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PODCAST: | “Freedom to Learn:” Supercharging Education Freedom Nationwide

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Jackie Guglielmo joined Freedom to Learn to explain the impact of the new federal tax credit scholarship

Jackie Guglielmo, Vice President of Services at ACE Scholarships, joined Freedom to Learn to discuss how the new federal scholarship tax credit — an Education Freedom Tax Credit — has the potential to “supercharge” education freedom across the country. Jackie explained how scholarship-granting organizations (SGOs) and tax credit scholarship programs work, and shares how families’ lives have been changed by access to the right educational environment. We delve into the details of the federal scholarship tax credit, including the opt-in process for governors and Treasury Department rulemaking, and Jackie shares how experienced organizations like ACE are preparing to scale responsibly while prioritizing the needs of low-income students.

Federal Tax Credit for Scholarships
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This conversation has been edited for length and clarity.

Our regular listeners know that we often talk about education freedom and the federal scholarship tax credit. We’ll get to those topics. Let’s start with ACE Scholarships’ history and mission.

Jackie Guglielmo: We’re entering our 26th year as a nonprofit scholarship-granting organization (SGO). ACE was founded in Denver, Colorado by five individuals who were very passionate about providing low-income families with access to the educational environment that best met their needs. Since our founding in 2000, we’ve expanded into 13 states, four of which are state tax credit programs.

What is the role of your organization?

Jackie Guglielmo: We’re really end-to-end. We have a team of fundraisers. We cultivate relationships with donors. We fundraise to provide scholarships to low-income families. That’s what we’ve always prioritized and what we’re going to continue to do.

How does verifying eligibility of students work for your organization?

Jackie Guglielmo: We kept our application pretty simple and collected some basic information from families in order to verify that they were, in fact, low-income families meeting a low-income threshold in order to receive our privately funded scholarships. We’re really excited about the investments that we’ve made in our technology to enhance the application. We built a brand new application that’s more sophisticated technologically in order to be compliant with the federal tax credit and in anticipation of the verifications and eligibility determinations we’re going to need to support those students nationwide.

You say that you’re operating in four states with state programs. How does that differ from what you do with a privately funded scholarship program?

Jackie Guglielmo: With our private scholarships, we have a little bit more flexibility with who we can scholarship and where they might be. With our state tax credit, we need to be compliant with the state tax credit law in those four states. And those differ pretty dramatically from state to state. We have development officers that are in those states that help us to operate those programs.

How would you describe how a state tax credit program works?

Jackie Guglielmo: Typically, it’s either individuals or corporations that can provide a donation to a scholarship granting organization for a tax credit or a tax deduction on their state tax liability. A scholarship granting organization then delivers scholarships based on those funds raised to eligible students within that state.

I think that’s helpful to let people know these have been around for a long time.

Jackie Guglielmo: That’s right, Ginny. They’re not new and we have a good amount of very established, very sophisticated scholarship granting organizations like ACE that have been in the business of doing this for quite some time and been very successful with it. And you know, it’s so exciting to see something pass that’s going to give an opportunity to bring these scholarships to the federal level to students potentially in all 50 states if the states opt in.

Do you have anything to share about ACE’s experience running these programs at the state level, any feedback that you’ve gotten from families as they’ve benefited from scholarship programs?

Jackie Guglielmo: Absolutely. We’ve delivered over 121,000 scholarships totaling over $395 million. We have lots of families, lots of stories to share. One that stands out to me is the story of one of our families down in Texas, [a mother named] Greta, and she has been an amazing advocate for school choice. She’s what we call the story of two paths. She had a son who was attending public school and, sadly, she did not know about ACE Scholarships when her son was in the public school and she lost him to drug addiction. During that time, her adoptive daughter, Miracle, was born, and she adopted her and found ACE Scholarships.

She was invited to testify in Texas for the ESA program and did a phenomenal job, so much so that she caught the attention of Governor Abbott, who invited her to meet with him one-on-one. She told him about her children and about the two different paths that they were able to take, one that did not have access to education that met his needs. And then her daughter, Miracle, who’s thriving at a private school. Governor Abbott was so moved that he amplified her story on social media and invited her to come to the bill signing right alongside him when Texas passed the ESA there. So, just an amazing example of the reach that ACE has had, and of the incredible impact that programs like this can have for families.

Your organization has an ambitious vision for engaging with the federal scholarship tax credit and expanding the potential for serving even more students in more places across the country. Let’s start with a reminder of what the tax credit is. What’s your elevator pitch?

Jackie Guglielmo: It’s really important to recognize that this is a tax bill that promotes charitable giving and benefits school choice. It’s not just a school choice bill. It’s so much more than that. And it’s the first time in our nation’s history that we’re going to have a tax credit that brings educational freedom to families across America simultaneously. So I just wanted to get those two really important points out there.

My elevator pitch is that the new federal tax credit for scholarships offers a dollar-for-dollar tax credit up to $1,700 for individuals who donate to qualifying nonprofit scholarship granting organizations like ACE. And then those scholarship granting organizations can deliver scholarships to qualified K-12 students in states that opt in.

