CALPADS Update Flash #292

To:           Local Educational Agency (LEA) Representatives

From:      California Department of Education (CDE) –
                California Longitudinal Pupil Achievement Data System (CALPADS) Team

Date:      October 25, 2024

Subject:  CALPADS Update FLASH #292

SUN Bucks Update

2024 was the first summer of the new federal SUN Bucks program. With Summer 2024 winding down, California has provided roughly $642,600,000 in food benefits to nearly 5.4 million children throughout the state. The California Department of Education (CDE) would like to recognize the work of local educational agency (LEA) staff for supporting the successful implementation of the SUN Bucks program. Recently, the United States Department of Agriculture (USDA) released a video thanking states that were able to start up this program in 2024 within challenging timelines. The SUN Programs 2024 Thank You Message is located on the USDA Food and Nutrition Service YouTube Channel at: https://www.youtube.com/watch?v=6Ca9cnlgjtA.

SUN Bucks is a new federal program that shares similarities with the prior temporary Pandemic Electronic Benefit Transfer (P-EBT) program. These similarities have resulted in some confusion about the new program. As the 2024 SUN Bucks program comes to a close, and with the eligibility window for 2025 SUN Bucks program now open, this Flash aims to clarify the differences between SUN Bucks and the prior P-EBT programs. It also offers important reminders and best practices for both the 2024 and 2025 SUN Bucks programs.

Understanding 2024 and 2025 SUN Bucks

The confusion regarding the SUN Bucks program partly stems from its differences from the prior P-EBT and Summer P-EBT programs. The SUN Bucks program is different from the prior P-EBT programs in these ways:

1. The eligibility window for P-EBT programs was generally within a school year. The eligibility window for SUN Bucks spans across two school years, from July 1 of one school year to August 31 of the next school year:
   • 2024 SUN Bucks: July 1, 2023 – August 31, 2024
   • 2025 SUN Bucks: July 1, 2024 – August 31, 2025
2. SUN Bucks eligibility is determined at the individual level based on household income. Students must be enrolled in a school participating in a federal meals program (National School Lunch or School Breakfast program), and must meet the income eligibility requirements based on:
   • A National School Lunch Program (NSLP) application or Alternative Income Form (AIF) and a corresponding Free or Reduced-Price Program (FRPM) record in CALPADS, or
   • A homeless or migrant program record, or foster status in CALPADS, or
   • Participation in CalFresh, CalWORKS, or Medi-Cal (at or under 185 percent of the Federal Poverty Level).
     
     Under P-EBT, all students enrolled in a Community Eligibility Provision (CEP) school were eligible for benefits based on their enrollment in the CEP school and not based on their individual household income. Under SUN Bucks, students must be individually eligible, therefore students enrolled in a CEP school who do not meet income requirements are not eligible for SUN Bucks benefits.

3. Under SUN Bucks, NSLP applications and AIFs may be accepted throughout the eligibility window, and students may become eligible for SUN Bucks based on those applications/forms. This means that LEAs must accept and evaluate these applications/forms throughout the eligibility window. For any student who becomes eligible during the eligibility window, LEAs must upload an FRPM program record that has the appropriate start date within the eligibility period (July 1, 2023 – August 31, 2024). These records must be uploaded by the last date that data will be pulled from CALPADS, and they must be sent to the California Department of Social Services (CDSS) for benefit issuance (The pull dates are announced in CDE in flashes when they are established. The last pull date for 2024 SUN Bucks is December 31, 2024).
4. The P-EBT programs used the Direct Certification status in CALPADS to identify students participating in CalFresh, CalWORKS, or Medi-Cal. SUN Bucks instead uses data directly from the authoritative source, the Statewide Automated Welfare System (SAWS), maintained by CDSS. This change is expected to identify more students.
5. For the SUN Bucks program, it is extremely helpful for families submitting AIFs at CEP schools and Provision 2/3 school during non-based years to be informed regarding whether or not they are eligible for, and can expect to receive, benefits. Therefore, the CDE encourages LEAs to inform families of the disposition of their AIFs. If a student meets the criteria for being an unduplicated pupil under the Local Control Funding Formula (LCFF), then that student is eligible for SUN Bucks benefits. Informing families of this disposition lets them know whether they should or should not be expecting SUN Bucks benefits, which enables them to appropriately inquire through the SUN Bucks Helpline if they do not receive benefits in the expected time frame.

