Georgia ESA Program

# The Georgia Model: A Comprehensive Analysis of the Promise Scholarship and the Architecture of a Targeted ESA

Introduction: Georgia's Measured Entry into the ESA Landscape

In 2024, Georgia lawmakers enacted one of the most significant pieces of K-12 education legislation in the state's recent history: the Georgia Promise Scholarship Act.1 Established through Senate Bill 233, the program creates Georgia's first Education Savings Account (ESA), providing state funds for families to use on a wide array of non-public educational expenses, including private school tuition, homeschooling curriculum, and specialized therapies.3 The program's launch in the 2025-2026 academic year marks a pivotal moment, placing Georgia among a rapidly growing number of states embracing ESAs as a primary vehicle for school choice.5

However, Georgia's approach is not a pioneering effort into uncharted territory but rather a calculated, "second-generation" policy design. The architecture of the Promise Scholarship represents a deliberate choice to prioritize fiscal predictability, targeted intervention, and robust oversight from its inception. This measured design stands in stark contrast to the universal, market-driven models that have emerged elsewhere, most notably in Arizona, which in 2022 became the first state to make every K-12 student eligible for an ESA.5 The national trend has been a rapid push toward such universal eligibility, but this expansion has not been without significant challenges.5 In Arizona, the move to a universal entitlement program led to an explosive and difficult-to-predict surge in costs—from approximately $189 million for a targeted program to a projected $1.037 billion for the universal version—and exposed severe administrative and oversight deficits unprepared for the massive growth.5

Observing this precedent, Georgia lawmakers crafted a program built on caution. The Promise Scholarship is not merely a smaller version of a universal program; it is a fundamentally different policy instrument. Its narrow eligibility criteria, firm legislative budget cap, and multi-layered accountability framework were engineered as a direct response to the fiscal volatility and operational challenges witnessed in first-generation universal ESAs. Instead of maximizing access, Georgia's design maximizes state control over the program's fiscal footprint and growth trajectory, creating a model intended to prevent the "runaway train" scenario that critics allege occurred in other states. This report provides a comprehensive analysis of this unique model, examining its architectural blueprint, financial mechanics, the profile of its inaugural student cohort, its framework for accountability, and a critical comparative analysis with Arizona's universal experiment to illuminate the strategic policy choices and trade-offs inherent in Georgia's targeted approach.

The Architectural Blueprint of the Georgia Promise Scholarship

The Georgia Promise Scholarship is defined by a precise and multi-layered legal and administrative framework designed to control its scope and scale. This architecture reflects a clear legislative intent to create a limited, targeted intervention rather than a universal entitlement.

Legislative Foundation and Administration

The program was officially established by Senate Bill 233, "The Georgia Promise Scholarship Act," which was signed into law and became effective on April 23, 2024\.3 The legislation includes a sunset clause, stipulating that the program will be repealed on June 30, 2035, unless it is proactively renewed by a future legislative body, ensuring a mandatory long-term review of its performance and viability.3

Administrative oversight is vested in the newly created Georgia Education Savings Authority (GESA), which operates as a companion entity to the state's well-established Georgia Student Finance Commission (GSFC), the agency responsible for managing programs like the HOPE Scholarship.8 This structure leverages the institutional experience of the GSFC while creating a dedicated body to manage the unique operational demands of an ESA. GESA's duties include managing program funds, ensuring program integrity through audits, and monitoring student testing requirements.9 In a unique governance feature, the law also establishes a "Parent Review Committee" tasked with reviewing expenditures, adding a layer of direct stakeholder oversight to the program's administration.8

The Eligibility Funnel: A Multi-Layered, Targeted Approach

Unlike universal programs, eligibility for the Georgia Promise Scholarship is not automatic. Instead, it is determined by a multi-stage "funnel" of criteria that applicants must successfully navigate. This design deliberately limits participation to a specific, legislatively defined target population.

