America First Policy Institute

The Cost of Opting Out

Projecting charitable education donations foregone in states that refuse to participate in the Education Freedom Tax Credit — 2027 through 2029

Tax Filers — Adjusted Gross Income ≥ $75,000 (2022 IRS SOI)  |  Source
StateIndividual
Filers
Joint
Filers
(max $3,400)
2027
I:10% / J:6%
2028
I:12% / J:8%
2029
I:14% / J:10%
3-Yr Total
Arizona330,680732,580$266.72M$327.78M$388.84M$983.34M
California2,619,5804,047,560$1.27B$1.64B$2.00B$4.91B
Connecticut239,890458,130$134.24M$173.55M$212.86M$520.65M
Delaware54,190118,570$33.40M$43.31M$53.21M$129.92M
District of Columbia97,45048,650$26.49M$33.11M$39.73M$99.34M
Hawaii77,210156,600$45.07M$58.35M$71.62M$175.04M
Illinois715,0801,426,500$533.88M$655.20M$776.51M$1.97B
Kansas97,930344,860$113.78M$140.56M$167.34M$421.68M
Maine56,390163,520$42.94M$55.98M$69.02M$167.94M
Maryland444,830716,450$221.78M$285.62M$349.46M$856.86M
Massachusetts529,930895,740$272.82M$351.75M$430.67M$1.06B
Michigan399,1401,096,180$291.47M$379.59M$467.70M$1.14B
Minnesota283,240780,780$207.43M$270.15M$332.88M$810.46M
New Jersey637,3001,149,170$342.77M$442.58M$542.40M$1.33B
New Mexico82,800172,980$49.36M$63.94M$78.52M$191.83M
New York1,441,6001,825,150$617.40M$790.53M$963.65M$2.37B
North Carolina403,4701,130,360$299.18M$389.77M$480.35M$1.17B
Oregon216,250490,200$136.76M$177.45M$218.14M$532.35M
Pennsylvania613,1001,499,110$532.83M$655.62M$778.40M$1.97B
Rhode Island65,490118,930$45.71M$56.02M$66.34M$168.07M
Vermont29,01079,860$21.22M$27.64M$34.06M$82.92M
Washington522,0901,036,010$300.10M$388.30M$476.50M$1.16B
Wisconsin241,480762,610$196.62M$256.69M$316.76M$770.08M
All States10,198,13019,250,500$6.00B$7.66B$9.31B$22.98B
Amber rows = states with existing or recent Tax Credit Scholarship program infrastructure
Adjust Participation Assumptions
Individual Filers (max $1,700)
Joint Filers (Married Filing Jointly — max $3,400)
Individual Filers — Participation Rate
2027
10%
+
2028
12%
+
2029
14%
+

Joint Filers — Participation Rate
2027
6%
+
2028
8%
+
2029
10%
+

TCS Program Boost: +2pp
Added to base rate for states with existing TCS infrastructure (AZ, IL★, KS, PA, RI). States that have operated scholarship tax credit programs have established SGO networks and donor bases already familiar with this type of giving — advantages that states starting from scratch will not have at launch.
Joint Filer Credit Cap:
Both spouses claim up to $1,700 each — $3,400 total per household.
Treasury guidance is expected before the 2027 program launch and will clarify whether joint filers may each claim up to $1,700, or whether $1,700 is the cap per return regardless of filing status.

★ Illinois note: Illinois is classified as a TCS program state despite not currently operating an active program. The state administered the Invest in Kids Act through 2023, creating established SGO infrastructure and a donor base familiar with this giving vehicle. That infrastructure can be reactivated quickly.

