ENOUGH Eligibility & Methodology

Related Resources: 2026 Eligibility Map (New) | 2025 Eligibility Map | 2024 Eligibility Map | Interactive Analysis Map (filterable by county, grantee, legislative district — shows coverage gaps)

1. The 2026 Eligibility Map is Ready for Release

The 2026 ENOUGH Community Eligibility Map is the third iteration of the ENOUGH eligibility mapping tool. Previous versions were released for the 2024 application cycle and the 2025 application cycle.

The 2026 map incorporates updated data from the 2024 American Community Survey 5-Year Estimates (released December 2025) and implements the proposed census tract qualification methodology that accounts for margins of error in poverty estimates.

2. Legal Requirements for ENOUGH Eligibility

The ENOUGH Act (Senate Bill 482, Chapter 408, signed May 9, 2024) establishes the legal framework for community eligibility. The statute is codified at Maryland State Government Article § 9-2801.

2.1 The Dual-Test Requirement

Per § 9-2801(B), an "Eligible Neighborhood" must satisfy two conditions simultaneously:

Two separate qualification tests must be passed:

1. Census Tract Poverty Rate Qualification: The community must include at least one census tract where "more than 30% of children [are] living in poverty"
2. School Poverty Rate Qualification: The community must be served by a school with a Concentration of Poverty Grant (CPG) level meeting the threshold for the applicable fiscal year

2.2 School Poverty Rate Threshold: 75% for FY2027 (2026 Cycle)

The 2026 application cycle awards grants for Fiscal Year 2027. Per the statutory schedule, the school CPG threshold for FY2027 is ≥75%. This is a reduction from the 80% threshold used in FY2025-2026 and represents the legislature's intent to progressively expand access to communities with moderately high school poverty.

This threshold change is established in statute and does not require additional approval. It results in 287 schools qualifying (vs. 217 that would qualify at the previous 80% level) — an additional 70 schools.

2.3 Census Tract Child Poverty: The 30% Threshold

The statute requires "more than 30% of children living in poverty" but does not prescribe a specific data source or estimation methodology. The only available source for census-tract-level child poverty estimation is the American Community Survey (ACS) 5-Year Estimates published by the U.S. Census Bureau using the Official Poverty Measure (OPM).

3. How Census Tract Child Poverty is Measured

3.1 The ACS 5-Year Estimates: The Only Option

Census tract child poverty rates come exclusively from the ACS 5-Year Estimates. No other source provides poverty measurement at the census tract level. These estimates:

• Combine 5 years of survey responses to achieve adequate sample sizes for small geographies
• Use the Official Poverty Measure (OPM), which counts only gross pre-tax cash income against fixed thresholds
• Are published by the Census Bureau with 90% confidence interval margins of error
• Are released approximately 11 months after the reference period ends

3.2 The Problem: High Margins of Error

ACS tract-level estimates carry substantial statistical uncertainty. Among Maryland's 1,463 census tracts:

A margin of error of 12.4 percentage points (the average) means that a tract reporting 28% child poverty has a true value that falls somewhere between 15.6% and 40.4% with 90% confidence. For nearly half of all Maryland tracts, this uncertainty band exceeds 10 percentage points.

3.3 The Problem: Year-over-Year Volatility

Because estimates are imprecise, child poverty rates fluctuate dramatically between ACS releases — not because communities genuinely improved or deteriorated, but because the underlying sample shifted.

189 tracts experienced child poverty rate shifts exceeding 10 percentage points between the 2023 and 2024 ACS 5-Year releases. These shifts do not reflect genuine one-year changes in community economic conditions — they are artifacts of the 5-year rolling sample methodology.

3.4 Example: Somerset County

3.5 Example: Baltimore County

4. The Proposed Census Tract Qualification Methodology

The proposed methodology introduces a second pathway for census tract poverty rate qualification:

4.1 The Dual-Year Safeguard

The second condition (previous year >30%) prevents over-expansion. A tract with low poverty but high MOE (due to a very small child population) cannot qualify through Path 2 unless it demonstrably had high poverty in the prior year. This ensures the provision only captures tracts with genuine sustained poverty that appears to have improved due to sampling variability.

