Arkansas ESA Program

# Arkansas's Education Freedom Account Program: A Comprehensive Analysis

Section I: Legislative Architecture and Program Design

The establishment of Arkansas's Education Savings Account (ESA) program in 2023 marks a pivotal moment in the state's K-12 education policy. The program was not conceived as a standalone initiative but as a central pillar of the Literacy, Empowerment, Accountability, Readiness, Networking, and School Safety (LEARNS) Act, a sweeping and highly partisan legislative package that fundamentally reshaped the state's educational landscape.1 This context is essential for understanding the program's design, its political dynamics, and the legal challenges it has faced. The program's carefully structured, multi-year implementation reveals a deliberate strategy to manage its political, administrative, and fiscal rollout.

A. The LEARNS Act Context

The official name of the program is the Arkansas Children's Educational Freedom Account Program, often referred to as Education Freedom Accounts (EFAs).3 Its legal foundation is codified in Arkansas Code §§ 6-18-2501 through 6-18-2511, which outlines its structure, eligibility, and operational parameters.4 Administrative authority for the program is vested in the Arkansas Department of Education (ADE), specifically through its Office of School Choice and Parent Empowerment, which is responsible for processing applications, overseeing compliance, and establishing detailed rules for implementation.3

The program's inclusion within the omnibus LEARNS Act was a significant legislative maneuver. The Act bundled the controversial EFA program with other major, and in some cases broadly popular, education reforms, most notably a landmark increase in the minimum teacher salary to $50,000.2 This strategy of "logrolling" created a complex political dynamic, making it difficult for legislators to oppose the EFA without also voting against a substantial pay raise for teachers. This approach contributed to the stark partisan divide over the legislation, which saw near-unanimous Republican support and unanimous Democratic opposition.2 It also shaped the initial legal battles, which focused on the procedural passage of the entire LEARNS Act—specifically the validity of its emergency clause—rather than the constitutional substance of the EFA program itself.5

B. The Three-Year Phased Rollout to Universal Eligibility

Rather than launching as a fully universal program, the LEARNS Act established a three-year phased rollout, gradually expanding eligibility and participation caps. This incremental approach was not merely a timeline but a calculated strategy to manage the program's implementation. It provided a political shield by initially focusing on sympathetic student populations, allowed the administrative agency to scale its operations in a controlled manner, and created a fiscal safety valve to prevent the kind of sudden, unmanageable budget impacts seen in states like Arizona that moved directly to universal eligibility.3

• Year 1 (2023-2024): In its inaugural year, the program's eligibility was narrowly targeted to specific student populations. These included students with disabilities, homeless students, children in or formerly in the foster care system, previous participants of the state's Succeed Scholarship Program, children of active-duty military personnel, students zoned to attend public schools with an "F" rating, and students enrolling in kindergarten for the first time. Total participation was statutorily capped at 1.5% of the state's total public school enrollment from the preceding year.1
• Year 2 (2024-2025): The second year saw a significant expansion of eligibility. The program opened to students from public schools with a "D" rating and to children of veterans, military reservists, first responders, and law enforcement officers. The enrollment cap was doubled to 3% of the state's total public school enrollment.5 A critical policy change this year was the inclusion of homeschooling expenses as an allowable use of funds, which effectively opened the program to the state's substantial homeschooling population for the first time.9
• Year 3 (2025-2026): The program is set to reach its final, intended form. Eligibility becomes universal, open to all K-12 students in Arkansas who are eligible to enroll in a public school. The statutory enrollment cap is removed, though the total number of participants remains contingent on the annual legislative appropriation for the program.1

This phased design allowed state administrators to build capacity, test systems, and onboard vendors before facing the full demand of a universal program. The early termination of the program's first financial management vendor for performance issues underscores the practical wisdom of this gradual scaling, as it allowed the state to address a major logistical failure while the program was still relatively small.11

Section II: The Financial Framework: Funding, Allocation, and Management

The financial architecture of the Arkansas EFA program dictates its value to families, its cost to the state, and the central arguments in the debate over its fiscal sustainability. The specific formula for calculating award amounts, the mechanisms for managing and disbursing funds, and the rules governing their use are all deliberate policy choices that shape the program's economic impact.

