

QUEST cards; that mailer shares information more pertinent for SNAP recipients (as QUEST cards have historically

been issued primarily for the purposes of getting SNAP benefits into the hands of eligible individuals).

sent to the household explaining how to activate/use it and S-EBT-specific

information as to why they are being issued a QUEST card.

o S-EBT benefits (and the EBT card onto which they are issued) will be in the

parent’s/caretaker’s name – they are not issued directly to the student. This is in

line with how Wisconsin handles SNAP and P-EBT issuances.

o When multiple students in a household are eligible for benefits, benefits for all

students will be added onto one EBT card/account per household whenever

possible. Only in rare circumstances will separate EBT cards be issued to the same

household for their eligible students.

- A unique S-EBT benefit type will be created and utilized.

o Similarly, SNAP has its own benefit type, and P-EBT has its own benefit type.

o Despite these three benefit types potentially being issued onto the same EBT card,

this will allow for the continued clear tracking and reporting of S-EBT benefit

issuance, spending, and expungement.

o The spend priority will be (1) Summer EBT, (2) P-EBT, and (3) SNAP benefits. This will

allow for S-EBT benefits to be spent before other benefit types (with longer

expungement periods) are utilized.

- Replacement of benefits

o Summer EBT benefits will be eligible for replacement by DHS when a household

reports that food purchased with their benefits was destroyed in a household

misfortune or disaster per 7 CFR § 292.15(g)(5). This will follow existing SNAP

benefit replacement processes as much as possible.

- Expungement

o Any Summer EBT benefits remaining on a QUEST or P-EBT card for more than 122

days after the date the benefits were issued will be systematically removed as

required by 7 CFR § 292.15(h)(1)(i).

o Information about expungement will be included in notices sent at the time of

benefit issuance.

o Households with a non-zero balance of Summer EBT benefits as of 60 days post-

issuance will be sent a notice informing them of their upcoming expungement and

steps to take to avoid benefit removal.

 This ensures that all households are warned at least 30 days prior to

expungement of their benefits, per federal requirements.

 This notice will be similar to existing expungement warning letters sent to

SNAP and P-EBT households but will include specific information about the

Summer EBT program rules and where to direct Summer EBT-specific

questions.

Instructions: The Summer EBT agency will need a plan to provide benefits to eligible children

whose benefits are not loaded on an existing EBT account, either because the Summer EBT

agency chooses not to co-load benefits or because the child is not associated with an existing

EBT account (e.g., a SNAP or WIC account). The Summer EBT agency may provide each eligible

child with their own Summer EBT card and/or issue cards to the head of household, grouping

children in households as able.

2.7 Describe the procedures the Summer EBT agency will implement to provide access to

households experiencing homelessness and other vulnerable populations, e.g., children in foster

care, children from households with limited English proficiency [7 CFR 292.8(e)(10)(vi), 7 CFR

292.15(c)(1)(v)].

DHS will bring on seasonal contracted staff to serve as the Summer EBT Support Team, a specific

unit to support case management and problem resolution for all Summer EBT operations. As was

the case with Wisconsin’s Pandemic EBT Support Team in prior years, this group will support

customer service via a dedicated phone line and email inbox.

This Summer EBT Support Team will utilize the same translation services used by the DHS SNAP

team, which will help address challenges encountered by families with limited English proficiency.

Program promotional materials and notices will be available in Wisconsin’s most commonly

spoken languages, to the extent practicable. Children living in foster care are known to the State’s

eligibility system, so they will be treated in the same manner as children within SNAP households

and identified as eligible through streamlined certification. Children experiencing homelessness

are also known to the State’s eligibility system. As such, these children already have case numbers

which include mailing addresses (which can include county agencies or shelters). Additionally,

information about homeless children covered under the McKinney-Vento Act will be shared

within the DPI FRPL data. Since these children are often already known to our system, benefits

will be loaded systematically onto existing EBT (QUEST) cards whenever possible. Social Security

Numbers (SSNs) are not required as part of Summer EBT eligibility. There will be no impacts to

those students who either do not have an SSN. Additionally, as with SNAP recipients in Wisconsin

who have disabilities, Summer EBT recipients with disabilities can request to have notices read to

them or explained in a different way. To continue, parents of children without internet access can

call the Summer EBT hotline with questions. Internet access is not an eligibility factor for Summer

EBT, and, as such, Wisconsin will make every effort to provide the same level of service to those

without internet access.

Instructions: Summer EBT agencies are responsible for assisting children who do not live in a

permanent dwelling or have a fixed mailing address so they may obtain Summer EBT benefits.

This can be accomplished by assisting such households in finding an authorized representative

who can act on their behalf, or through other appropriate means. For example, schools have

social workers or coordinators for homeless children who may be able to assist these households.

Vulnerable populations such as these may need benefits quickly to meet an acute need.

2.8 Describe the claims procedures for cases of erroneous payments in accordance with

requirements at 7 CFR 292.27.

Wisconsin will limit claims made against households to situations where there is evidence that

the household knowingly obtained benefits through fraudulent activities in alignment with 7 CFR

§ 292.27(c)(2). To limit the risk of unintentional use of any erroneously issued benefits, in the

notices of eligibility determination sent to households being issued benefits, DHS will provide

sufficient information to the household about how eligibility is determined, how much in benefits

each eligible child is entitled to receive, and information about what to do in the event an

incorrect amount of benefits was issued (either an amount too high or too low). When an

incorrect issuance is identified, DHS will attempt to recover the incorrectly issued amount if

possible/unspent. However, DHS will never reclaim Summer EBT benefits by reducing a

household’s SNAP or WIC benefit per 7 CFR § 292.27(c)(3).

Instructions: Summer EBT agencies must develop a process to manage cases of erroneous

issuances and pursue claims against a household, as appropriate. Summer EBT agencies have the

discretion to determine when to pursue a claim when erroneous issuances are discovered based

on cost effectiveness or the individual circumstances. Most children who receive Summer EBT

benefits will be enrolled through streamlined certification with no action on the part of the

household required. Therefore, a child enrolled through streamlined certification might

unknowingly use benefits that were issued in error, including a situation where the child’s

household applies for duplicate benefits because they are not aware of their automatic

enrollment. It may be a significant burden on low-income households to pay back benefits

already spent, especially when they were unaware of the error and do not have sufficient funds

on hand to pay the claim. To the maximum extent practicable, Summer EBT agencies should limit

claims against households to situations where there is evidence that the household knowingly

obtained benefits through fraudulent activities. To limit risk of unintentional use of erroneous

benefits, Summer EBT agencies have the responsibility to communicate eligibility determinations

to households and provide sufficient information for households to determine their eligibility

status and the amount they should be issued. In addition, Summer EBT agencies may not reclaim

Summer EBT benefits by reducing a household’s SNAP or WIC benefit. Summer EBT agencies

must also develop a process to allow households to submit a claim for benefits that were not

issued or issued in the incorrect amount.

2.9 Describe the plan to ensure that Summer EBT benefits are issued to children based on their

eligibility at the end of the instructional year immediately preceding each summer [7 CFR

292.8(e)(6); 7 CFR 292.12(e)(2); 7 CFR 292.12(f)(4)].

