“Alternative Income Applications” refer to forms used to assess household income for purposes other than USDA programs. Some Local Education Agencies (LEAs) use these forms to gather information at their special provision schools, information that would typically be collected through National School Lunch Program (NSLP) or SUN Bucks Program (SBP) for Summer EBT applications annually. These forms may also be known as “family income surveys” or “household income data forms.”
The data gathered through alternative income applications serves purposes unrelated to school meal programs, such as determining educational funding allocations and other student benefits. These applications are familiar to households and often collect sufficient information to assess whether the household income meets the NSLP/SBP eligibility threshold. Applications that meet the minimum Summer EBT requirements outlined in 7 CFR 292.13 are considered Summer EBT applications and can be used to determine eligibility for the Summer EBT program. For 2024, alternative income applications may be used to establish Summer EBT eligibility, provided they collect enough information to confirm that the household’s income is at or below 185% of the Federal poverty level.
Does our Alternate Income Form meet the requirements for Summer EBT/SUN Bucks program?
Summer EBT applications must contain the following elements:
- Required income information. The information requested on the application with respect to the current income of the household must be limited to:
- The income received by each member identified by the household member who received the income or an indication which household members had no income; and
- The source of the income (such as earnings, wages, welfare, pensions, support payments, unemployment compensation, social security and other cash income). Other cash income includes cash amounts received or withdrawn from any source, including savings, investments, trust accounts, and other resources which are available to pay for a child’s meals.
- Household members. The application must require applicants to provide the names of all household members. However, the application must allow the household to provide a case number if they participate in SNAP, or another means-tested program that has been approved by the Secretary, in lieu of names of all household members and household income information.
- Name of school where child is enrolled. A State- or ITO-wide application must contain a space for the household to indicate the name of the school or district where each eligible child is enrolled.
- Mailing address. The application must contain a space for the household to list their mailing address. However, the application must be accepted and processed as complete even if the field was not completed by the applicant. The instructions should communicate that it will be used to mail their EBT card, as applicable, and therefore should be the address that will be used by the household at the time the Summer EBT agency issues benefits.
- Adult member’s signature. The application must be signed by an adult member of the household.
- Attesting to information on the application. The application must also include a statement, immediately above the space for signature, that the person signing the application certifies that all information furnished in the application is true and correct, that the application is being made in connection with the receipt of Federal funds, that the applicant is not already receiving Summer EBT benefits in another State or ITO, that Summer EBT agencies may verify the information on the application, and that deliberate misrepresentation of the information may subject the applicant to prosecution under applicable State and Federal criminal statutes.
- Race and ethnicity. The application must contain space for collection of information on race and ethnicity of applicants. The questions should be labeled as optional, and incomplete responses cannot be used as the basis for the denial of benefits.
- Accompanying instructions. The application must contain clear instructions is with respect to the completion and submission of the application to the Summer EBT agency to make eligibility determinations. The instructions should inform households that if they intend to move, or have recently moved, that they should apply for benefits in the State where their child will complete or completed the school year immediately preceding the summer operational period.
- Required statements for the application. The application and descriptive materials must include substantially the following statements:
- “The Richard B. Russell National School Lunch Act requires that we use information from this application to determine who qualifies for Summer EBT benefits. We can only approve complete forms. We may share your eligibility information with education, health, and nutrition programs to help them deliver program benefits to your household. Inspectors and law enforcement may also use your information to make sure that program rules are met. Some children qualify for Summer EBT without an application. Please contact your State or ITO to get Summer EBT for a foster child, and children who are homeless, migrant, or runaway.”
- When either the Summer EBT agency or the LEA plans to use or disclose children’s eligibility information for non-program purposes, additional information, as specified below, must be added to this statement. State agencies and LEAs are responsible for drafting the appropriate statement.
- For disclosures to programs, other than Medicaid or SCHIP, that are permitted access to children’s eligibility information, without parent/guardian consent, the State agency or local educational agency, as appropriate, must notify parents/guardians at the time of application that their children’s free and reduced price meal or free milk eligibility information may be disclosed. The State agency or local educational agency, as appropriate, must add substantially the following statement under the Richard B. Russell National School Lunch Act statement or the categorically eligible statement of the NSLP Free and Reduced Lunch application, “We may share your eligibility information with education, health, and nutrition programs to help them evaluate, fund, or determine benefits for their programs; auditors for program reviews; and law enforcement officials to help them look into violations of program rules.” For children determined eligible through direct certification, the notice of potential disclosure may be included in the document informing parents/guardians of their children’s eligibility for free meals or free milk through direct certification.
- For disclosure to Medicaid or SCHIP, the State agency or local educational agency, as appropriate, must notify parents/guardians that their children’s free and reduced price meal or free milk eligibility information will be disclosed to Medicaid and/or SCHIP unless the parent/guardian elects not to have their information disclosed. Additionally, the State agency or local educational agency, as appropriate, must give parents/guardians an opportunity to elect not to have their information disclosed to Medicaid or SCHIP. Only the parent or guardian who is a member of the household or family for purposes of the free and reduced price meal or free milk application may decline the disclosure of eligibility information to Medicaid or SCHIP. The notification must inform parents/guardians that they are not required to consent to the disclosure, that the information, if disclosed, will be used to identify children eligible for and to seek to enroll children in a health insurance program, and that their decision will not affect their children’s eligibility for free and reduced price meals or free milk. The notification may be included in the letter/notice to parents/guardians that accompanies the free and reduced price meal or free milk application, on the application itself or in a separate notice provided to parents/guardians. The notice must give parents/guardians adequate time to respond. The State agency or local educational agency, as appropriate, must add substantially the following statement under the Richard B. Russell National School Lunch Act statement or the categorically eligible statement of the NSLP Free and Reduced Lunch application, “We may share your information with Medicaid or the State Children’s Health Insurance Program, unless you tell us not to. The information, if disclosed, will be used to identify eligible children and seek to enroll them in Medicaid or SCHIP.” For children determined eligible through direct certification, the notice of potential disclosure and opportunity to decline the disclosure may be included in the document informing parents/guardians of their children’s eligibility for free meal or free milk through direct certification.
- The application must contain the USDA nondiscrimination statement for Child Nutrition Programs.
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident.
Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English.
To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at How to File a Program Discrimination Complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by:
(1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410;
(2) fax: (202) 690-7442; or
(3) email: program.intake@usda.gov.
USDA is an equal opportunity provider, employer, and lender.
- The Summer EBT agency must inform applicants and prospective applicants that a non-household member may be designated as the authorized representative for application processing purposes if they have difficulty completing the application process.
Source: Title 7 Subtitle B Chapter II Subchapter C Part 292 Subpart C § 292.13 – Title 7 was last amended 2/12/2025.
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