A. Award Calculation and Funding Source

The value of an individual student's EFA is determined by a statutory formula. Each account is funded at an amount equal to 90% of the state's per-pupil foundation funding amount from the prior school year.1 This design choice is itself a pre-emptive fiscal argument; by setting the award at 10% less than the state's cost for a public school student, the program is framed as a fiscally efficient alternative that automatically generates savings for every student who switches from the public system.1 The program is funded through direct state appropriations.13

The per-student award amount has increased slightly each year in line with the state's foundation funding:

• 2023-2024: $6,672 1
• 2024-2025: $6,856 9
• 2025-2026: $6,864 (with some projections as high as $6,994) 7

A notable exception exists for students who previously participated in the Succeed Scholarship Program, which was folded into the EFA program. These students receive a higher allocation equivalent to 100% of the foundation funding amount, which was $7,617 in the 2024-25 school year.9

B. Financial Management and Allowable Expenses

To ensure accountability, EFA funds are not disbursed directly to parents as cash. Instead, the state contracts with a third-party financial services vendor to manage the accounts. After an initial contract with Student First Tech was terminated, the state now uses ClassWallet as its financial management platform.11 Parents access a digital portal to pay approved schools and service providers directly, or to submit requests for reimbursement for pre-approved, out-of-pocket expenses.15 Funds are deposited into these parent-managed accounts in four equal quarterly installments throughout the school year.7

The scope of allowable expenses is broad, designed to give parents flexibility in customizing their child's education. Qualifying expenses include:

• Private school tuition and fees
• Uniforms and textbooks
• Testing fees, including for college admission exams
• Curriculum and supplemental instructional materials
• Private tutoring and educational therapies
• Technology and educational software (with some exclusions, such as TVs and cell phones)
• Fees for career training courses
• Transportation (capped at 25% of the total award) 5

A significant policy evolution is the treatment of unspent funds. In the program's first year, any unused funds at the end of the school year were returned to the state, making it a simple annual scholarship.5 However, beginning with the 2025-26 school year, the program will permit unused funds to roll over from year to year, up to a maximum amount to be determined by the ADE.5 This change transforms the EFA into a true "savings account," providing families with greater flexibility to save for larger future expenses. It also introduces a long-term fiscal complexity for the state. As seen in mature programs like Arizona's, this rollover provision can lead to the accumulation of hundreds of millions of dollars in obligated state funds that exist outside the annual budget cycle, creating a "long-tail" fiscal liability that must be managed.3

Section III: Enrollment Trajectory and Participant Profile

The most critical data for understanding the EFA program's real-world impact comes from analyzing its enrollment growth and the characteristics of its participants. The official 2024-25 annual report, prepared by the University of Arkansas Department of Education Reform in collaboration with the ADE, provides the first definitive, empirical snapshot of the program's user base. This data is the lynchpin of the entire fiscal and political debate, offering concrete evidence on the central question of who the program serves.

A. Explosive Enrollment Growth

The demand for EFAs in Arkansas has far exceeded initial projections, demonstrating a significant latent desire for educational alternatives. In its first year of operation (2023-24), the program served 5,548 students.9 In the second year (2024-25), participation more than doubled to 14,256 students, representing a 157% increase.9 This growth trajectory is set to accelerate dramatically with the advent of universal eligibility. As of the publication of the annual report, the ADE had already approved 46,578 applicants for the 2025-26 school year, signaling a potential tripling of the program's size in a single year.9

B. The 2024-25 Participant Profile: An Empirical Snapshot

The 2024-25 annual report provides granular data on the composition of the program's participants in its second year, a year in which eligibility was still targeted but significantly expanded.

• The "Switcher Rate": The single most consequential data point from the report is the "switcher rate"—the percentage of participants who were previously enrolled in a public school. For the 2024-25 school year, only 12% of EFA participants had attended a public school in the prior year.9 This low figure is the central fact of the EFA debate. The primary fiscal argument for ESAs rests on generating savings when students switch from the more expensive public system. This official data provides powerful evidence for critics who argue that, in its early years, the program has functioned primarily as a state subsidy for families already utilizing private educational options, representing a new cost to the state for the vast majority of its participants.2
• Prior Educational Setting: The data on where students came from reinforces the low switcher rate. The largest single cohort of new participants were those who had attended a private school in the prior year (25%), followed by those who were homeschooled (17%). A third of all participants (33%) were students who were retained in the program from its first year. This means that a combined 42% of participants were already outside the public system before joining the EFA program in its second year.9
• Current Educational Setting: In its second year, the program served two distinct educational sectors. The majority of participants, 76% (10,834 students), used their EFA funds to attend one of 126 participating private schools. The remaining 24% (3,422 students) used the funds to support homeschooling.9 The emergence of this large, state-funded homeschooling cohort in the very first year it was an option signals a fundamental shift in the state's educational landscape, creating a new market for curriculum vendors and other service providers and introducing new oversight challenges.10
• Key Eligibility Subgroups: The program's targeted eligibility in its second year is reflected in the demographic breakdown of its participants. The largest single group consisted of students with disabilities (36%), a population often at the center of school choice advocacy. The next largest group was first-time kindergarteners (27%), followed by children of active-duty military or reserve parents (16%).9