Wisconsin plans to issue benefits to all children who were eligible at some point during the period

of eligibility (7/1/2023 through 8/29/2024) unless they are known to be deceased or enrolled in

school and receiving a benefit in another State or Indian Tribal Organization. Specifically, prior to

their provision of the FRPL dataset to DHS near the end of the 2023-2024 school year, DPI will

review and reconcile the data to ensure that no ineligible or duplicate records are shared with DHS

and to ensure that the data is not only comprehensive but that any children known to be deceased

or to have unenrolled and permanently moved out of state prior to that point in time have been

removed. Additionally, prior to issuance of Summer EBT benefits onto new QUEST cards and

issuance of benefits based on an approved Summer EBT application, there will be a DHS-led

system check to ensure that the QUEST card is only sent to a Wisconsin-based mailing address.

Further, there are multiple administrative data sources that will be consulted prior to the issuance

of benefits to streamlined certified children that are much more regularly updated than, for

instance, DPI’s FRPL data from WISE or data shared by non-WISE-reporting districts via the

Student Information Portal. Specifically, DCF’s Direct Certification data, DCF’s data on out-of-home

care (OHC) and kinship placements, and the CARES statewide eligibility system will all be

checked/matched against in late May/early June (and then again prior to any subsequent

issuance) to ensure that benefits are always being issued to the most up-to-date, Wisconsin-based

address possible for each eligible child. These steps will ensure that 2024 Summer EBT benefits

are issued to children based on their eligibility (and state of residence) as of the end of the 2023-

2024 instructional year.

Instructions: Summer EBT agencies have the responsibility to ensure that all children identified as

eligible at any time during the instructional year still reside in the State or ITO at the time benefits

are issued. For example, a child who enrolls in school in September and moves to another State in

December should not be issued benefits from the State they moved from, even though they were

certified for SNAP (or another allowable program) or as FRP eligible in that State in the

immediately preceding school year. The child would be streamline certified in the State they moved

to in December, or may complete an application if attending an NSLP/SBP school. It would be

impractical for Summer EBT agencies to confirm school enrollment at the very end of the school

year given the time it takes to pull data and issue cards. However, Summer EBT agencies must still

have a plan to confirm that a child has not left the State or service area.

Summer EBT agencies can accomplish this by establishing a process for confirming that children

identified as eligible earlier in the instructional year are still students within the State or ITO’s

school system by using other administrative databases such as SNAP rolls. Ideally, this check

would occur right before Summer EBT issuance lists are finalized so the most current information

is used. In addition, the Notice of Approval that goes to households should include a statement

USDA intends to provide flexibility as Summer EBT agencies work to stand up this program.

Summer EBT agencies are best positioned to determine a process and timeline that make sense

given the individual confines of their program. Summer EBT agencies should include timelines for

finalizing data and issuing benefits and should justify why this is reasonable given the

requirements of the law.

Section 3: Enrollment and Verification

3.1 Streamlined Certification [7 CFR 292.12(d)

]

3.1.a Program data that will be used to enroll children through streamlined certification (check

all that apply):

 NSLP/SBP free and reduced price lists (required)

 SNAP (required)

 TANF (Temporary Assistance for Needy Families) (required if used for Direct Certification

in the school meal programs)

 FDPIR (Food Distribution Program on Indian Reservations) (required if used for Direct

Certification in the school meal programs)

 Medicaid data confirming Summer EBT income eligibility (only allowed if participating in

the Direct Certification with Medicaid Demonstration projects in the school meal

programs – this means the State is approved to use the income information from

Medicaid eligibility or enrollment files to assess whether a student is eligible for free or

reduced price meals based on household income

 Other (explain how the income eligibility guidelines for each align with Summer EBT

requirements, as well as how each program’s eligibility is determined):

Instructions: Check each box that corresponds to data you will use to enroll children through

streamlined certification. If the ‘other’ box is checked, provide an explanation of this data

including a detailed justification for how the program’s eligibility standards and certification

processes provide assurance that participating children also meet the eligibility requirements.

3.1.b Describe how, when, and in what format the Summer EBT agency will obtain data on

eligibility determinations made by LEAs (i.e., children certified by schools through an NSLP/SBP

application or categorial eligibility). Address specific data needs such as the child’s date of birth,

mailing address, and other information required to issue benefits. Address how data

confidentiality will be maintained [

7 CFR 292.12(b)-(d)].

Data containing information about all children who attend NSLP schools that are enrolled to

receive free or reduced price meals (via an FRPL application submitted for/during the 2023-2024

school year) will be shared with DHS by DPI. DPI collects this data from public and some private

NSLP schools in the state via the WISE data reporting system. DPI will pull a WISE report at the

end of May 2024 that will show all FRPL-enrolled students at most NSLP schools and securely and

confidentially share it with select representatives at Deloitte and DHS via Sharepoint (a secure

file-sharing mechanism). This dataset will include all necessary student-identifying information,

such as child’s full name, date of birth, enrolled school/district, grade, gender, primary parent or

caretaker full name, and mailing address. This dataset will be cross-checked against all other data

sources of eligible children prior to the June 22

issuance to eliminate any duplicates and/or

identify any discrepancies that need to be investigated (such as the same student listed in two

sources under two different mailing addresses).

Importantly, select NSLP-participating schools/districts in Wisconsin do not use the WISE system

to report all necessary student information to DPI. These are commonly (but not exclusively)

private schools. These also include certain schools that operate HeadStart programs. For these

specific schools, DHS is repurposing its Student Information Portal (originally created for Pandemic

EBT). This Portal will be sent to representatives of each of these non-WISE-reporting NSLP school

districts in April 2024. The representative will have secure log-in credentials and will be expected

to use this Portal to upload information about each of the FRPL-enrolled (and, if applicable,

HeadStart-enrolled) students in their schools. The same information shared by DPI in

their file of eligible FRPL-enrolled children (child name, date of birth, school, grade, gender,

primary parent/caretaker, mailing address) will be required to be uploaded into the Portal.

Representatives of these non-WISE-reporting NSLP districts will upload their student data into the

secure Portal by the end of May 2024 so as to allow DHS and Deloitte enough time to eliminate

duplicates, address any discrepancies, and include these students in the June 22

major issuance.

Instructions: Summer EBT agencies will issue benefits to a significant portion of eligible children

using data that are already available at the LEA level. To facilitate this, Summer EBT agencies

must be able to efficiently collect student eligibility data from all NSLP participating LEAs in a

format that has all the necessary elements and can be manipulated for Summer EBT use. This

includes data necessary to match and deduplicate records, and complete mailing addresses.

The Summer EBT Playbook

developed by Code for America and Share our Strength discusses

approaches that the Summer EBT agency could employ.

3.1.c For each other data source listed above, describe how, when, and in what format the

Summer EBT agency will obtain data sufficient to determine a child’s eligibility for Summer EBT.

Address specific data needs such as the child’s date of birth, mailing address, and other

information required to issue benefits. Address how data confidentiality will be maintained

CFR 292.12(b)-(d)].

