TAKE ACTION: Submit a Public Comment to Help Shape SUN Bucks!

Published on Aug 21, 2024 in Child Nutrition, Federal Advocacy, School-Aged Children

Share your thoughts about the SUN Bucks Interim Final Rule!

You have an opportunity to provide feedback on the SUN Bucks Interim Final Rule and improve the SUN Bucks program.

Read below to learn about the SUN Bucks Interim Final Rule, how you can take action, and see a sample template & comments!

You can also read our submitted comment here.

What is SUN Bucks?

SUN Bucks (Summer EBT) is a new federal program that helps eligible school-aged children access food during the summer months when schools are closed. Each child receives $120 in food benefits. To learn more, visit www.cdss.ca.gov/sun-bucks or read our blog post.

Summary of the SUN Bucks Interim Final Rule

The SUN Bucks program was established through the Consolidated Appropriations Act of 2023. This legislation sets the main guidelines, such as establishing the benefit amount, setting eligibility criteria, and the funding provisions.

Some key highlights of the SUN Bucks Interim Final Rule (IFR) include:

For more details, read the Food Research & Action Center’s summary here.

Why Your Voice Counts: The Public Comment Period

When Congress passes a law, federal administrative agencies, such as the US Department of Agriculture (USDA), create rules to make programs like SUN Bucks work.

USDA has opened up a public comment period for anyone to provide feedback on the SUN Bucks IFR. The IFR outlines the detailed steps and procedures to make the SUN Bucks program run smoothly. USDA must gather information, ask for feedback, and make necessary changes before finalizing the rules. Your input can help improve SUN Bucks.

How do Public Comments work, and why do they matter?

Take Action!

USDA is accepting comments on the IFR by August 27, 2024, no later than 11:59PM EST (8:59PM PST). They are required to read through each comment and make necessary changes before publishing a final rule. You can read the comments that have already been submitted here.

Comments on the interim final rule are most helpful if they are unique, if they show why the issue matters to you, and if they are specific about the changes you want to see.

You can choose if you want to identify yourself as an individual, an organization, or anonymously. Please note that anything you share will be made publicly available. See tips on how to submit an effective comment here.

Additionally, the IFR touches on multiple aspects of the SUN Bucks program – you don't need to comment on all of them! Choose the issues that affect you or your community the most.

Submit your comment through our action alert link!

SHARE your perspective

Sample template:

Dear Community Meals Policy Division:  

Thank you for the opportunity to comment on the Interim Final Rule that establishes the SUN Bucks Program.

As a [student, parent, teacher, school administrator, community organizer, community member], SUN Bucks is important to me because… [Add your personal comments here].

I have some suggestions to improve the rule for families in California and nationwide.

[Add 3-5 sentences of what changes you would like to see. Scroll down to see sample comments]

I appreciate USDA’s hard work to implement the SUN Bucks Program and provide for millions of children and their families. I encourage USDA to take the steps described above. Thank you for your consideration of these comments.

Sample comments:

APPLICATION

I support the development and implementation of a statewide SUN Bucks application in 2025 or as soon as possible. The application should be easy to access, simple to understand, and available in several languages. A centralized application will be less confusing for families, especially in California where we have over 1,000 school districts, each with different school meal applications and alternative income forms.

EXPUNGEMENT

I ask USDA to reset the expiration timelines of SUN Bucks cards after each use.  Removing the benefits from cards after 122 days from issuance creates uncertainty and confusion for families. Resetting the timeline after each use of the card, as some states do with SNAP benefits, would give families more time to fully use their benefits and reduce confusion.

BENEFIT REPLACEMENT

I applaud USDA for requiring that states replace SUN Bucks benefits in situations of household misfortune or disaster. I ask USDA to reconsider their position and allow replacement of stolen benefits. Stolen benefits from EBT cards is unfortunately a common issue in California and families should not lose their essential food benefits due to no fault of their own.

HEARINGS

USDA should ensure that families have a clear and timely process to appeal decisions about their SUN Bucks eligibility. A hearing procedure and appeal process is crucial to support families who experience difficulties in getting their SUN Bucks cards.

CLAIMS

The IFR does not completely protect families from being held accountable for overpayments. Since the SUN Bucks benefit in California is $120 per child, which is below the $125 threshold for SNAP claims, USDA should mandate that the Summer EBT benefit is too low for states to submit a claim against a household.