Florida ESA Program

# The Florida Model: An In-Depth Analysis of the Nation's Largest and Most Complex School Choice Ecosystem

Section I: The Architectural Blueprint of Florida's School Choice Landscape

Florida's K-12 education system has undergone a profound structural transformation, evolving from a system of targeted educational aid into the nation's largest and most intricate school choice ecosystem. This evolution, culminating in near-universal eligibility, has established a national precedent in both scale and complexity. A thorough analysis of this system requires a meticulous deconstruction of its component programs, each with a distinct legislative framework, funding mechanism, and target population. Understanding this architecture is the essential foundation for any credible assessment of the system's fiscal, demographic, and administrative realities.

The Legislative Pivot: From Targeted Aid to Universal Eligibility

The pivotal moment in Florida's school choice history was the passage and enactment of House Bill (HB) 1 in 2023\.1 This landmark legislation effectively eliminated most financial eligibility restrictions for the state's primary scholarship programs, expanding access to nearly all of Florida's 3.5 million K-12 students.1 This act was not a sudden development but the culmination of a multi-decade legislative trend. The state's journey began with programs like the Florida Tax Credit (FTC) Scholarship, created in 2001 with a clear focus on providing options for children from low-income families.2 The subsequent creation of the Family Empowerment Scholarship (FES) in 2019 further expanded access, signaling a consistent legislative trajectory away from narrow, means-tested interventions and toward a universal model of publicly funded educational choice.5

Deconstructing the Four Pillars: A Programmatic Taxonomy

The Florida model is not a single, monolithic "voucher" program but a portfolio of distinct instruments designed to serve different segments of the K-12 population through varied funding streams. This deliberate market segmentation allows the state to maximize participation and provides a degree of political and financial resilience not seen in states with a single, unified program. The four primary pillars of this ecosystem are:

• Family Empowerment Scholarship for Educational Options (FES-EO): This is the state's principal universal scholarship, functioning as an Education Savings Account (ESA)-style program. It is funded via direct appropriation from the Florida Education Finance Program (FEFP), the state's main K-12 funding formula.6 While eligibility is now open to any Florida resident student in grades K-12, a priority system remains in statute, favoring students from lower-income households (those at or below 185% of the federal poverty level) and those in foster care.8 Allowable expenses are broad but primarily centered on covering private school tuition and associated fees.8
• Family Empowerment Scholarship for Students with Unique Abilities (FES-UA): This program, which absorbed the state's former Gardiner and McKay scholarships, operates as a true ESA specifically for students with qualifying disabilities.1 Its funding structure is similar to the FES-EO, but it offers parents greater flexibility. Funds are deposited into a government-authorized savings account and can be used for a wide array of expenses beyond tuition, including specialized therapies, private tutoring, curriculum, instructional materials, and technology.1 To be eligible, a student must have an Individualized Education Plan (IEP) or a documented diagnosis of a qualifying disability from a licensed physician or psychologist.8
• Florida Tax Credit Scholarship (FTC): The FTC program is architecturally distinct from the FES programs. It is not funded by direct legislative appropriation but by corporate contributions. Corporations that donate to non-profit Scholarship Funding Organizations (SFOs) receive a dollar-for-dollar credit against their state tax liabilities.2 This mechanism functions as an indirect public subsidy, diverting state revenue to fund private school scholarships. The annual cap for these tax credits is substantial, exceeding $1.1 billion for the 2024-25 fiscal year.6 The FTC program shares an application and the same income-based priority structure with the FES-EO program, making them functionally similar for families but legally and financially distinct for the state.13
• Personalized Education Program (PEP): As the newest component of the ecosystem, the PEP is an ESA designed specifically to provide public funds for students in a home education setting.11 It is funded through the same tax-credit mechanism as the FTC scholarship and was launched with an initial enrollment cap of 100,000 students for the 2025-26 school year.2 The creation of the PEP represents a significant policy step, formalizing the use of public funds to support customized, parent-directed home education on a large scale.

This multi-program, dual-funding-stream architecture is a sophisticated design. It creates a segmented market that caters to different constituencies—traditional private school families, families of students with special needs, and homeschooling families—while leveraging different financial and political pathways. This complexity makes any simple, one-dimensional analysis of the system's impact inherently incomplete. Unlike a state with a single, unified program like Arizona's Empowerment Scholarship Account 20, the Florida model must be evaluated as an integrated ecosystem of interacting parts.