NSLP/SBP free and reduced price lists:

In late May 2024, DPI will provide a dataset to DHS with all FRPL-enrolled students

(students who were individually certified to receive meals via an FRPL application and

students directly certified to receive meals) at NSLP WISE-reporting schools from the start

of the period of eligibility (7/1/2023) through that point in the 2023-2024 school year.

Students who are known to be deceased or to have unenrolled and permanently moved out of state

will be removed from this dataset. It will be shared confidentially and securely via Sharepoint

with only designated staff having access at each state agency. This dataset will include all

necessary student-identifying information, such as full name, date of birth, grade, gender,

specific school enrollment information, parent/caretaker name, and mailing address.

Also by late May 2024, for districts with NSLP non-WISE-reporting schools, a designated

representative of each will be expected to upload an Excel file into the S-EBT Student

Information Portal. The representative will have unique log-in/access credentials in order

to securely and confidentially share information about every FRPL-enrolled student at

their school(s). Once uploaded into the Portal, DHS and Deloitte will be able to access

their eligible student information and export it so that the file format matches that of the

files share by DPI and DCF. This information to be uploaded by these districts will include

all necessary student-identifying information, such as full name, date of birth, grade,

gender, specific school enrollment information, parent/caretaker name, and mailing

address.

SNAP, TANF, FDPIR, and Medicaid enrollment lists:

In late May 2024, DCF will provide a dataset of all Directly Certified students in Wisconsin

during the 2023-2024 school year. This dataset will include those who are directly

certified due to their enrollment in SNAP, TANF, FDPIR, and/or Medicaid at any point

during the 2023-2024 school year. This dataset includes any school-age children

categorized as a foster child, homeless, a migrant child, and/or a runaway child. Further,

this dataset provided by DCF will not be limited to children who attend NSLP schools;

rather, it will be constructed to include any child who was enrolled in one of the

aforementioned public assistance programs and meets the State’s definition of school-

age (See Section 3.1.d). DHS and DCF have systems in place so that this dataset can be

shared automatically (no manual compilation or manipulation of the file is needed). This

dataset will include all necessary student-identifying information, such as full name, date

of birth, grade, gender, and specific school enrollment information. To ensure all school-

age students enrolled in SNAP, TANF, FDPIR, and/or Medicaid in Wisconsin are captured,

DHS and Deloitte will also facilitate a data-pull from the CARES statewide eligibility system

of all children of compulsory/school-age who were part of a household receiving benefits

from one of these programs during the 2023-2024 school year (as well as 1-3 more times

throughout the 2024 summer operational period). Prior to every systematic benefit

issuance, the CARES data pull and the DCF dataset will be compared and de-duplicated to

ensure no duplicate benefits are issued.

Instructions: Summer EBT agencies will issue benefits to a significant portion of eligible children

using only data that are already available at the State or ITO level. To facilitate this, Summer EBT

agencies must be able to efficiently collect eligibility data from programs used for direct

certification in the NSLP, and any other programs approved by USDA to use for streamlined

certification. This data must be sufficient to confirm the child’s income eligibility, match and

deduplicate records, and mail cards, as necessary.

The Summer EBT Playbook

developed by Code for America and Share our Strength discusses

approaches that the Summer EBT agency could employ.

3.1.d For the purposes of streamline certifying children without matching to NSLP enrollment

provide the State or ITO’s legal ages of compulsory school enrollment [7 CFR 292.2; 7 CFR

292.12(d)].

Minimum age: 6 – Children must be at least 6 years of age at some point during the

2024 period of eligibility (7/1/2023 through 8/29/2024). In other words, children must

have a date of birth on or before 8/29/2018 to be considered “school-age”.

Maximum age: 18 – Children must not be more than 18 years of age on or before 7/1/2023

(the start of the 2024 period of eligibility). In other words, children must have a date of birth on

or after 7/1/2005 to be considered “school age”.

Instructions: The compulsory school age is the ages during which attendance in school is required

by State or Tribal law. This should not be confused with the minimum or maximum age to which

free education must be offered by a State or ITO. A child must be within that age range and

categorically eligible during the Summer EBT Period of Eligibility in order to be eligible for

streamlined certification.

3.1.e Describe the process you will use to compile your issuance list from the data sets used for

streamlined certification [7 CFR 292.12

As described, several weeks before the June 22

issuance, DHS and Deloitte will receive data

about children eligible via streamlined certification from DPI, DCF, the Student Information Portal,

and from the CARES statewide eligibility system. Deloitte and DHS have put processes in place so

that these datasets will be combined and then rigorously scrutinized.

After combining all datasets into one master list, at a high level, the first phase of this analysis

involves identifying and eliminating any duplicate records. As all of the datasets getting combined

will include several identifiers (first name, last name, date of birth, gender, etc), it is expected that

many duplicates will be easily identified and excluded through this process. In any cases where it

is uncertain whether two student entries are duplicates (for example, they have the same first

name, last name, date of birth, and gender), these student records will be funneled into a separate

spreadsheet for manual investigation by DHS contracted S-EBT staff. This will involve researching

each record – including any outreach to agency staff or the household – before making an

individual determination as to whether benefits should be issued or not.

Once this first phase of ensuring there is only one ‘row’ in the master dataset per eligible child,

then a complex, multi-tiered data matching process will commence through which the State can

be sure that these eligible children are being matched to existing cases, when applicable, and that

the most appropriate parent/caretaker and mailing address information are being utilized

. This

step is important in that it is likely an eligible child may have several different mailing addresses

associated with them (perhaps one that was submitted by DPI via WISE and another that was

available via the CARES eligibility system). As was successfully done throughout P-EBT’s

implementation, DHS and Deloitte have designed a hierarchy to help prioritize case matching and

mailing address information. This ensures that, to the best of our ability, Summer EBT benefits

will be issued to existing CARES cases (and existing QUEST cards) when available and will be issued

to the most applicable parent/caretaker and address. This minimizes the need for returned mail,

benefits issued to the wrong parent/caretaker, and fair hearings.

Of specific importance, DHS compares every S-EBT-eligible student record to OHC placement data provided by DCF

before any benefits can be issued. This data – collectively referred to as OHC data – is the most up-to-date source

for information about where children in these types of living situations are currently placed. This data source is given

the top priority in our data matching hierarchy, meaning a match to an address in this dataset will be used instead

of an address that, for example, was provided for the same student via the DPI WISE dataset.

Instructions: The Summer EBT agency must take participation lists from programs approved for

streamlined certification and remove duplicate children, as well as children who are not school

aged, consistent with the State or ITO’s legal ages of compulsory school enrollment. Describe this

process. Reminder, children attending NSLP schools do not need to be of compulsory school age

to participate in the Program.

3.1.f Describe the process to encourage and facilitate households to provide updated contact

information for the purpose of receiving Summer EBT.

With Deloitte’s help, DHS has designed the Benefit Management Tool that will be made publicly

available in early March 2024. This tool serves two Summer EBT-specific purposes – it allows

households to update their contact information prior to benefits being issued in late June 2024,

and it allows households to opt their students out from receiving 2024 Summer EBT benefits if

they choose. This Benefit Management Tool will be available online and clearly explains what

information is needed, how it will be used, and provides a confirmation post-submission for a

household to retain for their records.