Law updated to allow provision schools to redetermine student FRPM eligibility for LCFF purposes during non-based years

Current law allows Provision 2/3 and CEP schools to establish a base year for LCFF and only collect AIFs for LCFF purposes once every four years in the LCFF base year. While Education Code (EC) Section 42238.01 previously prohibited collecting AIFs for continuing students in non-base years, Assembly Bill 176 (Chapter 998, Statutes of 2024) includes amendments to EC Section 42238.01 to allow Provision 2/3 and CEP schools to redetermine student FRPM eligibility for LCFF purposes during non-base years with the AIF. This means that Provision 2/3 and CEP schools may collect AIFs for students whose FRPM eligibility changed after the base year. This ensures that SUN Bucks benefits are provided to eligible students not identified as FRPM in the base year, and these students will also be included in the unduplicated pupil count for LCFF.

The CDE LCFF Frequently Asked Questions (FAQs) and the Alternative Income Forms web pages have been updated to reflect the amendments to EC Section 42238.01:

• LCFF FAQs: https://www.cde.ca.gov/fg/aa/lc/lcfffaq.asp#PROV2and3
• Alternative Income Forms: https://www.cde.ca.gov/fg/aa/pa/altincomeforms.asp

LEAs with Provision 2/3 status and/or CEP schools using the LCFF base year option should communicate to families that they must submit a new AIF if their FRPM eligibility has changed since the base year for SUN Bucks and LCFF funding purposes.

2024 SUN Bucks Reminders

The SUN Bucks program provides families $120 per eligible student to buy groceries to cover the summer months (June – August) when students are not in school. This period is referred to as the “Operational Period.” The 2024 operational period for 2024 SUN Bucks ended on August 31, 2024. However, data for 2024 SUN Bucks will continue to be pulled from CALPADS on these dates (see explanation below):

• October 31, 2024
• November 27, 2024
• December 31, 2024

Why is student data still being pulled from CALPADS for 2024 SUN Bucks if the operational period ended August 31, 2024?

These additional data pulls are intended to identify the following students who may be eligible for 2024 SUN Bucks benefits:

• Students enrolled for the first time at a school participating in a federal meals program in the next school year (2024−25 school year) through August 31, 2024, who submitted NSLP applications or AIFs by August 31, 2024. This mostly includes students in transitional kindergarten or kindergarten who are enrolling in a California public school for the first time in 2024−25.
• Students who during the 2023−24 school year did not submit or who submitted an NSLP application or AIF but whose income changed during the eligibility period and submitted an updated application or form by August 31, 2024.

These students who meet the FRPM income requirements based on applications or forms submitted by August 31, 2024, are eligible for 2024 SUN Bucks benefits. LEAs should upload FRPM program records (181,182) to CALPADS with a Program Start Date on or before August 31, 2024. These records must be submitted before the final pull of data on December 31, 2024.

NOTE: California requested and received a waiver to continue to pull data from CALPADS through December even though the operational period ended on August 31, 2024. The waiver was requested to provide LEAs with ample time to submit these records in this first year of the program. Additionally, this timeline aligns with existing LEA processes, which are designed to ensure that all records are submitted to CALPADS by the Fall 1 certification deadline of December 13, 2024, so that they are included in the LEA’s Unduplicated Pupil Count. The CDE does not currently know whether this waiver will be granted for the 2025 SUN Bucks. We will provide updates on any changes to the 2025 SUN Bucks process as soon as that information is available.

Is there a benefit to submitting records for these students earlier?

