New Hampshire ESA Program

# New Hampshire's Grand Experiment: A Comprehensive Analysis of the Education Freedom Account Program and its Transition to Universal Choice

Section I: The Architectural Evolution of New Hampshire's EFA Program

New Hampshire's Education Freedom Account (EFA) program represents a significant and rapidly evolving experiment in American K-12 education policy. Its trajectory from a targeted, means-tested program into a universal entitlement has been swift, establishing a unique administrative framework and raising fundamental questions about funding, equity, and public accountability. Understanding this architectural evolution is essential for contextualizing the program's current enrollment dynamics, fiscal debates, and administrative challenges.

Legislative Genesis (2021): A Targeted Intervention

The EFA program was formally established in 2021, enacted through Senate Bill 130 and incorporated into the state budget.1 The program's legal foundation is codified in the New Hampshire Revised Statutes, Title XV, Chapter 194-F.3 In its initial form, the program was a targeted intervention aimed at expanding educational options for lower- and middle-income families. Eligibility was restricted to households with annual incomes at or below 300% of the Federal Poverty Level (FPL).1 This threshold was subsequently raised to 350% of the FPL, expanding access to a broader segment of the population but still maintaining its means-tested character.6 Proponents framed these initial income caps not as a permanent feature defining the EFA as an anti-poverty initiative, but as a pragmatic, temporary measure to manage initial demand, ensure a successful rollout, and limit the immediate fiscal impact on the state's Education Trust Fund.4

The Universal Leap (2025): A Paradigm Shift

The program's defining moment arrived in June 2025 with the signing of Senate Bill 295\. This landmark legislation eliminated the income threshold entirely, transforming the EFA from a targeted support mechanism into a universal program accessible to all K-12 students in New Hampshire.10 This policy shift aligned New Hampshire with a growing number of states embracing universal school choice.

Recognizing the potential for a surge in demand, the legislation incorporated several key structural features. It established a statewide enrollment cap of 10,000 students for the 2025-2026 school year.11 However, this cap is not static. The law includes an automatic escalator clause: if applications in any year reach 90% of the existing limit, the cap for the following year automatically increases by 25%.11 This design feature is more than a simple limit; it is a built-in growth engine, suggesting a legislative intent for the program to scale rapidly in response to demand, thereby automating a process of expansion that would otherwise require a contentious annual political debate.

To manage enrollment should demand exceed the cap, the law established a clear priority system for admissions. The order of priority is: (1) currently enrolled EFA students, (2) siblings of current students, (3) students with disabilities, and (4) students from families with incomes at or below the previous 350% FPL threshold.6

Administrative Structure: A Public-Private Partnership

The administrative architecture of the EFA program is a unique public-private partnership that bifurcates responsibility. The New Hampshire Department of Education (NHED) retains high-level statutory oversight, responsible for publishing annual reports, fact sheets, and fiscal analyses related to the program's performance.15

However, the crucial day-to-day operational responsibilities are outsourced to a single, third-party, non-profit "scholarship organization".3 This includes managing the entire lifecycle of a participant's interaction with the program: processing applications, verifying eligibility, approving vendors and educational expenses, and disbursing funds to families.18 Since the program's launch in August 2021, this role has been filled by the Children's Scholarship Fund New Hampshire (CSFNH), a New York-based nonprofit, under a sole-source contract with the state.2 Parents and families interact directly with CSFNH and manage their EFA funds through a third-party digital platform, ClassWallet.20

This decision to delegate core administrative functions to a private, out-of-state entity creates a fundamental structural tension between public funding and public accountability. It establishes an information asymmetry where the state agency provides the funds and holds ultimate responsibility, but the private contractor possesses the primary, granular data on program operations. This architectural choice is the root cause of the significant oversight and transparency challenges that have become a central point of contention in the program's implementation.

Section II: Financial Framework and the Flow of Funds

The financial architecture of New Hampshire's EFA program dictates the source of its funding, the value of its grants, and its overall cost to the state. The specific mechanics of the funding formula are critical, as they directly influence the program's attractiveness to families, its competitive posture relative to public schools, and the central arguments in the debate over its net fiscal impact.