Public communications will be created and shared by both DHS and DPI regarding the launch,

continued availability, and date by which households are encouraged to use the tool in order to

inform the June issuance. These communications will be shared on the DHS Summer EBT

webpage, social media accounts for DHS and DPI, shared verbally at stakeholder calls and calls

aimed at parents/caretakers, emailed to listservs, and shared with families through school

bulletins/communications. Of note, households will also be able to contact the Summer EBT

Support Team staff via phone if they need help understanding and/or completing their Benefit

Management Tool submission.

Additionally, DHS conducts extensive ongoing outreach to households already receiving SNAP and

Medicaid encouraging them to keep their addresses on file up-to-date. For these existing cases,

they are and will continue to be encouraged to use SNAP- and Medicaid-specific channels for

updating their addresses (and will not necessarily be encouraged to utilize this Summer EBT

Benefit Management Tool to do so).

Prior to the June 22

issuance, Deloitte will review all Benefit Management Tool submissions and

compare any updated parent/caretaker and mailing address information to the information

available via other data sources (like the CARES eligibility system). When appropriate (as

determined by DHS), the eligible student’s parent/caretaker and/or mailing address information

will be updated based on what was submitted via the Benefit Management Tool.

Instructions: Summer EBT agencies must establish procedures to allow households to provide

updated contact information for the purpose of receiving Summer EBT. This is especially

important for households that applied for NSLP benefits with a school meal application. It is not

uncommon for households to move during the school year or provide incomplete contact

information when enrolling children in school. Allowing households to easily update their contact

information before cards are mailed will reduce the number of cards that are returned.

3.1.g Describe the process for households to confirm eligibility status and unenroll if they do not

want to receive benefits [7 CFR 292.8(e)(11)(iii); 7 CFR 292.12(b)(3)

With Deloitte’s help, DHS has designed the Benefit Management Tool that will be made publicly

available in early March 2024. This tool serves two Summer EBT-specific purposes – it allows

households to update their contact information prior to benefits being issued in late June 2024,

and it allows households to opt their students out from receiving 2024 Summer EBT benefits if

they choose. This Benefit Management Tool will be available online and clearly explains what

information is needed, how it will be used, and provides a confirmation post-submission for a

household to retain for their records.

Public communications will be created and shared by both DHS and DPI regarding the launch,

continued availability, and date by which households are encouraged to use the tool in order to

inform the June issuance. These communications will be shared on the DHS Summer EBT

webpage, social media accounts for DHS and DPI, shared verbally at stakeholder calls, emailed to

listservs, and shared with families through school bulletins/communications. Of note, households

will also be able to contact the Summer EBT Support Team staff via phone if they need help

understanding their eligibility status and/or completing their Benefit Management Tool

submission. Their eligibility will also be confirmed via the Notices of Eligibility/Enrollment that are

sent to every household with at least one child receiving benefits.

In addition, language will be included in Notices of Eligibility/Enrollment about how to opt out

and, more specifically, that a household should contact the Summer EBT Support Team if they

have already been issued benefits that they do not want.

In all areas, it will be clearly communicated that the decision to opt out a student from receiving

Summer EBT in 2024 is only applicable for the 2024 year. If that student continues to be eligible

in future years and the household does not wish to receive benefits in those future years, they

will need to opt out again. This stipulation was put in place because it is likely that the opt-out

process and applicable platforms (like the Benefit Management Tool) will change from 2024 to

2025 once more permanent resources are developed.

As an additional avenue of communicating about the opt-out option, verbiage about opting out

and a link to the Benefit Management Tool has been included in FRPL approval letters sent to

families from DPI throughout the 2023-2024 school year. This means that any family whose

student became or becomes approved to receive free or reduced price meals via FRPL application

this year (and, therefore, who would be streamlined certified to receive S-EBT benefits in 2024)

will be provided with a way to opt out of also receiving S-EBT in 2024 if they choose.

Prior to the June 22

issuance and all subsequent issuances, Deloitte will review all Benefit

Management Tool submissions and remove from the master list of eligible students anyone who

has been opted out.

Instructions: Summer EBT agencies must develop a process to enable anyone who has been

determined to be eligible for Summer EBT benefits to see that they are eligible and unenroll, or

opt-out, of the Program if they prefer. This must be included in notice of eligibility and

enrollment.

Children from households which notify the Summer EBT agency that they do not want Summer

EBT benefits should not be issued benefits, or must have their benefits discontinued as soon as

possible, if already issued. If a Summer EBT agency is not able to stand up an opt-out system in

the immediate term, the agency may work with their RO to implement flexibilities for 2024, such

as directing households that do not want to participate to destroy their Summer EBT cards. Any

notification from the household declining benefits must be documented and maintained on file,

as required under 7 CFR 292.23, to substantiate any change in benefits. Households that opt out

of the Program may contact their Summer EBT agency at any time before the end of the summer

operational period to request reenrollment.

3.2 Applications [7 CFR 292.8(e)(7)

]

3.2.a For 2024, Summer EBT applications will be processed by (choose one) [7 CFR 292.13

 The Summer EBT agency

 LEAs

 The Summer EBT agency and LEAs

Instructions: Summer EBT applications are ultimately the Summer EBT agency’s responsibility.

Recognizing that Summer EBT agencies may need operational flexibilities as they launch their

programs, in Summer 2024 only, Summer EBT agencies may delegate (i.e., assign) activities

related to Summer EBT applications to LEAs, but the Summer EBT agencies must pay for new

costs associated with processing Summer EBT applications. For example, if a Summer EBT agency

needs a large LEA to collect applications for Summer EBT in 2024, the Summer EBT agency may

delegate application activities to the LEA and cover all costs associated with Summer EBT

activity. Summer EBT agencies do not need to cover LEA costs already associated with

alternative applications not used for Summer EBT purposes. In Summer 2025 and beyond,

Summer EBT agencies may enter into contracts or other similar arrangements with LEAs to

process applications, but they cannot compel them to do so. See Summer EBT Questions &

Answers #17 & 18 for more information.

3.2.b Will alternative income applications be used in 2024?

 Yes

 No

If yes, initial here to attest that the alternative applications collect enough

information to determine program eligibility.

In Wisconsin, CEP schools are accustomed to soliciting alternative income applications from their

families as well as processing and reporting information gleaned from these applications within

the WISE reporting system. Wisconsin’s existing alternative income application, when collected,

contains sufficient information to also determine Summer EBT program eligibility. Specifically,

each alternative income application is reviewed by the receiving CEP school, and any students

included are marked as “Economically Disadvantaged” if applicable. DPI has attested that this

“Economically Disadvantaged” designation indicates that the student’s household meets the

income criteria for FRPL eligibility. Existing processes include CEP schools then reporting this

information received via alternative income applications within WISE. As such, when DPI performs

their end-of-school-year data pull across all WISE-reporting schools (including CEP schools), the

resulting dataset will include CEP students who turned in an alternative income application and

who satisfy the income criteria for FRPL enrollment. As described, this dataset is shared with DHS

for the purposes of identifying and issuing benefits to all Summer EBT-eligible children across the

state.

While alternative income applications will be used in 2024 to identify (and ‘streamline certify’)

additional eligible students in Wisconsin, they will serve as a complement (not replacement) to

the Summer EBT application (See Section 3.2.c for more information on the S-EBT Application).

