ENOUGH Act Eligibility Analysis: Executive Summary
2026 Application Cycle | Data: 2024 American Community Survey 5-Year Estimates (OPM)
Prepared: May 2026
Bottom Line
The 2026 ENOUGH Grant cycle applies a proposed Margin of Error (MOE) methodology for census tract poverty rate qualification. Under this approach, 216 census tracts are Census Tract Poverty Rate Qualified (compared to 180 under the point-estimate-only approach). Combined with the statutory 75% school CPG threshold for Year 3, 181 tracts achieve full ENOUGH eligibility (both tests pass).
Key Findings
- 180 tracts exceed 30% child poverty by point estimate alone (Criteria 1)
- 216 tracts are Census Tract Poverty Rate Qualified under the proposed methodology (Criteria 1 + Criteria 2)
- 181 tracts are fully ENOUGH eligible (tract qualified AND school qualified)
- 287 schools are School Poverty Rate Qualified at the statutory 75% CPG threshold
- 11.3% statewide child poverty rate (156,135 children in poverty out of 1,376,500 total)
- 28 active grantees serve 114 census tracts (62 of which are fully eligible; grantee community boundaries extend beyond eligible tracts by design)
Two-Test Framework
Full ENOUGH eligibility requires passing BOTH tests:
- Census Tract Poverty Rate Qualified: Tract child poverty rate >30% (Criteria 1) OR upper bound >30% with previous year confirmation (Criteria 2, proposed methodology requiring Secretary's approval)
- School Poverty Rate Qualified: At least one school in the tract boundary with CPG at or above 75% (statutory requirement for Year 3)
Proposed Methodology Impact (MOE Provision)
The proposed upper-bound methodology adds 36 tracts to the Census Tract Poverty Rate Qualified pool beyond those qualifying via point estimate alone. This is a modest expansion that serves primarily as a stability mechanism, preventing communities from losing eligibility due to ACS sampling noise. The provision requires the Secretary's approval.
Key context for the MOE provision:
- ACS 5-Year estimates are the ONLY methodology available for neighborhood-level poverty measurement
- ~49% of Maryland tracts have margins of error exceeding 10 percentage points
- 189 tracts experienced >10pp year-over-year shifts between the 2023 and 2024 ACS releases
- The dual-year safeguard ensures only tracts with demonstrated sustained poverty qualify
School Threshold (Statutory)
The 75% CPG threshold for Year 3 is settled law. This is not subject to the Secretary's approval. Lowering from 80% (used in Years 1-2) to 75% qualifies 70 additional schools statewide. Counties most affected: Prince George's County (+27), Baltimore County (+12), Montgomery County (+11).
Related Documents
- Eligibility & Methodology (Comprehensive) -- legal framework, historical analysis, Somerset/Baltimore County examples, full 36-tract breakdown
- Full Analysis Memo -- comprehensive methodology and county profiles
- MOE Formula Change Memo -- detailed case for the proposed methodology
- Interactive Methodology Page -- charts and data supporting the MOE provision
Data Sources: Maryland Department of Planning ArcGIS Services, 2024 ACS 5-Year Estimates (U.S. Census Bureau, OPM), Maryland State Department of Education