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Texas ESA Program

Texas Education Freedom Accounts (TEFA)

UniversalLaunched: 2026Data Quality: Good

Key Program Statistics

Total Enrollment
479,500
FY2027 (2026-27 School Year - LBB Projection)
Average Award
$10,800
per student/year
Program Budget
$4600M
FY2030 (LBB Projection)
Switcher Rate
5%
FY2027 (LBB Year 1 Projection)

What is the Texas ESA Program?

Legislative Framework

Statutory Citation:
Texas Education Code, Chapter 29, Subchapter J (Senate Bill 2)
Administering Agency:
Texas Comptroller of Public Accounts
Year Enacted / Launched:
2025 / 2026
Financial Platform:
Odyssey (selected as Certified Educational Assistance Organization/CEAO for financial management)

Eligibility & Access

Eligibility Scope:
Universal
Who Can Apply:
Universal for all K-12 Texas students who are U.S. citizens/legal residents and eligible for public school. Includes active-duty military children. NO income limits or prior public school requirements for basic eligibility. However, $1B budget cap in first biennium creates competitive lottery with 4-tier priority system heavily favoring disabilities + low-income.
Enrollment Cap:
479,500 students

How Has the Texas Program Evolved?

2023

Decades of Failed Attempts

Voucher legislation consistently blocked by bipartisan coalition of rural Republicans and Democrats

2024

Political Realignment

Gov. Abbott primary campaign targets anti-voucher Republicans; Several incumbents defeated

2025

SB 2 Passage

Senate Bill 2 passes: Universal ESA with $1B first-biennium cap; House 85-63, Senate 19-12

2026

Program Launch

Application portal opens early 2026 for 2026-27 school year

How is the Texas ESA Program Funded?

Funding Mechanism

Direct appropriation from Texas General Revenue Fund; $1 billion cap for first biennium (FY2026-27); Cap is expected to expire after the first biennium.

Award Calculation

Tiered: (1) Private school: 85% of statewide average per-student expenditure from state/local funds (~$10,800). (2) Students with disabilities with a recent IEP: Up to $30,000. (3) Homeschool: Flat $2,000.

Award Amounts by Category

CategoryAnnual Award
Private School Students (85% of statewide avg state/local expenditure, FY2026-27)$10,800
Students with Disabilities + Recent IEP (Maximum, FY2026-27)$30,000
Homeschool Students (Flat Rate, FY2026-27)$2,000

What Can Texas ESA Funds Be Used For?

Private school tuition and fees
Textbooks and curriculum
School uniforms
Online learning programs
Private tutoring
Educational therapies
Transportation to approved providers
School meals

How Many Students Use the Texas ESA Program?

Fiscal YearTotal StudentsGrowth
FY2025-26 (Current - Not Yet Launched)0
FY2030 (LBB Projection)707,000Infinity%
FY2027 (2026-27 School Year - LBB Projection)479,500-32.2%

Enrollment by Category (FY2027 (2026-27 School Year - LBB Projection))

Homeschool Students ($2K grant)
269,500
56% of total
Existing Private School Students
175,000
37% of total
Public School 'Switchers' to Private
24,500
5% of total
Homeschool 'Switchers' to Private
10,500
2% of total

What is the Texas ESA "Switcher Rate"?

The "switcher rate" measures the percentage of new ESA participants who came from public schools (vs. those already in private schools or homeschooled). This is critical for understanding fiscal impact.

Latest data for Texas: 5% switcher rate in FY2027 (LBB Year 1 Projection)

Fiscal YearSwitcher RateDefinition
FY2027 (LBB Year 1 Projection)5%The LBB projects only 24,500 of 479,500 total participants (5.1%) will be direct public school switchers in Year 1. NOTE: The LBB's fiscal model relies on a separate, crucial assumption that 70% of *new private school capacity* will be filled by public school switchers. The overall program switcher rate is low due to the massive projected influx of existing private and homeschool students.

Key Findings for Texas's ESA Program

  • 1

    Represents a major political breakthrough after decades of failed school choice legislation, achieved after a targeted primary campaign by Gov. Abbott against anti-voucher Republicans.

  • 2

    Projected to be the largest ESA launch in the nation, with the Legislative Budget Board (LBB) projecting 479,500 participants in its first year (2026-27).

  • 3

    Administered by the Comptroller of Public Accounts, not the Texas Education Agency, signaling a legislative focus on fiscal control over educational oversight.