When we’re talking about donors, we’re not talking about people who have to cough up $1,700 out of their wallet, out of their pocket, out of their bank account. These are individuals who already owed the federal government $1,700, and they’re going to redirect the funds to scholarship-granting organizations.

And the scholarships are for a wide array of uses. In Washington, the teacher unions tends to control the narrative and you heard a lot about a federal “voucher” program—that’s not what this is. You mentioned ESAs, education savings accounts. That’s a model that already exists at the state level. Can you talk a little bit more about what it means to provide scholarships for expenses beyond just private school tuition?

Jackie Guglielmo: The typical structure for an education savings account and a model that we are looking at for the federal tax credit is an individualized account per student with the ability for that student to use those funds to pay for qualified K-12 expenses. These are things like books, tuition, fees, transportation, extended day programs, tutoring, so things that are supplementing their current educational setting. The federal tax credit refers to Coverdell. I think of it as a wraparound for all educational expenses.

What is ACE Scholarship’s vision for engaging with the tax credit?

Jackie Guglielmo: We see the federal tax credit as a complement to the work that ACE has done for the past 25 years. We call it supercharging. So it’s supercharging private and tax credit programs that we’ve already been involved with. This year alone, we were blessed to be able to scholarship over 16,000 students. Sadly, we had 8,000 students who qualified for our scholarship, but we didn’t have enough funding for them.

I think one of the things that the federal tax credit will be able to do is reach students that we weren’t able to reach our tax credit programs and our charitable giving. It just demonstrates the tremendous need that we have across the country, and something that’s really important to keep in mind for the federal tax credit is, the state efforts are amazing and we champion them, but they’re not enough. There’s still a need out there.

Sometimes the state tax credit programs and then privately funded scholarship programs aren’t sufficient to cover full tuition, certainly not to cover high school tuition. Are you looking to expand the amounts of scholarships that you’re offering as well?

Jackie Guglielmo: ACE’s model has always been that everyone has skin in the game. So for 25 years, we’ve never provided a full scholarship. We’ve always provided partial scholarships—parents pay a portion, and schools pay a portion.

We’ve got 25 years of data to show the transformational impact, the pride, and the investment that having to pay partial tuition has for a family. And we’re going to continue to prioritize low-income families and continue to shape our model in that way.

However, I think it’s important to take a look at the tuition amounts that parents are having to pay and whether or not our scholarships are making that education accessible for them. And that’s a decision that we’ll make as we move through 2026 and see how the rules are promulgated.

When you’re talking about expanding the number of families that you’re serving, you’re going to expand your geographic reach as well.

Jackie Guglielmo: That’s correct. We’re planning to operate in all 50 states to deliver scholarships in all states that opt in, which is really exciting for us to expand from 13 to 50. Something that’s really important to us is more dollars in the hands of more children. Really, that’s our mission.

But something that operating or planning to operate in all 50 states does for us is it allows us to reallocate our privately funded scholarships to students that are in states that don’t opt in. Obviously when we’re fundraising and we’re collecting federal tax credits to provide federally tax credit funded scholarships to students in states that opt in, that essentially leaves out students that are in states that fail to opt in. And we don’t want to see students left behind.

What are we talking about when we’re saying opt-in?

Jackie Guglielmo: Governors or a designee of the state needs to opt their state into the program. That means that scholarship granting organizations can fundraise and provide tax credits to donors in all states, but only students in states where governors opt in can receive the scholarships. So we’re already starting to see some governors come out publicly and comment that they intend to opt their state in, which means that scholarship granting organizations will be able to both raise funds and deliver scholarships to students in their states.

A question mark right now is how the Treasury Department is going to interpret the law; a big one would be that the scholarship granting organization needs to be located in the state. So what are you hoping when it comes to the Treasury Department’s interpretation of that?

Jackie Guglielmo: We’re hoping to see that simply means you registered to do business in that state. [A requirement to have] headquarters in every state, staff and buildings in every state, [is] just a barrier to entry for scholarship granting organizations.

And I said before, our mission is just more dollars in the hands of more children. The more barriers that we put in place for scholarship granting organizations to implement this program, the harder it’s going to be to get those funds to students.

So we’re looking for a very simplistic interpretation of “located in,” registered to business, often that’s with the Secretary of State. Obviously, a scholarship granting organization will have to file and register to solicit for charitable donations.

Yes, I’ve noticed that your organization has put out information like, “Are you interested in starting an SGO? Here’s an alternative model, partner with ACE Scholarships.”

Jackie Guglielmo: Yep, that’s exactly right. We started to take a hard look at what we would need to do to be compliant with the provisions of the federal tax credit and what’s going to come in the rules.

We thought about all of the smaller organizations that were thinking about forming an SGO and coming to us for guidance. These organizations are so mission driven, they’re making incredible impact in their communities. We want them to continue to be able to focus on their mission and their impact and let us do all the backend administrative stuff that we’ve done for 25 years. That includes an end-to-end technology solution, customer support, federal compliance, auditing, data, tech certifications — let us do all of that so you can focus on your communities and your donors and cultivating relationships.

