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    Harnessing the EITC and Other TaxCredits to Promote Financial Stabilityand Economic MobilityBy Rebecca Vallas, Melissa Boteach, and Rachel West October 2014

    WWW.AMERICANPROGRESS.ORG

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    Harnessing the EITC andOther Tax Credits to PromoteFinancial Stability andEconomic MobilityBy Rebecca Vallas, Melissa Boteach, and Rachel West October 2014

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    1 Introduction and summary

    3 Recent improvements must be made permanent

    4 Building on recent proposals to strengthen the EITC and C

    6 Enhancing the EITC as a tool to build savings

    10 Harnessing the EITC as a financial stability tool

    15 Harnessing the EITC to increase access to educationand training

    18 Conclusion

    19 About the authors and acknowledgments

    20 Endnotes

    Contents

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    1 Center for American Progress | Harnessing the EITC and Other Tax Credits

    Introduction and summary

    Te Earned Income ax Credi , or EI C, is one o he na ions larges and moseffec ive an i-pover y ools. I is a ederal ax credi or low- and modera e-income workers ha encourages work, boos s amily income, and offse s ederal payrolland income axes. In 2012, i helped more han 6.5 million Americans including3.3 million children avoid pover y.1 Te Child ax Credi , or C C, pro ec edabou 3 million people 1.6 million o hem children rom pover y in he same year.2 A growing body o research nds ha hese credi s are effec ive ools or

    boos ing economic mobili y: Children whose amilies receive he EI C and o herincome suppor s have higher ra es o high school comple ion and increased adulearnings.3 In addi ion o mi iga ing economic hardship, hese ax credi s serve asa power ul source o economic s imulus. For example, he EI C genera es some$1.50 o $2.00 in economic ac ivi y or every $1 ha goes o working amilies.4

    Bo h he EI C and C C have enjoyed wide bipar isan suppor hroughou heirhis ory. Presiden s rom bo h poli ical par ies have aken ac ion o s reng hen heEI C since i s enac men in 1975, and more recen ly, epublicans and Democra salike have joined in praising he program or i s effec iveness as an an i-pover yool.5 However, while he EI C effec ively boos s economic securi y amongamilies headed by low-wage workers, i is no a subs i u e or a living wage. Effor so s reng hen he EI C and C C mus go hand in hand wi h minimum-wage poli-cies o ensure ha no one who works ull ime has o live in pover y.6

    Congress should ac on several exis ing proposals o s reng hen he EI C andC C, such as making permanen he improvemen s enac ed as par o he American ecovery and einves men Ac o 2009, or A R; enhancing heEI C or workers wi hou quali ying children and lowering he minimum age

    or EI C eligibili y, as recommended in he new Genera ion Progress repor ALadder Up; and making he C C ully re undable and ying i s value o ina ion.In addi ion, his repor offers a se o new policy solu ions ha harnesses he EI Cas a ool or nancial empowermen and upward economic mobili y. Tese recom-menda ions include:

    The Center for AmericanProgress Poverty toProsperity team is explopolicy solutions thatstrengthen and modernizour nations safety net toreect 21st century reali

    and to better facilitateeconomic mobility forfamilies on the brink.

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    2 Center for American Progress | Harnessing the EITC and Other Tax Credits

    S reng hening he EI C as an asse -building ool or amilies who wish o useheir ax re unds o build savings

    Crea ing an early-access provision ha allows workers o access a small por iono heir EI C ahead o ax ime so hey do no have o rely on preda ory lending

    produc s and can ake advan age o mobili y-enhancing oppor uni ies

    Increasing access o higher educa ion and raining hrough ca egorical eligibili yor he maximum Pell Gran or EI C recipien s and re orms o s reng hen he

    American Oppor uni y ax Credi

    Building on exis ing proposals o s reng hen he EI C, hese re orms wouldenhance he credi s effec iveness as a ool or promo ing economic mobili y.

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    3 Center for American Progress | Harnessing the EITC and Other Tax Credits

    Recent improvements must bemade permanent

    Several key improvemen s o he Earned Income ax Credi and Child ax Credi were enac ed in 2009 as par o he American ecovery and einves men Ac .Firs , A R s reng hened he EI C or amilies wi h hree or more children, recog-nizing he ac ha larger amilies ace higher living cos s and are much more likelyo be poor han smaller amilies. Second, i lessened marriage penal ies or dual-earner amilies, addressing he reduced ax credi s ha some couples ace i heydecide o marry. Simul aneously, eligibili y or he C C was ex ended o working

    paren s wi h low earnings. Te C C is par ially re undable, subjec o an earnedincome hreshold. Te A R reduced his hreshold rom more han $12,500 o$3,000 s ar ing in 2009.7 Tis has enabled many more low-income amilies o ben-e rom he C C and has increased he amoun o credi or which hey quali y.8

    Tese re orms have had a power ul an i-pover y effec . Te improvemen s madeo he EI C helped an es ima ed 600,000 people avoid pover y in 2012; heylessened he severi y o pover y or an addi ional 10 million people in he same year.9 Likewise, he changes o he C C lifed an es ima ed 900,000 people ou opover y in 2012.10

    However, hese impor an improvemen s are se o expire in December 2017.11 Ac ion is needed o make hem permanen and o ur her s reng hen he EI Cand C C.

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    4 Center for American Progress | Harnessing the EITC and Other Tax Credits

    Building on recent proposals tostrengthen the EITC and CTC

    Policymakers have proposed several key re orms o s reng hen hese credi s abil-i y o boos he economic securi y o working amilies. As curren ly s ruc ured,he Earned Income ax Credi offers scan assis ance o workers wi hou quali-ying children12 he only group o very low-income earners who s ill see heirincomes subs an ially reduced by ederal income axes. Te maximum EI C or workers wi hou quali ying children is less han one- en h o he credi availableo amilies wi h wo children. Policymakers o all poli ical s ripes13 as well as our

    colleagues a Genera ion Progress14 have called or s reng hening he credi or workers wi hou quali ying children.15

    Te very limi ed credi curren ly available o childless workers and noncus odialparen s means ha hese workers are excluded rom he demons ra ed bene s ohe EI C, which include increased income, reduced pover y ra es, and increasedlabor-marke par icipa ion. Fur hermore, wi h he EI CS curren s ruc ure, hisgroup o workers may ac ually be a a disadvan age, as research sugges s ha heEI C implici ly leads employers o pay somewha lower wages.16 Tus, work-ers wi h children who receive he EI C experience a ne gain in income despi ehe wage decrease, bu workers wi hou quali ying children may end up wi h ane loss: Tey compe e or he same jobs bu are ineligible or a ax credi hamore han offse s any reduc ion in marke wages. Boos ing he EI C or childless workers and noncus odial paren s would largely address his problem. In addi ion,using minimum-wage policy o es ablish a s rong wage oor would limi employ-ers abili y o reduce overall marke wages in response o he boos in labor supplyhe EI C crea es.