  • 4

    Despite being a 'universal' program, a 4-tier lottery system heavily prioritizes students with disabilities and those from low-to-middle income families.

  • 5

    The LBB's entire fiscal model hinges on a critical, unproven assumption that 70% of new private school capacity will be filled by public school switchers.

  • 6

    Even with this optimistic assumption, the LBB projects a massive cost explosion, from the initial $1B cap to $4.6B annually by FY2030.

  • 7

    The largest projected cohorts are homeschoolers (56%) and existing private school students (37%), who represent entirely new costs to the state.

  • 8

    Features an unlimited rollover provision for unspent funds, creating a long-term, unfunded 'shadow budget' liability similar to Arizona's program.

What is the Fiscal Impact of Texas's ESA Program?

Analytical Disclaimer: The fiscal impact of ESA programs is actively debated. We present competing analyses transparently with source attribution, allowing you to understand the full methodological context.

Long-Term Savings via High Switcher Rate

Source: Texas Public Policy Foundation, Gov. Abbott Administration

The official LBB projection is based on a 70% switcher rate for new private school students, which will generate significant savings for the state's Foundation School Program over time. The 85% funding formula ensures the state saves 15% on every switcher. Polling shows broad, bipartisan public support for the program.

Unprecedented Budget Explosion

Source: Texas AFT, Raise Your Hand Texas

Even with the LBB's optimistic 70% switcher assumption, the program's gross costs are projected to explode from $1B to $4.6B by FY2030. The largest cohorts are homeschoolers and existing private school students, representing billions in new state spending. If the actual switcher rate is lower (like in other states), the fiscal impact will be catastrophic.

Data Sources for Texas

📊 Official State Sources

🔍 Independent Analysis

Last Updated: 2025-10-29 | Data Quality: Good

📚 Full Research Report: Texas ESA Program

Comprehensive analysis with legislative history, enrollment dynamics, fiscal impact debates, demographic analysis, and policy recommendations

📖 Full Texas ESA Research Report (Click to Collapse)

Report Table of Contents

  • • Legislative Architecture & Evolution
  • • Financial Framework & Funding
  • • Enrollment Trends & Growth Analysis
  • • Switcher Rate Analysis
  • • Participant Demographics
  • • Fiscal Impact Debate (Both Sides)
  • • Administrative Structure
  • • Accountability & Oversight
  • • Key Findings & Conclusions
  • • Policy Recommendations

About This Report: This comprehensive analysis was compiled from official state sources, legislative documents, and independent research organizations. All data points are verified and cited. Competing fiscal and demographic analyses are presented transparently with full source attribution.

Report available in our research reports directory:/research-reports/texas

# The Texas Experiment: A Comprehensive Analysis of the Nation's Newest Universal Education Savings Account Program

Section I: The Legislative Genesis of the Texas Education Freedom Accounts

The passage of Senate Bill 2 (SB 2\) by the 89th Texas Legislature marks a paradigm shift in the state's education policy, culminating a contentious, decades-long political battle over school choice.1 The resulting program, formally named the Texas Education Freedom Accounts (TEFA), establishes the state's first private school choice initiative. Set to launch for the 2026-2027 school year, it is poised to be one of the largest "day-one" universal Education Savings Account (ESA) programs in the nation.3 The program's final design is a testament to a series of hard-fought political compromises, meticulously crafted to overcome historical opposition from a powerful coalition of public school advocates and, most notably, rural legislators.2

The Political Crucible: From Stalemate to Landmark Legislation

For years, voucher-style legislation consistently failed in the Texas House of Representatives, blocked by a durable bipartisan coalition of rural Republicans and urban Democrats.2 This coalition was primarily motivated by concerns that diverting public funds to private schools would harm local public school districts, which often serve as the largest employers and central hubs of community life, particularly in rural areas.8

The political landscape began to shift dramatically following the 2023 legislative sessions. Governor Greg Abbott elevated school choice to a top-tier legislative priority, strategically tying its passage to a broader, popular education funding bill that included teacher pay raises. Despite this maneuver, the effort failed during a special session when an anti-voucher amendment to the omnibus bill passed the House by a decisive 84-63 vote, demonstrating the continued strength of the opposition coalition.2

This legislative defeat prompted a strategic pivot from the Governor's office. During the 2024 Republican primary elections, Governor Abbott and allied pro-choice advocacy groups targeted and successfully unseated several incumbent anti-voucher Republicans.7 This aggressive political campaign fundamentally altered the calculus in the House, eroding the opposition's majority and creating a viable path for passage in 2025\.

