CALPADS Update Flash #297

To:           Local Educational Agency (LEA) Representatives

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

Date:      March 24, 2025

Subject:  CALPADS Update FLASH #297

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Important Changes to Summer 2025 SUN Bucks

This Flash provides important information about current and anticipated changes to California’s implementation of the summer 2025 SUN Bucks program, which involves the use of a new Universal Benefits Application (UBA) that is fully compliant with federal SUN Bucks requirements.

Background

For 2024 SUN Bucks benefits, California was granted a waiver to allow the use of the Alternative Income Form (AIF) in place of a fully compliant SUN Bucks application. The AIF was implemented by California to identify students who met the Free and Reduced-Price Meal (FRPM) income eligibility criteria required to be included in the Unduplicated Pupil Count (UPC) used to determine supplemental and concentration grant funding under the Local Control Funding Formula (LCFF). The AIF was specifically needed because schools participating in a federal meals program under a Community Eligibility Provision (CEP) were prohibited from collecting National School Lunch Program (NSLP) applications that could have been used to determine income eligibility under LCFF. Additionally, schools participating under Provision 2 (P2) collected NSLP applications in base years and were prohibited from collecting NSLP applications in non-base years.

The U.S. Department of Agriculture (USDA) will not approve a waiver for California to continue using the AIF for the 2025 SUN Bucks program. This means that to be eligible for 2025 SUN Bucks benefits, students who are not already directly certified or categorically eligible based on their migrant, homeless, or foster status must submit an NSLP application or UBA (depending on how the student’s school or LEA operates their federal meals program) on or before September 1, 2025, which is the last day of the 2025 SUN Bucks eligibility period, to be determined eligible by their school based on their household income.

LEAs may continue to use the AIF to identify students eligible to be included in the UPC for LCFF purposes; however, students must submit UBAs or NSLP applications to receive SUN Bucks benefits if the students are not directly certified or categorically eligible.

What is the Universal Benefits Application?

The Universal Benefits Application (UBA) is a template developed by the CDE that is fully compliant with federal SUN Bucks requirements. It is very similar to the NSLP application, but there are distinct differences that do not make them interchangeable. The CDE Nutrition Services Division has posted the UBA template on the CDE Universal Benefits Application web page at https://www.cde.ca.gov/ls/nu/universalbenefitsapp.asp. Here is a direct link to the UBA template at https://www.cde.ca.gov/ls/nu/documents/uba2025-26.docx. The CDE has provided the template to student information system (SIS) vendors.

What application must students submit to be eligible for SUN Bucks?

To receive SUN Bucks benefits, students must be enrolled in a school participating in a federal meals program, and the type of application they must submit depends on how the school operates the federal meals program. Table 1 below summarizes what application must be used for the different school meal program participation models. While the NSLP application or UBA may be used for LCFF, the AIF cannot be used for federal meals eligibility or SUN Bucks benefits.

Table 1: Application Type Required Based on Model

Who does not need to submit a UBA? Who must submit a UBA?

To receive 2025 SUN Bucks benefits, students must be enrolled in a school participating in a federal meals program at any time during the eligibility period. The 2025 SUN Bucks eligibility period is July 1, 2024 – September 1, 2025.

• Students who DO NOT need to submit a UBA: Students enrolled at CEP or P2 (base year) schools who are directly certified based on participation in CalFresh, CalWORKs, or Medi-Cal (at or below 185 percent of the Federal Poverty Level) and students who are categorically eligible for free or reduced-priced meals based on their migrant, homeless, or foster status are automatically eligible to receive SUN Bucks benefits, without a UBA. Students enrolled at Standard Counting and Claiming schools must submit an NSLP application, not a UBA. Noting that students must submit an NSLP application to be eligible for SUN Bucks benefits if they are enrolled at Standard Counting and Claiming schools, or P2 schools in their base year, and they have not submitted a NSLP application, or they submitted an AIF instead of a NSLP application.
• Students who DO need to submit a UBA: Students enrolled at CEP or P2 (non-base year) schools who are not directly certified or categorically eligible must submit a UBA to receive SUN Bucks benefits.