That said, Wisconsin expects the leveraging of alternative income applications in 2024 to

significantly increase the number of children who can be streamlined certified and significantly

reduce the number of children who need to complete an S-EBT Application to receive benefits.

Instructions: During summer 2024, alternative income applications that are currently used in

some NSLP special provision schools may be used to confer eligibility if they allow a Summer EBT

agency to determine whether the household is at or below NSLP/SBP reduced price income

threshold. States, ITOs, and LEAs may use their alternative income applications for Summer EBT

in 2024 or make a Summer EBT application available for children, which could be the USDA

prototype application.

Alternative income applications refers to forms that are used to determine household income for

programs or reasons other than USDA programs. These forms are used by some LEAs to collect

information at their special provision schools that would have otherwise been collected through

NSLP/SBP applications on an annual basis. These applications may also be referred to as “family

income surveys” or “household income data forms.” Data collected through alternative income

applications are used for purposes not related to the school meal programs, such as determining

education funding allocations, and other student benefits. It is the responsibility of the Summer

EBT agency to ensure that alternative income applications meet the requirements for 2024.

See Summer EBT Questions & Answers #19

for more information.

3.2.c Describe the data and processes used to confirm that an applicant for Summer EBT is

enrolled at an NSLP/SBP school and that they are not issued duplicate benefits through the

streamlined certification [7 CFR 292.8(e)(7), 7 CFR 292.12(e)(2)

S-EBT Application Overview:

DHS has partnered with Deloitte to revamp an online application platform used during early 2023

for Pandemic EBT purposes. This application has been updated to meet all stated FNS

requirements for Summer EBT in 2024 regarding the identification of students eligible for Summer

EBT benefits. Specifically, this application allows a parent/caretaker to provide identity and

income information about themselves and all other adults and children in their household. For

each child in the household, it allows the parent/caretaker to specify information about their

NSLP/SBP school enrollment in the 2023-2024 school year. Finally, the application includes an

attestation section wherein the parent/caretaker must attest that all information provided in the

application is true, that all income has been accurately reported, that their household has not

received Summer EBT benefits from any other State, Territory, or ITO for 2024, and that they

authorize DHS and other State agencies to use the information provided for verification purposes.

S-EBT Application Process (Explained):

- DHS will oversee and maintain the S-EBT Application platform for 2024

o Both DHS and DPI will be promoting the availability of the S-EBT application via

multiple communications platforms (i.e. websites, social media, school bulletins,

etc)

o A paper version of the S-EBT Application will be made available upon request

o Households will also be able to contact the Summer EBT Support Team staff via

phone if they need help understanding and/or completing the S-EBT Application

- Applications submitted will come to DHS for the first round of review

o DHS will confirm that all necessary/satisfactory information was provided for

the student(s) included in the application, including that the family attests to a

household income level that is at or below the required threshold for their

household size

and checking that the students are not otherwise eligible for

Summer EBT benefits via streamlined certification (including checking to ensure

the student(s) on the application has not already received Summer EBT benefits

in Wisconsin in 2024).

o DHS will securely transfer a file

once per week to DPI that includes all students

who applied and who satisfy this first round of review

- DPI will conduct the second round of review

o DPI will verify whether each student shared by DHS is on file as being/having

been enrolled in the claimed NSLP school during the 2023-2024 school year

o DPI will then securely transfer a file back to DHS clearly listing which students

are verified/approved and which are not

- DHS will conduct the final processing/data matching and issuance steps

 Applications will be matched against the same administrative data sources

as streamlined certified students (including, for example, the DCF Direct

Certification data) prior to any benefit issuance

 For complete applications that are submitted on or before May 1

, 2024, if

determined eligible through this application review process, that the

student will be issued benefits on June 22

(and will be put through the

same data reconciliation and matching steps as all other streamlined

certified students and to ensure no duplicate benefits are issued).

 For completed applications that are submitted between May 2, 2024 and

June 27

2024, if eligible, the student will be issued benefits within 15

operational days after June 27

(and will be put through the same data

reconciliation and matching steps as all other streamlined certified students

and to ensure no duplicate benefits are issued).

 For completed applications that are submitted after June 27

, 2024, if

eligible, the student will receive benefits within 15 operational days of the

date of their received completed application (and will be put through the

same data reconciliation and matching steps as all other streamlined

certified students and to ensure no duplicate benefits are issued).

Per the FNS IFR, if an application is received prior to July 1

of each year, the prior year’s income threshold for free

or reduced meal receipt will be used. Conversely, review of any application received on or after July 1

of a given

summer will be based on the next year’s income threshold. For example, an application received on June 15, 2024

will be evaluated based on the 2023-2024 school year income threshold whereas an application received on July 15,

2024 will be evaluated based on the 2024-2025 school year income threshold.

Will utilize Sharepoint – same secure file sharing mechanism that DHS and DPI utilized for Pandemic EBT in the

2022-2023 school year and summer of 2023.

Instructions: Summer EBT agencies must be able to confirm whether children on applications are

enrolled in NSLP/SBP-participating schools within the State or ITO service area, as applicable, for

the purposes of certifying children for Summer EBT benefits and detecting and preventing

duplicate benefit issuance for children that were already certified through streamlined

certification.

Summer EBT agencies must ensure the confidentiality of all such data, and the data must be

used only for the purposes of the Summer EBT Program, or to provide other social service

benefits to eligible children.

State Summer EBT agencies must make this data available to ITO Summer EBT agencies for

children within an ITO’s Summer EBT service area, in a timeframe that allows ITO Summer EBT

agencies to issue timely benefits. ITO Summer EBT agencies must ensure confidentiality of the

data. Procedures to share data will be included in any State-ITO agreement.

3.2.d Describe how data confidentiality will be maintained [7 CFR 292.12(c)(2)

Select, designated representatives of DHS, DPI, and Deloitte will be given secure access to Summer

EBT student data. These representatives will be tasked with ensuring that all student information

is handled in a confidential, secure manner and is only accessed for the purposes of determining

Summer EBT eligibility and benefit issuance. This group will also work to ensure that no dual

participation occurs. There are no Wisconsin-based ITOs also operating a Summer EBT program

in 2024.

Instructions: The Summer EBT agency must ensure the confidentiality of all student data

exchanged that is applicable to Summer EBT program eligibility and dual participation; and data

must only be used for SEBT program purposes (c)(2), or for the purpose of use or disclosure to

provide other social service benefits to eligible children, in accordance with 7 CFR 292.12(c)(2). In

addition, student data may only be shared with persons authorized to receive eligibility

information consistent with § 292.13(o).

3.3 Verification of Summer EBT applications [7 CFR 292.8(e)(7)

]

3.3.a For 2024, the following types of verification will be implemented [7 CFR 292.14

 Verification for cause (required) [7 CFR 292.14(a)(1)]

 Direct verification of selected applications (required) [7 CFR 292.14(e)]

 3% random sample [7 CFR 292.14(a)(2)]

 Alternative verification procedure [7 CFR 292.14(a)(3)] (if selected, please describe

below):

Instructions: Verifying officials (i.e., staff that participate in verification activities) do not need to

complete verification for all applications. Summer EBT applications will be subject to verification

for cause in 2024, a process through which questionable applications are verified on a case-by-

case basis. Any application selected for cause must first be directly certified before the household

is contacted to request documentation. An additional 3% sample (or proposed alternative

procedure) is not required in 2024. However, if you intend to implement a verification procedure

beyond verification for cause and direct verification, please indicate that and describe in detail,

as applicable.