A big part of making sure things are heading in the right direction is the Treasury rulemaking process. At the end of 2025, the Treasury Department sought comments, largely from the scholarship granting organizations. They’ll take those comments and turn them into a draft regulations for the program, and then take more comments. What are some other topics that you’d like to see addressed in the rulemaking process?

Jackie Guglielmo: We’d love to see it codified that when a governor opts in, they’re opting in across the board for all K-12 students.

We don’t want winners and losers within a state. We want to make sure that this federal tax credit opportunity truly is going to impact all K-12 students in the state and have an impact for generations to come. We don’t want any governor in any state to be able to pick and choose the scholarship granting organizations that make the list.

In the request for comments, it certainly seems that they’re making a nod to the provisions of the law, which are ensuring that the SGO is compliant with the regulations and criteria there.

Any other topics that you’re hoping to see clarified in rulemaking?

Jackie Guglielmo: One that’s been brought up to us quite a bit is the 90-10 provision, so the 10% administrative cap. We’re no stranger to this in operating four state tax credit programs. There are limitations on the overhead cost of those programs. Louisiana, for example, has a 5% overhead cap.

The important part that we want the Treasury to really clarify in the rules is that that the 10% is applicable only to the income that comes to the organization through the funds raised through the federal tax credit and not cumulatively for all the income that the organization may generate.

Let’s loop back to that opt-in provision. Do you have suggestions on how people could go about convincing their governors to opt in?

Jackie Guglielmo: Absolutely. We have some materials on our website that are really good opt-in talking points, great resources for grassroots organizations that want to partner with other organizations within their state to start to raise awareness and educate executive leadership within their state. Something we realized early on is that governors and other executive leadership might not understand all the provisions. We wanted to make sure that they had the most accurate and up-to-date information.

Governor Polis has publicly announced that he plans to opt Colorado in to the federal tax credit. I think it’s a really big deal. Governor Polis is not the first Democratic governor to openly state that he plans to opt in, but he’s certainly the first Democratic governor with a Democratic House and Senate leadership.

I certainly hope that governors in other states are taking note of Governor Polis’ prioritization of all K-12 students in his state. I really hope that we see a tipping point now in the rest of the states across the nation.

We’ve had Jorge Elorza from the Democrats for Education Reform (DFER) on the podcast, making the case for why this is absolutely a bipartisan initiative and blue states should absolutely be opting in.

Jackie Guglielmo: I’m so glad you brought up the work of DFER. I think when we’re talking about opt-in strategies for all states, their analysis of the amount of funding that can be raised per state is tremendously helpful when putting some talking points in front of the governor.

We want funds raised to stay in the communities in which they were raised. Nobody wants to take funds from a state and deliver scholarships to students across state lines. But by failing to opt in, governors are allowing scholarship granting organizations to do precisely that. We’re prioritizing students most in need, income-based, and if we’re unable to deliver them in the states in which they’re raised, we’re going to find low-income students elsewhere who are pursuing educational opportunities.

As we conclude, Jackie, we like to ask our guests to dispel education myths. Is there one that’s pervasive that you’ve come across a lot or one that bothers you the most that you’d want to address?

Jackie Guglielmo: The one that rubs me the most is that just because a student is currently educating in a private school does not mean that their family is not making tremendous sacrifices to have them there.

School choice opponents would love us to believe that the private school population, and overall categorizing these private school choice programs, are welfare for the wealthy. As a scholarship granting organization that has prioritized low-income students for 25 years, we know that’s simply not the case.

We just recently launched private scholarships in Hawaii. We’re one of the only SGOs to be able to do that. One story there that illustrates that this is truly a myth is we were able to provide a scholarship to a high school student. His family was making incredible sacrifices. He’s got six siblings, two others of which are in high school, and his family was living in a multi-generational household, saving and sacrificing to be able to send him and a couple of his siblings to private school. When he was entering his senior year this year, they weren’t going to be able to do it. He would have had to return to a very dangerous public school that wasn’t going to meet his needs, allow him to thrive, allow him to continue to excel in academics and football.

And by the grace of God, we came into the state of Hawaii. We found him, we scholarshipped him, and he was able to finish his senior year at the private school where he was able to grow and learn. But it came at an incredible sacrifice for his family. This myth that all students in private schools are being subsidized or they’re the only population of students that actually benefit from these private school choice programs, whether at the state level or federal — it’s just simply not true.

How can people follow ACE Scholarships’ work?

Jackie Guglielmo: You can find us at acescholarships.org, and there’s a banner at the top if you want to specifically track our work on the federal tax credit. I encourage anybody who wants to learn more about our 50-state strategy or our turnkey solution to please get in touch with me. We’re so excited to come alongside other organizations that want to take full advantage of the federal tax credit, and we want to enable them to do that.

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