Funding Source: The Education Trust Fund

EFA grants are funded directly from New Hampshire's Education Trust Fund.3 This is the same pool of money, derived from sources including statewide property taxes, business taxes, and lottery funds, that is used to finance the state's obligation to its public district and charter schools.18 This arrangement places the EFA program in direct financial competition with the traditional public education system. Critics contend that this model diverts "scarce funding" away from public schools, placing additional strain on a trust fund that has historically been insufficient to cover the full constitutional cost of an adequate public education.7

Award Calculation Formula

The value of an individual EFA grant is explicitly tied to the state's primary school funding formula.14 Each grant is composed of two potential parts: the per-pupil "base adequacy" aid amount, and any applicable "differentiated aid" that the student would have generated for a public school district based on their specific needs.8

For the 2025-2026 school year, the base adequacy grant is set at a minimum of $4,265.64.18 However, due to the inclusion of differentiated aid for many participants, the program-wide average award is higher. In the 2024-2025 school year, the average grant was approximately $5,204.14 Following the universal expansion, the average award for the newly eligible population is projected to be lower—around $4,419—as fewer of these higher-income families will qualify for income-based differentiated aid.25 This direct link between the EFA and public school funding formulas creates a fiscal feedback loop; any legislative action to increase per-pupil adequacy aid for public schools will automatically and simultaneously increase the cost of the EFA program.

Differentiated Aid Categories

The program provides significant additional funding for students with specific, legally defined needs, which can substantially increase the value of their grants. These aid amounts are additive, allowing families of students with multiple needs to construct a more robust educational program. The key categories for the 2025-2026 school year include:

• Free or Reduced-Price Lunch (FRL) Eligibility: An additional $2,392.92 for students from low-income households.27
• Students with Disabilities: An additional $2,184.84 for students with an Individualized Education Program (IEP) or a qualifying determination from a licensed medical professional.28
• English Language Learners (ELL): An additional $832.32 for students requiring language support services.27

Utilization of Funds

Parents are empowered to use EFA funds for a broad array of approved educational expenses. These include private school tuition and fees, private tutoring, online learning programs, textbooks and curriculum, educational therapies for students with disabilities, fees for standardized tests like the SAT or AP exams, and transportation costs.5

A crucial feature of the program's financial design is the ability for unused funds to roll over from one quarter to the next and from one year to the next, remaining in the student's account until they graduate from high school.20 This provision transforms the EFA from a simple annual tuition subsidy into a true "Education Savings Account." While providing valuable flexibility for families to save for future educational needs, it also creates a significant and growing long-term fiscal liability for the state. As thousands of accounts accumulate unspent balances, this creates a multi-million-dollar "shadow budget" of obligated state funds that exists outside the normal annual appropriations cycle, a fiscal nuance often overlooked in debates focused on immediate, year-over-year costs.

Section III: Enrollment Trajectory and the Universal Leap

The growth trajectory of the EFA program provides a clear narrative of its evolution from a niche service into a major component of New Hampshire's K-12 landscape. The dramatic surge in participation following the 2025 universal expansion reshaped the program's scale and scope, while the underlying data on who these new participants are—specifically, whether they are "switching" from public schools—has become the central pivot point of the entire fiscal and policy debate.

Pre-Universal Enrollment (2021-2024)

As a means-tested program, the EFA saw steady and rapid growth in its initial years. Enrollment began with 1,635 students in the 2021-2022 school year, grew to 3,025 in 2022-2023, and reached 4,211 at the start of the 2023-2024 school year.32 By September 2024, participation had climbed to 5,321 students.33 During this period, the program was recognized for having the highest per-capita growth rate of any school choice program in the nation, indicating strong demand even within its income-restricted framework.35

The Post-Universal Surge (2025)

The removal of the income cap in June 2025 acted as a catalyst for an immediate and unprecedented surge in applications. The program's 10,000-student enrollment cap was reached within a single month, demonstrating a massive latent demand for subsidized private education, particularly among families who were previously ineligible due to income.37 This rapid absorption of demand immediately triggered the automatic escalator clause, raising the enrollment cap for the 2026-2027 school year to 12,500 students.11 Early reports indicated that approximately 11,000 applications were received for the 10,000 available slots, necessitating the creation of a waitlist.19 This was not merely growth; it was the opening of a floodgate, signaling a fundamental and permanent shift in the state's educational marketplace.