Each row below shows scholarships lost by year and over the 2027–2029 window, after deducting 10% for SGO administrative costs — the maximum permitted under IRC Section 25F. Funding figures carry over from the participation assumptions set in the Funding Loss Calculator tab. Adjust the average scholarship size below to reflect award levels in your state or policy context. These are scholarship opportunities that will not exist for students in non-participating states; the funding will instead support students in states that opted in.
Average Scholarship Size
$5,000
$2,000$12,000
State2027202820293-Yr Total
Arizona48,01059,00069,991177,001
California228,786294,360359,933883,079
Connecticut24,16331,23938,31493,716
Delaware6,0127,7959,57823,385
District of Columbia4,7685,9607,15217,881
Hawaii8,11310,50212,89231,507
Illinois96,099117,936139,772353,807
Kansas20,48025,30130,12175,902
Maine7,73010,07712,42330,230
Maryland39,92051,41262,903154,235
Massachusetts49,10763,31477,521189,943
Michigan52,46568,32584,185204,976
Minnesota37,33748,62859,918145,883
New Jersey61,69979,66597,631238,995
New Mexico8,88611,51014,13434,529
New York111,132142,295173,457426,885
North Carolina53,85370,15886,463210,474
Oregon24,61731,94139,26495,823
Pennsylvania95,909118,011140,112354,032
Rhode Island8,22810,08411,94130,252
Vermont3,8204,9756,13014,926
Washington54,01869,89485,770209,683
Wisconsin35,39246,20557,017138,614
All States1,080,5441,378,5871,676,6224,135,758
What This Tool Measures

This calculator projects charitable education donations that will not occur in states choosing not to opt into the Education Freedom Tax Credit. Beginning January 1, 2027, taxpayers in participating states may claim a nonrefundable federal credit of up to $1,700 for contributions to certified scholarship-granting organizations (SGOs). Participation is a state-level decision that is largely up to the governor. Residents of non-participating states are not eligible to direct those dollars to local students, though they may donate to SGOs operating in other states.

The projections are calculated separately for individual filers and joint filers, then combined for each state and year. "Individual filers" here covers both single filers and heads of household — any return filed by one person rather than a married couple. The formulas are straightforward:

  • Individual filers (single and head of household): Number of filers with AGI ≥ $75,000 × $1,700 × participation rate
  • Joint filers: Number of filers with AGI ≥ $75,000 × $3,400 × participation rate

The two filer types are modeled separately because pending Treasury guidance will determine whether married couples may each claim up to $1,700 (producing a $3,400 household total) or whether the credit is capped at $1,700 per return regardless of filing status. The tool defaults to $3,400 for joint filers. The Joint Filer Credit Cap toggle lets users apply the more conservative $1,700 assumption if they prefer.

Because the credit returns 100 cents on every dollar contributed, a full maximum contribution is assumed for every participating filer. Filer counts are restricted to returns with adjusted gross income of $75,000 or more — the threshold above which filers are most likely to carry enough tax liability to claim the full nonrefundable credit. These counts come from 2022 IRS Statistics of Income data and are held constant across the projection window. The model does not account for population growth or income increases, both of which would expand the eligible donor pool. Actual totals may be higher.

Participation Rate Assumptions

Baseline rates start at 10% for individual filers and 6% for joint filers in 2027, rising 2 percentage points per year through 2029. Joint filers are modeled at a lower participation rate despite their higher credit cap because not all filers may have $3,400 available to contribute upfront.

YearIndividual FilersJoint Filers
202710%6%
202812%8%
202914%10%
Context: The CARES Act Charitable Deduction

No federal program of this exact design has existed before, so there is no direct precedent for projecting EFTC participation rates. One reasonable benchmark is the CARES Act's $300 above-the-line charitable deduction, which was created in 2020. Claiming it required nothing beyond checking a box on a return already being filed. Despite offering minimal tax savings for most filers, 41.4 million Americans claimed it (IRS Statistics of Income, Publication 1304, Tax Year 2020, Table 1.3: Sources of Income, Adjustments, Deductions, Credits, and Tax Items).

Claiming the EFTC involves more steps than the CARES deduction did. A donor must identify a certified SGO, make an upfront contribution, and file a separate credit form. Those additional requirements may reduce participation relative to the CARES benchmark. The default rates here are set well below that ceiling while still reflecting a reasonable expectation that SGO outreach and tax preparer coordination will drive meaningful uptake from launch. Because these rates cannot be known in advance, the tool is designed to be adjusted. The sliders exist to let users apply their own assumptions.

Data Sources