Table 1: Florida's K-12 Scholarship Programs: A Comparative Overview

Section II: The Administrative Engine: The Role of Scholarship Funding Organizations (SFOs)

A defining feature of the Florida model—and a key point of divergence from state-run systems—is its reliance on a public-private administrative partnership. While the Florida Department of Education (FLDOE) provides high-level oversight, the state has delegated the vast majority of the operational and logistical responsibilities for its multi-billion-dollar scholarship ecosystem to a small number of non-profit entities known as Scholarship Funding Organizations (SFOs). This administrative architecture has significant implications for efficiency, data transparency, and public accountability.

The Public-Private Partnership Model

State law empowers the FLDOE to approve non-profit organizations to manage the day-to-day functions of the scholarship programs.1 These SFOs are responsible for the entire lifecycle of the scholarship process, from processing family applications and verifying eligibility to distributing funds to thousands of private schools and vendors.1 This model effectively externalizes the immense administrative burden of managing nearly half a million individual student accounts from the state government to the private sector.

The landscape is dominated by two SFOs: Step Up For Students (SUFS) and the AAA Scholarship Foundation.1 Of these, SUFS is by far the larger and more influential entity, administering scholarships for hundreds of thousands of students across all of Florida's major choice programs and positioning itself as the central operational hub of the entire system.11

Operational Mechanics: From Application to Payment

The operational flow bypasses direct state interaction for families and schools. Parents seeking a scholarship do not apply to the FLDOE but directly to an SFO, which is responsible for collecting and verifying all required documentation to determine eligibility.1 The movement of funds is similarly managed. For the state-funded FES programs, the FLDOE disburses lump sums to the SFOs, which then make quarterly payments to private schools on behalf of enrolled students.1 For the tax-credit-funded FTC and PEP programs, corporations make their tax-deductible contributions directly to the SFOs, which then manage and award the resulting scholarships.17

The SFOs' role extends to ensuring school-level compliance. Before funds are disbursed each quarter, participating private schools must submit "Verification Reports" through the SFOs' online portals to confirm that each scholarship student remains enrolled and in attendance, a critical check in the payment process.12

This delegation of administrative functions has created a system where the primary source of detailed, timely, and comprehensive data on program utilization is collected and held not by a public agency, but by private organizations. While the FLDOE publishes some high-level reports, they are often less frequent and granular than the data published by the SFOs themselves.22 This structure raises significant questions of public accountability, as the SFOs are not merely neutral third-party administrators. They are also powerful advocacy organizations, with missions centered on promoting and expanding school choice.4 This creates a dynamic where the primary entities responsible for reporting on the programs' performance are the same ones that lobby for their continuation and expansion. This potential conflict of interest stands in stark contrast to systems like Arizona's, where the state's Department of Education is the primary source of official data, ensuring a greater degree of public oversight and independence in reporting.20 The Florida model thus presents a fundamental trade-off: it achieves administrative efficiency for the state government at the cost of concentrating data and reporting power in the hands of private, mission-driven organizations.

Section III: Enrollment Dynamics and Participant Profile

The scale of Florida's school choice participation is unparalleled in the United States. The 2023 expansion to universal eligibility triggered an explosive growth in enrollment, fundamentally reshaping the state's educational landscape. An analysis of this growth, the demographic composition of the participant base, and the critical metric of prior school enrollment reveals a system that has successfully penetrated a massive market but has done so primarily by subsidizing existing private school populations.

Unprecedented Scale and Explosive Growth

Florida's scholarship programs are the largest in the nation by student participation.33 For the 2024-2025 academic year, Step Up For Students reported serving more than 500,000 students across its portfolio of programs.22 This includes 307,609 students in the combined FES-EO and FTC private school scholarship programs, 122,051 students in the FES-UA program for students with disabilities, and 59,925 students in the new PEP for home education.22

This surge in private and home education enrollment is part of a broader systemic shift. During the 2023-2024 school year, a milestone was reached: for the first time, more than half of all K-12 students in Florida—nearly 1.8 million children—attended a "school of choice" rather than their geographically assigned public school. This figure includes not only private school scholarship recipients but also students in charter schools, magnet programs, and other public choice options.32 This data indicates that the traditional model of the neighborhood public school is no longer the default educational experience for the majority of Florida's students.

