Comment from Citizens for Traditional Values

I am writing to express comments on Notice 2025-70, regarding the implementation of the FSTC program. On behalf of our organization, a non-profit civic organization that focuses on faith, family values and educational options for children in Michigan, we applaud the passage of this program as it will give parents more options and opportunities they need as they seek the best way to educate their children. I particularly want to address THREE elements of this program that are crucial to it being truly effective. First, we ask that if a state opts into the program, it must accept that ALL types of SGO's are eligible to participate in the program. It will make a huge difference for all children and should NOT matter if they attend a public or non-public school or if a parent home-schools. Secondly, the language should be clear regarding income -- 90% of income means was intended to mean 90% of SCHOLARSHIP donation income, NOT 90% of the overall budget for the SGO/501c3. This is critical for the program's success! Thirdly, we would encourage the Treasury to write guidance that opting in "as early as practicable" includes ANY TIME DURING 2027 during the FIRST year of the act -- as you know, many states will have new governors that may not be aware of all their options for this program. For 2028 and beyond we would request that you clarify that "no later than Jan. 1" should specifically be "no later than 11:59 p.m. on Jan.1." Thank you for your consideration of these recommendations.