A question comes up constantly from donors who care about one school in particular, and from schools wondering what they can tell their community about giving: can a gift to the Education Freedom Tax Credit (EFTC) be directed anywhere specific?
The answer turns on a single, careful distinction in the law. Scholarship Granting Organizations (SGOs) are barred from earmarking or setting aside contributions for any particular student. The prohibition is written around students, not schools. That distinction does the work: donors cannot buy a scholarship for a specific child, but nothing in the statute prevents an SGO from accepting a donor’s preference that a gift support scholarships at a particular partner school.
What donors can never do
No donor can name a student or family as the intended recipient of a scholarship. A parent cannot route a credited donation to an SGO with the expectation that it returns as their own child’s scholarship, that is earmarking for a particular student, exactly what the law forbids. And no gift can be conditioned, formally or informally, on a specific student receiving an award. An SGO that allows student-level earmarking risks its own qualifying status, which is why well-run SGOs enforce this line strictly.
School-level designation is a different question
This means a donor directs a gift toward a specific partner school’s scholarship fund. The SGO pools those dollars and awards scholarships from them to eligible students at that school, using its own criteria and the law’s required priority order. The donor chooses a destination. The SGO still decides everything about who receives an award. That separation is what keeps school-level designation on the right side of the law.
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This isn’t a new or untested design. State-level scholarship tax credit programs have operated this way for decades, and school designation is common and well understood in them. The federal program was modeled on that experience.
The rules that still apply, regardless of designation
Within a designated school’s applicant pool, the SGO must still verify household income against the eligibility threshold, apply the required priority order (renewing students first, then their siblings, ahead of new applicants), and make every award decision itself. The organization must also serve students at more than one school; a single-school pass-through does not qualify as an SGO under the law, even if every donor happens to designate the same school. AFC Scholarship Fund’s network already serves students across multiple states and school communities, which is the scale that structure requires.
One honest caveat
Federal guidance has not yet addressed school-level designation explicitly. The strongest case for it rests on the statute’s plain language, which restricts only student-level earmarking, and on the well-established practice in state programs. Careful SGOs describe school designation as a donor preference they intend to honor, rather than a binding guarantee, which keeps the organization’s award authority clear while guidance continues to develop.
Often, yes. The law prohibits earmarking for a particular student, not a particular school, and many SGOs let donors direct a gift toward a specific partner school’s scholarship fund. Whether a given SGO offers this option is that organization’s own policy.
No. The law is explicit that an SGO cannot earmark or set aside contributions for any particular student, and that includes a donor’s own children.
The SGO always does. School designation directs where the dollars go. It never determines who receives them; the organization still verifies eligibility, applies the required priority order, and makes every award decision.
