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E228: Code for America’s Summer EBT Playbook for State Implementation

Hosted by: Norbert Wilson (Duke)
February 5, 2024

In 2022, Congress established Summer EBT, the first new permanent federal food assistance program in almost 50 years. The authorization of Summer EBT represents a historic investment in the nutrition and wellbeing of almost 30 million children who will qualify for the program. But states that piloted Summer EBT, or operated Pandemic EBT programs in the early years of the COVID-19 pandemic know that getting these benefits into the hands of families will involve overcoming complex challenges related to data and technology. That’s why Code for America and No Kid Hungry, a campaign of Share Our Strength joined forces to create the Summer EBT Playbook, a comprehensive free resource designed to help state agencies plan for and implement a human-centered Summer EBT program. Today we will talk with Eleanor Davis, director of Government Innovation on the Safety Net team at Code for America. In her role, she helps government agencies adopt best practices for human-centered digital benefit delivery.

Eleanor Davis is the Program Director for Government Innovation at Code for America. In her role, she enables government agencies to adopt best practices for human-centered digital benefit delivery. She joined Code for America from Futures Without Violence, a national public health and social justice nonprofit dedicated to ending domestic and sexual violence. There she worked for 6 years on the Public Education Campaigns & Programs team, developing public-facing initiatives that support the ability of frontline providers and advocates to more effectively respond to and prevent violence and trauma. Eleanor is a graduate of the University of Chicago where she studied Sociology and Performance Studies, and received a Masters in Public Health from UC Berkeley. Outside of work you can often find her gardening in her backyard or singing in her family band.

Interview Summary

Why is Summer EBT significant?

Well, I think you gave us a good intro. Summer EBT is a brand-new benefit program and it’s designed to reduce childhood hunger during the summer months by providing families with a monthly grocery benefit to feed their kids when they’re not receiving meals at school. So, almost 30 million kids in the US receive free or reduced-price meals at school, but during the summer many of them struggle to access nutritious food because they’re not receiving those meals at school. School is out of session. Summer EBT is designed to give families $120 per child in the summer to help them buy groceries and it really has the potential to dramatically reduce childhood hunger. It’s a tremendous moment because Summer EBT is the first new permanent federal food assistance program in almost 50 years. For those of us in government or in the food access space, this is really I would say, a once in a generation opportunity to shape the implementation of the program to make sure it really meets the needs of families and children.

So, why did Code for America and Share Our Strength develop the Summer EBT Playbook? What was the challenge?

Code for America is a 501 C3 nonprofit organization. We partner with government at all levels to make the delivery of public services more equitable, more effective, and more accessible using technology and data. And we’ve spent the last decade helping states deliver safety net benefit programs in more human-centered ways. The Summer EBT program, as we mentioned, has immense potential, but we also know that states are going to encounter many challenges in implementing this program in 2024 and beyond. I think standing up a brand-new benefits program is a huge undertaking generally, but Summer EBT will present some really specific challenges to states and we learned a lot about this back in 2020. So, at the start of the pandemic, Congress authorized an emergency response program called Pandemic EBT, that was very similar to Summer EBT in many ways. It was the same idea, really sort of providing families with a grocery benefit while schools are closed because of COVID-19. And so, in 2020 and 2021, Code for America worked directly with about a dozen states to help them deliver Pandemic EBT benefits. And through that process we saw very up close what made that program so hard to implement. Delivery of the program really relies on effective data and technology systems. So, really being able to find the right data in state systems and use that data to deliver benefits. And a lot of these challenges will also be true for Summer EBT, right? It’s a very similar delivery process. So, states really needed help planning for Summer EBT and really designing systems and processes that will help them operationalize this brand-new program so that it can really live up to the promise spelled out in the policy. So, that’s why we partnered with the No Kid Hungry Campaign. We really wanted to develop a resource that would help states design effective and human centered Summer EBT programs. And our goal was really just to sort of help as many states as possible implement this program.

This is really interesting, and I would like to understand a little bit more. What challenges did states face in implementing the pandemic EBT and how do you see that showing up in the Summer EBT? I mean is it just getting the right software or is it something else?