NOTE: NSLP applications that are used to confer Summer EBT eligibility are not subject to

Summer EBT verification requirements. However, they are subject to regular NSLP verification

procedures, even if the household only applied for NSLP in order to get Summer EBT benefits.

3.3.b For 2024, Summer EBT applications will be verified by (choose one) [7 CFR 292.14

 The Summer EBT agency

 LEAs

 The Summer EBT agency and LEAs

Instructions: Summer EBT applications are ultimately the Summer EBT agency’s responsibility.

Recognizing that Summer EBT agencies may need operational flexibilities as they launch their

programs, in Summer 2024 only, Summer EBT agencies may delegate (i.e., assign) activities

related to Summer EBT applications to LEAs, including verification, but the Summer EBT agencies

must pay for all new costs associated with verification. For example, if a Summer EBT agency

needs a large LEA to verify applications for Summer EBT in 2024, the Summer EBT agency may

delegate verification activities to the LEA and cover all costs associated with Summer EBT

verification. In Summer 2025 and beyond, Summer EBT agencies may enter into contracts or

other similar arrangements with LEAs to process applications and conduct verification, but they

cannot compel them to do so.

3.3.c For Direct Verification purposes, Program data that will be used to verify selected

applications prior to contacting a household include (check all that apply) [7 CFR 292.14(e)

 NSLP/SBP free and reduced price lists

 SNAP

 TANF (Temporary Assistance for Needy Families)

 FDPIR (Food Distribution Program on Indian Reservations)

 Medicaid (only allowed if participating in the Direct Certification with Medicaid

Demonstration projects in the school meal programs)

 Other:

Section 4: Data Sharing and Preventing Dual Participation

4.1 Provide plans to coordinate among ITO Summer EBT Program(s) and/or State Summer EBT

Program(s), as applicable [7 CFR 292.8(e)(8), 7 CFR 292.9

At the time of the POM submission, the State is not aware of any Wisconsin-based ITOs planning

to operate a Summer EBT program in 2024. Should that change, the State is committed to

coordinating with the ITO(s) to the maximum extent practicable and in accordance with the IFR

requirements to prevent dual participation and ensure the seamless, timely administration of all

Summer EBT programs.

Instructions: State and ITO-operated Summer EBT programs serving proximate areas must

coordinate and communicate to ensure efficient and timely service to eligible individuals and

prevent duplicative issuance of benefits. If the geographic State is not operating a Summer EBT

Program in 2024, the ITO will coordinate with the State’s designee. If an ITO’s service area

crosses geographic State boundaries, the ITO and each applicable Summer EBT agency, or

designee of a State covering the geographic area(s) served by the ITO, must coordinate services.

FNS regional offices will facilitate discussions and information sharing between States and ITOs,

as appropriate.

ITO Summer EBT agencies will receive priority consideration to serve eligible children within

their service area, as identified in an FNS-approved POM. This means that children from the

ITO’s service area who can be enrolled through streamlined certification will automatically be

enrolled in the ITO-administered Summer EBT Program, to the maximum extent practicable.

However, children from ITO service areas may opt to participate in the State-operated program

and opt out of the ITO-operated program if they so choose.

State Summer EBT agencies must:

• Share student data with the ITO, including student eligibility status and contact

information of children deemed eligible within the ITO’s service area.

• Provide information in a manner and timeframe that will allow the ITO Summer

EBT agency to issue benefits timely.

• Ensure the confidentiality of all Program-related student data used to determine

Program eligibility and prevent dual participation.

ITO Summer EBT agencies and the State Summer EBT agencies serving proximate areas

must:

• Ensure the coordination of Summer EBT program services, which may include a

written agreement between both parties.

• Notify eligible children or households that they may choose to receive Summer

EBT program benefits from either the State or the ITO Summer EBT agency.

• Provide referral information to the alternative program upon a child or

household’s r

equest, thereby facilitating household choice.

4.2 Provide procedures to detect and prevent dual participation [7 CFR 292.8(e)(9); 7 CFR 292.9(b)(3); 7

CFR 292.12(c); 7 CFR 292.12(f)(4); 7 CFR 292.15(d)], which includes:

- A child simultaneously receiving benefits from more than one State or ITO-administered

Summer EBT program or,

- A child simultaneously receiving multiple allotments from the same State or ITO-

administered Summer EBT program.

he Notices of Approval/Eligibility sent to households with eligible children will contain a

statement clarifying that a child may not be issued Summer EBT benefits from more than one

Summer EBT program in Wisconsin in 2024, more than one time from the same program in

Wisconsin in 2024 (amounting to more than $120 per eligible child), or from more than one State

in 2024. The Summer EBT application’s attestation section also includes a statement through

which the applicant must certify that they have not already received Summer EBT benefits from

any other State-run or ITO-run program for the 2024 summer.

To prevent dual participation, as described in Section 3.1.e of this POM, a rigorous data

reconciliation process takes place before each issuance of Summer EBT benefits. Each eligible

child is compared against the list of children who have already received Summer EBT benefits via

the State-run Summer EBT program to ensure no duplication. Each eligible child is also compared

against all data sources containing eligible children (DPI dataset, DCF Direct Certification dataset,

Student Information Portal dataset containing info from non-WISE-reporting schools and

approved Summer EBT applications) to ensure a child has not already been accounted for through

a different source of available data. DHS intends to build off of its success through the years of P-

EBT implementation, during which it saw increasingly lowered instances of dual participation year

after year (per the below definition). Should any instances of dual participation come to the

State’s attention, they will be investigated swiftly and thoroughly as well as reported to USDA as

needed.

Instructions: Dual participation means a child simultaneously receiving benefits from more than

one State or ITO-administered Summer EBT program, or simultaneously receiving multiple

allotments from the same State or ITO-administered Summer EBT program. Relatedly, duplicate

benefit issuance includes situations where the Summer EBT agency allows an eligible household

to dual participate. For example, a child who moves in the spring may not receive a benefit from

both the State they left and from the State to which they moved. Likewise, a child living within an

ITO Summer EBT agency’s service area may not receive benefits from the ITO-administered

program and a State-administered program that operates in a proximate geographic area, nor

may they receive benefits from two ITO-administered programs.

State and ITO Summer EBT agencies must work together to prevent dual participation,

particularly in State border areas and around ITO service areas and must establish detection and

prevention procedures in their POMs. Summer EBT agencies could choose to adapt systems

already in place for their counterpart SNAP or WIC program, or propose an alternative approach.

In addi

tion, a participant’s notice of approval must include a statement communicating that

households that are erroneously issued duplicate benefits from more than one State or ITO

should only use benefits from the State or ITO where their child(ren) completed the instructional

year immediately preceding the summer operational period. Under no circumstances may they

use both, which would be dual participation. A State or ITO-level database could be used to

detect and prevent duplicate benefit issuance and increase data integrity across the Summer EBT

program.