    Fur hermore, many policymakers have proposed lowering he minimum age o

    eligibili y or childless workers curren ly 25 years o age o allow young adul s wi hou quali ying children o bene rom he EI C.17 When he EI C was rsin roduced, workers under age 25 wi hou quali ying children were excluded dueo he difficul y o de ermining s uden s a us or ax purposes. In ligh o improve-

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    5 Center for American Progress | Harnessing the EITC and Other Tax Credits

    men s in In ernal evenue Service da a-collec ion procedures ha make i pos-sible o dis inguish young people in he labor orce rom s uden s, our colleaguesa Genera ion Progress have recommended lowering he age o eligibili y o 18or young childless workers no claimed as dependen s on o hers ax re urns.18 Tis will enable young workers who are jus s ar ing ou in heir careers and or whom labor- orce par icipa ion and unemploymen remain eleva ed ollowing he2008 recession o bene rom he EI C. A ur her op ion discussed in heGenera ion Progress repor A Ladder Up is o ex end he EI C o low-incomes uden s who are nondependen s or ax purposes and who are working o puhemselves hrough school.19

    In addi ion o hese changes, wo common-sense re orms should be made o heChild ax Credi . Firs , i should be made comple ely re undable so ha he mos vulnerable amilies can bene rom i s ull value. Second, i s value curren ly$1,000 per child should be indexed o he ra e o ina ion. Indexing is impor-

    an o preven he value o he C C rom con inuing o erode, which shrinks heamoun o assis ance amilies receive wi h each passing year.

    Building on hese proposals, he ollowing policy solu ions would ur her booshe EI Cs power o promo e nancial s abili y and economic mobili y.

    Despite the fact that paid tax preparers remain EITC lersmost common access point to the tax system, the federalgovernment currently lacks the authority to regulate them.

    Although the IRS requires tax preparers to register with it,the courts have prohibited it from licensing and regulatingthem.20 Regulation at the state level is scarce as well: Only fourstates regulate paid tax preparers. 21 A recent report from theGovernment Accountability Office, or GAO, found that paidpreparers often make errors in ling.22 But in Oregonone ofthe states that regulate tax preparersGAO found that paidpreparers were 72 percent more likely to le accurate returnsthan the rest of the nation. 23 The GAO thus recommendedthat Congress consider legislation to allow the IRS to regulatethe industry in order to promote high-quality services from

    paid preparers, improve voluntary compliance, and ftaxpayer condence in the fairness of the tax system.24

    In keeping with this recommendation, President BarackObamas scal year 2015 budget proposal called for legithat would give the U.S. Treasury Department and the IRauthority to regulate paid preparers.25 Congress should asuch legislation to protect tax lers from costly errors; suregulatory authority would also enable the federal goverment to require increased transparency in paid preparersstructures. This would ensure that EITC lers are fully awhow much they can expect to pay for tax preparation assand thus are able to make informed decisions when selecpreparer to help them access their modest refunds.

    Unregulated tax preparers put low-income taxpayers at risk

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    6 Center for American Progress | Harnessing the EITC and Other Tax Credits

    Enhancing the EITC as a toolto build savings

    Savings are cri ical o help amilies wea her unan icipa ed nancial shocks. Evena small savings reserve can be a li eline or amilies, allowing hem o keep up onmor gage or ren paymen s, buy ood or heir children, or pay essen ial bills dur-ing nancial emergencies. In addi ion, having savings o all back on makes ami-lies less likely o need public assis ance in order o make ends mee when aced wi h an income shock. Fur hermore, savings help amilies plan or he u ure,enhancing heir long- erm nancial securi y and prosperi y.

    Ye , despi e he cri ical impor ance o building savings, many American amiliesare unable o do so due o a varie y o challenges. igh budge s, daily nancials rain, and unexpec ed emergencies as well as lack o access o affordable savingsmechanisms make i par icularly difficul or low-income amilies o regularlyse aside money. According o he FINR Inves or Educa ion Founda ions 2012Na ional Financial Capabili y S udy, wo in ve American amilies repor hahey would probably no or cer ainly no be able o come up wi h $2,000 in30 days in he even o an emergency or unexpec ed expense.26 Among amilies ahe botom hird o he income ladder, his share rises o 68 percen .27 Accordingo a separa e repor rom he Federal eserve, nearly hal 45 percen oresponden s repor ed ha hey did no save any share o heir income in 2012.28 Tese gures highligh he high degree o economic vulnerabili y among many American households.

    ax ime can provide a pla orm or helping recipien s o he Earned Income axCredi build crucial savings. Te majori y o EI C recipien s ge money back aax ime in he orm o a re und.29 In ac , he EI C is ofen he larges lump-sumpaymen ha low-income amilies receive all year: Te average EI C received in

    2013 was $2,335.30

    S udies indica e ha people are more likely o save par o largelump sums such as ax re unds han o save smaller, incremen al amoun s suchas paychecks.31 Tis may be par icularly rue or low-income amilies who livepaycheck o paycheck.

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    7 Center for American Progress | Harnessing the EITC and Other Tax Credits

    Indeed, many EI C recipien s already op o save a ax ime. A recen surveyound ha saving was among he mos common uses o ax re unds or EI Crecipien s: 47 percen repor ed saving a por ion o heir re unds.32 However, aneven higher percen age o EI C recipien s would like o save a por ion or savea grea er por ion o heir re und a ax ime: 69 percen o recipien s planned o

    save a share o heir EI C.

    Policymakers could ake several s eps o make i easier or EI C recipien s o build savings during ax ime. As his repor ou lines, policymakers could ur hersuppor hose already engaged in saving or planning o save and could provideaddi ional oppor uni ies and incen ives o hose who may wan o do so. A recenCen er or American Progress repor , Helping Families Build Weal h a axime, ou lines how Congress, he I S, and s a e policymakers can promo esavings among low-income amilies a ax ime.33 Drawing upon hese recom-menda ions, he s eps ou lined in he ollowing sec ions could make saving more

    rewarding, au oma ic, and exible or EI C recipien s.

    Make saving more rewarding

    In order o make saving more rewarding or EI C recipien s, Congress shouldmake wo modica ions o he Savers Credi , which provides a par ial ma ch orhe rs $2,000 o savings $4,000 or married couples ling join ly depos-i ed in a re iremen accoun .34 In i s curren orm, he credi is no re undable,meaning ha he many recipien s who have litle or no ederal income axliabili y are unable o bene rom i . Congress should make he Savers Crediully re undable.

