Comment from Engleside Baptist Church and Christian School

On behalf of Engleside Baptist Church and Christian School, I am writing to request your attention to the following 5 items when crafting regulations for the school choice program. 1. Protect the federal nature of the program by prohibiting governors from adding any additional requirements to scholarship-granting organizations (SGOs) beyond what the federal law outlines. The new federal law clearly allows governors only a simple opt-in or opt-out. Thus, the regulations must ensure that any eligible SGO that meets the federal requirements may operate within the state when a governor opts in. Additionally, Treasury must make clear the liberty protections afforded to religious schools by including protective language to the effect that: “Nothing in this part shall be construed to permit, allow, encourage, or authorize any Federal, State, or local government entity, or officer or employee thereof, to mandate, direct, or control any aspect of any scholarship granting organization or of any private or religious elementary or secondary education institution.” 2. Ensure that all federally eligible SGOs may grant scholarships in any state that has opted into the program. Since any SGO may receive donations from taxpayers across the United States, these same SGOs should also be allowed to grant scholarships to students in any state that opts into the program. 3. Prevent discrimination against married couples: the law allows each taxpayer to donate up to $1,700. Regulations should ensure that married individuals filing jointly on taxes each can receive the benefit, allowing up to $3,400 total. 4. Maximize student participation: regulations should ensure that funds follow the students so that, if they live in a state that opts in and attend school in one that does not, they can still use the scholarship. If they live in a state that does not opt in but attend school in a state that does, they can also participate. 5. Treasury regulations must clarify SGO income so that the federal statutory language requiring distribution of 90% of donations does not apply to donations that do not receive a federal tax credit. The law dictates that SGOs must spend 90% of their income on qualified scholarships. Congress intends the 90% requirement to apply only to income from federal scholarship tax credit donations, not to all possible sources of income to the organization. Any other interpretation amounts to federal intrusion on SGO’s unrelated income and operations. Thank you for your attention to these matters. Randall Keith Paddock Engleside Christian School Alexandria, VA 22309