• Comments submitted December 26, 2025, to Internal Revenue Service via www.regulations.gov •
Re: Docket ID IRS-2025-0466, Request for Comments on Individual Tax Credit for Qualified Contributions to Scholarship Granting Organizations (Notice 2025-70)
IDRA submits this comment opposing the implementation of the federal private school voucher program included in the “One Big Beautiful Bill Act,” yet still urging robust transparency and oversight of the program. IDRA is a national nonprofit organization with more than five decades of experience conducting research, policy analysis, and advocacy focused on building strong public schools and protecting all students’ rights.
Voucher programs harm students and public schools – a growing body of evidence documenting the negative impact of state vouchers demonstrates the harms that can be caused to students and the public schools that lose much-needed public resources. The expansion of these programs through the federal voucher will divert public funds away from public programs and allow them to be used in ways that undermine civil rights protections, weaken public education systems, and exacerbate longstanding educational inequities.
These harms are inherent to private school voucher programs, and along with other organizations, families, educators, and students across the country, IDRA opposes the implementation of the federal voucher program. Still, as the Treasury Department and the Internal Revenue Service (IRS) exercise authority to implement these provisions, IDRA urges that any regulatory framework include robust transparency, accountability, and oversight mechanisms.
Risks to Students and Public Schools Associated with Voucher Implementation
The implementation of a federal private school voucher program raises significant concerns regarding compliance with federal civil rights obligations. Voucher programs direct public funds to private educational entities that are frequently not subject to the same nondiscrimination requirements, procedural safeguards, or enforcement mechanisms that govern public schools.
Vouchers risk enabling practices in private schools that exclude or discourage enrollment of students with disabilities, English learner students, LGBTQ+ students, and students from low-income families. These risks are not hypothetical. Research consistently shows that private schools receiving public funds through voucher programs may maintain admissions, discipline, and retention policies that would be impermissible in public educational settings. And evidence indicates that some private schools that receive voucher funds fail to deliver promised academic benefits. Many parents may not be aware of these risks to their child’s achievement and rights when they accept a voucher.
Additionally, voucher programs redirect public funds from public services, including the public schools that serve 90% of children across the country. These public schools – many of which have been underfunded for years – will have fewer resources, but will continue to face significant demands, including facilities costs, staffing, transportation, and legally-required services for students (including some with disabilities who may no longer be enrolled in the public school).
This diversion of funds risks undermining the financial strength of public school systems, particularly those serving high concentrations of students living in poverty or students with greater educational needs. Over time, such fiscal pressures can lead to program cuts, staff reductions, and diminished educational opportunities for students who remain in public schools.
Transparency, Reporting and Oversight
Transparency and accountability should be central to any regulatory framework governing the federal voucher program. There must be clear and consistent reporting on the use and distribution of funds, student/family program enrollment demographics, student outcomes, practices of the recipient private school, and compliance with applicable civil rights laws.
This reporting should include detailed, publicly-accessible data and information about the fund donors/tax credit recipients, scholarship granting organizations (SGO), voucher recipients, and private schools that benefit from the program. In some cases, all of these actors may come from a single community, as could be the case with a religious community with donor-parishioners and with organizational divisions that are permitted to act as both the SGO and the private school. The public has a right to know if funds are being concentrated in specific communities and diverted away from systems that serve the general public good.
There should also be transparency about the fiscal implications of voucher implementation on public education systems. Without meaningful reporting and oversight, voucher programs operate with limited public visibility despite their reliance on public resources. Such opacity presents a significant implementation risk and undermines public trust in the stewardship of federal funds.
Evidence shows that federal and state voucher schemes can divert billions of public dollars away from the public education system that serves approximately 90% of U.S. students, weaken long-standing statutory protections for students of color, students with disabilities, English learners, and others, and accelerate patterns of racial and socioeconomic segregation in schooling. Voucher programs frequently operate with limited oversight or accountability regarding how funds are used or whether students retain access to essential civil rights protections, and they funnel resources to individual families rather than expanding meaningful access to high-quality education for all.
IDRA urges an implementation approach that prioritizes transparency and accountability, and that carefully evaluates the inherent and well-documented risks associated with voucher programs.