What records must LEAs submit to CALPADS for students to be identified as eligible for SUN Bucks benefits?

To be identified as eligible for 2025 SUN Bucks benefits, CALPADS must have:

• Enrollment records that show students were enrolled at any time during the eligibility period in a school participating in a federal meals program, and
• Records showing students are directly certified, migrant, homeless, foster, OR
• The CDE’s Education Data Collection System (EDCS) must have records submitted as part of the Supplemental SUN Bucks Collection (SSBC) indicating students have an approved UBA or NSLP application. (See the section further in this document entitled “How does the CDE know if a student submitted a UBA or NSLP application?”)

In summary: In order to be identified as eligible to receive 2025 SUN Bucks benefits, students who meet the following criteria must submit UBA or NSLP applications to their LEA and be found eligible based on household income:

• Students who are enrolled in a school participating in a federal meals program school during the eligibility period (July 1, 2024 – September 1, 2025).
• Students who are not directly certified based on their participation in CalFresh, CalWORKS, or Medi-Cal (at or below 185 percent of the Federal Poverty Level),
  OR are not categorically eligible to receive free meals based on their migrant, homeless, or foster status.

The LEA must then submit UBA or NSLP records to the CDE through the EDCS as part of the SSBC (details are further below), and LEAs must also submit an Education Program Code 181 – Free Meal Program, or Code 182 – Reduced-Price Meal Program record to CALPADS.

It should be noted that there is no change in operations for Standard Counting and Claiming schools as it pertains to collecting and processing NSLP applications. However, since Standard Counting and Claiming schools may be collecting AIFs for LCFF purposes from families who do not submit NSLP applications, LEAs need to submit to EDCS that a student has an approved NSLP application.

How often must SUN Bucks eligibility be determined?

SUN Bucks eligibility must be determined annually. This means that students enrolled in CEP schools who are not directly certified or categorically eligible must annually establish their eligibility for SUN Bucks benefits by submitting UBAs, and students enrolled in P2 schools must submit NSLP applications when schools are establishing their base year, and they must submit UBAs during non-base years. Students enrolled in Standard Counting and Claiming schools are already required to submit NSLP applications annually.

Data Submission and Pull Dates

When must students submit UBAs or NSLP applications to receive 2025 and/or 2026 SUN Bucks benefits? What federal Income Eligibility Guidelines must LEAs use when evaluating those applications?

Students enrolled in schools participating in a meals program, and who are not directly certified or categorically eligible, must submit UBAs or NSLP applications to their LEA as described in Table 2 (below) to receive 2025 and/or 2026 SUN Bucks benefits. The LEA must evaluate the application submitted within a school year (SY), which is July 1 – June 30, based on the Income Eligibility Guidelines (IEGs) for that SY. The IEGs are posted on the CDE Rates, Eligibility Scales, & Funding web page at https://www.cde.ca.gov/ls/nu/rs/. The 2024–25 IEGs, effective from July 1, 2024, through June 30, 2025, are posted on the CDE Income Eligibility Scales for School Year 2024–25 web page at https://www.cde.ca.gov/ls/nu/rs/scales2425.asp. The 2025–26 IEGs to be used for applications submitted July 1, 2025 through June 30, 2026 are posted on the CDE Income Eligibility Scales for School Year 2025–26 web page at https://www.cde.ca.gov/ls/nu/rs/scales2526.asp. 

Table 2: UBA/NSLP Student Submission Dates

How does the CDE know if a student submitted a UBA or NSLP application?

LEAs participating in federal meals programs must submit records specifically for students with approved UBAs or NSLP applications to the CDE for those students to receive SUN Bucks benefits in 2025 and/or 2026. For 2025 and 2026, LEAs will submit these data as part of the Supplemental SUN Bucks Collection (SSBC) to EDCS and not through CALPADS. The EDCS is the system by which LEAs currently submit data for the Armed Services Vocational Aptitude Battery (ASVAB) and the State Seal of Civic Engagement (SSCE) collections. The SSBC will be added to EDCS. The process for accessing EDCS and submitting data for any EDCS collection, including SSBC, will be the same as last year. This process will be described in an upcoming CALPADS Flash about EDCS and will include the submission dates for all EDCS collections.