The final legislative push during the 89th Legislature in 2025 saw SB 2 successfully navigate both chambers, championed by key figures including Governor Abbott, Lieutenant Governor Dan Patrick, Senator Brandon Creighton, and Representative Brad Buckley.6 The bill passed the House with a vote of 85-63 and the Senate 19-12, reflecting the new political alignment.1 The high-stakes nature of the debate was underscored by a phone call from former President Donald Trump to lawmakers, urging them to support the bill—a significant application of political pressure.1

The Program's Core Architecture

The TEFA program was officially established by Senate Bill 2, which Governor Abbott signed into law on May 3, 2025\. While the law took effect on September 1, 2025, the program is scheduled to launch for students in the 2026-2027 academic year.4 The legislation amends the Texas Education Code, adding Subchapter J to Chapter 29 to codify the program's framework.14

A significant structural choice was the decision to assign administrative authority to the Texas Comptroller of Public Accounts rather than the Texas Education Agency (TEA), the state's traditional overseer of K-12 education.5 This assignment to the state's chief financial officer signals a legislative prioritization of fiscal control, auditing, and fraud prevention over direct educational oversight. It also effectively minimizes the role of the traditional education establishment, which has historically been a locus of opposition to voucher programs. This structure, however, may create future administrative challenges, as the TEA remains responsible for calculating the per-pupil funding that determines ESA values while the Comptroller is responsible for disbursing the funds.

For day-to-day operations, the Comptroller's office selected Odyssey, a New York-based financial services company, as the program's Certified Educational Assistance Organization (CEAO).5 Odyssey will manage the online parent portal, process applications, and administer the payment platform through which families will access funds and pay approved vendors. The implementation timeline is aggressive, with the parent application portal expected to open in early 2026 for the inaugural 2026-2027 school year.4

The final version of SB 2 reflects the political realities of its passage. While the primary victories of Governor Abbott neutralized some of the staunchest rural opposition, the bill still contains features designed as concessions. The initial $1 billion budget cap prevents uncontrolled growth in the first biennium, and the prioritization of public school "switchers" in the final lottery tier is a direct attempt to address concerns about the program primarily subsidizing existing private school students.4 These are not the features of a pure, free-market choice program; they are political guardrails built to secure a fragile legislative majority.

Table 1: Texas TEFA Program \- Core Architectural Features

Data FieldDescription
Program NameTexas Education Freedom Accounts (TEFA) 5
Statutory CitationTexas Education Code, Chapter 29, Subchapter J 14
Year Enacted / LaunchedEnacted 2025 / Launched 2026-2027 School Year 4
Administering AgencyTexas Comptroller of Public Accounts 5
Financial Management PlatformOdyssey 18
Eligibility ScopeUniversal 20
Key Implementation DatesApplication opens Early 2026; Funds available for 2026-27 school year 4

Section II: Financial Architecture and the Flow of Funds

The financial structure of the Texas Education Freedom Accounts program was carefully designed with both robust funding for participants and explicit fiscal controls to manage the state's initial financial exposure.

Funding Mechanism and Scale

The TEFA program is funded through a direct appropriation from the state's General Revenue Fund, the same source that funds most state agencies and public services.21 This places the program in direct competition for funding with other state priorities, including the public education system itself. For its inaugural biennium (FY 2026-2027), the 89th Legislature established a firm $1 billion budget cap.4 This cap serves as a critical fiscal guardrail, limiting both the program's initial enrollment and the state's financial liability. The enabling legislation suggests this cap will expire after the first biennium, setting the stage for future legislative battles over the program's expansion and long-term cost.12

The Award Calculation Formula

The value of a student's TEFA is determined by a tiered formula based on their educational setting and needs.

  • Private School Students: The standard award is set by statute at 85% of the statewide average per-student expenditure from state and local funds.5 The Texas Education Agency is tasked with calculating this precise figure each year. For the program's launch, this amount is estimated to be approximately $10,800.5 This formula directly links the ESA's value to public school funding levels, a feature intended to counter criticism that choice programs could become more generously funded than the public system they are meant to supplement.24
  • Students with Disabilities: Acknowledging the higher costs associated with specialized education, students with a qualifying disability and a recent Individualized Education Program (IEP) are eligible for a significantly larger award, up to a maximum of $30,000 per year.3 The Comptroller's office will determine the specific amount based on the services outlined in the student's IEP.25
  • Homeschool Students: Families choosing to homeschool are eligible for a smaller, flat-rate award of $2,000 per year to be used for curriculum and other approved expenses.5