    Second, al hough he Savers Credi ma ches savings a a ra e o 50 percen or l-ers wi h adjus ed gross incomes o $27,000 or less $36,000 or married cou-ples he ma ching ra e drops off s eeply as earnings increase, o 20 percen and10 percen or single and married lers, respec ively.35 Tis means ha incomess ill land well below he EI C hreshold. Smoo hing hese cliffs in he ma chingra e would spur more EI C recipien s o ake advan age o he credi , encouraging

    and bols ering savings or a grea er share o low-income amilies.

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    8 Center for American Progress | Harnessing the EITC and Other Tax Credits

    In addi ion o modi ying he Savers Credi , re orming he asse limi s ha remainin cer ain public assis ance programs is necessary o remove signican savings barriers or EI C recipien s. Tese coun erproduc ive asse limi s, or eligibili yrequiremen s ha penalize savings and ownership, can make i difficul i noimpossible or amilies o ge he help hey need when hey all on hard imes

    and can effec ively prohibi amilies rom building savings as long as hey con inueo receive assis ance. Moreover, he exis ence o asse limi s discourages sav-ings among low-income amilies who canno afford o lose access o vi al publicprograms. Tis is de rimen al, as grea er savings will bols er amily economicsecuri y and enable progress oward economic sel -sufficiency. As recommendedin a recen CAP repor , Asse Limi s Are a Barrier o Economic Securi y andMobili y, asse limi re orm is needed o remove barriers o savings.36

    In 2010, Congress excluded he EI C rom considera ion as income or as an asseor one year in ederally unded, means- es ed programs; i made his impor an

    s ep permanen in 2013. In s a es ha have no already done so, policymakersshould exemp amilies EI C re unds rom s a e- unded programs. Addi ionally,Congress and s a e policymakers should exclude ax- ime savings rom coun ingagains asse limi s in all public assis ance programs.

    Make saving automatic

    ecognizing ha making saving easy and widely available can grea ly encouragepeople o save, he I S allows ax lers o designa e a por ion o heir ax re undor he purchase o U.S. savings bonds.37 Addi ionally, he I S provides lers wi hhe op ion o direc deposi o heir ax re unds.38Going orward, he ndings opilo programs such as e und o Savings an experimen launched in 2012 oes ways o presen ax- ime savings op ions may offer ur her lessons or hedesign o au oma ed savings oppor uni ies.39 As a growing number o Americansu ilize ree online sofware o comple e heir axes, in egra ing recommenda ionsrom such experimen s in o I S-approved sofware, such as urbo ax and H&Block, could reach an expanding audience.

    Impor an ly, one barrier o saving during ax ime is ha many EI C recipien s dono have checking or savings accoun s and hus have no place o direc ly deposia por ion o heir re unds.40 Te I S could address his problem by making i easyor hose who do no already have bank accoun s o open sa e, affordable savingsaccoun s a ax ime.

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    Make saving flexible

    Fur hermore, lers mus have a 401(k) or IR in order o ake advan age o heSavers Credi . Tis excludes many low-income amilies who do no have pre-es ablished re iremen accoun s or who may have more immedia e savings goals

    han re iremen . Ex ending he Savers Credi o accommoda e a wider range osavings objec ives and sa e, affordable accoun ypes could enable more amilieso ake advan age o his ma ching oppor uni y. Tese accoun s could includesavings bonds, cer ica es o deposi , and higher-educa ion savings accoun s suchas Sec ion 529 and Coverdell accoun s. In par icular, ex ending savings oppor u-ni ies o help amilies reach heir educa ion-rela ed goals could have he addi-ional bene o encouraging low-income children o seek ou higher educa ion.esearch sugges s ha dedica ing even very small amoun s o savings o highereduca ion can signican ly increase he likelihood ha children atend college.41

    The Treasury Offset Program, or TOP, is a mechanism for col-lecting certain kinds of federal and state debts via the with-holding of federal payments such as federal tax refunds.42 Eachyear, many low-income workers see their EITC refund partly orentirely withheld through the TOP to pay old debts.43 As muchas 100 percent of an individuals federal tax refundincluding

    the EITCcan be withheld to repay certain types of debts, suchas federal student debt and child support arrears.

    As a result, the TOP unintentionally erodes the EITCs power asan anti-poverty tool for low-income workers and their families.Protections are needed so that low-income workers do not see

    their earned EITC refunds seized, thus diminishing this tant boost to their household incomes.

    Recognizing the hardship that can result from the garnisof federal payments, the TOP already includes limits on percentage of certain types of payments that can be with

    For example, Social Security payments can only be withup to a cap of 15 percent of the monthly benet.44 To prolow-income workers, Congress should adopt a similar ca15 percent for TOP withholding of the federal tax refundEITC recipients and other low-income lers who live unpercent of the federal poverty level.

    Reforming the Treasury Offset Program to protect low-income Americansand their families

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    Harnessing the EITC as a financialstability tool

    As discussed above, he lump-sum na ure o he EI C can make i a power ul oolo help amilies build savings. However, because workers mus wai un il afer heend o he year o claim he credi ha hey have spen he en ire year earning,hey may all behind on expenses in he mean ime. Many amilies are orced ourn o preda ory lending produc s, which can resul in a downward deb spiral.Families may also nd hemselves shor on cash needed o inves in imely oppor-uni ies ha promo e upward mobili y, such as aferschool enrichmen programs

    or heir children.

    While o her in-kind work suppor s such as he Supplemen al Nu ri ion Assis anceProgram ormerly called ood s amps or Medicaid can help offse some olow-wage workers basic expenses, he EI C provides one o he ew signi-can sources o discre ionary income ha s ruggling amilies can use o pay orexpenses ranging rom car repairs o inves men s in heir childrens educa ion.However, or amilies living paycheck o paycheck, a broken radia or or unex-pec ed medical bill may no be able o wai un il ax ime. Tis leads some o urno preda ory lending produc s, such as payday or au o i le loans, o make endsmee . While hese ypes o loans average only abou $375, hey can send amiliesspiraling in o pover y: Te inabili y o repay loans wi h usurious in eres ra es canrap borrowers in a cycle o deb , cause people o lose he cars hey need o ge o

    work, and presen o her barriers o geting or keeping jobs.45

    A po en ial solu ion is o in roduce a par ial Early e und elemen in o heEI C. Tis ea ure would preserve he EI Cs abili y o help amilies build sav-ings, while a he same ime giving hem access o discre ionary income o meenancial challenges or oppor uni ies ou side o ax season. CAPs Early e und

    proposal is discussed in de ail below.