1. Geographic Limitation: The cornerstone of the program's targeted design is its geographic restriction. Eligibility is limited to students who reside in the attendance zone of a "low-performing" public school.9 A school is designated as low-performing if it ranks in the bottom 25% of all public schools statewide. This ranking is produced annually by the Governor's Office of Student Achievement (GOSA) and is based on the school's average College and Career Ready Performance Index (CCRPI) score over the two preceding years.7 The official list for the inaugural year included hundreds of schools, with significant concentrations in major metropolitan districts like Atlanta, DeKalb, and Clayton counties, as well as in various rural areas.14

A subtle but crucial detail in this criterion is the use of attendance zones rather than actual attendance at a designated low-performing school.16 This significantly broadens the potential applicant pool. A family could, for instance, live in a neighborhood served by a high-performing elementary school but be zoned to feed into a low-performing middle or high school. This makes their child eligible for the scholarship from kindergarten onward, even if their current school is not on the GOSA list. This design element subtly shifts the program's appeal from being solely a rescue mission for students currently in crisis to also being a preventative option for forward-looking parents concerned about their child's future educational path across a wider socioeconomic and geographic spectrum.

2. Prior Public School Enrollment ("Switcher" Mandate): To qualify, a student must have been enrolled in a Georgia public school for at least two consecutive full-time equivalent (FTE) counts, which typically corresponds to one full academic year.8 This "switcher" mandate ensures that the program primarily serves students transitioning out of the public system, rather than subsidizing families already in private education. A key exception is made for rising kindergarten students, who are eligible to apply without any prior public school attendance, allowing families to opt for a non-public option from the very beginning of their child's K-12 education.8

3. Income-Based Prioritization: The program does not have a strict income cap that automatically disqualifies families. However, it employs an income-based prioritization system to manage demand when applications exceed the program's funding capacity. In such cases, priority is given to renewing students already in the program, followed by new applicants from households with an income that does not exceed 400% of the Federal Poverty Level (FPL).7 For 2024, this threshold was approximately $124,800 for a family of four.9 This mechanism ensures that if the program becomes oversubscribed, its limited resources are directed first toward lower- and middle-income families.

4. Residency Requirement: Finally, the student's parent or legal guardian must have been a resident of Georgia for at least one year prior to applying. This requirement is waived for active-duty military personnel who have been transferred to a station in Georgia within the past year.8

The table below provides a concise summary of the program's core architectural features.

Financial Mechanics: A Capped and Targeted Funding Model

The financial architecture of the Georgia Promise Scholarship is the central control mechanism of the entire program, designed to ensure fiscal stability and predictability for the state. It achieves this through a fixed per-student award and a hard legislative cap on total program spending.

Per-Student Award and Funding Source

For its inaugural 2025-2026 school year, the program provides a flat award of $6,500 for each participating student.2 This amount is disbursed directly into the parent-managed ESA in four equal quarterly payments throughout the academic year.23 The enabling legislation allows GESA to withhold up to 5% of the award amount to cover administrative costs.24

The program's funding is derived from a recurring state appropriation. Crucially, the law establishes a firm ceiling on this appropriation: the total program budget cannot exceed 1% of the state's total appropriation for the Quality Basic Education (QBE) Program from the preceding fiscal year.7 For the 2025-2026 launch year, this formula resulted in a total program budget of approximately $141 million.7 This funding cap is the most significant structural difference between Georgia's model and the universal, entitlement-based programs in states like Arizona. In Arizona's system, funding follows the student, and the total program cost is a variable outcome of individual family decisions, creating significant fiscal uncertainty for state budget writers.5 In Georgia, the total cost is a fixed, predetermined legislative input, and the number of participants becomes the variable output. This structure fundamentally changes the politics of the program, reassuring fiscal conservatives that costs are contained while simultaneously forcing a conversation about rationing and prioritization. The program is effectively designed to manage demand against a legislatively controlled supply of scholarships.

Enrollment Cap and Rollover Provision

The hard budget cap creates a de facto enrollment cap. With a $141 million appropriation and a $6,500 per-student award, the program can fund a maximum of approximately 21,700 students in its first year.7 This fixed capacity makes the program highly sensitive to demand and necessitates the income-based prioritization system to allocate the limited scholarship slots.