There are so many really, it’s less about the software and more about the data. So fundamentally, I think some of the biggest challenges that we walk through in the playbook certainly, but that we know states are going to struggle with is really around using data to determine who is eligible for Summer EBT. So maybe just taking a step back, there are sort of two pathways for confirming who’s eligible for Summer EBT. The first is called streamline certification. Basically, this means that the state uses the data that it already must determine if a family is eligible for Summer EBT and then issues those benefits automatically. So, for example, if a child is already participating in a program that should make them eligible like SNAP or in some states Medicaid, they should automatically receive Summer EBT. And similarly, if a child is in the foster system or is in a Head Start program or if a child has applied for and is therefore receiving already free and reduced-price meals at school, those children should receive Summer EBT automatically. But children who can’t be certified as eligible through any of those pathways will have to apply for the Summer EBT benefits. So that’s sort of the other eligibility route. States must provide a way for families to directly apply if they can’t certify them through streamline certification. So, the idea is that the majority of children who are eligible for the program should actually get benefits automatically through streamline certification. And that’s really fantastic, right? We should always be looking for ways to reduce the administrative burden that low-income families face when they aim to gain access to programs they’re entitled to. So theoretically, if a state already has enough information to say this family is eligible for Summer EBT, they should just send that money out automatically and without the family having to do anything. That’s sort of the best-case scenario. On the state side though, this is actually really complicated to do. The data that states need to use to determine that eligibility is all over the place, right? It’s in Head Start programs, it’s in the foster care system, it’s in a state’s SNAP or Medicaid eligibility system and it’s in the schools, and school data presents really specific challenges for states to be able to use. So, states therefore have to identify where is all this data? What systems is it in? What agencies have this data? They then must aggregate all that data in one place that’s central and usable. They have to clean and de-duplicate and match all that data across those different data sources. And then of course they have to deal with any inaccuracies or gaps in the data. So, data collection, data aggregation, data management, these are really sort of the core challenges of implementing this program. How do you collect all of this information into one place and use it to deliver benefits to families? This is really one of the core challenges that we focus on in the playbook.

It’s really helpful to hear how you all are helping states think through this. And I would imagine that there are some differences across states. How in the playbook have you been able to best manage the uniqueness of these different states?

It’s really tricky. I think we always say if you’ve seen one state system, you’ve seen one state system, no two states really look the same. And I’m using state really as a shorthand, tribal nations can implement this program, territories, US territories can also implement this program. So, there really is no one standard way that states backend infrastructure looks. And even when it comes to implementing this program, Summer EBT, different state agencies are sort of taking the lead in different states on administering this program. So, I think we’re doing our best to help understand what unique challenges states are facing while also recognizing that the sort of themes, the main things, the primary challenges are going to remain the same basically across a lot of states. And so, we are really sort of in the playbook offering best practices, recommendations that we know will be universally helpful no matter really what a backend state system looks like.

Can you give us a little bit of the flavor of those best practices?

Absolutely. So, I want to talk about a couple here because this program gets really weedy really fast. I think the first one that we really talk about is client support. As we’ve been discussing, this is a really complicated program to administer. It’s also brand new, right? So, families are going to need support navigating this program. They’re going to have questions; they’re going to be confused. Even after multiple years of Pandemic EBT, many families were still confused about why they did or did not end up receiving benefits. So, who is eligible? Can I expect these benefits? How do I get them? These are all questions that families are going to have. So, states need to be prepared to provide really consistent and clear communication to families. And they also need to have really easily accessible pathways for families to reach out and ask questions when they have them. And we can already really anticipate what a lot of those questions are going to be. One of the biggest points of confusion for families is going to be, “Do I need to apply or not?” Right? We talked earlier about the two different pathways streamline certification or filling out an application. From the state perspective it’s pretty clear, but as a family, how do I know if I can expect to receive these benefits automatically or if I need to apply? And the complicated policy language here, of course you know about streamline certification, families don’t understand that, right? We have to sort of really communicate clearly with families. I think one example of this is families whose children attend community eligibility provision schools or CEP schools; these are schools that serve free meals to all of their students. They’re usually schools that are in low-income areas and because a certain percentage of their students are categorically eligible for free meals because they participate in other programs like SNAP or TANF, they’re able to just give free meals to all of their students. So, families at CEP schools have never had to apply for school meals, their kids just get them. But because these families haven’t applied for free or reduced-price meals, they’re actually going to have to apply for Summer EBT. You can see how from a family perspective, this starts to get really confusing from a messaging standpoint, right? We’re telling families if your income was below this level, at any point in the previous school year, you’re going to be eligible for Summer EBT. But if you haven’t applied to free or reduced-price meals this year, you have to apply unless you already received SNAP or TANF, in which case don’t apply, you’ll get benefits automatically. So, the messaging starts to get really confusing. How states communicate with families about this program and how to access it really matters. So, in the playbook we have a lot of resources on best practices for community outreach, how to talk about this program, how to leverage many methods of communication, right? Like email, text, phone calls, to really let families know about this program and give them the information they need to navigate it.