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    Lessons from past policies

    Te abili y o access EI C unds ahead o ax ime is no a new idea. Un il 2010,an EI C op ion called he Advance EI C allowed workers wi h quali ying chil-dren o access unds earlier.46 Workers could choose o claim up o 60 percen o

    heir an icipa ed EI C as par o heir rou ine pay; employers used ables similaro wi hholding ables o de ermine how much money hey should add o employ-ees paychecks each pay period.

    However, less han 3 percen o eligible workers ook advan age o he program,and here were several downsides o i s approach.47 Firs , he program was difficulo adminis er and had a high error ra e. Some Advance EI C recipien s did nohave a valid Social Securi y number, some did no have a quali ying child, andsome did no le he required ederal ax re urn a he end o he year. Amonghose who did le, many ailed o repor receiving he Advance EI C perhaps

    orgeting hey had par icipa ed, as he money came as par o heir regular pay-checks. Some employers repor ed providing he Advance EI C which loweredhe amoun o payroll axes hey were required o deposi bu did no add hepaymen s o workers paychecks. Given he very small amoun s o money workersreceived hrough he Advance EI C, he I S rarely ook ac ion agains par ici-pan s in he program who erroneously received unds.

    Impor an ly, workers also eared owing money o he I S a he end o he yeari heir earnings differed rom ini ial expec a ions.48 Tese ears were largelyun ounded, since he advance paymen was pegged o earnings in he con empora-neous pay period, adjus ed o reec changes in hours or pay, and s opped i he jobended. However, addi ional earnings by a spouse, rom a second job, or rom sel -employmen could change he amoun o EI C or which workers qualied, andi workers were ound ineligible or he EI C a ax ime, hey would owe advancepaymen s o he I S. Uncer ain o he eligibili y rules, many workers eared ha byaccep ing an Advance EI C, hey risked owing money a ax ime. Tis rein orcedhe idea ha wai ing or he lump-sum re und was he sa es op ion.

    Ano her drawback o he Advance EI C is ha i delivered he credi in he orm

    o an ongoing wage supplemen . S ruc uring he credi in his way could under-mine effor s o raise he minimum wage. esearch indica es ha approxima ely25 percen o he EI C is effec ively passed on o employers in he orm o loweremployee wages.49 Providing he EI C as a rou ine par o workers paychecks risksrein orcing or even increasing he role he EI C plays in allowing employers

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    o offer lower wages. Ins ead, he EI C should be viewed as an impor an comple-men o he minimum wage in boos ing he earnings o low-wage workers.50

    Policies ha crea e an avenue o access par o he EI C ahead o ax ime musaddress hese challenges and limi a ions.

    Insurance against predatory lending and a chance to invest inmobility opportunities

    o address he problem o insufficien access o income a nancially sensi ivepoin s hroughou he year which leaves amilies vulnerable o preda ory lend-ing while mi iga ing he shor comings o he Advance EI C, CAP proposes apar ial Early e und op ion wi hin he curren EI C.

    Under his op ion, workers would be able o access he par o he EI C accruedin he rs hal o he year a some poin during he second hal o he year.S ar ing on July 1 o a given year, workers could access he por ion o he EI Chey earned up o ha poin , subjec o a cap o $500 and indexed o he ra eo ina ion in u ure years. Since he value o he ypical payday loan is abou$375,51 his amoun would be sufficien o preven many ins ances o preda orylending and hus preclude he high cos s and cycles o deb associa ed wi hsuch lending prac ices.52

    Because he Early e und op ion would require workers o projec heir es ima edEI C, workers who use he op ion should be required o le axes a he yearsend under he same s a us single or join ha hey declared or purposes ohe Early e und op ion. Ta is, in he even o a ling s a us change hroughouhe year such as marriage he workers ling s a us or ax purposes would noreec he change un il he ollowing year.

    Enabling workers o access a par ial re und six mon hs in o he year wouldmake i unlikely ha changed circums ances could cause hem o owe he I Smoney a ax ime: Po en ial recipien s would already have worked or hal he

    year, es ablishing an income base. Moreover, workers who ended up receiving asmaller EI C han hey originally expec ed likely would s ill be pro ec ed againsindeb edness o he I S because hey would have received only a rac ion o heirprojec ed credi s.53

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    Given ha mos amilies receive a lump-sum ax re und be ween February and Aprilor heir previous years work, hose ha experience nancial dis ress generally havea small nancial cushion o ge hem hrough o July 1. A his poin , hey would be able o access he earned por ion o he curren years credi i he need arose. Inaddi ion, approxima ely wo- hirds o workers EI C would s ill be available he ol-

    lowing year in a lump sum, preserving heir abili y o use i as a savings ool.

    Under his model, a amily acing evic ion, scrambling o ge he hea urned back on, or s ruggling o come up wi h cash or car repairs could access money ahe ime o he emergency, ra her han wai ing weeks or mon hs o ge help andpo en ially urning o payday lenders in he mean ime.

    Such a policy mus go hand in hand wi h an expansion in he EI C or adul s wi hou quali ying children, which is curren ly signican ly lower han he EI Cor households wi h cus odial children. I an expansion in he EI C or childless

    adul s were no pu in place in andem wi h an Early e und op ion, access ohese small advance lump sums would be limi ed o amilies wi h children, heonly group whose credi is large enough o meri receiving up o $500 in advance.

    Under his proposed expansion o he childless workers credi , he cap o $500 would be sligh ly less han hal o he maximum credi available. In 2011, heaverage EI C claimed by childless workers $270 was abou 58 percen o hemaximum possible credi o $464.54 Presuming his patern con inues under heexpanded childless worker credi , which would raise he maximum EI C or hisgroup o $1,005 per year, he average EI C claiman wi hou quali ying children would receive abou $585 well above he $500 maximum Early e und. For workers wi h children, he $500 cap is much lower rela ive o he average an ici-pa ed EI Cs. In 2011, he average EI C or workers wi h one or more quali yingchildren was abou $3,050 in odays dollars;55 he maximum Early e und would be only abou 16 percen o ha amoun .

    Te goal o he Early e und op ion would no be o ac as a wage supplemen , asearlier models o he Advance EI C envisioned. In ac , he de aul op ion woulds ill be or amilies o receive 100 percen o heir ax re und as a lump sum a

    he normal ime. Te Early e und would ins ead be a orm o earned insuranceagains he ypes o unexpec ed expenses ha can lead o a downward spiral oreduced income and deb . Addi ionally, i could serve as a sor o earned oppor-uni y und, enabling amilies o capi alize on imely upward mobili y oppor uni-

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    ies, such as summer enrichmen programs or heir children. Te success o heproposal would no be measured by i s ake-up ra e bu ra her by a decline in heshare o amilies urning o preda ory lenders.

