The superintendents' association booked a White House meeting on the §25F rules. So did an attorney who forms SGOs.

When Treasury sent the §25F regulations to the White House on September 10, we pointed out that a short window had opened. While a rule sits at OIRA, the Office of Information and Regulatory Affairs, Executive Order 12866 lets any member of the public ask for a meeting about it, and the Treasury staff drafting the rule ordinarily attend. On September 11 the meeting log showed no requests on either §25F rule. It now shows two, both on RIN 1545-BR97, the proposed rule covering enforcement, recordkeeping, and reporting for Scholarship Granting Organizations.

The first is set for September 25 at 3:00 p.m. The requestor is listed as Christian Matozzo, with no organization named. An attorney of that name at Brown & Streza, a law firm that represents religious nonprofits, describes his practice as including the formation and operation of scholarship granting organizations, and says he is "working to form and qualify scholarship granting organizations under the provisions of both the Education Freedom Tax Credit and relevant state tax credit laws." The OIRA record does not say whom he is appearing for.

The second is set for September 28 at 2:00 p.m., requested by AASA, The School Superintendents Association, with Sasha Pudelski, its director of advocacy, as the contact. AASA refers to the credit as a "voucher program" in its own advocacy, and it has spent the year working on how the program will run. Last winter it filed comments asking Treasury to leave states broad discretion over the design. On July 30 it led a thirteen-organization letter to Treasury asking that the 90% spending test be measured against an SGO's segregated §25F account rather than its total receipts, that states be allowed to list an organization while its 501(c)(3) application is pending, and that qualified expenses be read broadly enough to cover afterschool, summer, and tutoring programs. AASA has also run a webinar series for district leaders under the title "Leveraging the Federal Scholarship Tax Credit." The meeting record does not list a topic, so what the association plans to raise on September 28 is not public, but that letter is the most recent statement of what it wants from these rules.

Both meetings are about BR97, not the companion rule, RIN 1545-BS17. BS17 is the one filed as an interim final rule, covering state elections and the SGO lists states submit this fall, and it binds the day it publishes. BR97 was filed as an ordinary proposed rule, so a formal comment period will follow its publication in any case. A meeting now is a chance to be heard before the draft goes public rather than after.

Some caution about reading too much into a calendar entry. A meeting request is not a position, and OIRA meetings are routine for rules this size. The attendee list and any materials handed over are posted on reginfo.gov after the meeting, and that record, not the booking, will show what each side asked for. Neither review has concluded, and nothing about the rules is final until they appear in the Federal Register. Treasury has said it expects the proposed regulations by the end of September.

The request that stands out is AASA's. The superintendents' association is taking its requests directly to the people drafting the rule, which is the same direction we saw when a Kentucky SGO built by regional development districts said it would fund public-school students. The statute allows it: eligibility follows the student's household income, not the school the student attends, and qualified expenses include tutoring, special-needs services, and technology. How the final rules treat those expenses and the 90% test will decide how practical a public-school SGO is. For more on how the credit can reach public-school families, see our guide for public schools. If you already run a nonprofit and are weighing whether to add an SGO, read converting an existing nonprofit, and see who is already organizing in the SGO directory. We will report what the meeting records show once they post.