This 85% funding formula provides a built-in argument for fiscal efficiency. Proponents can claim that for every student who switches from a public school, the state saves the remaining 15% of that student's funding.5 However, this state-level accounting may mask a more complex reality at the local level. A significant portion of a school district's budget consists of fixed costs, such as debt service, building maintenance, and core administrative staff. When a single student leaves, the district does not save the full average per-pupil amount; it primarily saves the marginal costs associated with that student, like supplies. The district's fixed costs must then be spread across a smaller student population, potentially creating a net financial strain that is not reflected in the state's top-line savings calculation.

Program Utilization: Allowable Expenses and Fund Management

The TEFA program gives parents considerable flexibility in directing their child's education. Funds can be used for a broad range of approved expenses, including private school tuition and fees, textbooks and curriculum, school uniforms, online learning programs, private tutoring, educational therapies, transportation to approved providers, and even school meals.4

Parents will manage these expenditures through a digital platform provided by Odyssey, which will feature a secure digital wallet for each student and an e-commerce marketplace of pre-approved vendors and service providers.5 A key feature of the program's design is that any unused funds may roll over from one year to the next for as long as the student remains eligible, with no statutory cap on the total amount that can be accumulated.4 This transforms the TEFA from a simple annual scholarship into a true "Education Savings Account."

This uncapped rollover provision, however, creates a significant and unfunded long-term liability for the state. As seen in Arizona's mature ESA program, unspent funds can accumulate into hundreds of millions of dollars held in thousands of private accounts.26 Each unspent dollar represents an obligated state liability that exists outside the normal biennial appropriations cycle. Over a decade, as tens of thousands of Texas families participate, this cumulative liability could grow into a substantial "shadow budget" that is not captured in the Legislative Budget Board's five-year fiscal projections, which focus on annual cash flow rather than long-tail obligations.

Section III: Projected Enrollment Dynamics and the "Switcher Rate"

While the Texas Education Freedom Accounts program is branded as universal, its initial implementation will be shaped by a combination of a firm budget cap and a multi-tiered lottery system designed to prioritize specific student populations.

Universal Eligibility Tempered by Prioritization

The program is open to all K-12 students in Texas who are U.S. citizens or legal residents and are eligible to attend a public school, including the children of active-duty military personnel.5 Crucially, there are no initial income limits or requirements for prior public school attendance to be eligible to apply.12

However, the $1 billion budget cap makes it impossible to serve every applicant if demand is high. To manage this, SB 2 establishes a lottery system with four distinct priority groups 4:

  • Priority Group 1: Children with a qualifying disability whose family income is at or below 500% of the Federal Poverty Guidelines (FPG).
  • Priority Group 2: Children from families with incomes at or below 200% FPG.
  • Priority Group 3: Children from families with incomes between 201% and 500% FPG.
  • Priority Group 4: All other eligible children.

This structure creates a "universal in theory, targeted in practice" program. The vast majority of initial spots are reserved for students with disabilities and those from low- to middle-income households. Higher-income families are relegated to the final priority group, which is further constrained by a rule capping its participants at 20% of the total program appropriation.12 A final, critical provision within this fourth group gives preference to students switching from a public school over those already enrolled in private school, a direct legislative attempt to engineer a higher "switcher rate".19

Official Enrollment Projections (Legislative Budget Board)

The official fiscal note for SB 2, prepared by the Legislative Budget Board (LBB), provides the state's only forward-looking enrollment projections. The LBB assumes the $1 billion cap will be reached in the first year of operation (FY 2027\) and projects a diverse mix of participants drawn from three distinct pools 21:

  • Current Public School Students ("Switchers"): The LBB projects 24,500 students will leave the public school system to use a TEFA to attend a private school in FY 2027\.
  • Current Homeschool Students: Projections show 269,500 homeschoolers applying for the $2,000 grant, with an additional 10,500 switching from homeschool to private school.
  • Current Private School Students: The LBB anticipates 175,000 students already enrolled in private schools will apply for a TEFA in the first year.