Section 5: Customer Service Plan

5.1 Provide a customer service plan that includes [7 CFR 292.8(e)(11); 7 CFR 292.15(g)

a. A single point of contact for all customer service information and inquiries including a

hotline and website;

b. A plan to inform eligible households of the availability of Program benefits and the

process to apply for benefits, if necessary; and

c. A simplified process for households to opt out of the program.

DHS’s Summer EBT Support Team will serve as the primary point of contact for

households and other stakeholders with questions about the Summer EBT program. This

Team will manage a dedicated call center, phone number, and email account for Summer

EBT (phone number and email account TBA).

The call center will only acvely take calls during

stated business hours, but the dedicated call center will allow for callers to leave voicemail

messages, even during non-business hours.

Regarding the overall public communication plan for Summer EBT, communications will be

created by DHS and DPI in 2024 and shared by both agencies, when applicable, via multiple

channels (stakeholder calls/webinars, school bulletins, school superintendents, GovD listservs,

agency websites/social media accounts, etc). The communications to be created/published

include but are not limited to:

o Communications (beginning in early spring of 2024) through existing school/SFA

channels introducing/explaining the Summer EBT program (will potentially utilize

new FNS program branding)

o Custom mailer with Summer EBT-specific information sent with new QUEST cards

issued

o Notice of Eligibility/Benefit Issuance (including how eligibility was determined,

where benefits can be used, what can be purchased with them, penalties for misuse

of benefits, opt-out information, etc)

o Notice of Upcoming Expungement (will be mailed at 60 days post-issuance to any

household with a non-zero balance at that time, will contain information about the

upcoming removal date for any remaining balance of S-EBT benefits)

o Notice of S-EBT application denial via regular review (including reason for

ineligibility and appeal/fair hearing information)

o Notice of S-EBT application denial via direct verification following the need for

verification for cause (including reason for ineligibility and appeal/fair hearing

information)

o Notice (and follow-up attempts) to households who submitted an S-EBT application

and have been pulled due to verification for cause (sent after direct verification has

been attempted and was inconclusive or unsuccessful) – includes instructions

regarding the documentation/information that needs to be submitted and by when

o Resources for schools and partner organizations to use to explain the S-EBT program

and promote the S-EBT application and Benefit Management Tool

o Written manual and video to explain how to properly use the Student Information

Portal for SFAs that do not report data to DPI WISE

o Email reminders to SFAs that do not report data to DPI WISE regarding the Student

information Portal

o Public-facing GovD emails to subscribers/partners announcing:

 Launch of the Summer EBT program for 2024

 Launch of S-EBT Application and Benefit Management Tool

 Upcoming cut-off date (May 1, 2024) for use of S-EBT Application and

Benefit Management Tool (to be included in June 2024 issuance)

 Systematic issuance on June 22

, 2024

 Deadlines for use of S-EBT Application and Benefit Management Tool as well

as deadline for submitting appeal/fair hearing requests near end of summer

operational period

Instructions: Although Summer EBT Program implementation will be a partnership between

agencies in most cases, Summer EBT must be a unified program from the perspective of

participants. Summer EBT customer service plans must include a single point of contact for all

customer service information and inquiries and must include a telephone hotline and website. In

addition, the customer service plan must communicate how households can opt out of

participating in the Program.

Because Summer EBT is a new program, stakeholders at all levels need information that clearly

explains what the Program is, who is eligible, and how benefits can be accessed and redeemed.

Summer EBT agencies will need to provide information to clarify differences between Summer

EBT and PEBT.

Summer EBT agencies must provide written materials to each household prior to Summer EBT

issuance and as needed during ongoing operation of the Summer EBT Program. At a minimum,

the household materials must provide information including, but not limited to: where benefits

can be used, what foods are eligible for purchase, unallowable uses of benefits and penalties for

misuse, use of security Personal Identification Numbers (PINs), how families may access

customer service supports during non-business hours, the eligibility criteria for benefits,

disclosure information regarding adjustments and a household’s rights to notice, fair hearings,

and provisional credits, and must include the USDA statement of non-discrimination and be

prepared at an educational reading level suitable for participant households. These standards

are a minimum, and USDA highly encourages Summer EBT agencies to maintain more frequent

contact with eligible households to ensure they have the information they need to access

program benefits. Examples include providing information through the schools before the end of

the school year, robo-calls and texts to families to remind them that they have benefits available

to spend, and social media ads. Summer EBT agencies should consider how they can incorporate

outreach throughout the summer period in a manner that is inclusive of individuals with

disabilities or limited English proficiency, and people who are unhoused, or generally are not well

connected with community services or media.

Section 6: Program Violations

6.1 Provide a plan for timely and effective action against program violators [7 CFR 292.8(e)(4), 7

CFR 292.25].

Similar processes used for SNAP and Pandemic EBT intentional program violations will be put in

place for Summer EBT violations. All instance of intentional program violation will be promptly

investigated, and, if/when confirmed, will be acted on as immediately as is practicable. DHS will

maintain on file all evidence relating to such investigations and actions and will inform the FNS

Midwest Regional Office of any suspected fraud or criminal abuse which would result in a loss or

misuse of federal funds.

Instructions: The Summer EBT agency must promptly investigate complaints received or

irregularities noted in connection with the operation of the Program and must take appropriate

action to correct any irregularities including, but not limited to, disqualification and claims. As

Summer EBT adapts aspects of WIC, SNAP, and Child Nutrition Programs, some program

violations will be similar to violations seen in these programs, and may benefit from similar

processes.

6.2 Attach a copy of the Summer EBT agency’s fair hearing procedures for participants [7 CFR

292.8(e)(12), 7 CFR 292.26].

Instructions: See regulations at 7 CFR 292.26

for complete hearing requirements to help

complete this requirement.

Section 7: Indian Tribal Organizations

In addition to Sections 1-6, provide the below information if you are an ITO administering the Summer

EBT program.

Required Attachments:

 A map or other visual reference aid of the service area of the ITO, including a description of any

areas beyond the ITO’s jurisdiction that the ITO proposes to serve [7 CFR 292.8(f)(1)

Instructions: ITO service area means the geographic area served by an ITO Summer EBT agency.

In WIC, ITO service areas have typically included reservations, or specific Tribal lands in

Oklahoma. FNS expects that ITOs will continue to use existing Tribal service areas for the

purposes of Summer EBT. However, if an ITO proposes to serve children in areas beyond typical

WIC or FDPIR service areas, potentially including other Tribal areas, the ITO must indicate the

modified service area, as appropriate and only applicable to Summer EBT. The map or visual

reference should include a description of any Tribal areas outside of the ITO’s typical jurisdiction

(e.g., other Tribal areas) that they propose to serve, if applicable. Please note, if an ITO’s service

area crosses geographic State boundaries, the ITO and each applicable State Summer EBT

agency, or designee of a State covering the geographic area(s) served by the ITO, must

coordinate services.