Table 2: Enrollment and Program Scale by Scholarship, 2024-2025

Participant Demographics: A Pre- and Post-Universal Snapshot

The most comprehensive demographic data available provides a snapshot of the participant base immediately prior to the shift to universal eligibility. The SUFS annual report for the 2021-2022 school year, when the FES-EO and FTC programs were still largely means-tested, offers a critical baseline for understanding who these programs historically served.31

The data from this period shows that the programs were highly successful in reaching their intended audience of lower-income and minority families. In 2021-22, 68% of all participants came from households with incomes at or below 185% of the federal poverty level. The student population was highly diverse, with 38% of students identifying as Hispanic and 27% as Black. Approximately 46% of students resided in single-parent households.31 While more recent, comprehensive demographic data post-universalization is not yet available, the removal of income caps in 2023 has undoubtedly shifted this profile by bringing in a substantial new cohort of middle- and higher-income families who were previously ineligible.

Table 3: Participant Demographics (FES-EO/FTC, 2021-22 Baseline)

The "Switcher Rate": The Fulcrum of the Fiscal Debate

The single most consequential metric for determining the net fiscal impact of a universal school choice program is the "switcher rate"—the percentage of new participants who came directly from a public school versus those who were already enrolled in private school or homeschooled. A student who "switches" from a public school generates a cost savings for the state, as the scholarship amount is typically less than the full per-pupil cost in the public system. Conversely, a scholarship awarded to a "non-switcher"—a student whose education the state was not previously funding—represents an entirely new cost to the state budget.

Multiple analyses of the Florida data converge on a consistent and critical finding: the program has a very high non-switcher rate. Data from Step Up For Students for the 2022-23 school year showed that 69% of new scholarship recipients had already been enrolled in private schools.35 An independent analysis by EdWeek for the same period arrived at an identical figure of 69% 36, while another analysis suggested the rate could be as high as 70%.37

This indicates that the universal expansion functioned primarily as a financial subsidy for the nearly 70% of new participants who were existing private school families, rather than as an "exit ramp" for the 30% of participants who were leaving the public system. This dynamic is the inverse of the situation in Arizona, where a majority of new universal participants (57%) are "switchers" from public schools, which forms the basis for credible arguments that the program may be revenue-neutral or even generate savings.20 The high non-switcher rate in Florida fundamentally defines the program's fiscal impact, making it a net cost to the state by design. This reality is the primary driver of the "Deficit-Driver" fiscal model that characterizes the budgetary debate surrounding the program.

Section IV: The Multi-Billion Dollar Question: Fiscal Impact and Budgetary Debates

The fiscal impact of Florida's universal school choice expansion is the subject of intense debate, centering on the program's effect on the state budget and funding for traditional public schools. The sheer scale of the program, combined with its high non-switcher rate, forms the foundation of the "Deficit-Driver" model, which posits that the universal scholarships represent a massive new financial obligation for the state that diverts billions of dollars from the public education system.

Funding Mechanisms: Direct Appropriation and Tax Credits

As previously established, Florida's scholarship ecosystem is financed through two distinct channels. The Family Empowerment Scholarship (FES) programs are funded by a direct appropriation from the Florida Education Finance Program (FEFP), the state's primary funding formula for K-12 public schools.6 This means FES dollars are drawn from the same pool of general revenue that supports district and charter schools. The Florida Tax Credit (FTC) Scholarship and Personalized Education Program (PEP) are funded indirectly via corporate tax credits, which divert over $1.1 billion in state revenue annually before it can be used for other public services.2

Gross Program Cost: A Multi-Billion Dollar Enterprise

The total public cost of these programs is substantial and growing rapidly. During the current school year, an estimated $3.2 billion is being directed to FES scholarships for over 380,000 students.6 Legislative proposals for the 2025-26 fiscal year seek to increase this direct FES allocation by more than $800 million.6 When this direct spending is combined with the more than $1.1 billion in foregone revenue from the FTC/PEP tax credit programs, the total annual public cost of the scholarship ecosystem is projected to exceed $4 billion.2 This figure aligns with projections from the Florida Policy Institute and the Education Law Center, which estimated that the 2023 universal expansion would cost the state $4 billion in its first year of implementation alone.2

The "Deficit-Driver" Model: Analyzing the Net Fiscal Impact

The prevailing critical analysis of the program's fiscal impact, advanced by organizations like the Florida Policy Institute, is that the universal expansion is a significant drain on public funds.2 The central premise of this model is rooted in the program's high non-switcher rate of 69-70%.35 Because the vast majority of new scholarship recipients are students whose education the state was not previously funding, each of these scholarships represents an entirely new expenditure. The model concludes that the massive new cost incurred to subsidize these existing private school and homeschool populations far outweighs any marginal savings generated by the smaller cohort of students who switch from public schools.