4.2 Three Reasons This Methodology Should Be Approved

1. The statute requires >30% child poverty — it does not prescribe how that is determined. The ENOUGH Act says "census tracts with more than 30% of children living in poverty." It does not specify that this must be the point estimate alone. Using the upper bound of the confidence interval is a statistically valid interpretation of whether children are "living in poverty" given the inherent uncertainty of the measurement tool.
2. The methodology has been validated as statistically robust. Alfred Sundara, Director of the Maryland State Data and Analysis Center at the Maryland Department of Planning — the official Maryland conduit to the U.S. Census Bureau and the authority on Maryland census reporting — has reviewed and approved this approach as statistically sound.
3. The methodology is more equitable. The old point-estimate-only approach structurally disadvantaged rural and suburban communities with smaller child populations, which have wider margins of error simply because the Census sample is smaller. The upper-bound provision corrects this structural bias by accounting for measurement uncertainty, ensuring that communities are not excluded from anti-poverty resources because their census tracts happen to have fewer residents.

5. Impact of the Proposed Methodology

The proposed methodology adds 36 net census tracts to the qualified pool — a 20% increase over the point-estimate-only approach. This is a conservative expansion. Many of the 159 tracts meeting Path 2 criteria also meet Path 1; the overlap accounts for the modest net gain.

5.1 Tracts Failing One Test but Passing the Other

Full ENOUGH eligibility requires passing both the census tract poverty test and the school poverty test. Some tracts pass one but not the other:

Scenario	Count	Meaning
Tract Qualified + School Qualified	181	Fully ENOUGH eligible
Tract Qualified, No Qualifying School	35	High poverty but no school with ≥75% CPG in boundary
School Qualified, Tract Not Qualified	518	Qualifying school present but tract poverty below threshold

5.2 Census Tracts Qualifying Under the Proposed Methodology

The following 36 census tracts qualify for the Census Tract Poverty Rate test exclusively through the proposed upper-bound methodology (Criteria 2). They do not meet the standard >30% point estimate threshold but their upper bound exceeds 30% and their previous year exceeded 30%.

Note: Tracts marked Ineligible in the 2026 column pass the census tract poverty rate test via MOE but do not have a qualifying school in their boundary, so they do not achieve full ENOUGH eligibility.

6. Historical Eligibility Analysis

Cycle	ACS Data	Tract Threshold	School Threshold	Tracts Poverty Rate Qualified	Tracts Meeting School Test	Fully Eligible (Both Tests)
2024	2022 ACS 5-Year	>30%	≥80% CPG	175	453	115
2025	2023 ACS 5-Year	>30%	≥80% CPG	167	554	123
2026	2024 ACS 5-Year	>30% or MOE provision	≥75% CPG	216	699	181

Fully eligible tracts grew from 115 to 181 across three cycles — driven by both the expanded tract qualification methodology and the statutory school threshold reduction. The decrease from 175 to 167 tract-qualified tracts between the 2024 and 2025 cycles illustrates the problem the MOE provision addresses: 8 tracts lost qualification status due to ACS data fluctuation, not genuine poverty reduction. The 2026 methodology prevents this instability while the school threshold expansion simultaneously brings more tracts into full eligibility.

7. Conclusion

The 2026 eligibility map is ready for release. It implements a methodology that is:

• Legally sound — consistent with the statutory language requiring "more than 30% of children living in poverty"
• Statistically validated — approved by the Maryland State Data and Analysis Center
• Conservative in scope — adds only 36 net tracts (20% expansion) with a dual-year safeguard
• Equitable — corrects structural bias against smaller communities with wider confidence intervals
• Protective — prevents communities from losing access to anti-poverty resources due to measurement noise