The "Switcher Rate": The Fulcrum of the Debate

The most critical key performance indicator for understanding the program's systemic and fiscal impact is the "switcher rate"—the percentage of EFA participants who were previously enrolled in a New Hampshire public school. This metric determines whether the program primarily generates new costs or reallocates existing funds more efficiently. The data on this point is contested.

• Official State Data: The New Hampshire Department of Education's 2024-2025 Fact Sheet reports a cumulative total of 1,925 "switchers" out of 5,321 total participants. This yields a cumulative switcher rate of 36%.40
• Analysis of New Enrollees: An analysis by the advocacy group Reaching Higher NH, using the same state data, focuses specifically on the 1,527 new students who enrolled in 2024\. Of this group, only 493 came from a public school, yielding a switcher rate for new participants of just 32%.18 This implies that 68% of new families joining the program were already utilizing private or homeschool options and paying for them out-of-pocket.
• A Competing Model: In contrast, an analysis by the pro-school choice organization EdChoice argues that the official state methodology undercounts switchers. Their model, which adjusts for students who were in public school in a prior year or are new kindergarteners, estimates the true switcher rate is closer to 45%.41

This low official switcher rate of 32-36% provides the core evidence for the "Deficit Driver" fiscal model discussed in Section V. The logic is straightforward: if the vast majority of EFA recipients (approximately two-thirds) were not enrolled in public schools to begin with, the state was not previously funding their education. Therefore, every EFA grant awarded to these "non-switchers" represents an entirely new expenditure from the Education Trust Fund. The cost savings generated by the minority of students who do switch from the public system are mathematically insufficient to offset the large new costs associated with the majority who do not. This is the fundamental basis for the argument that the program functions as a net drain on the state budget.

Section IV: The Participant Profile: A Shifting Demographic Landscape

A central question in the debate over any universal school choice program is a simple one: who uses it? The answer is critical to assessing the program's equity and its alignment with its purported goals. In New Hampshire, the data before and after the 2025 universal expansion paints a stark picture of a program that has undergone a fundamental demographic transformation, shifting from a resource for low-to-middle income families to one that now appears to predominantly benefit more affluent households in specific geographic areas.

Pre-Universal Demographics (Income-Limited)

Prior to June 2025, the EFA program was, by design, a means-tested initiative. With an income cap set at 350% of the FPL, it was explicitly targeted at lower- and middle-income families.34 Data from the 2024-2025 school year reflects this focus. Of the 5,321 students enrolled, 1,974 (37%) were eligible for Free or Reduced-Price Lunch (FRL), a key indicator of low household income.18 Additionally, 377 students, or 7% of the total, were identified as receiving special education services.18

Post-Universal Demographics: A Shift Toward Affluence

The universal expansion immediately and profoundly altered this demographic profile. An analysis of the initial 10,000-student cohort in the 2025-2026 school year reveals a dramatic shift away from the program's original constituency.39

• Income: The proportion of low-income (FRL-eligible) students plummeted from 37% of participants pre-expansion to just 15% post-expansion. This participation rate is now significantly lower than the 24% FRL rate across the state's public schools, indicating the program serves a wealthier population than the public system it is meant to provide an alternative to.39
• Special Education: The share of students receiving special education services also declined, falling to 7.8% of EFA participants, a figure well below the approximately 20% of students who qualify for such services in public schools.39
• Higher-Income Growth: Conversely, the number of students receiving only base adequacy aid—meaning they are not low-income, disabled, or English language learners—surged from 3,118 to an estimated 7,715.27

This is not an incremental change; it is a complete inversion of the program's user base. The data strongly suggests that the universal expansion did not simply broaden the existing program but transformed its primary function. What began as a program aiding low-to-middle income families has, in practice, become a mechanism that predominantly subsidizes the educational choices of more affluent households. This mirrors the "handout to the wealthy" critique that has been a central feature of the debate over Arizona's pioneering universal ESA program.42