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

The "switcher rate"—the percentage of participants who were previously enrolled in a public school—is the single most important variable for determining the program's net fiscal impact. Each switcher generates a corresponding savings for the state under its primary K-12 funding mechanism, the Foundation School Program (FSP). The LBB's most critical assumption is that any new private school capacity spurred by the TEFA program will be filled by 70% former public school students and 30% former homeschool students.22

This 70% figure serves as the state's de facto projected "switcher rate" for new private school entrants. The entire fiscal debate between the "Deficit-Driver" and "Net Savings" models hinges on the financial impact of these projected 24,500 annual switchers versus the massive new costs incurred by subsidizing hundreds of thousands of existing private and homeschool students for the first time.

However, this projection of 24,500 switchers in the first year may be optimistic. The LBB's model assumes a rapid and responsive supply-side expansion of the private school market. In reality, building new schools and expanding existing ones is a slow, capital-intensive process. Early data from the launch of other universal programs, such as Iowa's, show very low initial switcher rates (e.g., 6.8%) as the program is first absorbed by the existing population of private school families.29 If the actual switcher rate in Texas is lower than the LBB's assumption, the FSP savings will be smaller, and the program's net cost to the state in its initial years will be significantly higher than projected.

Table 2: LBB Projected Enrollment and Participant Mix (FY2027-FY2030)

Participant Category & Fiscal DataFY2027 (Projected)FY2028 (Projected)FY2029 (Projected)FY2030 (Projected)
Public School "Switchers"24,50049,00073,50098,000
Homeschool "Switchers"10,50021,00031,50042,000
Existing Private School Participants175,000192,500211,750245,000
Homeschool Participants ($2k Grant)269,500296,450311,273322,000
Projected Gross Program Cost$1.0 Billion (Capped)$3.2 Billion$3.8 Billion$4.6 Billion
Projected FSP Savings from Switchers$0 (Lagged)$257.5 Million$522.4 Million$805.5 Million

Source: Legislative Budget Board Fiscal Note for SB 2 22

Section IV: The Anticipated Participant Profile: A Demographic Forecast

Forecasting who will utilize the Texas Education Freedom Accounts requires an understanding of the state's unique demographic landscape and the specific contours of public opinion regarding school choice.

The Texas Demographic Context

Texas is one of the nation's youngest and most rapidly growing states, on a trajectory to become the most populous in the country.30 This demographic dynamism provides a large and expanding potential market for the TEFA program. The state's K-12 population is already majority-minority, a trend that is accelerating. The Hispanic population is now the state's largest ethnic group and is projected to become the majority across every age category by 2050, while the Asian population is also expected to grow significantly.30 This contrasts with a projected national "demographic cliff," where the number of high school graduates is expected to decline. Texas, by contrast, is projected to see continued growth in its number of high school graduates through at least 2041, ensuring a sustained K-12 population.31

Public Opinion and Demand for School Choice

Recent polling reveals strong majority support for ESAs in Texas, with approval ratings ranging from 63% to 69%.32 This support is notably broad, cutting across partisan, racial, and geographic lines.

  • Partisan Support: While strongest among Republicans (73-78%), a significant share of Democrats (46-55%) also favor the policy.33
  • Racial and Ethnic Support: Support is particularly high among Black (69-70%) and Latino (59-64%) Texans. In some polls, these groups show higher levels of support than white Texans, especially for programs targeted toward low-income families.32
  • Geographic Support: Countering the long-standing political narrative of rural opposition, polls show majority support for universal vouchers in urban (67%), suburban (64%), and rural (63%) areas.34

This data reveals a significant disconnect between the historical voting patterns of rural legislators, who have been the key obstacle to school choice, and the stated preferences of their constituents.2 The strong majority support among rural residents suggests that legislative opposition may be more reflective of the influence of local public school leadership than the will of the broader electorate. The success of Governor Abbott's primary challenges against anti-voucher incumbents indicates this disconnect was politically vulnerable.

Furthermore, the polling reveals a complex and pragmatic view of school choice among minority families. Black Texans, for instance, register as the strongest supporters of ESAs while simultaneously being the group most likely to agree with anti-voucher arguments, such as the concern that these programs divert funding from public schools.32 This is not a contradiction but a pragmatic calculation. It suggests that while these families are acutely aware of the potential systemic risks, their dissatisfaction with existing public school options is so profound that they are willing to support alternatives despite those risks.

Forecasting the TEFA Participant Profile

Based on the program's structure and public demand, the initial participant profile can be forecast with some confidence.

