Per the updated guidance, this article was updated on October 26, 2026

Treasury’s proposed Federal Scholarship Tax Credit rules are out, confirming that states certify SGOs rather than design the program. Much is still unresolved, but states still face real choices: whether to participate, how the program will affect their public schools, and how to build the governance, SGO, donor, and compliance infrastructure to make it work. The states that get it right will start intentionally, now.

Our updated framework for state leaders is below.

“Should we participate?”

This is still each state’s call to make, grounded in your state’s needs and priorities.

The proposed rules, released October 1, clarify what that call involves. States certify SGOs; they don’t design the program or set their own SGO requirements. The real questions are which organizations will serve your public school students and to what extent can they access the dollars.

Afton has developed a decision protocol for states working through this, because the short- and long-term implications informs not just the answer but what needs to happen next.

“What could this mean for our public education system?”

Participation or non-participation both have material fiscal and enrollment implications which play out differently in every state.

The proposed rules include services that fit public schools, like need-based tutoring and special-needs scholarships in low-income areas.

Whether those tools reach your students with this funding depends on the next question.

“How do we get our education ecosystem ready?”

Dollars are not automatically captured. Readiness for states starts with SGO infrastructure.

If no SGO is built around public school students, the market will be shaped by whoever registers. States that don’t yet have a statewide SGO serving public school students should catalyze one now.

And for the work beyond, Afton also helps build it: oversight and governance, certification, donor strategy, data reporting and compliance systems, and program launch.

This is a consequential decision. Not one to navigate alone.

We’ll help you choose well, with your students at the center. Let’s talk.