7.1 A plan and procedures to enroll children already deemed eligible by a State Summer EBT agency

serving the same geographic area, without further application [7 CFR 292.8(f)(2)

Instructions: The State Summer EBT agency must share data, including household contact

information, indicating those individuals deemed eligible in the ITO Summer EBT agency’s service

area in a manner and timeframe that will allow the ITO Summer EBT agency to issue program

benefits timely. The ITO Summer EBT agency must receive priority consideration to serve eligible

individuals within its service area. Please indicate the ITO Summer EBT agency’s plans to work

with the State Summer EBT agency to obtain necessary data, including reference to any informal

or formal discussions or agreements on-topic.

7.2 A plan and procedures to determine eligibility for and enroll children who must apply through

the ITO Summer EBT agency to receive benefits because they have not already been identified

as eligible (i.e., via streamlined certification or the State Summer EBT agency) [7 CFR

292.8(f)(3)].

Instructions: Summer EBT agencies must enroll eligible children in Summer EBT if it is determined

that they meet the requirements to receive free or reduced-price meals, as determined through a

complete Summer EBT application. The ITO Summer EBT agency must use the eligibility criteria

under 7 CFR 292.6.

The Summer EBT agency will need a plan to develop, distribute, collect, and

process Summer EBT applications consistent with the Summer EBT standards. Describe this

process, why it is appropriate and accessible for the population served, and how the Summer EBT

agency will ensure integrity throughout.

7.3 A description of the benefit delivery model to be used including how the benefit issued will be

equal to or not exceed $120 for summer 2024. The ITO Summer EBT agency must use the same

benefit model for all participants throughout its service area [7 CFR 292.8(f)(4); 7 CFR 292.19(a)

Select one:

 C

ash-value benefit model (CVB). Describe:

 Food package model. Describe, including a chart or table detailing the types and

quantities of foods which can be purchased with Summer EBT benefit, as well as the

average cost of each within the ITO service area:

 Combination of CVB and food package. Describe:

 Alternative benefit delivery model. Describe:

Instructions: SEA instructions: An ITO Summer EBT agency’s POM must include a description of

the benefit delivery model to be used (i.e., a cash-value benefit (CVB) model, a food package

model, a combination of the two, or an alternate model) and must also provide the list of

supplemental foods which participants can purchase upon enrollment in the Summer EBT

Program. ITOs should explain their model and why it is appropriate for their participants.

ITOs using a CVB-only benefit delivery model must issue a benefit level equal to $120 per

summer in 2024. For ITOs using a food package benefit delivery model, a combination CVB and

food package benefit delivery model, or an alternate benefit delivery model, the benefit level

cannot exceed $120 per summer at the time of initial submission of the POM.

ITOs proposing to use a food package or similar model should include a chart or table detailing

the types and quantities of foods which can be purchased with Summer EBT benefits, as well as

the average cost of each within the ITO service area, to establish that the value of the package

does not exceed $120 per summer. Although, prices for individual items may vary over time or by

retailer, ITO Summer EBT agencies will not be required to cover the difference when a child’s

food costs exceed $120/summer at the point of sale, provided that the child’s purchases follow

the ITO’s approved food package. Accordingly, it is important that ITOs provide FNS detailed

information on their proposed package and average costs within the ITO service area so that the

estimated cost of the food package is as accurate as possible.

7.4 A list of supplemental foods for which participants can transact upon enrollment, excluding

infant formula and infant foods [7 CFR 292.8(f)(5); 7 CFR 292.19(a)(3)

Instructions: Specifications for supplemental foods are included in 7 CFR 292.19(a)(3)

Supplemental foods mean, for the purposes of Summer EBT, foods:

(1) containing nutrients determined by nutritional research to be lacking in the diets

of children; and

(2) promoting the health of the population served by the program under this section,

as indicated by relevant nutrition science, public health concerns, and cultural eating

patterns, as determined by FNS; and

(3) Supplemental foods authorized for the WIC Program by the applicable WIC ITO

meet the requirements set forth in this subparagraph, excluding infant foods and

infant formula.

The ITO Summer EBT agency does not need to provide its entire WIC product list for Summer EBT

or use the same foods in the Summer EBT Program as the WIC Program. However, the ITO should

indicate what WIC foods will be allowed in Summer EBT, describe any additional foods not

included on the WIC product list that will be offered for Summer EBT.

7.5 Requirements for vendors to transact and redeem Summer EBT Program benefits [7 CFR

292.8(f)(6); 7 CFR 292.19(a)]. Check each of the following to verify compliance:

 Only vendors authorized by the ITO to accept WIC benefits will be eligible to enroll in

the ITO’s Summer EBT Program.

 Only vendors that can accept the ITO-defined benefit, as identified in the POM and

subject to FNS approval, will be eligible to enroll in the ITO’s Summer EBT Program.

 Enrolled vendors will only provide foods from the ITO-submitted, approved foods list.

 Enrolled vendors will charge prices for eligible food items which are reasonable for the

area(s) served and are at the current price or less than the current price charged to

other customers.

Instructions: As a prerequisite, vendors must be approved for participation in the ITO’s WIC

Program in order to participate in their Summer EBT Program. The ITO Summer EBT agency must

attest that it will comply with the required vendor standards by checking the boxes listed in this

section.

7.6 A plan for providing technical assistance and training to vendors enrolled to transact and

redeem Summer EBT program benefits [7 CFR 292.8(f)(7)]

Instructions: Because WIC vendors are authorized by WIC agencies, the ITO Summer EBT agency

must support and monitor enrolled Summer EBT program vendors so they are able to support

Summer EBT purchases. Summer EBT agencies should, at a minimum, address how they will

inform vendors about Summer EBT, train vendors to recognize and accept the benefit, train

vendors to offer enough authorized supplemental foods to meet demand, and provide technical

assistance, as needed.

7.7 Provide a plan for enrolling vendors, including how the ITO Summer EBT agency will seek out

such vendors for participation in the Program [7 CFR 292.19(c)].

Instructions: As a prerequisite, vendors must be approved for participation in the ITO’s WIC

Program in order to participate in their Summer EBT Program. The ITO Summer EBT agency must

describe how it will enroll and hold vendors in the Summer EBT Program.

7.8 Provide a plan for vendor integrity and monitoring. Describe how vendors that will be held

accountable to meet all other applicable vendor-specific program requirements in 7 CFR 292.19,

as well as any additional requirements set by the ITO Summer EBT agency which are consistent

with regulation [7 CFR 292.19(c)].

Instructions: The ITO Summer EBT agency must set forth a system which ensures:

• Requirements and restrictions on the participation of vendors and the transaction of

food benefits described at 7 CFR 246.12

apply to activities involving Summer EBT

benefits; and

• V

endors are subject to the actions and penalties described at 7 CFR 246.12 of this

chapter for noncompliance or violations involving Summer EBT benefits; and

• Th

e standards for determination and disposition of claims against vendors described at 7

CFR 246.12 of this chapter apply to Summer EBT benefits;

-- or --

• Set forth an alternate system to ensure effective vendor management and vendor

integrity.

Summer EBT Agency Signatures

COORDINATING AGENCY (DHS)

PARTNERING AGENCY (DPI)

By (Signature)

Title

Director

Bureau of Eligibility Operations and Training

Division of Medicaid Services

Title

Assistant State Superintendent,

Division for Finance and Management

Date

02/13/2024

Date

2/13/2024