Geographic Distribution: An Urban/Suburban Concentration

The demographic shift is also geographic. The data shows a stark divergence in the program's uptake between the state's wealthiest communities and its poorer, more rural areas.39

An analysis comparing participation before and after the universal expansion found that a group of eight wealthy suburban towns (including Bedford, Bow, Hanover, and Windham) saw EFA enrollment explode by 221%. In stark contrast, a group of eight poorer, more rural communities saw a negligible increase of only 20%.39 For example, participation in the affluent town of Bedford jumped from 39 students to 152, while in the less wealthy community of Newport, enrollment was flat.39

This geographic disparity reveals a potential "access desert" for educational choice. New Hampshire is a predominantly rural state with urban and suburban pockets.43 The concentration of private schools and other educational service providers in wealthier suburban areas means that even with a universal financial grant, families in remote, rural communities may lack viable, accessible options to use it. The policy provides financial access but does not address the underlying geographic and logistical barriers to entry, resulting in a program that is universal in name but inequitable in practice.

Section V: The Fiscal Impact: A Dueling Analysis

The fiscal impact of the EFA program is the most contentious and politically charged aspect of the policy debate. The program's exponential growth in cost has led to a high-stakes battle over its effect on the state budget and the Education Trust Fund. Two diametrically opposed narratives have emerged, each supported by its own analytical model. Understanding these competing models is essential, as the difference between them is not merely an accounting dispute but a fundamental disagreement over how to calculate the costs and benefits of a large-scale school choice initiative.

Gross Program Cost

There is general agreement on the program's top-line, or gross, cost. Total program expenditures grew from approximately $8.1 million in its first year (FY22) to an estimated $27.7 million by FY25.34 With the universal expansion to 10,000 students, the projected gross cost for FY26 has surged to between $50 million and $52 million.18 This figure significantly exceeds the amounts allocated in the state budget, which were closer to $39 million to $47 million, creating a budget shortfall for the program.13 The debate, however, is not about this gross figure but about the net cost to the state after accounting for offsetting savings.

Model 1: The Net Savings Model (Proponents: Josiah Bartlett Center, EdChoice)

This model, advanced by program proponents, argues that the EFA program is largely revenue-neutral or may even produce a net savings for state and local taxpayers.

• Core Premise: The central argument is that the program saves taxpayers money because the average EFA grant (e.g., \~$5,200) is substantially less than the average total per-pupil expenditure in a public school, which exceeds $20,000.1
• Methodology: This model's calculations are driven by the "switcher" population. Every time a student leaves a more expensive public school to use a less expensive EFA, the state avoids the marginal cost of educating that student. This avoided cost is treated as a direct saving that more than offsets the cost of the EFA grant.
• Findings: An analysis by EdChoice of the 2023-24 school year, when the program was still means-tested, calculated a net fiscal benefit of $8.7 million for state and local taxpayers combined.41 A forward-looking analysis of the universal expansion by the Josiah Bartlett Center for Public Policy projected that a "switchers-only" version of the program would generate net state savings of $5.6 million in its second year. Even a fully universal model was projected to have only modest net costs to the state ($5 million) while generating significant savings ($22.7 million) for local taxpayers.47

Model 2: The Deficit Driver Model (Critics: Reaching Higher NH, InDepthNH.org)

This model, championed by critics, presents a starkly different picture, concluding that the program is a significant new drain on state resources.

• Core Premise: This analysis focuses on the large new financial obligation the state has taken on to subsidize the education of students who were never enrolled in the public system to begin with—the "non-switcher" population.
• Methodology: This model is driven by the low official "switcher rate" of 32-36%.18 It argues that while some savings are generated from the minority of students who switch, these savings are dwarfed by the massive new cost of funding the majority of participants who were previously in private or homeschool settings. Every dollar spent on these students is a new expenditure from the Education Trust Fund.
• Findings: Reaching Higher NH projects the FY26 gross cost will be approximately $50 million, nearly double the prior year and $10 million over budget.28 The analysis frames the program as a primary driver of shortfalls in the Education Trust Fund, diverting tens of millions of dollars to subsidize private education for families the state was not previously responsible for funding.13

The core of this billion-dollar debate in Arizona is being replicated on a smaller scale in New Hampshire. The fundamental disagreement lies not in the raw numbers but in the analytical framework. The "Net Savings" model employs a systems-thinking approach, viewing the EFA and public school systems as interconnected, where a cost in one system creates a larger saving in the other. The "Deficit Driver" model uses a siloed accounting approach, treating the EFA budget as a standalone cost center and viewing spending on non-switchers as a pure liability.