    Conceiving o he Early e und EI C in his way, as opposed o an ongoing wage

    supplemen , dis inguishes i rom policies ha allow employers o pay pover y-level wages. In order o maximize heir effec iveness, enhancemen s o he EI Cshould be made in andem wi h an increase in he minimum wage.

    Administration of the partial Early Refund option

    CAP proposes pilo ing he EI C Early e und o observe how i per orms. Tepilo programs could be rolled ou in several areas hroughou he year o es sev-eral differen kinds o approaches. One ype could be adminis ered hrough a sys-

    em similar o he quar erly ling ha sel -employed Americans u ilize, in which aler sends a orm o he I S or processing on or afer a cer ain da e wi h income verica ion in orma ion, making i easier or he I S o rack and iden i y people who did no subsequen ly le a ax re urn. In a leas one o hese models, he piloshould be unded o include addi ional suppor or keeping Volun eer Incomeax Assis ance, or VI A,56 available afer ax season o help people ake advan ageo his op ion a no cos . Chicago is curren ly es ing a quar erly advance EI Csys em, which engages VI A si es o provide ling suppor ; i s ndings couldin orm program design.57 O her pilo programs could explore wha happens whenamilies do no receive VI A suppor and ei her le independen ly or wi h anen i y such as H& Block.

    Ano her pilo op ion is adminis ra ion hrough employers, who would requireheir employees o ll ou a W-5 orm ormerly used or he Advance EI C. Inhe even ha an employee elec ed o use he Early e und op ion, he employer

    would advance he money o hem and offse he amoun by reducing payroll axdeposi s. Tis was wha happened in he Advance EI C.

    Te Early e und could be evalua ed bo h in erms o i s goals reducing he

    need or amilies o urn o preda ory loans and reducing ma erial hardship as well as i s adminis ra ion. Te resul s o he pilo programs would in orm hedesign o an Early e und op ion ha could be brough o scale.58

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    Harnessing the EITC to increaseaccess to education and training

    Many low-wage workers canno realis ically afford o go back o school, ge heirGED, or ob ain he addi ional qualica ions or licensure hey need o advance inhe job marke . As discussed in he recen CAP repor Harnessing he ax Codeo Promo e College Affordabili y, bo h prohibi ive cos s and lack o awarenessregarding he aid available o low-income s uden s presen signican barriers oaccessing higher educa ion,59 precluding upward economic mobili y among hese workers and heir amilies. Te ollowing policy solu ions would harness he EI C

    o increase access o educa ion and raining, helping low-wage workers gain heskills and qualica ions hey need o climb he economic ladder.

    Categorical eligibility for Pell Grants for workers who receive theEITC and reforms to increase Pell Grants reach

    Pell Gran s are a orm o need-based educa ion assis ance ha , along wi h o herorms o ederal s uden aid, pu higher educa ion wi hin he nancial reach omillions o low-income s uden s every year. Nearly 10 million undergradua es uden s received Pell Gran s in 2013.60 o quali y, a s uden mus be enrolledor accep ed or enrollmen in an eligible cer ica e or degree program and musalready have comple ed high school or ob ained a GED. S uden s and heirparen s comple e he Free Applica ion or Federal S uden Aid, or FAFSA, or heupcoming academic year, and Pell Gran s are hen paid direc ly o he educa ionalins i u ion on behal o quali ying s uden s in order o mee educa ional expenses.Pell Gran unds go rs o ui ion, ees, room, and board; any remaining unds aredisbursed direc ly o he s uden . Te maximum Pell Gran was $5,645 per yearor he 201314 school year.61

    Many workers are unaware ha hey may quali y or Pell Gran s or ha heunds can be used or programs beyond hose o radi ional our-year colleges.In addi ion, requiring workers o comple e an addi ional ederal orm heFAFSA likely remains a barrier. S uden s who receive ederal assis ance hrough

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    Supplemen al Securi y Income, or SSI; he Supplemen al Nu ri ion Assis anceProgram; ree or reduced-price school lunches; emporary Assis ance or NeedyFamilies, or ANF; or he Special Supplemen al Nu ri ion Program or Women,In an s, and Children, or WIC, are ca egorically eligible o receive he maximumPell Gran under a simplied eligibili y process. Making workers who receive he

    EI C similarly ca egorically eligible or he maximum Pell Gran in he ollowing year would crea e a new oppor uni y o connec low-wage workers wi h he educa-ion and raining hey need o access higher-paying jobs and would reduce barrierso accessing Pell Gran s.

    Broadening ca egorical eligibili y or Pell Gran s o include EI C recipien s isunlikely o expand he popula ion o hose who are echnically eligible becausehe wo programs serve individuals in similar income ranges. However, i woulds reamline access o Pell Gran s, increase awareness o hem, and remove he barri-ers associa ed wi h a separa e and burdensome applica ion process. As previously

    no ed, research sugges s ha children who have even a small amoun o dedica edhigher-educa ion savings are signican ly more likely o atend and gradua e romcollege.62 Te knowledge ha one is au oma ically eligible or he maximum PellGran may have a similar effec on low-income s uden s college atendance.

    Tis policy should go hand in hand wi h re orms o increase he reach o PellGran s. Under curren law, a s uden mus be enrolled in an academic programha las s a leas a ull academic year, dened as 30 weeks o ins ruc ional ime.63 Many raining and cer ica e programs las ewer han 30 weeks, making heirpar icipan s ineligible or Pell Gran s. educing he number o weeks o ins ruc-ional ime required o access Pell Gran s rom 30 weeks o 15 weeks would boosheir reach, bene ing many low-wage workers seeking o ob ain addi ional skillsand qualica ions o advance in he job marke . Te Depar men o Educa ionis conduc ing an experimen o es he impac o such a change;64 i he experi-men s ndings demons ra e posi ive effec s, i is impera ive o crea e a s ruc ureor expanding his policy as soon as he resul s are available. In addi ion, res oringPell Gran s or s uden s wi hou a high school diploma hrough a rigorous abili yo bene process while expanding he deni ion o quali ying educa ional orraining ac ivi ies o include GED programs, adul basic educa ion, and cer ied

    raining programs would boos Pell Gran s power o promo e upward eco-nomic mobili y.