Section IV: The Fiscal Impact Debate: A Tale of Two Models

The rapid growth of the EFA program has ignited a fierce and polarized debate over its fiscal impact on the state of Arkansas. The controversy is not about the program's gross cost, which is a matter of public record, but about its net cost after accounting for potential savings. Two competing analytical models have emerged, each leading to a starkly different conclusion about the program's affordability and its effect on the state budget. The entire debate hinges on the treatment of the "switcher rate" and reflects a fundamental conflict between predictive economic modeling and officially reported empirical data.

A. Model 1: The Net Fiscal Impact / Affordability Argument

This model, most prominently articulated in analyses by the Reason Foundation, calculates a net fiscal impact by subtracting the savings generated by "switchers" from the gross program cost.1 The core premise is that for every student who leaves a public school to use an EFA, the state saves the per-pupil funding it would have otherwise spent on that student in the public system. Because the EFA award is only 90% of that amount, each switcher generates a net savings for the state.1

The methodology of this model relies heavily on estimating the switcher rate. For its analysis, the Reason Foundation estimated a switcher rate of 34.8% for Year 1 and 27.5% for Year 2\.1 Based on these assumptions, the analysis concluded:

• In Year 1 (2023-24), the program had a net cost of $17.7 million, equivalent to just 0.3% of the total state budget.1
• In Year 2 (2024-25), the program had an estimated net cost of $66.9 million, or 1.1% of the state budget.1

Proponents of this model argue that the program is affordable and sustainable. They project that as the program becomes universal, the switcher rate will inevitably rise, mirroring the trajectory of Arizona's universal ESA, where the switcher rate grew from 21% to 57% over three years.3 This projected increase in switchers would generate greater offsetting savings, causing the program's net cost to decrease over the long term and making it a cost-effective policy for the state.20

B. Model 2: The Gross New Spending / Deficit-Driver Critique

The second model, advanced by program critics and public education advocacy groups like Arkansas Advocates for Children and Families, focuses on the gross new spending required for students who were never enrolled in the public system.2 This perspective argues that every dollar spent on a non-switcher represents an entirely new drain on the state's general fund, subsidizing educational choices that were previously funded privately.

This critique is powerfully supported by the official state data. The first report on the program after its launch noted that 95% of voucher users at private schools did not attend a public school in the prior year, meaning the overwhelming majority of the program's initial cost was new state spending.2 The 2024-25 annual report's finding of a 12% switcher rate further solidifies this argument, indicating that 88% of participants represented a new cost to the state.9

From this viewpoint, the program is a fiscally irresponsible policy that diverts hundreds of millions of dollars from public schools, particularly those in under-resourced poor and rural communities, to fund private education.22 Critics point to the program's rapidly escalating budget—from approximately $97.5 million in FY25 to a projected $277 million in FY26—as evidence of an unsustainable fiscal trajectory driven by the subsidization of private and homeschool families.13 This debate is not merely an accounting dispute but a proxy war over state spending priorities, with critics linking the new EFA expenditures to perceived underfunding in the public system, such as the flattening of salary schedules for veteran teachers.2

The core of the disagreement lies in the conflict between the estimated switcher rate used in the net-cost models and the much lower official switcher rate reported by the state. The Reason Foundation's conclusion of affordability for Year 2 was based on an estimated 27.5% switcher rate, whereas the official data for that same year showed the rate was less than half of that, at 12%.1 This discrepancy reveals that the debate is not just between two different philosophies, but between a predictive model that assumes future trends will align with other states and the current, officially reported data, which paints a much more costly picture for the program's early years.

Section V: Administration, Oversight, and Program Integrity

As the EFA program scales into a multi-hundred-million-dollar initiative, the administrative structures designed to ensure accountability and program integrity become critically important. Arkansas appears to have proactively designed an oversight framework intended to prevent the kinds of accountability challenges that have plagued more mature ESA programs in other states. However, this framework remains largely untested at the scale of a universal program, and the state's approach to regulation has shown signs of being reactive to emerging issues.