Yes. The earlier that the records for these groups of students are sent to CALPADS, the earlier those families will receive benefits. This is because records updated in CALPADS will be pulled on the next monthly pull date and sent to CDSS for processing and card issuance.

To enable these families to receive 2024 benefits earlier, LEAs may consider prioritizing the processing of the applications or forms of these families, particularly transitional kindergarten or kindergarten students who are newly enrolled to a California public school on or before August 31, 2024. LEAs are also reminded that if any of these students are directly certified by August (which means they will be identified from SAWS data), or if they are already identified as migrant, homeless, or foster in CALPADS with start dates on or before August 31, 2024, then they are already eligible for 2024 SUN Bucks and do not need to be identified as eligible via an application or form. Therefore, the CDE encourages LEAs to prioritize the processing of applications or forms for students who are not already eligible through these other means.

After processing these applications or forms, LEAs must upload eligible students’ enrollment, FRPM program records, and addresses to CALPADS before the next data pull date in order for the family to receive their cards earlier. LEAs are reminded that SUN Bucks cards are mailed to the addresses uploaded to CALPADS, and if students’ addresses are missing, the district office address is sent to CDSS, and the district office will receive cards to distribute to students.

When should these families expect 2024 SUN Bucks benefit cards in the mail?

Eligible students who are newly enrolled, or students newly identified as eligible, will not receive 2024 SUN Bucks benefits immediately and may not receive benefits for a few months. This is because:   

• The AIF and NSLP applications must be evaluated by the LEA.
• The LEA must upload FRPM records for eligible students to CALPADS.
• The CALPADS data must then be pulled on the next monthly pull and transferred to the CDSS.
• The CDSS must process the CALPADS data and send the data for the issuance of the EBT cards, which are then mailed to families.

LEAs are encouraged to communicate to families that they may not receive benefits until late in 2024, so that these families know when they should inquire about the status of their SUN Bucks cards with the Helpline.

Since SUN Bucks cards are mailed to the address uploaded to CALPADS, if the LEA has not uploaded student addresses to CALPADS for these students, the cards will be mailed to the district office, and the LEA will need to distribute cards to families.

Best Practices for Summer 2025 SUN Bucks

California is currently in the 2025 SUN Bucks eligibility period. California is again seeking a waiver to use the Alternative Income Form (AIF) to determine SUN Bucks eligibility for students enrolled in CEP and Provision 2 and 3 schools (during non-base years). Assuming California is granted the waiver, 2025 SUN Bucks will operate essentially the same as 2024 SUN Bucks. The timeline for data pulls, however, may differ, and the CDE will announce those timelines when available.

Enabling families to establish SUN Bucks eligibility throughout the operational period

LEAs will have submitted the necessary eligibility data for most students who will qualify for 2025 SUN Bucks by submitting the data required for their Fall 1 submission to CALPADS. This will generally include data submitted for students enrolled on Census Day, which represents most students enrolled in 2024−25. If your school has a highly transitory student population, most of those students likely have eligibility data already submitted to CALPADS by another LEA.

Students continually enrolled at your school, however, may become eligible for 2025 SUN Bucks at any point during the school year and during the first months of the next school year up until August 31, 2025. This means, throughout the eligibility period (July 1, 2024 – August 31, 2025), LEAs, should:

• Collect NSLP applications or AIFs from families whose economic circumstances have changed, including from students enrolled in Provision 2/3 or CEP schools since the Provision or LCFF base year, throughout the July 1, 2024 – August 31, 2025 eligibility period, and upload any resulting FRPM records to CALPADS as soon as the determination is made.

If this data is updated in CALPADS throughout the year, most students will be included in the first data pull in April 2025 and will receive benefits in the first card issuance for 2025 SUN Bucks.