Complicating the "Net Savings" calculation is a provision in state law known as the EFA Phase-Out Grant. This rule requires the state to compensate public school districts for students who switch to an EFA, paying them 50% of the adequacy grant in the first year and 25% in the second year after a student leaves.12 This grant is a direct cost to the state that is incurred because of a switcher, effectively reducing the net savings that student generates. The very existence of this provision is a tacit legislative acknowledgment of the financial strain that student transfers can cause to public districts, lending credibility to a key argument made by program critics.

Section VI: Administration and Accountability: The Oversight Deficit

While public debate often centers on the high-level fiscal and demographic impacts of the EFA program, a critical and growing concern lies in its operational reality. The program's unique public-private administrative structure has created significant oversight challenges, culminating in the reported inability of state auditors to access primary program data and raising serious questions about public accountability for the use of taxpayer funds.

A Bifurcated and Contentious Structure

The program's administrative model creates a structural division of responsibility. The New Hampshire Department of Education holds the statutory authority and the contract, but the third-party administrator, Children's Scholarship Fund New Hampshire, holds the detailed operational data, including applications, eligibility documentation, and expenditure records.18 This has led to a breakdown in transparency, with critics asserting that crucial data on program implementation is treated as the "sole property of the contractor" and can be withheld from public and legislative scrutiny at the contractor's discretion.18

The Impeded Performance Audit

This structural flaw came to a head in 2024\. A 2022 state law (HB 1135\) explicitly required the Office of the Legislative Budget Assistant (LBA)—the non-partisan auditing arm of the state legislature—to conduct a comprehensive performance audit of the EFA program.50 The audit was mandated to review participant eligibility, program expenditures, and the recovery of improper payments.

However, the LBA reported to the legislature that the audit would be severely limited because it could not access "most documents pertaining to the EFA program".50 The NHED, supported by a legal opinion from the state Attorney General's office, argued that the LBA's authority was limited to auditing the department's oversight of its contract with CSFNH. They contended that the LBA had no legal authority to directly access the primary program data held by the private contractor.50 This created a jurisdictional standoff that effectively blocked the LBA from examining the core operational functions it was legally required to audit. As a result, no comprehensive performance audit of the EFA program by the LBA has been published.52 This inability of the state's own legislative auditors to conduct a full performance audit represents a critical failure of public governance, establishing a precedent where state-funded programs operated by private entities can be shielded from the highest level of state oversight.

Evidence of Administrative Shortfalls

While a full audit was impeded, a limited compliance review conducted by the NHED itself in 2023 uncovered evidence of concrete administrative problems.54 The review examined a small sample of just 50 applications from the program's first two years and found significant errors in 12 of them—an error rate of 24%. These errors resulted in over $103,000 in potentially ineligible funds being disbursed. CSFNH was required to file corrective action plans and reimburse the state for over $18,000 in confirmed mispayments.54

The identified issues included:

• Improper income verification, such as using net income instead of the legally required gross adjusted income.
• Clerical errors that led to large overpayments to families.
• Misapplication of the rules for awarding differentiated aid.54

The discovery of a 24% error rate in a small, random sample is a major red flag. It suggests that the administrative problems are not merely theoretical but are real and quantifiable. If such a rate were extrapolated across the program's entire budget, it would imply that millions of dollars in taxpayer funds could be at risk of being misspent. This finding validates the concerns that motivated the legislature's call for a full audit and elevates the issue from a procedural dispute to a serious matter of fiscal stewardship.