A. Administrative Framework

The primary administrative body for the EFA program is the ADE's Office of School Choice and Parent Empowerment.6 This office is responsible for all aspects of program implementation, from developing the application portal and verifying student eligibility to approving schools and service providers and handling parent inquiries.6 The ADE has promulgated detailed administrative rules that govern the program's operation, including specific timelines for application processing and a formal process for appealing eligibility or fund misuse decisions.25

The administration of the program has not been without significant challenges. The state's first financial management vendor, Student First Tech, was fined and terminated for performance issues that led to payment delays and a non-functional portal for homeschool families.11 This early failure prompted a switch to the current vendor, ClassWallet, and highlighted the immense logistical complexity of managing thousands of individual accounts and transactions.11

B. Accountability and Integrity Mechanisms

Arkansas's enabling legislation and administrative rules established several oversight mechanisms from the program's inception, suggesting an attempt to learn from the "oversight deficit" that has been a major criticism of Arizona's universal ESA.3

• Auditing Requirements: State law and administrative code mandate that the ADE conduct random audits of individual EFA accounts, participating private schools, and approved service providers. These audits are intended to ensure that public funds are used only for qualifying educational expenses and to verify the financial integrity of participating entities.27
• Fraud Reporting: The ADE has established an anonymous fraud reporting service, including a dedicated telephone hotline and email address, to allow the public, school officials, or other stakeholders to report suspected fraud or misuse of funds. The department is empowered to conduct an inquiry into these reports or to refer credible cases to the Arkansas Attorney General or the Secretary of the Department of Inspector General for investigation.27
• Academic Accountability: Unlike some ESA programs, Arkansas's includes a mandate for academic assessment. All students participating in the EFA program are required to take a nationally norm-referenced test in reading and math each year.5 The 2024-25 annual report provided the first aggregated results from this requirement, showing that participating students scored, on average, at the 57th percentile in math and the 59th percentile in English Language Arts (ELA), both above the national median of the 50th percentile.9

While these on-paper accountability measures are robust, their effectiveness will depend entirely on the ADE's capacity to implement them as the program triples in size. The true test will be whether the state allocates sufficient funding and staffing to the Office of School Choice and Parent Empowerment to conduct meaningful audits and investigations across tens of thousands of accounts.

Furthermore, the state has already demonstrated a "regulate-as-you-go" approach to oversight. After the program expanded to homeschoolers, reports emerged of funds being used for non-academic extracurricular activities like cotillion fees and gym memberships.2 The legislature responded swiftly by passing a bill to cap spending on extracurriculars at 25% of a student's total award.5 This sequence reveals an iterative regulatory process, where loopholes created by program expansion are identified and subsequently closed through legislative or administrative action.

Section VI: Legal Challenges and the Broader Political Landscape

The Arkansas EFA program was born from a contentious political environment and has been the subject of legal and legislative battles since its inception. It stands as a signature policy achievement for Governor Sarah Huckabee Sanders' administration and the Republican-controlled legislature, but it faces persistent opposition from public education advocates and Democratic lawmakers. This ongoing conflict has played out in the courts and at the state capitol, shaping the program's implementation and ensuring its status as a permanent fixture of political debate in Arkansas.

A. A Contentious Origin

The EFA program was the centerpiece of the LEARNS Act, which was passed by strong Republican majorities and signed into law by Governor Sanders in 2023\.2 The bill faced unified opposition from legislative Democrats and vocal criticism from public education advocacy groups, including the Arkansas Public Policy Panel, Arkansas Advocates for Children and Families, and the Little Rock branch of the NAACP.2 The debate was highly polarized, with supporters framing the program as a necessary step to empower parents and improve educational outcomes, while critics argued it would drain vital resources from public schools and primarily benefit wealthy families.2

B. The Evolving Legal Battlefront

The program has faced two distinct and strategically different legal challenges.

• Round 1 (Procedural Challenge): The first lawsuit, filed shortly after the LEARNS Act was passed, did not challenge the substance of the EFA program. Instead, it targeted the legislative process, arguing that the emergency clause that allowed the law to take effect immediately was passed in violation of the state constitution's requirement for a separate roll-call vote. A circuit court initially agreed, halting the law's implementation. However, the Arkansas Supreme Court ultimately ruled in favor of the state in October 2023, finding that the legislative journals properly recorded the vote and allowing the law, including the EFA program, to stand.5
• Round 2 (Substantive Challenge): With the procedural challenge defeated, opponents launched a new legal attack in June 2024\. This lawsuit, Faulkenberry et al. v. Arkansas Department of Education, makes a more fundamental, substantive argument. The plaintiffs contend that the EFA program is unconstitutional because it diverts public funds designated for the state's system of free public schools to private institutions, thereby violating the state's constitutional obligations to maintain a general, suitable, and efficient public school system. This case, which is currently pending, represents a direct assault on the core function of the EFA program.5 This evolution in legal strategy from a procedural technicality to a fundamental constitutional question signifies a maturation of the opposition's approach, setting the stage for a prolonged legal battle over the future of school funding in the state.