For SSBC, LEAs will submit the following data for all students who have submitted UBAs or NSLP applications that have been approved by the LEA:

• County-District-School (CDS) code where the student is enrolled
• The student’s Statewide Student Identifier (SSID)
• The student’s Local student identifier
  and
• The date the UBA was submitted to the LEA
  or
• The date the NSLP application was submitted to the LEA

The SSBC will remain open throughout the year. The CDE will communicate more about the SSBC and the EDCS in the coming months, including when LEAs may begin submitting data.

NOTE: Students enrolled in schools participating in a federal meals program, who are not directly certified or categorically eligible, will not be eligible for SUN Bucks benefits based solely on 181 or 182 records in CALPADS. To be eligible, students must have a UBA or NSLP record in the SSBC. LEAs, however, should continue to submit 181 or 182 records to CALPADS for students with approved UBAs and NSLP applications, as these records are used to identify inclusion in the UPC and eligibility for grants and other programs.

When will data be pulled from EDCS and CALPADS for 2025 SUN Bucks?

CALPADS: The data pulled from CALPADS for 2025 SUN Bucks will take place on the first of each month, which began on March 1, 2025, and will continue through January 1, 2026. Note that the data pulled from CALPADS extend well past the end of the eligibility period of September 1, 2025 because it is recognized that LEAs may not submit the required data to CALPADS until later, particularly as they follow their past pattern of getting all data updated by the Fall 1 certification deadline in mid-December. The CDE, however, highly recommends that LEAs prioritize submitting the relevant records (181, 182, 135, 191) to CALPADS as early as possible to ensure that students receive SUN Bucks benefits in a timely manner. In 2025, this also includes prompt submission of SSBC data to EDCS.

EDCS: The data pulled from EDCS for 2025 SUN Bucks will take place on the first of each month beginning July 1, 2025 through January 1, 2026. The SSBC data will be merged with CALPADS data (direct certification and categorical eligibility records) and provided to the California Department of Social Services (CDSS) for benefit card issuance.

Alternative Income Form

LEAs may continue to use the AIF to identify students that may be included in the Unduplicated Pupil Count (UPC) for LCFF purposes. The AIF, however, can no longer be used to identify students eligible for SUN Bucks benefits. The AIF has never been used to identify students enrolled in Standard Counting and Claiming schools as eligible for free or reduced-priced meals and federal reimbursement.

LEAs opting to continue using the AIF may collect the form in the spring prior to the upcoming school year. LEAs also must continue to submit 181/182 records to CALPADS by the required dates to be included in the UPC.

Suggested Practices for Summer 2025 SUN Bucks

Target outreach to students that need UBAs or NSLP applications to receive 2025 SUN Bucks benefits

For CEP and P2 schools (in non-base years) that must now collect the UBA, most of their students have already been identified as eligible for Summer 2025 SUN Bucks and do not require a UBA to receive benefits for 2025. Specifically, students who have already been identified as eligible for 2025 SUN Bucks, are those students who:

• Have been directly certified; or
• Have a migrant or homeless program record in CALPADS that is or was open at any time during the eligibility period (note that the program record does not have to overlap with the current school of enrollment); or
• Have been identified as foster in CALPADS at any time during the eligibility period.

Since these students do not require UBAs, LEAs may want to focus UBA collection efforts in 2025 on students who are likely eligible for SUN Bucks benefits and need UBAs to receive benefits. This includes all other students with an AIF that had been submitted earlier in the year, or an AIF or NSLP application submitted in the LCFF base year and were approved for inclusion in the UPC. Since the AIF is no longer valid for determining SUN Bucks eligibility, these students will need UBAs.

Of those students, LEAs may want to prioritize:

• Collecting and submitting UBAs before the end of the school year from students who are in Grade 12 in the 2024−25 school year. If these students graduate or otherwise complete and are no longer enrolled, LEAs will not be able to submit UBA records to EDCS for these students.
• Collecting and submitting UBAs between July 1, 2025 and September 1, 2025 (inclusive), from all other students who were enrolled in 2024−25 and will be returning in the 2025−26 school year. These applications provide students with eligibility for both 2025 and 2026 SUN Bucks benefits.
• Collecting and submitting UBAs between July 1, 2025 and September 1, 2025 (inclusive), from all students enrolling in the LEA for the first time in 2025−26 (generally transitional kindergarten or kindergarten students). These applications provide students with eligibility for both 2025 and 2026 SUN Bucks benefits.