  • Initial Cohort: The income-based prioritization tiers in the lottery system ensure that the first cohorts of TEFA participants will be disproportionately composed of low- and middle-income families. Given the high levels of support in polling and the state's demographics, it is highly likely that a large number of these initial participants will be Black and Latino families.
  • Students with Disabilities: This group is a primary target population for the program, receiving the highest priority in the lottery (if low-income) and the largest potential awards. They are expected to constitute a significant and high-cost segment of the participant base, a dynamic also observed in Arizona's ESA program.26
  • Long-Term Profile: Should the program expand and the budget cap be lifted, the demographic profile may shift. The Arizona experience suggests a strong potential for heavy utilization by middle-income families.26 However, the robust support from Texas's large and growing Black and Latino populations suggests the TEFA program may ultimately serve a more diverse user base than similar programs in other states, provided that financial and logistical barriers—such as tuition gaps and transportation—can be overcome.

Table 3: Public Opinion on ESAs in Texas by Demographic Group

Demographic Group% Support Universal ESA% Support Low-Income-Only ESASource(s)
Overall69%64%32
Republican73%57%32
Democrat55%60%32
White63%52%32
Black70%72%32
Latino64%65%32
Urban67%N/A34
Suburban64%N/A34
Rural63%N/A34

Note: Data compiled from multiple polls conducted in 2024 and 2025\. Slight variations exist between polls.

Section V: The Fiscal Impact: A Multi-Billion-Dollar Projection

The fiscal impact of the Texas Education Freedom Accounts program is the subject of an intense and polarized debate. While both sides of the argument draw from the same foundational data, their differing analytical models produce starkly different conclusions about the program's effect on the state budget.

The Foundational Data: The Legislative Budget Board Fiscal Note

All credible fiscal analyses of the TEFA program begin with the LBB's official fiscal note for SB 2, which provides the baseline projections for the program's costs and savings.21

  • Gross Program Cost: The LBB projects the program will exhaust its $1 billion budget cap in FY 2027. If the cap were removed and demand were fully funded, the LBB projects gross costs would escalate rapidly to $3.2 billion in FY 2028 and $4.6 billion by FY 2030.22
  • Offsetting Savings: The LBB calculates that as public school students "switch" to the TEFA program, the state will realize savings in its Foundation School Program (FSP) funding obligations. These savings are projected to be $257.5 million in FY 2028 (reflecting the first full year after the initial cohort of switchers leaves the public system) and are expected to grow to $805.5 million by FY 2030.22
  • Net Fiscal Impact: By subtracting the FSP savings from the projected gross costs, the LBB calculates a significant net negative impact on the state's General Revenue fund. This net cost is projected to be ($2.98 billion) in FY 2028, growing to ($3.75 billion) by FY 2030.22

Model 1: The Deficit-Driver Model

This analytical model, advanced by public school advocacy groups such as Every Texan, the Texas State Teachers Association (TSTA), and Texas AFT, frames the TEFA program as a massive new state expenditure that will create a structural deficit and divert essential funding from an already under-resourced public school system.35

The core of this model's argument focuses on the gross new cost of subsidizing the education of hundreds of thousands of existing private school and homeschool students whom the state was not previously funding. According to the LBB's own projections, these "non-switchers" will constitute the overwhelming majority of initial program applicants.28 From this perspective, every dollar spent on these students is a new drain on the General Revenue fund. While the model acknowledges the FSP savings generated by switchers, it argues these savings are dwarfed by the massive new financial obligation. An analysis by Every Texan, for example, projects a $2.25 billion annual loss to public schools with just a 5% student take-up rate—more than double the program's initial appropriation.36 The central claim is that every dollar spent on the TEFA program is a dollar that could have been used to increase the basic allotment for the 5.5 million students remaining in Texas public schools.35

Model 2: The Revenue-Neutral / Net Savings Model

This competing model, championed by program proponents like the Texas Public Policy Foundation (TPPF) and EdChoice, posits that the TEFA program represents a more efficient allocation of existing education dollars that could be revenue-neutral or even generate net savings for taxpayers over time.39

This model's analysis centers on the per-student savings generated each time a student leaves the public school system. The FSP savings calculated by the LBB are treated as a direct, dollar-for-dollar credit against the program's gross cost. Proponents also extend the analysis beyond the immediate state budget, arguing that the long-term benefits of improved educational outcomes—such as higher graduation rates, a more skilled workforce, and reduced social costs—will lead to significant growth in the state's Gross Domestic Product (GDP). One TPPF-cited analysis projects that a universal ESA program could increase Texas's GDP by $290 billion to $510 billion annually over a 25-year period.39 This reframes the debate from one of short-term budgetary cost to one of long-term economic investment.

