The US Treasury Department and the IRS are now writing the regulations to implement the new federal voucher program and issued a request for comments from the public in November. Below you can read the comment that Illinois Families for Public Schools submitted.
Online submission December 26, 2025 via: https://www.regulations.gov/commenton/IRS-2025-0466-0001
Re Notice 2025-70:
Public schools are essential to every community across our state and nation.
Public schools are a public good, providing access to opportunity for all in our multicultural, multiracial society: they must educate all students regardless of income, race, religion, sexual orientation, gender identity, English language proficiency, immigration status, disability, or academic ability.
Moreover, strong public schools are at the heart of our democracy. They are unique as an institution that provides children with the experiences, both academic and social, necessary to develop into adult citizens who are capable of carrying out self-governance; in other words, they are a foundational element in a functioning and stable democracy.
Diverting public dollars from public schools, many of which are inadequately and inequitably funded, is fundamentally incompatible with improving both individual access to opportunity and also the common good.
School vouchers, including tax credit scholarships, perpetuate and deepen the gross inequities in education that plague Illinois and many other states.
Also, the majority of private schools are run by religious groups, and using public dollars to fund religion runs counter to the principles on which our country was founded.
Illinois experimented with a state-run tax credit scholarship voucher program from 2018 through 2024, and, thankfully, our General Assembly declined to continue that experiment.
The voucher program failed to improve education equity, sending hundreds of millions of dollars from Illinois’ General Revenue Fund to private schools with little oversight or accountability. The vast majority of schools receiving funds, 95%, were religious. Furthermore, the majority of them had policies that discriminated against students in a variety of protected classes. Our organization documented these shortcomings of the voucher program extensively and in detail.
In light of this failed experiment with vouchers in Illinois, we oppose any diversion of federal funds as a tax expenditure that will be used to pay for tuition at private and religious schools and other private educational expenses under new Section 25F of the Internal Revenue Code, as added by Section 70411 of Public Law 119-21, 139 Stat. 72.
The cost of the new federal voucher program will surely be in the billions, and possibly tens of billions, of dollars. Instead, we support our federal taxes to be used for fully funding federal responsibilities for public education, in particular those under the Every Student Succeeds Act and the Individuals with Disabilities Education Act, and oppose any cuts to such funding.
Respectfully submitted on behalf of Illinois Families for Public Schools,
Cassie Creswell, PhD
executive director and president
[email protected]