There is a guidebook. We have 8 of its 10 components.
ExcelinEd’s 2022 Implementation Guide names ten components a state needs in place for a universal ESA to function. Read against NC’s published milestones, eight are visibly in place. The remaining two are filed in Raleigh as SB 990 and SB 1006.
01What the guidebook is
Not leaked. Not rumored.
The Foundation for Excellence in Education, ExcelinEd, was founded by Jeb Bush in 2008. In 2022 they published a 36-page implementation guide for legislators standing up an Education Savings Account program. The PDF is online. The chapters are numbered.
What follows below is the ten-component framework, with the receipt showing where North Carolina sits on each component today. The components aren’t a sequence; NC built coalition and agency in parallel starting in 2013, and the wallet and credential pieces arrive together in SB 990 and SB 1006. Eight components are visibly in place. Two are filed. An 11th piece, the unwritten one, comes after the published guide ends.
Each component is one chapter of the guidebook. The receipt under each one is what NC has done, or filed, that fills that role.
01
Build the coalition.
In place
Line up advocacy groups, sympathetic legislators, and a parent-facing nonprofit that can speak in front of cameras.
Parents for Educational Freedom in NC (PEFNC), a 501(c)(3) advocacy nonprofit funded in part through the national school-choice donor network, has been the lead lobbying voice for vouchers in NC since 2005.
02
Pass the income-capped pilot.
In place
Sell as a lifeline for the kids who need it. Small enough not to alarm anyone.
Opportunity Scholarship Program enacted 2013, income-capped at the time.
03
Stand up the administering agency.
In place
Pick an agency that does not already answer to the public-school constituency. Higher-ed aid agencies recur.
OSP routed through SEAA, the higher-ed aid agency. Not DPI.
04
Launch the digital purchase platform.
Filed Apr 30, 2026
A wallet or account that lets families buy approved goods and services directly. The rail must exist before universal eligibility.
SB 990 establishes the Student-Based Educational Wallet Pilot, run by SEAA.
05
Fill the program.
In place
Outreach, application portals, marketing budget. Raise headcount so a political constituency exists by the time anyone debates rolling it back.
OSP enrollment grew from a pilot cohort to roughly 80,000 students by FY24.
06
Build the service-provider catalog.
Not yet
Tutors, curriculum vendors, microschools, therapists. Anything a parent might spend wallet dollars on must be listable.
The catalog needs Component 4 to function. SB 990 builds the rail it runs on.
07
Run the marketing.
In progress
Branded outreach. Glossy parent-navigator websites. Public dollars buying public-facing advocacy.
PEFNC, the same nonprofit that lobbied the Opportunity Scholarship into law (see Component 1), holds an NCSEAA outreach contract capped at $500,000 per year. The cap is written into SB 671 (Session Law 2023-11): NCSEAA may contract with a nonprofit representing parents and families for outreach and application assistance. PEFNC is the only NC nonprofit that fits that description, and they confirm it: PEFNC is receiving state funds to promote the program to parents across the state.
08
Onboard providers via credentials.
Filed Apr 30, 2026
Use modern identity rails so the catalog can scale fast. Verified-vendor IDs, digital credentials.
Help families choose. The 2022 ExcelinEd guidebook spotlights NC’s SEAA as the model administrator for this component.
NC is named in the published guidebook as the model state for parent navigation.
10
Take the caps off.
In place
Universal eligibility. Program is now too big and too constituent-rich to roll back.
Income caps removed October 2023. FY26 voucher appropriation roughly $625M.
Source
PEFNC outreach contract authorization: SB 671 / Session Law 2023-11 (NC General Assembly, 2023); EdNC, “Bill expanding access to vouchers to all students filed in N.C. Senate,” March 30, 2023; PEFNC’s own acknowledgment in N&O coverage reposted to their site, Feb 6, 2024. PEFNC IRS Form 990 filings via GuideStar, EIN 20-2754466, document the scholarship education program managed for NCSEAA.
03The architect document
The components aren’t accidental. Someone published a model bill that specifies them.
ExcelinEd’s 2022 Implementation Guide is the operations manual: ten components and how to put them in place. The 2026 Model Policy is the bill template: the legislative language for enacting them. Same shop, complementary documents, four years apart.
In 2026 ExcelinEd published a model bill titled Education Scholarship Accounts (not “Savings”). It carries the ALEC ESA chassis forward with three specific design choices that SB 990 mirrors directly.