Wow, that’s great. And it’s interesting to hear you talk about this because early on I had the impression you were really worried about the data, but you’re also really concerned about how people function in the system. So, I’ve heard you mention this idea of human-centered design and human-centered digital benefit delivery. Can you explain a little bit more about what that really means and why it’s important?

Human-centered design really just means creating things that really meet people’s needs and that are really easy for people to use and access. And that’s really important, right? Just like the example I was just sharing with this program. It’s a complicated program and if the systems aren’t designed in a way that makes it easy for families to access, easy for families to interact with, they’re not going to see the benefit of the program ultimately, and the program isn’t going to meet its goals, which is reducing childhood hunger. So, the principles of human-centered design are really about thinking through what do families need when it comes to interacting with this program and how do we design the program in such a way that gives them those things? I think a great example of this is the application, right? We have a lot of best practices in the playbook related to the application component of the program. I mentioned that while many families will receive benefits automatically, the regulations for Summer EBT do require that many families will have to apply. So, states have to design applications and there are a lot of considerations that need to go into creating an application in a human-centered way, right? It needs to be accessible, which means it needs to be available in a lot of different languages, which can be really tough. California has 19 threshold languages that people speak. So, we need to translate this into the languages that people speak. The questions need to be written in what we call plain language, which is just conversational, the way that people actually talk so that they’re really easy to understand and they need to flow in a way that makes sense to someone filling out the application. And this really matters because if the questions are hard to understand or hard to answer, it’s likely that more people will answer incorrectly or submit the wrong answer. Meaning that they might not get the benefit even if they are in fact eligible. And then we also talked a lot about the importance of mobile accessibility. And this is really critical because more and more low-income families are what’s called smartphone dependent, which means they don’t have internet in their homes, but they do have a smartphone. So, they rely on that smartphone to do things online like fill out applications. But a lot of government websites are not built to fit the smaller screen on a mobile phone. And that makes it really hard for people to do things like fill out online applications for benefit programs. So, it’s really important to make sure that the online application is designed to work on a mobile phone because that’s how we know most families will be accessing it. I think the application component demonstrates a lot of the sort of thoughtful design work that’s going to be required to create a program that’s truly accessible for the people that need it.

I’m really appreciative of this. And as I heard you talk about this, especially with mobile devices and I was thinking about younger folks, but I also know that there are grandparents or older adults who will care for young children who may be eligible. What considerations do you make for older adults or people with disabilities that may make using certain devices difficult?

That’s a great question. We have done a fair amount of research on this and what we found is that the sort of principles of human-centered design we really need to design for everyone. And that means designing for accessibility or ability, right? Designing for multiple languages, designing for whatever device people have access to, designing for different levels of comfort with technology. I think we really believe in the sort of principle that if you design it for the person that’s going to have the most trouble accessing the program, you make it easier for everybody, right? So, we really think about the highest need population and design for that population and then really believe that we sort of make it more accessible for all populations that need to access the program.

This has been really helpful for me to consider how government can work for people by using human-centered design to really move the process of applying and attaining these assets or these benefits, easier for folks. And I’m really grateful to hear the work that you all are doing with Share Our Strength. I got to ask this last question. What are your hopes for Summer EBT in 2024 and even beyond?

I love this question. I have so many, I spent a lot of time so far talking about how hard this program is going to be for states to implement and it will be, I don’t want to downplay the significant effort that it’s going to take for states to stand up this program and deliver benefits, especially in this first year. That said, in my experience, people who work in government are incredibly resilient and resourceful and they are incredibly creative problem solvers. Pandemic EBT was really hard to implement, and states were trying to figure out how to deliver that program in the first few months of a global pandemic where everything was shut down and there was sort of historic need for benefit programs. But by the time that program ended, every single state had delivered Pandemic EBT benefits to families. So Summer EBT, especially in these first few years of its implementation, will be challenging certainly, but it won’t be impossible. States have really proved that they can do this, right? States are good at this. So, I guess my greatest hope is that states are able to address many of the challenges of implementation this year in order to put benefits in the hands of families and that more states opt in, in future years, right? So that eventually all families get to benefit from this program. Ultimately a policy is only as good as its implementation, right? We have to help states design programs that are effective for them to implement, but also that work for the families that they’re serving so that the Summer EBT program can live up to the promise outlined in the policy.


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