relative to student data sharing for the Summer EBT program.

The entity responsible for transmitting student data to DHHS changed from individual school districts and SAUs to the state Department of Education, centralizing the process at the state level rather than requiring each district to act independently.

The timing of the opt-out notice changed from being provided concurrently with the annual application for free/reduced-price meals to being provided concurrently with the notice of decision (i.e., when parents learn their child's eligibility status).

Contingency provisions were added: if SB 615 becomes law, one version of the DHHS implementation section takes effect; if it does not, the other version takes effect. A renumbering provision also adjusts cross-references accordingly.

A new 15-day deadline was added: if a parent does not return the opt-out form within 15 days of receiving the notice of decision, the student is automatically enrolled in Summer EBT.

A data limitation was added stating that no additional personally identifiable information beyond name, date of birth, and household address may be transmitted.

New data protection requirements were added: data must be confidential, used exclusively for Summer EBT administration and distribution, and deleted upon completion of benefit distribution unless required by federal law.

A memorandum of understanding between the Department of Education and DHHS is now required to govern data transmissions, with minimum terms established by rule.

Rule-making requirements under RSA 541-A were added for the electronic mechanism, transmission protocols, data retention/deletion procedures, and MOU terms.

The effective date changed from a flat 60 days after passage to a contingent schedule tied to whether SB 615 becomes law.

The House version used an opt-in model where parents had to check a box on forms to allow their child's address to be shared. The Senate version uses an opt-out model where students are automatically enrolled in Summer EBT unless the parent or guardian returns a separate opt-out form.

The House version only required sharing student addresses. The Senate version requires school districts and SAUs to provide the student's name, date of birth, and household address - a broader set of personal data.

The statutory basis shifted from RSA 189:68 (Student Privacy provisions) to RSA 189:11 (Food and Nutrition Programs), reframing the data sharing as part of meal program administration rather than a privacy exception.

The House version placed the data-sharing obligation on the Department of Education via a memorandum of understanding with DHHS. The Senate version places the obligation directly on individual school districts and SAUs to transmit data to DHHS, removing DOE as the intermediary.

A new section (RSA 161:15) requires DHHS to establish and maintain a secure electronic mechanism to receive student data from schools, and to provide standardized language for the notice and opt-out form.

The effective date changed from immediate upon passage (House) to 60 days after passage (Senate), giving agencies time to build out the required systems.

A new paragraph VI requires the Department of Education to include an opt-in question (with yes/no checkbox) on all forms in all formats that collect information, asking whether the family consents to address sharing with DHHS for Summer EBT. Failure to mark is interpreted as a denial.

The MOU paragraph (renumbered from VI to VII) now limits data sharing to only those student addresses whose parents have opted in pursuant to the new paragraph VI, rather than all student addresses being shared automatically.