Informing families of students enrolled in a CEP school whether they are eligible for SUN Bucks

Under the previous P-EBT programs, all students enrolled in CEP schools received P-EBT benefits. Under SUN Bucks, this is not the case, as students must be individually eligible. This means, unless a student is migrant, homeless, foster, or participating in CalFresh, CalWORKS, or Medi-Cal (at or below the 185 percent Federal Poverty Level), students at CEP schools must submit an AIF to determine whether they are eligible for SUN Bucks benefits.

If an LEA evaluates the AIF and determines the student meets the income requirements for being included as an unduplicated pupil for LCFF purposes, then the student is eligible for SUN Bucks benefits. While LEAs are not required to inform families submitting AIFs of this disposition, it is very helpful for families to know whether or not they are eligible for SUN Bucks and should or should not expect benefits.

Therefore, for families whose students are enrolled in CEP schools, it is a suggested best practice that LEAs communicate that eligibility for 2025 SUN Bucks benefits will be based on the LEA’s evaluation of the individual student’s AIF. Specifically, LEAs should communicate that:  

• Students are not automatically eligible for SUN Bucks because they are enrolled in a CEP school.
• Unless a student is migrant, homeless, foster, or participating in CalFresh, CalWORKS, or Medi-Cal (at or below the 185 percent Federal Poverty Level), the student must submit an AIF.
• Submitting an AIF does not automatically make a student eligible for SUN Bucks, because the information on the form must be evaluated to determine whether the family meets the income requirements to receive SUN Bucks benefits.
• If eligible, families should not expect to receive benefits until summer 2025.

LEAs are encouraged to notify families regarding whether or not they are eligible for SUN Bucks based on the AIF, so that families know whether to expect SUN Bucks benefits.

Summary of Key Tasks for LEA (Non-CALPADS) and CALPADS Staff for 2025 SUN Bucks

• Provide families the opportunity to submit NSLP applications or AIFs throughout the year, evaluate those applications or forms as they come in, and inform families of the disposition of those applications or forms.
• Ensure that enrollments/exits and program records for FRPM (181, 182), migrant (135), and homeless (191) for 2024−25 are updated throughout the year. This will help ensure that the data are updated prior to the first pull of data for SUN Bucks purposes in April 2025, and that the maximum number of eligible families will receive benefits by the summer.
• Ensure address changes that occur during the school year are updated by April 2025.
• Provide the school or district address in CALPADS for students without an address so that cards are mailed to those locations, and ensure that a local plan is in place to contact families that are unhoused regarding how cards will be distributed.
• Once the 2025 SUN Bucks data pull schedule from CALPADS is announced by the CDE, develop a process for collecting and evaluating applications or forms for students enrolling by August 31, 2025 for the first time in the 2025−26 school year (generally transitional kindergarten or kindergarten students). Upload student enrollments, FRPM records, and student addresses for eligible students to CALPADS prior to the final pull date for the 2025 SUN Bucks program.
• Collaborate with CDE Nutrition Services staff on the SUN Bucks program. The CDE’s Nutrition Services Division (NSD) has provided information on Summer EBT to their school nutrition partners, located on the CDE Summer EBT 2024 Announcement web page at https://www.cde.ca.gov/ls/nu/smmrebt2024announcement.asp.

Resources

The USDA has developed a Summer EBT Outreach Toolkit for use on their website at https://www.fns.usda.gov/sebt/outreach-toolkit. The outreach toolkit includes a video, fact sheets, and customizable resources in a variety of languages to inform households about SUN Bucks and how to use their benefits.

In addition, the CDSS provides resources via their Sun Bucks web page at https://www.cdss.ca.gov/sun-bucks, and outreach materials for SUN Bucks partners on their Sun Bucks Partners web page at https://www.cdss.ca.gov/sun-bucks/partners.

Contact Information

For household questions, the CDSS has a customer service helpline: (877) 328-9677. General information about SUN Bucks can be found at https://www.cdss.ca.gov/sun-bucks.

For LEA questions ONLY, please reach out via email to SummerEBT@cde.ca.gov. This email address is not for household inquiries about Summer EBT.

For CALPADS questions, please submit them to calpads-support@cde.ca.gov.