Is this school in a HUD qualified census tract? §25F tutoring safe harbor checker

The census-tract safe harbor

Treasury’s proposed regulations (October 2026), which SGOs may rely on for 2027, include a safe harbor at proposed § 1.25F-3(c)(6)(iii)(C). When a Scholarship Granting Organization funds individual academic tutoring, or special-needs services for a special-needs student, and the school selects the students based on each student’s academic or other need, those students are treated as meeting the §25F household income test whether or not the SGO verifies household income. The school has to meet one of two tests:

• Location: the school is in a HUD qualified census tract; or
• Enrollment: the school certifies that at least 80% of its students live in a qualified census tract, wherever the school itself is.

The rule doesn’t limit this to private schools, so a public school that meets either test can use it too. Treasury estimates the safe harbor would make about 170,000 more students eligible.

What it waives, and what it doesn’t

It waives one thing: the household income check (income at or below 300% of area median gross income), and only for individual tutoring or special-needs awards to students the school picks by need. A family can’t opt in on its own. The rule doesn’t say whether a tuition award to the same student can skip the income check too, so the cautious reading is to verify income for any other award. The student still has to be eligible to enroll in a public school and live in a state where the SGO is listed, and the SGO still has to meet every other §25F rule, including the 90% spending test.

The annual audit

An SGO that uses the safe harbor must get a third-party audit every year and give it to the state. The audit has to certify that:

1. the school meets the census-tract test or the 80% test;
2. the school selected the recipients based on academic or special need;
3. the tutors or other providers were qualified to provide the services;
4. each student’s need, including the nature and extent of the services, was diagnosed independently by a professional not associated with the provider; and
5. the services met appropriate quality standards, were provided often enough and long enough to produce a benefit, and had their impact on each student assessed.

Which HUD list this checks

The proposed rule points to qualified census tracts as identified on HUD’s QCT map but doesn’t name a year, and HUD designates tracts every year. HUD’s 2027 list (14,539 tracts, published October 6, 2026) is the newest, and 2027 is the first year of §25F scholarships, so it is the main result here. We also show the 2026 list (14,496 tracts), which Treasury used for its estimate. By our count of HUD’s files, 1,695 tracts are new on the 2027 list and 1,652 dropped off, so a school’s answer can change from one year to the next.

Under 26 U.S.C. § 42(d)(5)(B)(ii), a qualified census tract is one where at least 50% of households have incomes below 60% of the area median gross income, or the poverty rate is at least 25%. The designated tracts in a metropolitan or nonmetropolitan area can’t hold more than 20% of that area’s population, so some tracts that meet the income test are not on the list.

All of this is proposed, not final. Comments are due December 1, 2026, and the final rule could change the safe harbor or say which year’s list applies. See our full guide to the census-tract safe harbor, our summary of the proposed regulations, and how SGOs verify income.

How this works

1. Enter the school's street address with city, state, and ZIP. Our server sends it to the U.S. Census Bureau's geocoder, which returns the census tract the address is in.
2. We look that tract up in HUD's official qualified census tract lists: the 2027 list (published October 6, 2026), which is the newest and matches the first year of §25F scholarships, and the 2026 list for comparison.
3. For the 80% route, paste student home addresses, one per line, up to 50 at a time. We count how many are in a qualified tract and compare the share to 80%. For a larger school, add each batch to the running total.
4. Addresses are used for that one check and are not logged or stored. Treat the answer as a first check: an SGO using the safe harbor needs an annual third-party audit that certifies the school's eligibility.

Questions, answered