The data shows a clear trend of funds being redirected from the public system. Between the 2019-20 and 2022-23 school years, the amount of funding diverted from the FEFP to FES vouchers increased by $1 billion. By 2022-23, this diversion accounted for an estimated 10% of all state aid intended for public schools.7 This diversion has a direct impact at the district level, as the entire cost of the vouchers is deducted from school districts' state aid allocations, disproportionately affecting districts that are more reliant on state funding versus local property tax revenue.7

Furthermore, the state's budgetary process appears to obscure the program's full cost. In addition to the primary FES appropriation within the FEFP, the state budget has included a separate $350 million line item for an "Educational Enrollment Stabilization Program" (EESP).6 Legislative analysis reveals that this fund is designed to absorb cost overruns from the scholarship programs, specifically to cover any additional students beyond what the main appropriation can support.38 This practice suggests that the official FES budget figure is an intentional underestimate, with a multi-hundred-million-dollar contingency fund held in reserve. This lack of transparency makes a straightforward assessment of the program's true, anticipated cost difficult and indicates that legislators are planning for expenditures to exceed the primary appropriation.

Table 4: Deconstructing the Fiscal Impact: The "Deficit-Driver" Model

Section V: The Accountability Framework: Oversight, Testing, and Auditing

Given the multi-billion-dollar public investment in Florida's school choice ecosystem, the framework for ensuring program integrity and academic quality is of paramount importance. The state's accountability system is built on statutory requirements for student testing and financial audits of both the SFOs and participating private schools. However, a closer examination reveals a system that emphasizes procedural compliance over performance outcomes, raising questions about its effectiveness in guaranteeing educational quality for scholarship recipients.

Academic Accountability: The Testing Mandate

Florida Statutes mandate that all private schools participating in the FES, FTC, or PEP programs must demonstrate academic accountability.39 This requirement is fulfilled by annually administering a state-approved assessment to all scholarship students. Schools have two primary options: they can administer one of a long list of nationally norm-referenced tests approved by the FLDOE—such as the ACT, SAT, Iowa Assessments, or NWEA MAP tests—or they can apply to administer Florida's own statewide standardized assessments.39 Students with disabilities for whom standardized testing is deemed inappropriate are exempt from this mandate.39

The accountability loop requires participating schools to report the scores of their scholarship students to two parties: the students' parents and an independent research organization contracted by the state, which is currently housed at Florida State University.39

Financial Oversight and Auditing

The financial oversight framework is designed to monitor the flow of public funds through the system. The primary subjects of this oversight are the SFOs. State law requires that each SFO undergo an annual financial and compliance audit conducted by an independent Certified Public Accountant (CPA), with the results submitted to the state.22

Participating private institutions are also subject to financial review. Florida statutes require private schools receiving state student financial aid to secure periodic audits from independent CPAs.41 The frequency of these audits—either annual or biennial—is determined by the total amount of scholarship funds the school receives.41 These audits are designed to ensure that the institution has an adequate internal control structure and has complied with state rules regarding the certification of student eligibility, the maintenance of supporting documentation, and the proper accounting of scholarship funds. Critically, auditors are required to report all instances of noncompliance or questioned costs, no matter how small.41 Additionally, any school receiving more than $250,000 in scholarship funds is required to file a separate financial report.42

While these requirements create the appearance of a robust accountability system, the framework is fundamentally procedural rather than performative. The statutes require that students be tested and that scores be reported, but there are no consequences tied to the results. A private school can continue to receive public funds regardless of how poorly its scholarship students perform academically. The mandate is to administer the test, not to demonstrate academic growth or proficiency. Similarly, the financial audits are designed to ensure compliance with administrative rules—verifying that funds were spent on allowable expenses for eligible students—rather than to assess educational efficacy or return on investment. This creates a system of "accountability theater," where the mechanisms for oversight are in place but lack the substantive authority to ensure that the state's multi-billion-dollar investment is translating into high-quality educational outcomes for students.