The program also includes a provision for unused funds, though it is more restrictive than in some other states. Families may roll over a portion of their unspent award to the following academic year, but this is limited to a maximum of 50% of the unused funds from the current year.7 If an account remains inactive for two consecutive years, any remaining funds revert to the state's general fund, and the account is closed.7 This prevents the large-scale accumulation of unspent state funds in private accounts, a long-term fiscal liability that has become a point of concern in other ESA programs.5

The Inaugural Cohort: An Analysis of Initial Enrollment and Demographics

The launch of the Georgia Promise Scholarship in 2025 generated significant interest, and the data from its first application cycles provide a clear picture of the program's initial reach, the demographic profile of its participants, and how families intend to use the funds.

Application and Approval Data

During the initial application windows between March and June 2025, nearly 15,300 families applied for the scholarship.23 Following a review process to ensure applicants met the strict, multi-layered eligibility criteria, 8,559 students were approved to receive the $6,500 award for the 2025-2026 school year.26 This means that roughly 6,700 applicants—approximately 44% of the initial pool—were turned away for not meeting the geographic, prior-enrollment, or other requirements.26 This high rejection rate underscores the targeted nature of the program's design and highlights the significant unmet demand from families who were interested but ultimately ineligible.

Demographic Profile and Intended Use

The demographic data of the inaugural cohort reveals that the program is serving a diverse, majority-minority population, heavily concentrated in the early elementary grades.

• Race and Ethnicity: The approved student population is 52% Black, 33% White, 9% Multiracial, 4% Hispanic, and 1% Asian or Pacific Islander. This profile is notably different from the overall demographics of Georgia's public schools, which are approximately 37% Black and 38% White, indicating that the program's geographic targeting is successfully reaching a high proportion of minority families.26
• Grade Level: The program's participants are overwhelmingly young. A full 32% of the inaugural cohort are rising kindergarteners, and another 45% are in grades 1 through 6\. In contrast, middle schoolers (grades 7-8) and high schoolers (grades 9-12) make up only 11% and 12% of participants, respectively. This suggests the program is most appealing to families seeking to alter their child's educational path at an early stage.26

When surveyed on how they planned to use the scholarship funds, a clear majority of families (64%) indicated they would pay for private school tuition.23 Another 16% planned to use the funds to support a homeschooling program, while 14% intended to purchase educational support services such as tutoring or therapies.23 A small portion (6%) were still undecided at the time of the survey.26 Early data confirms this trend, showing funds flowing to over 360 approved private schools across the state. Some institutions have seen significant enrollment boosts, with one school in Macon enrolling 80 new students and receiving over $100,000 in scholarship funds.26

The table below summarizes the key data points for the inaugural 2025-2026 cohort.

A Framework for Flexibility: Allowable Expenses and Parental Choice

A core feature of the ESA model is the flexibility it affords parents in customizing their child's education. The Georgia Promise Scholarship provides this flexibility through a broad list of allowable expenses, managed through a modern financial platform and governed by specific rules designed to ensure funds are used for their intended educational purpose.

Financial Management and Allowable Expenses

All program funds are managed and disbursed through a third-party financial services platform provided by Odyssey.22 This platform creates a digital wallet for each student and an online marketplace where parents can directly pay approved schools, service providers, and vendors for qualified expenses.30 This system of direct payment, rather than reimbursement, is a key administrative feature designed for efficiency and fraud prevention.9

The program permits a wide range of qualified education expenses, empowering parents to unbundle educational services.4 The major categories include:

• Tuition and Fees: At participating private schools, accredited community colleges, postsecondary institutions, or approved nonpublic online learning programs.31
• Curriculum and Materials: Including required textbooks, workbooks, and complete curricula for various subjects, which is particularly vital for homeschooling families.31
• Tutoring Services: For core academic subjects, provided by educators who are certified by the Georgia Professional Standards Commission.20
• Therapeutic Services: Fees for services from licensed physicians or therapists, covering occupational, behavioral, physical, or speech-language therapies.9
• Transportation: Up to a maximum of $500 per year for fee-for-service transportation to and from an eligible school or service provider. This is the only expense category eligible for direct parental reimbursement.8

Spending Restrictions and Price Caps

To prevent the misuse of public funds, the program's regulations include highly specific restrictions and price caps, particularly for technology and other potentially dual-use items. These rules provide clear guardrails for parental spending.

