Columbus County educators formed an SGO so North Carolina's §25F scholarships reach their own public school students

A rural North Carolina school district's own educators have built a scholarship granting organization for its public school students. The Columbus County Educational Opportunity Foundation was formed in June by Kelly Jones, the district's arts education director; Dan Strickland, a former Columbus County Schools superintendent; Laura Hunter, the district's chief academic officer; and teacher Anthony Martin, the Border Belt Independent reported on October 7. The foundation has tax-exempt status and wants to be on the list of qualifying SGOs North Carolina sends to the IRS. If it makes the list, it plans to raise money for academic, arts and other programs for the district's 5,200 students, 74% of whom are economically disadvantaged.

“We're always looking for opportunities for kids, ways that we can expand their learning in the classroom and outside the classroom,” Jones said. “A lot of those take money.” The district is on board. “Like many rural districts, we are always looking for additional partnerships and resources that can benefit students,” Superintendent Eddie Beck said in a statement, calling the foundation “a potential partner that could bring new opportunities directly to children and families in our community.” Jones is counting on local businesses and families, who he says “consistently step forward” for students: “When you combine a program like this with a community that has consistently demonstrated its willingness to invest in its children, I believe the benefits can be extraordinary.”

This is the model Gov. Josh Stein pointed to in June, after the legislature overrode his veto, when he said he wanted to make it easy to direct §25F donations to SGOs that benefit public school students. Columbus County now has one forming. It joins a growing list of public school systems treating the credit as money for their own students: Denver and Clark County, Nevada, Logan and Russell counties in Kentucky, Pasco County, Florida, and three new Colorado groups.

Why a separate foundation. A school district is a unit of government, not a 501(c)(3) public charity, so it cannot be an SGO itself. A foundation can. A §25F scholarship follows the student: a child qualifies if household income is at or below 300% of area median gross income and the child is eligible to enroll in a public school, and the qualified expenses come from the Coverdell list in section 530, which includes tutoring and special needs services. Treasury's detailed guidance on exactly which expenses qualify is still to come. The SGO, not the district, awards the money, and it must fund at least 10 students who do not all attend the same school, spend at least 90% of its income on scholarships, and never earmark a gift for a particular student. Our guide to what §25F allows for public school students walks through it.

Two rules a staff-founded SGO should plan around. First, under the October 1 proposed rules, an SGO's officers and directors, anyone who helps select recipients or set awards, and all of their family members are disqualified persons who cannot receive scholarships, with no exception for blind selection or volunteers. In a foundation run by district educators, that reaches the founders' own children and grandchildren in the district, so it pays to settle early who sits on the board and who sits on the selection committee. Second, the proposed rules offer an income-verification safe harbor for individual tutoring or special-needs services at schools in a HUD qualified census tract, or schools that certify at least 80% of their students live in one, with students chosen by the school on need and an annual third-party audit. For a high-poverty rural district, that route may fit some schools well, depending on where they sit.

The North Carolina clock. The state's opt-in law names the North Carolina State Education Assistance Authority as the office that certifies SGOs and submits the list, and gives it 120 days from the federal regulations to write its rules, which runs to about late January 2027. The Authority's SGO page now says it is reviewing the federal materials and will begin developing its guidance in the coming weeks; there is no application yet, and questions go to SGO_NC@ncseaa.edu. The 2027 list is due to the IRS by February 15, 2027 (full calendar). Every SGO must also register on the IRS SGO portal, which has not opened. Donations can start January 1, 2027, at up to $1,700 per taxpayer, or $3,400 for a married couple when each spouse gives.

Track the state's process on our North Carolina SGO page and the North Carolina state page. A district foundation working toward the same list can go through formation and compliance step by step with the free SGO Builder.