School Year 2021-2022 P-EBT: Recording COVID-19 Related Absences

Date:  November 11, 2021
Subject: School Year 2021-2022 P-EBT: Recording COVID-19 Related Absences
Category: Information Update
Next Steps:  Start tracking COVID-19 related student absences


This message is about P-EBT benefits for school year 2021-2022.

The USDA Food and Nutrition Service announced Pandemic Electronic Benefit Transfer (P-EBT) is offered to states for the current school year. Texas Health and Human Services (HHS) is partnering with the Texas Department of Agriculture (TDA) and the Texas Education Agency (TEA) to inform local educational agencies (LEAs) that they need to immediately start collecting data regarding COVID-19-related absences and virtual attendance for students during the 2021-2022 school year in anticipation of the P-EBT plan approval for Texas. This information will be essential in providing National School Lunch Program (NSLP)-eligible students and students that attend Community Eligibility Provision (CEP) or Provision 2 (P2) schools with P-EBT benefits for the 2021-2022 school year. This includes schools that have implemented the Seamless Summer Option (SSO) program. Further eligibility requirements are below.

For school year 2021-2022, P-EBT benefit amounts will be different for each NSLP-eligible student because they are federally required to be based on the number of absences they have related to COVID-19 or the number of days the student participated in virtual learning. (This is different from previous P-EBT programs that provided the same benefit amount to all eligible students at the same school.) For this reason, P-EBT for this school year relies on schools tracking and reporting COVID-19-related student absences and virtual attendance for the entire year. If your LEA has not had a policy to track COVID-19-related absences and virtual attendance, please start tracking them as soon as possible, and use whatever data is available to retroactively report them going back to the start of the school year.

The Texas state P-EBT plan has not been approved for SY 2021-2022, so this guidance is subject to change.


When the Texas plan is approved, it is expected that the school must meet the following criteria to receive P-EBT for this school year:

The school is closed OR has been operating with reduced attendance or hours for at least five (5) consecutive days due to the COVID-19 emergency in the current school year. (This could be a single student at the school with five consecutive days of COVID-19-related absences or virtual attendance.)

Once the school meets eligibility, the student must also meet each of the following to receive P-EBT for this school year:

  1. The child is enrolled in an NSLP-eligible Texas school. (This includes schools that are operating the Seamless Summer Option (SSO) during the school year.)
  2. The child has COVID-19-related absences or eligible virtual attendance during the 2021-2022 school year.
  3. The child would have received free or reduced-price school meals under the NSLP and School Breakfast Program (SBP) if not for the COVID-19 health emergency. This includes children who are directly certified or certified by NSLP household application. It also includes children enrolled in a CEP school or a school operating under Provisions 2 or 3, or a school that is operating the SSO.
    1. The P-EBT eligibility requirement to be certified for free or reduced-price meals through direct certification or through the NSLP household application also applies to children attending a school that is operating the SSO.

Once a school has one student who is absent for at least five consecutive days for a COVID-19-related reason (definition below) OR they offer virtual attendance for at least five consecutive days, NSLP-eligible students at that school become eligible for P-EBT dating back to the first day of the school’s first COVID-19-related absence or first day of virtual attendance.

The following are possible (but not all) scenarios for how a school could become eligible.

Scenario 1:

  • The 2021-2022 school year begins Monday, August 16. No students are reported as absent for a COVID-19-related reason.
  • Student A attends school on August 16, but is absent from Tuesday, August 17 through Monday, August 23, and returns to school on Tuesday, August 24. This results in five absences.
  • Student A’s parent/guardian notifies the school these absences were due to the student testing positive for COVID-19.
  • NSLP-eligible students at that school are eligible for P-EBT benefits for any COVID-19-related absences they have during the entire school year, beginning August 17.

Scenario 2:

  • On September 18, a school decides an entire class should stay home the following week to quarantine due to possible exposure.
  • The class stays home for the week of September 20 to September 24, totaling five school days.
  • NSLP-eligible students at that school are eligible for P-EBT benefits for any COVID-19-related absences they have during the entire school year, beginning September 20.

Scenario 3:

  • To start the school year, a school offers virtual instruction for a certain percentage of students. (See requirements under “Virtual attendance” below for what qualifies.)
  •  After five days of virtual instruction, NSLP-eligible students at that school (both virtual and in-person) are eligible for P-EBT benefits for any virtual attendance and any COVID-19-related absences.

COVID-19 Absences & Virtual Attendance

Below are examples of circumstances that should be counted as days a child lost access to free or reduced-price meals due to COVID-19.


  • The school sends student(s) home due to COVID-19 (e.g., students from an entire class, grade or school are sent home to quarantine after possible exposure or increased case count).
  • Parent/guardian notifies the school that the student has contracted COVID-19, and the school directed the student to quarantine.
  • A student is enrolled for on-campus learning but parent/guardian chooses to temporarily keep student home due to COVID-19 exposure, fear of COVID-19 contraction, or the student is experiencing COVID-19 symptoms.

This list does not include every possible COVID-19 absence scenario. If a student at your school has a different scenario that would be considered an absence because of COVID-19, please follow your local policies related to identifying COVID-19 related absences.

Virtual attendance:

  • Parent/guardian opted to have their student participate in virtual learning offered by his/her school due to COVID-19 precautions or because student received virtual learning due to COVID-19 quarantine.
    • Curriculum must be provided by staff hired by the school.
    • Virtual academies that require separate enrollment from the student’s home school and do not operate NSLP are not eligible for P-EBT, per federal regulations.

Tracking COVID-19 Absences

P-EBT benefits will be issued based on the number of school days a student is absent due to COVID-19 or the number of school days they participate in a virtual learning option provided by their school in response to the COVID-19 pandemic. It is recommended that schools track the following information in their attendance records:

  • Whether an in-person learning student’s absence is due to COVID-19 and the school day dates.
  • Number of school days and dates a student is enrolled in a virtual learning model offered because of COVID-19 precautions or because student received virtual learning due to COVID-19 quarantine.

NSLP Household Application for Free and Reduced-Price Meals

Receiving free meals at school does not automatically make a student eligible for P-EBT. While NSLP-participating schools have the option to serve free meals to all students this school year through the SSO, it is important to note that P-EBT benefits require individual income eligibility unless a child attends a CEP or P2 school. Income eligibility must be determined through direct certification or though completion of the household meal application (NSLP form). For this reason, districts that operate the SSO must continue to make the NSLP form available to families.

More information will be provided about how to submit your COVID-19-related student data in the coming months once a state plan is approved by the USDA Food and Nutrition Service.