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    The American Opportunity Tax Credit, or AOTC, serves as acomplement to Pell Grants, providing qualifying students andfamilies with a credit of up to $2,500 per academic year to

    partially offset educational expenses. As much as 40 percent ofa lers AOTC is refundable. While individuals who earn up to$90,000 per year and joint lers who earn up to $180,000 mayqualify for the AOTC, the vast majority who receive it earn lessthan $60,000 per year.65 As described in a recent CAP report,the following reforms would make the AOTC more effective as atool for increasing access to training and education.66

    First, the AOTC should be made fully refundable; at present, thecredit is only 40 percent refundable.67 Full refundability is mostimportant for individuals and families with incomes so low thatthey owe no federal income tax but nonetheless pay payroll,state, and local taxes. Second, the scope of qualifying educa-

    tional and training activities should be broadened to matthe proposed expansion for Pell Grants outlined above. Tas currently structured, the AOTC presents timing proble

    many low-income individuals seeking to access educatiotraining, as people must front the money for tuition and costs and wait until tax time to be reimbursed by the AOAdvance AOTC option should be explored to address thtion. Finally, the ban on the AOTC for individuals with fdrug convictions should be removed. The current lifetimunjustly singles out students with a particular type of crirecord, effectively hindering their ability to move on witlives after completing the terms of their sentences.68 Thereforms would strengthen the AOTC and broaden its reamore low-wage workers, enabling them to obtain the addal skills and qualications they need to advance their car

    Enhancing access to training and education through reforms to strengthen the AOTC

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    Conclusion

    Te Earned Income ax Credi and he Child ax Credi are wo o he na ionsmos effec ive an i-pover y ools. Congress should ac o ensure ha he improve-men s made under he American ecovery and einves men Ac do no expirein 2017 and ake he common-sense s eps o indexing he C Cs value o ina ionand making i ully re undable. Fur hermore, Congress should s reng hen heEI C so i does no exclude millions o hardworking Americans wi hou quali y-ing children. I should also lower he eligibili y age or hese workers o 18.

    Congress and s a es should also ake s eps o enhance he EI Cs power as a sav-ings ool. Ac ions ha would make saving more rewarding, au oma ed, and ex-ible include modi ying he Savers Credi ; crea ing sa e, affordable savings vehiclesor EI C recipien s; and removing coun erproduc ive penal ies or saving rompublic assis ance programs. Early access o a small por ion o he credi , hroughhe crea ion o an Early e und op ion, could reduce he use o preda ory lendingproduc s and pu mobili y-enhancing oppor uni ies wi hin reach.

    Finally, increasing access o raining and educa ion oppor uni ies by makingEI C recipien s ca egorically eligible or Pell Gran s coupled wi h re orms o broaden he reach o bo h Pell Gran s and he AO C would ur her boos heEI Cs power o promo e economic oppor uni y. All o hese changes woulds reng hen he EI C and C C as ools or increasing nancial securi y andupward economic mobili y.

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    About the authors

    Rebecca Vallas is he Associa e Direc or o he Pover y o Prosperi y Program ahe Cen er or American Progress, where she plays a leading role in an ipover ypolicy developmen and analysis, wi h a par icular ocus on s reng hening our

    na ions income securi y programs. Previously she worked as he Depu y Direc oror Governmen Affairs a he Na ional Organiza ion o Social Securi y Claiman sepresen a ives, and an atorney and policy advoca e a Communi y LegalServices in Philadelphia.

    Melissa Boteach is he Vice Presiden o he Pover y o Prosperi y Program a heCen er and he Vice Presiden o he Hal in en Educa ion Fund, where she over-sees he pover y eams policy developmen and advocacy ini ia ives. Previously,Melissa worked as a senior policy associa e and he pover y campaign coordina ora he Jewish Council or Public Affairs.

    Rachel West is a Senior Policy Analys wi h he Pover y o Prosperi y Program ahe Cen er, where she con ribu es o policy developmen and analysis. Previouslyshe was an economic policy researcher a he Ins i u e or esearch on Labor andEconomics a he Universi y o Cali ornia, Berkeley, where her work ocused onminimum-wage policy and public assis ance programs.

    Acknowledgments

    Te au hors wish o hank David Bergeron, Shawn Frems ad, Pa rick Hain,Chye-Ching Huang, Sharon Parrot, Alex Torn on, Joe Valen i, and John Wancheck or heir help ul commen s on an earlier draf.

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    22 Ibid.

    23 Ibid.

    24 Ibid.

    25 Department of the Treasury, General Explanationsof the Administrations Fiscal Year 2015 RevenueProposals (2014), available at http://www.treasury.gov/resource-center/tax-policy/Documents/General-Explanations-FY2015.pdf.

    26 FINRA Investor Education Foundation, FinancialCapability in the United States: Report of Findings fromthe 2012 National Financial Capability Study (2013),available at http://www.usnancialcapability.org/downloads/NFCS_2012_Report_Natl_Findings.pdf

    27 Ibid.

    28 Board of Governors of the Federal Reserve System,Report on the Economic Well-Being of U.S. Householdsin 2013 (2014), available at http://www.federalreserve.gov/econresdata/2013-report-economic-well-being-us-households-201407.pdf.

    29 Joe Valenti Helping Working Families Build Wealth at Tax Time (Washington: Center for American Progress,2013), available at http://www.americanprogress.org/issues/economy/report/2013/02/27/54845/helping-working-families-build-wealth-at-tax-time/.

    30 Internal Revenue Service, Statistics for Tax Returnswith EITC, available at http://www.eitc.irs.gov/EITC-Central/eitcstats (last accessed October 2014),

    31 Internal Revenue Service, Retirement Topics Retire-ment Savings Contributions Credit (Savers Credit),available at http://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credit) (last accessed October 2014).

    32 Ruby Mendenhall and others, The Role of EarnedIncome Tax Credit in the Budgets of Low-IncomeHouseholds, Social Science Review 86 (3) (2012). Th etwo most commonly reported uses of EITC fundsincluded paying debt or cover bills84 percentandcovering child-related expenses61 percent.

    33 Joe Valenti, Helping Working Families Build Wealth at Tax Time.

    34 Internal Revenue Service, Retirement Topics - Retire-ment Savings: Contributions Credit (Savers Credit),available at http://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credit) (last accessed August 2014).

    35 Ibid.

    36 Rebecca Vallas and Joe Valenti, Asset Limits are aBarrier to Economic Security and Mobility (Washing-ton: Center for American Progress, 2014), available athttp://www.americanprogress.org/issues/poverty/report/2014/09/10/96754/asset-limits-are-a-barrier-to-economic-security-and-mobility/.

    37 Richard H. Thaler and Shlomo Benartzi, Save More Tomorrow: Using Behavioral Economics to Increase Em-ployee Saving, Journal of Political Economy 112 (2004):164187.