• Technology Caps: Purchases of computer hardware are strictly limited. The price cap for a new or refurbished laptop is $1,000, while desktops and tablets are capped at $500. Families are restricted to purchasing one device across these categories every one to two program years. Peripherals also have strict limits, including monitors ($200), printers ($200), keyboards ($75), and webcams ($50).31
• Prohibited Expenses: The rules explicitly prohibit the use of scholarship funds for several categories of spending. Funds cannot be used for any services provided by a student's family members or businesses they own. They also cannot be used to cover late fees owed to schools or providers, or for any personal, non-education-related expenses.33 Furthermore, fees or donations with a religious purpose are explicitly excluded from being paid with program funds.31

The table below outlines the primary categories of allowable expenses and highlights key spending limitations.

Building the Guardrails: Accountability and Oversight

A defining characteristic of Georgia's "second-generation" ESA is its comprehensive, multi-pronged accountability structure. The program's enabling legislation was written with robust guardrails designed to ensure academic transparency, financial integrity, and a baseline of quality among participating providers, preemptively addressing the most common criticisms leveled against school choice programs.

Academic and Provider Accountability

To ensure academic transparency, the program mandates annual testing for all participating students. Each student must take either a nationally norm-referenced test or a Georgia state-wide assessment that measures academic progress in mathematics and language arts.2 GESA provides families and schools with a list of pre-approved standardized tests, including well-known assessments like the ACT, SAT, Iowa Assessments, NWEA MAP, and TerraNova, offering flexibility while still requiring a consistent measure of student performance.34

The program also establishes strict eligibility requirements for schools and other educational providers wishing to receive scholarship funds. These requirements act as a barrier to entry for potentially unstable or low-quality operators.

• Accreditation: Private schools must be accredited, or be in the process of becoming accredited, by an agency recognized and approved by GESA.2
• Fiscal Soundness: Schools must demonstrate financial stability. This can be done by showing they have been in operation for at least one full school year or, if they are newer, by submitting a formal Independent Auditor's Report prepared by a certified public accountant.2
• Legal Compliance: All participating schools must comply with federal anti-discrimination provisions (42 U.S.C. Section 2000d) and all applicable state health and safety codes.2

Financial Auditing and Public Reporting

The program's financial integrity is protected by multiple layers of auditing and reporting. GESA is legally required to conduct random audits of individual student accounts every year to detect and deter misspending.11 In addition, the state's Department of Audits and Accounts is mandated to perform a comprehensive audit of the entire Promise Scholarship program on an annual basis. The law gives the program teeth, stipulating that cases of serious or fraudulent misuse of funds may be referred to the Georgia Attorney General for investigation and potential prosecution.11

Finally, participating schools are subject to annual public reporting requirements. Each year, schools must submit a report to GESA that includes aggregate student test results from the mandated assessments, student enrollment dates, and, beginning in 2029, on-time graduation rates for participating students.11 This combination of mandatory testing, provider vetting, and multi-layered auditing creates a comprehensive accountability framework designed to build and maintain public trust in the program's stewardship of taxpayer dollars.

A Tale of Two Models: Georgia's Targeted Approach vs. Arizona's Universal Experiment

Georgia's Promise Scholarship and Arizona's Empowerment Scholarship Account program represent two divergent evolutionary paths for ESAs in the United States. While both empower families with public funds for private educational choices, their underlying philosophies, architectural designs, and resulting impacts are profoundly different. Arizona's program embodies a strategy of universal access and rapid market disruption, while Georgia's reflects a deliberate philosophy of controlled access, targeted intervention, and fiscal containment. A direct comparison of the two models illuminates the critical policy trade-offs involved in designing a school choice program.