C. The Political "Trench Warfare"

The EFA program remains a political flashpoint. Opponents in the legislature have introduced bills seeking a full repeal of the program, such as HB1020 and HB1144 in the 2025 session, though these efforts have so far failed to advance out of committee in the face of strong majority opposition.32 The program enjoys robust political backing from the current administration and legislative leadership, who have demonstrated their commitment by significantly increasing its funding to meet surging demand.13 This dynamic has created a state of political "trench warfare." The program is a durable, but not yet settled, policy shift. Its short-term continuation is assured, but its long-term status will be subject to the outcomes of the pending constitutional challenge and future elections.

Section VII: Concluding Analysis and Forward-Looking Implications

After two years of operation, the Arkansas Children's Educational Freedom Account Program has established itself as a transformative and deeply polarizing force in the state's education system. The program's design and implementation offer a critical national case study in the strategic rollout of a universal ESA, while its early performance data provides an invaluable, evidence-based look at the fiscal and demographic realities of such a program. The analysis reveals a central tension: the EFA has been remarkably successful in creating a high-demand market for educational choice, yet its current participant profile validates the critique that it functions primarily as a state subsidy for non-public school populations, representing a significant new cost to taxpayers.

A. Synthesis of Key Findings

The program's phased rollout was a strategically sound approach that enabled administrative scaling and blunted initial political opposition. This controlled implementation has allowed the program to manage explosive growth, surging from just over 5,500 students in its first year to an anticipated 46,000+ in its third. However, the official data from the program's second year presents a challenging fiscal narrative for its proponents. The low 12% "switcher rate" demonstrates that, to date, the program has not primarily served as an "exit ramp" from public schools. Instead, it has overwhelmingly subsidized students already enrolled in private schools or homeschools. This empirical fact fuels the polarized fiscal debate, pitting predictive models that assume a future rise in switchers against the current data, which points to the program being a major new state expenditure.

Simultaneously, the program has catalyzed the growth of a large, state-funded homeschooling sector and has been designed with a proactive, though largely untested, oversight framework intended to ensure program integrity. This framework, however, will face its true test as the program's size and complexity multiply under universal eligibility.

B. The Central Tension: A Successful Market vs. A Contested Subsidy

The core conclusion from the program's first two years is that it has successfully tapped into a significant, latent demand among Arkansas families for educational alternatives. The rapid and sustained growth in applications is undeniable proof of concept for creating a state-supported educational marketplace. Families are voting with their feet, and the supply of participating schools and service providers is growing to meet that demand.21

However, this market success is shadowed by the fiscal reality revealed in the participant data. With nearly 90% of its second-year participants representing a new cost to the state, the program currently functions less as a more efficient allocation of existing K-12 funds and more as a large-scale subsidy for private educational choices. This dynamic places the EFA program at the center of a fundamental debate over state spending priorities and the constitutional definition of the state's role in funding education.

C. Forward-Looking Implications for a Universal Program

As the Arkansas EFA program transitions to full universal eligibility in the 2025-26 school year, several key factors will determine its future trajectory and ultimate impact:

1. The Switcher Rate is the Key Variable to Watch: The program's entire fiscal and political future hinges on this single metric. If, as proponents predict, the switcher rate increases dramatically now that all families are eligible, the net cost to the state will decrease, and the argument for its fiscal efficiency will be strengthened. If the rate remains low, the program will continue to be a significant and growing line item in the state budget, intensifying the political conflict over its funding.

2. The Challenge of Rural Access: With universal eligibility, questions of geographic equity will become more acute. National data indicates that private schools are disproportionately concentrated in urban and suburban areas.35 A critical question for Arkansas will be whether the EFA program can effectively serve families in rural communities or if it will primarily benefit those in metropolitan areas where more non-public options already exist.

3. Oversight Under Stress: The ADE's administrative and oversight capacity is about to be severely tested. Scaling from managing 14,000 accounts to potentially 50,000 or more in a single year is a monumental task. The state's ability to maintain program integrity, conduct meaningful audits, and prevent fraud at this scale will be paramount to sustaining public and political trust in the program.

Ultimately, the Arkansas EFA program stands as a bold and consequential policy experiment. Its early years have provided a wealth of data that both animates its supporters and arms its critics. As it enters its universal phase, it will offer invaluable lessons for the rest of the nation on the fiscal realities, administrative challenges, and political fault lines of creating a comprehensive, statewide system of school choice.

#### Works cited

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