501(c)(3) Program Manager preference. The model prefers a private nonprofit as Program Manager, not a state education agency. NC matches this via NCSEAA’s structural relationship to the program: a higher-ed aid agency administering K-12 disbursements through a nonprofit-style purchase rail.
10% administrative cap. ALEC’s earlier model used 3%. The 10% ceiling allows program operators to scale administrative infrastructure roughly threefold without exceeding the published cap. The wallet rail and credential layer in SB 990 / SB 1006 fit inside that headroom.
Footnote 5. A written instruction to fund the program through automatic formula funding rather than annual appropriations. The reasoning is published, verbatim, in the footnote.
“Less prone to persistent political controversy” is the design intent stated plainly. The recommended mechanism is to insulate the voucher line from the annual budget argument that would otherwise let voters and legislators litigate it. A program funded through formula doesn’t need a yes vote every year. It just keeps going.
Source
ExcelinEd, Model Policy: Education Scholarship Accounts (2026). PDF in the local corpus; Wayback capture pending before publish.
Source
Ben Scafidi, Enrollment Decline Windfall, EdChoice, Feb 2025, Table 1 p. 41.
04The operational layer
One catalog. Five named vendors run every ESA in the country.
The wallet rail isn’t generic infrastructure. ESA programs in the United States are administered by one of five named vendors, per EdChoice’s own March 2024 implementation guide: ClassWallet, Merit International, Odyssey (formerly Primary Class), Step Up for Students, and Student First Technologies.
NC’s existing ESA+ program already runs on ClassWallet, the same vendor that runs Arizona, Indiana, New Hampshire, and Missouri. SB 990’s “new” wallet pilot isn’t introducing a system. It’s scaling one that’s already operating.
Source
EdChoice, ESA Implementation Guide (March 2024). Vendor list and program associations.
Four regulations to avoid. Published, not whispered.
The Heritage Foundation (the conservative policy organization that authored Project 2025) published an ESA regulatory-design guide in December 2016 called Recalibrating Accountability. It names four regulations states should not adopt when designing an ESA program:
Open admissions requirements
Price controls (tuition caps)
State testing mandates
Excessive reporting requirements
When SB 990 and SB 1006 do not include testing or reporting mandates, it isn’t an oversight. It’s the published instruction.
Source
Burke & Bedrick, Recalibrating Accountability: Education Savings Accounts as Vehicles of Choice and Innovation, Heritage Foundation, December 2016.
What the floor looks like. Said by an advocate.
Marcus Brandon, executive director of NorthCarolinaCAN, describing the regulatory standard for new microschools and learning pods that can accept ESA dollars under NC’s current rules:
“
All it takes is a fire and health inspection.
— Marcus Brandon, NorthCarolinaCAN, to The 74, September 2023
That’s a voucher advocate openly describing the regulatory floor for a school receiving public dollars. The point isn’t that Brandon let something slip. The point is that this is the published design.
Source
The 74, Linda Jacobson, “Pod People: The Rise of the Microschool,” September 22, 2023.
05In their own words
The architect said the universal expansion was the point.
Paul “Skip” Stam, former NC Speaker Pro Tempore and the original sponsor of the Opportunity Scholarship, told WUNC’s Liz Schlemmer the week before the HB 10 veto override vote (the override that authorized $463M to clear the voucher waitlist) that the size of the program was the point.
“
With this expansion, there will be enough people that, politically, they won’t be able to do away with it.
— Paul ‘Skip’ Stam, to WUNC, Nov 18, 2024
That is the design intent stated plainly. The point of universal eligibility is the constituency it builds. Once the constituency is built, the program is durable. The next ask follows on schedule.
Source
WUNC, “Private school voucher to nearly double under proposed North Carolina veto override,” Nov 18, 2024. wunc.org
06The unwritten 11th
The published end game. Voucher equals per-pupil.
EdChoice, the research arm of the movement, publishes the Friedman Index every year. The rubric awards full marks when a state’s voucher amount equals state-plus-local per-pupil spending and eligibility includes every student in the state. That is parity. North Carolina’s 2026 score is 1 out of 100.
Today, NC’s voucher tier 1 is roughly $7,942 per student. NC state+local+federal per-pupil spending per ADM, drawn from NCDPI Highlights of the NC Public School Budget 2026via Public Schools First NC, is roughly $9,528. The gap is about $1,586 per voucher student. At full eligibility, closing that gap is the next ask.