• Scope and Eligibility: The most fundamental difference lies in who can participate. Arizona's program is universal, making all of the state's more than one million K-12 students eligible for an account.5 Its model is an open door, designed to maximize parental choice. In stark contrast, Georgia's program is highly targeted. Its multi-layered eligibility criteria—requiring residence in a low-performing school zone and prior public school enrollment—act as a narrow funnel, restricting access to a small, specific subset of the state's student population.9
• Scale and Fiscal Impact: This difference in scope leads to a dramatic divergence in scale and cost. Arizona's program is an uncapped entitlement; its budget is demand-driven and has exploded from $189 million before universal expansion to a projected $1.037 billion, serving over 100,000 students.5 Georgia's program is a capped appropriation; its budget is fixed by the legislature at $141 million, limiting its reach to a maximum of roughly 21,700 students.7 In Arizona, the program's cost is a variable outcome of market forces; in Georgia, it is a fixed input controlled by lawmakers.
• Data and Demographics: The two states' approaches to data collection have created vastly different levels of transparency. Arizona's enabling legislation does not require the state to collect or report data on participant income or race, creating a "data vacuum".5 This has fueled a contentious "battle of the models," with competing think tanks using ZIP-code analysis to argue whether the program primarily benefits affluent or middle-income families.5 Conversely, Georgia's application process, which requires income documentation for prioritization, has produced clear, official demographic data from its very first year. This data shows the inaugural cohort is majority-minority and heavily weighted toward younger students, providing a factual basis for evaluating the program's equity and reach.26
• Oversight and Accountability: The programs' growth trajectories have had significant consequences for oversight. In Arizona, the program's exponential and under-resourced expansion overwhelmed its administrative capacity, creating a severe "oversight deficit" with just a handful of auditors responsible for nearly 100,000 accounts.5 Georgia, benefiting from this lesson, built a robust, multi-layered accountability framework directly into the enabling legislation, including mandatory annual testing, provider vetting for fiscal soundness, and multiple levels of auditing.11 Arizona's oversight has been reactive and under-resourced; Georgia's was designed to be proactive and comprehensive from the start.

The table below distills these critical differences, providing a side-by-side comparison of the two models.

Concluding Analysis and Forward-Looking Implications for Georgia

The Georgia Promise Scholarship Act stands as a uniquely methodical and fiscally conservative entry into the national ESA landscape. Its architecture is a study in deliberate trade-offs, successfully containing costs and targeting a specific student population, but at the clear expense of broader access. By observing the challenges faced by first-generation universal programs, Georgia has crafted a "second-generation" model that prioritizes stability over scale, and control over market disruption. The initial data from its launch confirms the program is reaching its intended demographic—primarily younger, minority students from designated low-performing school zones—and that demand for such educational alternatives is significant, far outstripping the program's limited capacity.

As the program moves beyond its inaugural year, its design raises several critical questions that will define its future trajectory and ultimate impact.

1. The Sustainability of the Cap: The most pressing political question is whether the $141 million budget cap will remain in place. With thousands of families already turned away in the first application cycles, the program's very design creates a natural and growing constituency of interested but ineligible parents. This will inevitably generate political pressure on lawmakers from school choice advocates to expand the program's funding and, potentially, its eligibility criteria.

2. Market Response and Provider Capacity: A key long-term question is how the private school and educational services market in Georgia will evolve in response to this new, albeit limited, stream of funding. Will the infusion of $141 million incentivize the creation of new schools or the expansion of existing ones, particularly in or near the low-performing zones where eligible students are concentrated? Or is the funding level too modest to spur significant market changes?

3. Demonstrating Long-Term Impact: The program's robust accountability framework, particularly the mandatory annual testing, will produce a rich dataset on participant outcomes over time. The central question for the program's long-term viability will be whether this data demonstrates a clear and positive impact on the academic trajectories of its students. The ability to show measurable educational improvements will be crucial for justifying the program's continuation and any potential expansion.

Ultimately, the success of the Georgia Promise Scholarship will not be measured by how many students it eventually serves, but by its ability to deliver meaningful educational improvements for its narrowly defined target population while operating within its strict fiscal and accountability guardrails. It serves as a critical national case study in controlled, incremental school choice policy, offering a clear alternative to the universal models that have dominated the recent policy debate. Its evolution will provide invaluable lessons for other states grappling with how to balance the promise of parental choice with the imperatives of fiscal responsibility and public accountability.

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