The entire multi-billion-dollar fiscal debate is thus a proxy war over a single, unproven variable: the "switcher rate." Both models use the same LBB data, but their conclusions diverge based on the philosophical weight they assign to the costs of non-switchers versus the savings from switchers. As the LBB's projections are merely assumptions about future behavior and market capacity, the program's true fiscal impact remains unknowable until several years of actual enrollment data are available.

Furthermore, the legislative design includes a "ticking time bomb" in the form of the sunsetting $1 billion budget cap.12 This provision forces the 90th Legislature in 2027 to make an explicit choice: either fully fund the program at a projected cost of over $3 billion or actively vote to impose a new cap, a politically difficult move once tens of thousands of families are dependent on the program. This creates a powerful "constituency of dependence" that will make containing future costs exceedingly challenging.

Table 3: The Dueling Fiscal Impact Models (FY2028 Projections)

Fiscal ComponentDeficit-Driver Model (Source: Every Texan, TSTA)Revenue-Neutral/Savings Model (Source: TPPF)
Projected Gross Program Cost$3.2 Billion 22$3.2 Billion 22
Projected FSP Savings from Switchers$257.5 Million 22$257.5 Million 22
Treatment of FSP SavingsAcknowledged, but insufficient to cover massive new costs for non-switchers.36Treated as a direct, dollar-for-dollar offset to the gross program cost.39
Primary Analytical FocusThe new state liability incurred for hundreds of thousands of previously unfunded private/homeschool students.36The per-student savings generated by each "switcher" leaving the more expensive public system.39
Inclusion of Broader Economic ImpactNo. Focus is strictly on the direct impact to the state budget and public school funding.35Yes. Argues for massive long-term GDP growth from improved educational outcomes.39
Resulting Net Fiscal ImpactMajor Deficit Driver. Program is a primary contributor to a structural state deficit and harms public schools.36Modest Net Cost with Potential for Long-Term Savings. Program is a fiscally efficient reallocation of existing K-12 funds.39

Section VI: Administration and Accountability: Building the Oversight Engine

The architecture of the TEFA program includes a multi-layered system of administration and accountability, designed to manage the flow of public funds while preserving the autonomy of participating private schools.

The Administrative Structure: Comptroller and CEAO

Ultimate oversight authority for the TEFA program rests with the Texas Comptroller of Public Accounts.5 The Comptroller's office is responsible for adopting the program's rules, ensuring funds are used for approved expenses, and reporting on the program's status to the legislature. The agency released a set of proposed rules for public comment in August 2025, outlining the operational framework.43

The day-to-day operational management is outsourced to a Certified Educational Assistance Organization (CEAO). The Comptroller selected Odyssey for this role, tasking the company with managing the online parent portal, processing all applications, maintaining the e-commerce marketplace of approved vendors, and providing customer support.5 Concerns have been raised by program critics regarding Odyssey's track record in other states, citing an incident in Idaho where the company was ordered to repay the state for interest it had collected on unspent program funds.17

Accountability for Schools and Providers

Participation in the TEFA program is entirely voluntary for private schools.12 Those that choose to participate must meet several key requirements:

  • Accreditation: A participating private school must be accredited by an organization recognized by the Texas Private School Accreditation Commission (TPSAC) or the TEA and must have been in continuous operation for at least two years prior to applying.5
  • Testing Mandates: Schools are required to annually administer a nationally norm-referenced assessment to all TEFA-funded students in grades 3 through 12\.5 Parents must agree to allow these results to be shared with the CEAO. This serves as a key academic accountability measure, although it stops short of requiring the state's own STAAR test, a point of contention for critics who argue it creates an uneven playing field.37 Homeschool students are exempt from all testing requirements.20

A central feature of SB 2 is the inclusion of strong statutory language protecting the autonomy of participating schools. The law explicitly states that receiving TEFA funds does not make a private school a "state actor" and prohibits any state agency from regulating a school's curriculum, admissions policies, or religious values as a condition of participation.12 This provision creates a potential long-term conflict with the principle of public accountability for public funds. As the program grows to a multi-billion-dollar scale, it is inevitable that issues of public concern—such as discriminatory admissions practices or the use of controversial curricula—will arise. At that point, public demand for greater accountability will clash directly with the statutory autonomy protections that were necessary to secure the support of private schools for the bill's passage.