Section VI: Concluding Analysis: Florida as a National Bellwether

Florida's expansive and complex school choice ecosystem has firmly positioned the state as a national bellwether in the evolution of K-12 education policy. Its journey provides a critical case study for policymakers nationwide, illustrating the profound consequences of adopting a universal choice model at an unprecedented scale. The analysis reveals a system that has successfully created a massive market for educational alternatives but has done so at a significant net cost to the state, primarily by subsidizing existing private school populations within an accountability framework that prioritizes procedure over performance.

Synthesis of Findings: A System of Unprecedented Scale and Cost

The core findings of this report paint a clear picture of the Florida model. Architecturally, it is a sophisticated portfolio of distinct scholarship programs, administered through a unique public-private partnership with SFOs that externalizes state administrative burdens but concentrates data and reporting power in the hands of private advocacy groups. The 2023 universal expansion catalyzed explosive enrollment growth, making it the largest choice system in the nation. However, this growth was driven overwhelmingly by students already enrolled in private schools, as evidenced by a high non-switcher rate of nearly 70%. Consequently, the program's primary fiscal effect is a massive new cost to the state budget, diverting billions of dollars that would otherwise fund the public education system. This immense public expenditure is governed by an accountability system that, while requiring testing and financial audits, lacks the mechanisms to enforce academic quality or ensure a positive return on investment.

The Florida vs. Arizona Models: A Tale of Two Universal Systems

When contrasted with Arizona's universal ESA program—the nation's first—Florida's divergent policy choices and their resulting outcomes become starkly apparent.

• Administration and Data Transparency: Florida's decentralized, SFO-led model 1 contrasts sharply with Arizona's centralized system, which is run directly by the state's Department of Education (ADE).20 This structural difference has profound implications for public accountability. In Arizona, the ADE is legally required to produce detailed, public quarterly reports on enrollment, demographics, and switcher rates, creating a transparent, government-verified data source.20 In Florida, the most detailed and timely data comes from the SFOs, which are also advocacy organizations, creating a potential conflict of interest and a less transparent data environment.22
• Fiscal Impact and the Switcher Rate: The most critical distinction lies in who uses the programs. Florida's high non-switcher rate of 69% means its program functions primarily as a subsidy, creating a clear net cost to the state.35 Arizona's high switcher rate of 57% means its program functions primarily as an exit ramp from public schools, forming the basis of a credible argument for revenue neutrality or net savings.20 This demonstrates how program design choices—such as whether to include a prior public school enrollment requirement—can fundamentally alter the fiscal reality of a universal choice policy.

Forward-Looking Implications and Recommendations

The Florida model serves as a crucial, cautionary case study. It demonstrates that implementing universal choice without specific guardrails or a focus on fiscal sustainability can result in the state assuming a massive new financial obligation to subsidize private education for families who were already paying for it. For other states considering similar policies, Florida's experience offers several vital lessons and suggests a path toward a more accountable and sustainable model.

Recommendations for Policymakers:

1. Mandate Centralized, Public Data Reporting: To ensure transparency and enable independent analysis, the Florida Legislature should require the Department of Education—not just the SFOs—to collect and publish detailed, anonymized quarterly reports. These reports must include participant demographics and, most critically, prior school enrollment status to allow for an official, publicly verifiable "switcher rate."

2. Commission a Comprehensive Net Fiscal Impact Study: The state should commission an independent, non-partisan entity to conduct a rigorous analysis of the scholarship ecosystem's true net cost. This study must account for the high non-switcher rate and quantify the fiscal impact on public school districts, providing a clear and unbiased picture of the program's effect on the state budget.

3. Link Accountability to Performance: The current accountability framework should be evolved beyond procedural checks. Policymakers should introduce mechanisms to measure the academic growth of scholarship students over time and establish meaningful performance standards for participating private schools. Continued eligibility for public funds should be contingent on demonstrating positive educational outcomes, not merely on administering a test.

4. Re-evaluate Funding for Non-Switchers: Given the immense fiscal impact of subsidizing existing private school populations, policymakers should consider whether providing a full scholarship to families who have demonstrated the ability and willingness to pay for private education is a sustainable or equitable use of limited public funds. Exploring a tiered or means-tested scholarship amount within the universal framework could help mitigate the program's net cost while still expanding choice for families who need it most.

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