For Standard Counting and Claiming schools, students should have submitted NSLP applications. However, if this is not the case for all students, Standard Counting and Claiming schools may want to prioritize:

• Students who have not submitted an NSLP application or AIF.
• Students who submitted an AIF and were included in the UPC, since these students are likely to be eligible.

Modify business processes in Provision schools for UBA collection in 2024−25 to also support 2026 SUN Bucks

Modifying business practices now for the collection of UBAs in the 2024−25 school year will support the collection of UBAs for 2026 SUN Bucks (eligibility period July 1, 2025 – August 31, 2026). This is because any UBAs collected and evaluated at the beginning of the 2025−26 school year not only support 2025 SUN Bucks, but also support 2026 SUN Bucks benefits. Additionally, LEAs should continue to collect and process UBAs after September 1, 2025 through October 31, 2025, as those students will also be included in the UPC for the 2025−26 school year. LEAs are reminded that after October 31, 2025, and throughout the rest of the eligibility period, LEAs should continue to collect UBAs from newly enrolled students, or students whose economic circumstances change, so that those students are able to receive 2026 SUN Bucks benefits.

Summary of Key Tasks for LEA Staff

• Develop a plan for collecting UBAs (or NSLP applications in Standard Counting and Claiming Schools) to ensure that students receive SUN Bucks benefits, and determine how the AIF might be used to ensure an accurate UPC count. The plan will depend on the school meal program participation model (Standard Counting and Claiming, CEP, or P2) used by schools in the LEA.
• For 2025 SUN Bucks, determine a strategy for collecting the necessary applications. For LEAs with CEP and P2 schools, the focus should be on how to distribute, collect, and process UBAs, and to target outreach to certain students. For LEAs with Standard Counting and Claiming schools, the focus should be on students who did not submit an NSLP application but have an approved AIF. (Refer to the section in this document entitled “Target outreach to students that need UBAs or NSLP applications to receive 2025 SUN Bucks benefits.”)  
• Ensure that UBAs and NSLP applications are collected, processed, and uploaded to EDCS throughout the year. The CDE will announce when EDCS is available for submission of SSBC data.
• As a best practice, ensure that enrollments/exits and program records for Free-Reduced Price Meal (181, 182), migrant (135), and homeless (191) are updated throughout the year. This will help ensure that the data are updated prior to each pull of data, which occurs on the first day of each month (March 1, 2025 through January 1, 2026).
• Student addresses for 2025 SUN Bucks have already been pulled from CALPADS. LEAs are reminded that benefit cards for any students who do not have an address in CALPADS will be sent to the LEA’s district office. Therefore, LEAs should develop plans for distributing the benefit cards.

Resources

The CDE has a SUN Bucks web page at https://www.cde.ca.gov/ls/nu/sunbucks.asp with resources geared toward LEAs. The CDSS is in the process of updating their SUN Bucks web page and we will provide a link when it is available.

Here are some resources on the USDA website:

• SUN Programs Communications Toolkit
  https://www.fns.usda.gov/summer/toolkit
  This communications toolkit contains materials for use by agencies implementing the SUN programs, including SUN Bucks benefits. The toolkit includes videos, fact sheets, and customizable resources in a variety of languages to inform households about SUN Bucks and how to use their benefits.
• SUN Bucks (Summer EBT)
  https://www.fns.usda.gov/summer/sunbucks
  Information about SUN Bucks benefits.

Contact Information

For household questions, the CDSS has a customer service helpline: (877) 328-9677.

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

For CALPADS questions, please send an email to calpads-support@cde.ca.gov.

For EDCS questions, please send an email to educationdatacollection@cde.ca.gov.

For questions about the Alternative Income Form and the Local Control Funding Formula, please reach out to PASE@cde.ca.gov.