Financial Oversight and Parental Responsibility

The program's accountability framework prioritizes financial compliance over academic performance. The system is led by a fiscal agency (the Comptroller), and its primary oversight tools are financial. The enabling legislation requires regular audits of program accounts and participant eligibility, which can be conducted by private firms or the State Auditor.12 However, critics have noted that the law does not explicitly mandate that the results of these audits be made public.17

Parents who enroll their children in the program must formally agree to several conditions, including spending funds only on eligible expenses, sharing their child's assessment results with the CEAO, and promptly notifying the CEAO if their child re-enrolls in a public school.4

A critical area of concern involves students with disabilities. The law does not require participating private schools to provide the same level of special education services or adhere to the same legal protections guaranteed to students in public schools under the federal Individuals with Disabilities Education Act (IDEA).25 While non-religious private schools must comply with the Americans with Disabilities Act (ADA), religious schools are largely exempt. This creates a situation where families of students with disabilities may unknowingly waive significant legal rights upon accepting a TEFA.

Section VII: Concluding Analysis and Forward-Looking Implications

Synthesis of Findings: A Grand Experiment in Market-Based Education

The Texas Education Freedom Accounts program represents one of the nation's most ambitious experiments in creating a large-scale, state-funded, market-based K-12 education system. Its legislative design reflects a core tension: a program with universal eligibility that is functionally constrained by a firm budget cap and an income-based lottery system. This creates a "universal in theory, targeted in practice" model for its initial years. The program's ultimate success, both fiscally and politically, will depend almost entirely on two yet-to-be-seen factors: the actual "switcher rate" of students leaving public schools and the long-term willingness of the Texas Legislature to fund the program beyond its inaugural $1 billion appropriation.

Comparison to the Arizona Model

While Texas joins a growing number of states with universal ESAs, its program design contains notable differences when compared to the nation's first and most mature universal program in Arizona.

  • Similarities: Both Texas and Arizona have universal ESA programs that offer broad allowable expenses, tiered funding for students with disabilities, and the use of a third-party financial platform to manage parent accounts.26 Both states have also been the site of intense, data-driven debates over the programs' net fiscal impact and participant demographics.
  • Key Differences: Texas is launching its program with a much larger initial budget ($1 billion) and a legislatively mandated, income-based lottery system from day one. The most significant structural departure is Texas's choice to have a fiscal agency, the Comptroller of Public Accounts, administer the program, whereas Arizona's Department of Education is in charge.26 This reflects a greater emphasis on financial control in the Texas model. Additionally, Texas has built stronger and more explicit statutory protections for private school autonomy into its enabling legislation from the outset.

Forward-Looking Recommendations for Texas Policymakers

As Texas moves toward implementation, the experience of Arizona and the contours of the state's own policy debate suggest several critical steps to ensure transparency, fiscal responsibility, and long-term stability.

  • Mandate Transparent Reporting: The Legislature should amend the statute to require the Comptroller to publicly report anonymized, aggregate data on participant demographics (income, race, disability status), prior school type ("switcher" data), and academic outcomes from the mandated norm-referenced tests. This is the only way to resolve the dueling fiscal and demographic debates with empirical evidence rather than competing models.
  • Conduct a Marginal Cost Study: The state should commission an independent study to determine the true marginal cost of educating a student in Texas public schools. This would provide a more accurate baseline for calculating the net fiscal impact of "switchers" than the current reliance on the statewide average per-pupil expenditure.
  • Clarify Special Education Rights: The Comptroller and the CEAO must be statutorily required to provide parents of students with disabilities with a clear, explicit "rights waiver" notification. This document should explain in plain language the differences in legal protections and service requirements between public schools (under IDEA) and private schools before a family accepts a TEFA.
  • Plan for the Fiscal Cliff: The Legislature must begin planning immediately for the expiration of the $1 billion budget cap in 2027\. A sudden move to fully fund uncapped demand could have severe budgetary consequences, while a failure to address a potentially large waitlist could create a significant political backlash. A multi-year, phased-in budget expansion should be developed to ensure predictable and sustainable growth.

Implications for the National School Choice Movement

The launch of a universal ESA in Texas, the nation's second-most populous state, is a watershed moment for the school choice movement. The program's success or failure will have national repercussions. The Texas model—with its fiscal agency administration, income-based lottery, and strong school autonomy protections—provides a new and distinct blueprint that other large, politically diverse states may seek to emulate. Ultimately, the Texas experiment will generate the largest-scale data set to date on the central questions of the school choice debate: Does a state-funded educational market improve student outcomes, is it fiscally sustainable, and who does it truly serve? The nation will be watching the results.

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