Audit ESAs Like We Mean to Keep Them

This week, state auditors dug into the spending data for the 2024-25 school year for the Utah Fits All scholarship program and surfaced purchases they deemed “wasteful and extravagant”: ski passes at Snowbird, zoo memberships, bicycles.

Critics of education savings accounts got the headlines they want, and every expansive ESA program in the country got a preview of the test it will eventually face.

But the more useful question for those of us who believe in educational freedom for all families is a step removed from the particulars of Utah’s finances. When an audit like this happens, what should we actually do with the information?

It is worth stating plainly before anything else: the auditors themselves concluded that the majority of scholarship funds went to legitimate educational expenses, mostly for private school tuition. The controversy, in other words, is about the margins. That context appeared in the official report and vanished from most of the headlines, which is itself instructive.

When reviewing an audit report, I’d recommend doing three things. First, ask if the purchase is something that other schools already buy. Second, keep an open mind. And third, avoid overreaction. Let’s go one by one.

Ask the question, do other schools purchase this?

Let’s begin with the purchases themselves, because they deserve a harder look than the coverage gave them. Public school districts fund ski trips. They charter buses to the zoo every spring. They buy PE equipment, stock band rooms with instruments, and furnish classrooms—all with taxpayer dollars, all without a state audit or a news cycle to follow. The purchases are often the same; what changes is the decision maker.

In fact, in this case, some of the purchases labeled extravagant by the auditors have been happening in K-12 education for quite some time. SkiUtah (the membership association representing Snowbird, one of the ski resorts quoted in the article) boasts the following on their website: “The 4^th grade Ski Utah Program has been in place for over 30 years. In that time, Ski Utah has successfully introduced alpine snow sports to over 150,000 students who widely claim the trip to be the best field trip of the year.”

In a similar vein, Utah’s Hogle Zoo offers free field trips to K-12 public, private, or charter schools in Utah. Homeschool students, unfortunately, are not eligible for the field trip discount. It’s worth noting the zoo itself is already publicly subsidized for everyone else, as Hogle Zoo receives millions in taxpayer funds through Salt Lake County’s ZAP sales tax.

A homeschooling parent who buys a Hogle Zoo membership for their child’s education is doing precisely what a public school administrator does when they book a field trip to the zoo for their students.

If a bicycle counts as physical education when a school buys thirty of them, it is worth asking why it becomes extravagance when a family buys one.

Keep an open mind

Going back to the original question of what to do with this audit information, I feel strongly that we should keep an open mind as to what qualifies as an educational expense. The audit painted zoo memberships and ski passes in a negative light, despite the fact that Utah’s public schools have deemed these activities acceptable for decades. That suggests a lack of open-mindedness and impartiality. These examples feel like a decently easy test that state auditors and media, so far, have failed.

And we’re going to need open-mindedness to fairly interpret more challenging examples.

Figuring out whether something constitutes a legitimate educational expense won’t always be as straightforward as a zoo membership. Imagine a family purchases a $3,000 drone for their child’s education. The shocking headline practically writes itself, but FAA Part 107 certification is a genuine career credential that a student can earn at 16. Learning to be a drone pilot can easily feed into surveying, agriculture, cinematography, or emergency services work in the future.

There are endless hypotheticals for this exercise, but we need to remember the reason these programs exist in the first place: to enable families to choose the individualized education that works best for their child. These programs are meant to empower families, the ones who have more interest in their child’s education and more intimate knowledge of their needs than anyone else. The future is changing rapidly, while student learning is on a trajectory to becoming more personalized than ever before. We have no idea what the future will ask of this generation of students or what problems they’ll be tasked with solving. If we start limiting what ESA funds can be used for, we are effectively narrowing our list of tools to equip students for future learning. What may seem “extravagant” now could very well become vital to learning in the next few decades.

There are more prudent questions that the auditor’s report brought to the surface, though. For example, the auditors flagged that more than half of the computers reimbursed through the program cost over $1,000 and recommended spending caps in response. It was noted that 70% of school-issued devices in Utah are Chromebooks and cost less than $800 on average. Price reasonableness is a completely fair question for any program using public funds, and one that a cap can address without banning an item outright. That, to me, is a fairer critique than the educational legitimacy of ski or zoo passes, and one worth engaging on its merits.

Avoid overreaction

Utah’s policymakers, unfortunately, already modeled the wrong response before the auditors even finished their work.

In 2025, reacting to earlier expense reporting, the Legislature banned ski passes, furniture, and musical instruments outright; capped extracurricular and physical education spending at 20 percent per scholarship; and cut award amounts for homeschooling families nearly in half for younger students. Each measure followed the same reflex: an outlier purchase gets heat in the media, so policymakers create a categorical ban. Repeat that cycle a few times and voila—you have rebuilt, restriction by restriction, the line-item budget logic these families opted out of in the first place. Flexibility is the entire value proposition of an ESA. Regulate it away and what remains is a smaller, clumsier voucher with extra steps.

So here is a better habit for policymakers when the next audit arrives.

First, separate fraud from preference. Self-dealing, fake vendors, and reimbursements for goods that never existed should be policed aggressively; the credibility of every ESA program depends on it. A purchase you personally would not have made is a different thing entirely. That is pluralism doing its job.

Secondly, when guardrails are genuinely needed, prefer structural ones (such as provider vetting or price thresholds) over statutory lists of forbidden objects. A legislator in Salt Lake City is poorly positioned to decide what educates a particular child in Cedar City, which is the founding insight of the program itself.

None of this argues against auditing ESA programs. It argues for auditing them like we mean to keep them. These programs are version 1.0 of something larger: an adaptive educational marketplace where funding follows children to whatever combination of schools, tutors, materials, and experiences their families assemble.

Version 1.0 of anything is messy. States with newer, larger ESA programs like Arkansas, Iowa, or Texas will see similar audits and similar media commentary. The question is whether we respond to any bumps in the road with a clear mind or with overreaction.

This was originally published to our Substack.