Comment from New America

RE: IRS-2025-0466 New America is an independent, nonprofit policy and research organization. Our PreK-12 team, as a part of the Education Policy Program, focuses on strengthening and improving public education to better ensure all students have equitable access to high quality learning opportunities. We appreciate the opportunity to provide feedback on the US Department of the Treasury’s implementation of the Individual Tax Credit for Qualified Contributions to Scholarship Granting Organizations (SGOs). In order to preempt potential harms in the operations of the tax credit system and to bolster the educational options embraced by most students and families, we have outlined ways that the Treasury Department can use its forthcoming regulations to ensure the execution of this program is equitable and efficient. The attached PDF provides details on the following recommendations: Treasury should clarify federal nondiscrimination requirements. Treasury should affirm State discretion to set requirements for Scholarship Granting Organization (SGO) eligibility. Treasury should affirm State discretion to interpret the laws regarding allowable expenditures in line with the needs of students in their states. Treasury should issue specific rules to ensure effective, transparent, and fair SGO operations. We thank the US Department of the Treasury for the opportunity to provide feedback on the future of the Individual Tax Credit for Qualified Contributions to Scholarship Granting Organizations. For any questions or clarifications please reach out to Lisa Guernsey, Senior Director, Birth–12th Grade Policy (guernsey@newamerica.org).