    38 Internal Revenue Service, Get Your Refund Faster: TellIRS to Direct Deposit Your Refund to One, Two, or ThreeAccounts, available at http://www.irs.gov/Individuals/Get-your-refund-faster-Tell-IRS-to-Direct-Deposit-Your-Refund-to-One,-Two-or-Three-Accounts (last accessedOctober 2014).

    39 Refund to Savings is a collaboration between the Cen-ter for Social Development at Washington University inSt. Louis and Duke University, and Intuit, Inc. See Centerfor Social Development, Refund to Savings, availableat http://csd.wustl.edu/AssetBuilding/Pages/Refund-to-savings.aspx (last accessed October 2014).

    40 For example, a study of family nances estimatedthat 20 percent of taxpayers who earned less than$25,000 per year in 1998a large share of the EITC-eligible populationlacked bank accounts. Arthur B.,Kennickell , Martha Starr-McCluer, and Brian Surette,Recent Changes in U.S. Family Finances: Results fromthe 1998 Survey of Consumer Finance (Washington:Federal Reserve Board, 2000). Another survey foundthat 44 percent of EITC recipients in in ner-city Chicagoused check-cashing serviceswhich tend to involvehigh feesto cash their refund checks. Michael S. Barr,Banking for the Unbanked, Law Quad 45 (2) (2002):6063. Essay based on testimony delivered before theSenate Committee on Banking, Housing, and UrbanAffairs in May 2002.

    41 William Elliott, Small dollar accounts and childrensoutcomes (Lawrence, KS: Assets and Education Initia-tive, University of Kansas, School of Social Welfare,2012).

    42 Other types of payments that can be withheld throughthe Treasury Offset Program include: federal salary andmilitary pay (up to 15 percent of disposable pay for

    federal debts and up to 65 percent for child support);Office of Personnel Management retirement benets(up to 25 percent for federal non-tax debts and up to15 percent for federal tax debts); Social Security andRailroad Retirement benets (up to 15 percent forfederal tax and non-tax debts); and state payments(up to 100 percent for federal non-tax debts, wherethere is a reciprocal agreement in place). Bureau of theFiscal Service, Frequently Asked Questions: TreasuryOffset Program, available at http://scal.treasury.gov/fsservices/gov/debtColl/faqs/debt_questions_top_pub.htm (last accessed October 2014).

    43 The IRS does not report the number of lers who havetheir refunds withheld; however, they do put the totalamount withheld via tax refund offset at $5.5 billion in2013. U.S. Department of the Treasury, U.S. GovernmentReceivables and Debt Collection Activities of Federal Agencies (2014), available at http://scal.treasury.gov/

    fsservices/gov/debtColl/pdf/reports/debt13.pdf.

    44 Bureau of the Fiscal Service,Fact Sheet: Treasury OffsetProgram: Summary of Program Rules and Requirements (U.S. Department of Treasury, 2014), available at http://scal.treasury.gov/fsservices/gov/debtColl/pdf/top/ TOP_rules_reqs_fact_sheet.pdf.

    45 Alyssa Peterson, Predatory Payday Lending: ItsEffects and How to Stop I t (Washington: Center forAmerican Progress, 2013), available at http://cdn.americanprogress.org/wp-content/uploads/2013/08/PredatoryLending-brief-1.pdf.

    46 The Advance EITC was repealed by the Education Jobsand Medicaid Assistance Act of 2010, signed into law inAugust of 2010. In ternal Revenue Service, Overview ofEITC, available athttp://www.eitc.irs.gov/EITC-Central/press/overview (last accessed October 2014).

    47 Government Accountability Office, Advance EarnedIncome Tax Credit: Low Use and Small Dollars PaidImpede IRSs Efforts to Reduce High Noncompliance(2014).

    48 Elaine Maag, Giving Up on the Advanced EarnedIncome Tax Credit (Washington: Tax Policy Center,2009), available at http://taxvox.taxpolicycenter.org/2009/03/04/giving-up-on-the-advanced-earned-income-tax-credit/.

    http://www.eitc.irs.gov/EITC-Central/eitcstatshttp://www.eitc.irs.gov/EITC-Central/eitcstatshttp://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credithttp://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credithttp://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credithttp://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credithttp://www.irs.gov/Individuals/Get-your-refund-faster-Tell-IRS-to-Direct-Deposit-Your-Refund-to-One,-Two-or-Three-Accountshttp://www.irs.gov/Individuals/Get-your-refund-faster-Tell-IRS-to-Direct-Deposit-Your-Refund-to-One,-Two-or-Three-Accountshttp://www.irs.gov/Individuals/Get-your-refund-faster-Tell-IRS-to-Direct-Deposit-Your-Refund-to-One,-Two-or-Three-Accountshttp://csd.wustl.edu/AssetBuilding/Pages/Refund-to-savings.aspxhttp://csd.wustl.edu/AssetBuilding/Pages/Refund-to-savings.aspxhttp://www.eitc.irs.gov/EITC-Central/press/overviewhttp://www.eitc.irs.gov/EITC-Central/press/overviewhttp://www.eitc.irs.gov/EITC-Central/press/overviewhttp://www.eitc.irs.gov/EITC-Central/press/overviewhttp://csd.wustl.edu/AssetBuilding/Pages/Refund-to-savings.aspxhttp://csd.wustl.edu/AssetBuilding/Pages/Refund-to-savings.aspxhttp://www.irs.gov/Individuals/Get-your-refund-faster-Tell-IRS-to-Direct-Deposit-Your-Refund-to-One,-Two-or-Three-Accountshttp://www.irs.gov/Individuals/Get-your-refund-faster-Tell-IRS-to-Direct-Deposit-Your-Refund-to-One,-Two-or-Three-Accountshttp://www.irs.gov/Individuals/Get-your-refund-faster-Tell-IRS-to-Direct-Deposit-Your-Refund-to-One,-Two-or-Three-Accountshttp://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credithttp://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credithttp://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credithttp://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Retirement-Topics-Retirement-Savings-Contributions-Credit-(Saver%E2%80%99s-Credithttp://www.eitc.irs.gov/EITC-Central/eitcstatshttp://www.eitc.irs.gov/EITC-Central/eitcstats
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    49 Rothstein, Is the EITC as Good as an NIT? ConditionalCash Transfers and Tax Incidence.

    50 Williams and Mai, State Earned Income Tax Credits andMinimum Wages Work Best Together.

    51 Nick Bourke, Alex Horowitz, and Tara Roche, PaydayLending in America: Who Borrows, Where They Borrow,and Why (Washington: The Pew Charitable Trusts,2012), available at http://www.pewstates.org/upload-edFiles/PCS_Assets/2012/Pew_Payday_Lending_Re-port.pdf.