Section VII: Concluding Analysis and Forward-Looking Implications

New Hampshire's journey with the Education Freedom Account program has established it as a key national case study in the rapid implementation of universal school choice. The program's evolution provides a rich, complex, and cautionary tale, offering profound lessons for policymakers, researchers, and advocates. The analysis reveals a core tension: New Hampshire has successfully created a large-scale, high-demand educational marketplace, yet its growth has dramatically outpaced the development of the fiscal and administrative infrastructure required to manage it effectively and maintain long-term public trust.

Synthesis of Findings

The rapid adoption of the universal EFA, surging from just over 5,000 students to a capped 10,000 in a single month, demonstrates a significant latent demand for educational alternatives, particularly among higher-income families. However, this success in market creation has been shadowed by significant challenges. The program's expansion precipitated a fundamental shift in its user base, moving from a program primarily serving low-to-middle income families to one that now predominantly benefits more affluent, suburban households. A polarized and unresolved debate over the program's net fiscal impact persists, driven entirely by competing methodologies for accounting for savings from public school "switchers" versus new costs from "non-switchers." Most critically, the program's unique public-private administrative architecture has created a significant oversight deficit, shielding core operational data from state auditors and undermining public accountability for tens of millions of dollars in taxpayer funds.

Comparison to the Arizona Proving Ground

New Hampshire's experience closely mirrors that of Arizona, the nation's first state with a universal ESA, in several key respects: explosive enrollment growth following universal expansion, a contentious debate over demographics (affluent subsidy vs. middle-class empowerment), dueling fiscal impact models, and significant administrative challenges stemming from rapid, under-resourced scaling.42

However, there is a crucial difference in the source of the oversight problem. In Arizona, the challenge is primarily one of capacity; the state's Department of Education is chronically understaffed and overwhelmed by the sheer volume of transactions in a billion-dollar program.42 In New Hampshire, the problem is structural and legal. The state's decision to outsource core administration and, consequently, data ownership to a private third party has created a legal barrier that has, to date, prevented the state's own legislative auditors from conducting a full and proper review.50

Forward-Looking Implications and Recommendations

For other states considering or implementing universal ESA programs, New Hampshire's experience offers several critical lessons that can help avoid similar pitfalls.

For New Hampshire Policymakers:

1. Mandate Data Transparency in Statute: The legislature should amend RSA 194-F to explicitly define all data generated through the administration of the EFA program as public data. The statute must require any third-party administrator to provide all program-level data, including anonymized participant applications and expenditure details, to the Legislative Budget Assistant and NHED upon request.

2. Resolve the Fiscal Debate with a Standardized Model: The legislature should mandate a single, transparent methodology for calculating the program's net fiscal impact. This model must be used by all state agencies in their reports and should specify how switchers, non-switchers, and provisions like the Phase-Out Grant are to be accounted for.

3. Strengthen State Oversight Capacity: Rather than relying solely on the administrator's self-reporting and limited compliance reviews, the state should provide the NHED and the LBA with the explicit authority and resources to conduct their own regular, rigorous, and unrestricted audits of the third-party administrator's performance and data.

For Other States:

1. Design for Accountability from the Outset: States must build robust transparency and auditing requirements directly into any ESA-enabling legislation. The law must explicitly address data ownership and guarantee unrestricted access for state auditors, particularly when using third-party administrators.

2. Anticipate the Demographic Shift: The experiences of both Arizona and New Hampshire demonstrate that universal programs will, by their nature, be heavily utilized by families who can already access or afford private options. Policymakers must be transparent about this reality rather than framing universal programs solely as tools for low-income equity.

3. Model the Full Fiscal Impact of Non-Switchers: Any credible fiscal analysis of a universal ESA proposal must account for the high percentage of non-switchers that will inevitably materialize. This population represents the largest and most significant new cost to the state and is the primary driver of the program's impact on the state budget.

In a policy environment characterized by rapid change and contested facts, New Hampshire's EFA program underscores the urgent need for robust data, transparent reporting, and an administrative capacity that is equal to the scale of the promises being made. While a well-designed program can be a powerful tool for families, its long-term success and political viability depend entirely on building a foundation of fiscal responsibility and public accountability.

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