    52 Ibid.

    53 Furthermore, many errors in anticipating the value ofEITC stem from mistakenly or improperly claiming oneor more dependent children. Capping the Early Refundoption at $500 entails that workers who expected toclaim qualifying childrenbut were unable to do so would nonetheless be unlikely to owe money back attax time: The cap of $500 is about half of the proposedmaximum credit for childless workers and somewhatless than the EITC received by an individual working fulltime at the minimum wage. Thus, even if a worker wasunable to claim her children as qualifying dependents,as anticipated, the value of her EITC would not be likelyto exceed her maximum Early Refund option.

    54 Internal Revenue Service, Table 2.5: Returns withEarned Income Credit, by Size of Adjusted Gross

    Income, Tax Year 2011 (2013), available at http://www.irs.gov/le_source/pub/irs-soi/11in25ic.xls.

    55 Authors calculations based on Ibid.

    56 The Volunteer Income Tax Assistance, or VITA, programprovides tax help free of charge to low- and middle-income lers, as well as persons with disabilities andlimited English prociency. See Internal RevenueService, Free Tax Return Preparation for Qualifying Taxpayers, available at http://www.irs.gov/Individuals/Free-Tax-Return-Preparation-for-You-by-Volunteers (lastaccessed October 2014).

    57 Center for Economic Progress, Periodic Earned Income Tax Credit (EITC) Payment Pilot Project available athttp://www.taxcreditsforworkingfamilies.org/wp-con-tent/uploads/2010/09/EITC-Pilot-2-Pager-Policy-Brief.pdf (last accessed October 2014).

    58 In the long run, the Affordable Care Act, or ACA, couldpotentially provide an infrastructure portal for admin-istration of Early Refund option: Under the ACA, healthcare consumers project their income for the followingyear to receive an income-based tax credit, which helpsthem purchase insurance on the health insuranceexchanges. As the ACA enrollment system evolves andthe web platform advances over the next several years,the ACA may emerge as a strong option for eventuallybringing an Early Refund option to scale.

    59 Joe Valenti, David Bergeron, and Elizabeth Baylor,Harnessing the Tax Code to Promote College Afford-ability: Options for Reform (Washington: Center forAmerican Progress, 2014), available at http://www.americanprogress.org/issues/higher-education/report/2014/05/28/90444/harnessing-the-tax-code-to-promote-college-affordability/.

    60 Congressional Budget Office, The Pell Grant Program:Recent Growth and Policy Options (2013), available athttp://www.cbo.gov/publication/44448.

    61 Department of Education, Federal Pell Grants, avail-able at http://studentaid.ed.gov/types/grants-scholar-ships/pell#how-much-money (last accessed October2014),

    62 William Elliott, Hyun-a Song, and Ilsung Nam, Relation-ships Between College Savings and Enrollment, Gradu-ation, and Student Loan Debt (St. Louis, MS: Center forSocial Development, George Warren Brown School ofSocial Work, 2013), available at http://csd.wustl.edu/Publications/Documents/RB13-09.pdf .

    63 Department of Education, Federal Student Aid Hand-book (2013), Chapter 3, Calculating Pell Grant Awards.

    64 Department of Education, Current Experiments, avail-able at https://experimentalsites.ed.gov/exp/approved.html (last accessed October 2013).

    65 Valenti and others, Harnessing the Tax Code to Pro-mote College Affordability.

    66 Ibid.

    67 Internal Revenue Service, American Opportunity TaxCredit: Questions and Answers, available at http://www.irs.gov/uac/American-Opportunity-Tax-Credit:-Questions-and-Answers (last accessed October 2014),

    68 The Reimagining Aid Design and Delivery Consortiumfor Higher Education Tax Reform, Higher Education TaxReform: A Shared Agenda for Increasing College Afford-ability, Access, and Success (2013).

    http://www.irs.gov/Individuals/Free-Tax-Return-Preparation-for-You-by-Volunteershttp://www.irs.gov/Individuals/Free-Tax-Return-Preparation-for-You-by-Volunteershttp://www.taxcreditsforworkingfamilies.org/wp-content/uploads/2010/09/EITC-Pilot-2-Pager-Policy-Brief.pdfhttp://www.taxcreditsforworkingfamilies.org/wp-content/uploads/2010/09/EITC-Pilot-2-Pager-Policy-Brief.pdfhttp://www.taxcreditsforworkingfamilies.org/wp-content/uploads/2010/09/EITC-Pilot-2-Pager-Policy-Brief.pdfhttp://studentaid.ed.gov/types/grants-scholarships/pell#how-much-moneyhttp://studentaid.ed.gov/types/grants-scholarships/pell#how-much-moneyhttp://csd.wustl.edu/Publications/Documents/RB13-09.pdfhttp://csd.wustl.edu/Publications/Documents/RB13-09.pdfhttps://experimentalsites.ed.gov/exp/approved.htmlhttps://experimentalsites.ed.gov/exp/approved.htmlhttp://www.irs.gov/uac/American-Opportunity-Tax-Credit:-Questions-and-Answershttp://www.irs.gov/uac/American-Opportunity-Tax-Credit:-Questions-and-Answershttp://www.irs.gov/uac/American-Opportunity-Tax-Credit:-Questions-and-Answershttp://www.irs.gov/uac/American-Opportunity-Tax-Credit:-Questions-and-Answershttp://www.irs.gov/uac/American-Opportunity-Tax-Credit:-Questions-and-Answershttp://www.irs.gov/uac/American-Opportunity-Tax-Credit:-Questions-and-Answershttps://experimentalsites.ed.gov/exp/approved.htmlhttps://experimentalsites.ed.gov/exp/approved.htmlhttp://csd.wustl.edu/Publications/Documents/RB13-09.pdfhttp://csd.wustl.edu/Publications/Documents/RB13-09.pdfhttp://studentaid.ed.gov/types/grants-scholarships/pell#how-much-moneyhttp://studentaid.ed.gov/types/grants-scholarships/pell#how-much-moneyhttp://www.taxcreditsforworkingfamilies.org/wp-content/uploads/2010/09/EITC-Pilot-2-Pager-Policy-Brief.pdfhttp://www.taxcreditsforworkingfamilies.org/wp-content/uploads/2010/09/EITC-Pilot-2-Pager-Policy-Brief.pdfhttp://www.taxcreditsforworkingfamilies.org/wp-content/uploads/2010/09/EITC-Pilot-2-Pager-Policy-Brief.pdfhttp://www.irs.gov/Individuals/Free-Tax-Return-Preparation-for-You-by-Volunteershttp://www.irs.gov/Individuals/Free-Tax-Return-Preparation-for-You-by-Volunteers
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