ENOUGH Act Eligibility: Full Analysis Memo

1. Program Overview & Eligibility Framework

The ENOUGH Grant Program supports anti-poverty initiatives at the community level across Maryland. Per statute, full ENOUGH eligibility requires a community to meet both of the following tests:

1. Census Tract Poverty Rate Qualified: The community must include at least one U.S. Census tract where more than 30% of children are living in poverty (measured using ACS 5-Year OPM estimates)
2. School Poverty Rate Qualified: The community must be served by a Maryland community school with a Concentration of Poverty Grant (CPG) level of at least 75% (the statutory requirement for Year 3)

For the 2026 application cycle, the census tract test includes a proposed methodology (requiring Secretary's approval) that accounts for the margin of error in ACS estimates. The school threshold at 75% is statutory for Year 3 and does not require additional approval.

2. Statewide Summary

Metric	Value
Total Census Tracts in Maryland	1,463
Total Children (Under 18)	1,376,500
Children in Poverty (OPM)	156,135
Statewide Child Poverty Rate	11.3%
Census Tract Poverty Rate Qualified (Criteria 1: >30%)	180
Census Tract Poverty Rate Qualified (Criteria 2: MOE provision)	159
Total Census Tract Poverty Rate Qualified (either criteria)	216
School Poverty Rate Qualified (75% CPG, Year 3 statutory)	287
Fully ENOUGH Eligible (both tests)	181
Total Public Schools Analyzed (2026)	1,420
Active Grantees (FY26)	28
Grantee Census Tracts (total service area)	114
Eligible Tracts With Grantee Coverage	62 of 181

3. Census Tract Poverty Rate Qualification

3.1 Data Source

Census tract child poverty rates are derived from the American Community Survey (ACS) 5-Year Estimates, the only nationally standardized source for neighborhood-level poverty data. These estimates use the Official Poverty Measure (OPM) -- pre-tax cash income compared to federal poverty thresholds. The Supplemental Poverty Measure (SPM) is not available at the tract level.

3.2 Known Limitations

• High margins of error: ~49% of Maryland tracts have MOE exceeding 10 percentage points
• Year-over-year volatility: 189 tracts shifted more than 10pp between the 2023 and 2024 ACS releases
• 5-year rolling average: Estimates reflect a 5-year period, not current conditions
• Small sample sizes: Tract-level estimates are based on limited household surveys

3.3 Qualification Criteria

Criteria	Definition	Tracts Qualifying
Criteria 1	2024 ACS point estimate >30%	180
Criteria 2 (Proposed)	Upper bound (estimate + MOE) >30% AND 2023 ACS >30%	159
Combined (either)	Criteria 1 OR Criteria 2	216

3.4 Geographic Concentration

County	Criteria 1	Total Qualifying	Fully Eligible	Avg Child Poverty
Baltimore City	74	85	85	25.3%
Prince George's County	28	32	32	13.5%
Baltimore County	21	31	15	11.4%
Montgomery County	13	15	11	8.9%
Allegany County	7	7	5	21.5%
Washington County	6	6	5	16.9%
Cecil County	5	6	4	16.0%
Dorchester County	5	5	5	28.5%

4. Proposed MOE Methodology

See the dedicated MOE Formula Change Memo and the interactive methodology page for the full argument for Secretary's approval.

Key points:

• The proposed methodology adds 36 net tracts to the Census Tract Poverty Rate Qualified pool (216 vs. 180)
• This is a modest 20% expansion of the qualifying tract count, not a dramatic change
• The provision primarily serves as a stability mechanism against ACS sampling noise
• The dual-year safeguard (previous year must also exceed 30%) prevents spurious qualification
• It aligns with statistical best practices for threshold decisions based on uncertain estimates
• This methodology change requires the Secretary's approval

5. School Poverty Rate Qualification

The second statutory criterion requires a community school with a Concentration of Poverty Grant (CPG) level of at least 75% for Year 3 of the program. This threshold is settled law.

Cycle	Threshold	Schools Qualified
2024 Cycle	80% CPG	244
2025 Cycle	80% CPG	284
2026 Cycle	75% CPG (statutory Year 3)	287

The statutory reduction from 80% to 75% for Year 3 qualifies 70 additional schools compared to the 80% threshold applied to the same 2026 data (217 at 80% vs. 287 at 75%).

6. FY26 Grantee Landscape

28 grantee organizations serve 114 census tracts across Maryland, distributed across three program phases. Note: grantee service areas extend beyond eligible tracts — only 62 of their 114 tracts are fully ENOUGH eligible. A grantee only needs at least one eligible tract in its community boundary to qualify.

Phase	Tracts	Description
Planning	55	Community assessment and strategy development
Partnership	47	Building coalitions and capacity
Implementation	18	Active program delivery

Of the 181 fully eligible tracts, only 62 have an active grantee present in that tract. 119 eligible tracts have no grantee coverage, representing significant opportunities for new applicant organizations. Four current grantees serve communities where none of their tracts currently meet full eligibility under the 2026 formula, likely reflecting shifts in ACS data since their original qualification.

7. County Profiles

Baltimore City

• 199 total tracts; 74 meet Criteria 1, 85 total Census Tract Poverty Rate Qualified
• All 85 qualifying tracts are fully ENOUGH eligible (school test is not the binding constraint here)
• Average child poverty: 25.3% (highest jurisdiction average)
• 89 schools qualified at 75% CPG

Prince George's County

• 214 total tracts; 28 meet Criteria 1, 32 total qualifying
• All 32 qualifying tracts are fully eligible
• 95 schools qualified at 75% CPG
• Largest beneficiary of the 75% school threshold (27 schools gained vs. 80%)

Baltimore County

• 219 total tracts; 21 meet Criteria 1, 31 total qualifying
• Only 15 of 31 qualifying tracts are fully eligible -- 16 lack a qualified school
• The school test is the binding constraint in Baltimore County
• 17 schools qualified at 75% CPG (12 gained by lowering from 80%)

Montgomery County

• 232 total tracts; 13 meet Criteria 1, 15 total qualifying
• 11 of 15 qualifying tracts are fully eligible
• 25 schools qualified at 75% CPG (11 gained by lowering from 80%)

8. Findings & Recommendations

Key Findings

1. The proposed MOE methodology results in a modest 20% expansion of Census Tract Poverty Rate Qualified tracts (180 to 216). It primarily stabilizes eligibility rather than dramatically expanding it.
2. The school test (75% CPG) is the binding constraint in several jurisdictions, particularly Baltimore County (16 tracts qualify on poverty but lack a qualifying school).
3. Current grantees cover only 62 of 181 fully eligible tracts, leaving 119 eligible tracts without active coverage. Grantee service areas include 49 non-eligible tracts within their community boundaries.
4. ACS estimate volatility is substantial: 189 tracts shifted >10pp between releases, underscoring the need for the MOE provision.
5. The statutory 75% school threshold for Year 3 qualifies 70 additional schools compared to the previous 80% standard.

Recommendations

1. Approve the proposed MOE methodology -- it is statistically sound, conservative in application, and prevents harm from sampling noise.
2. Develop targeted outreach to communities in newly-eligible areas, particularly in counties where the school threshold lowering creates new full eligibility.
3. Address the school criterion gap in Baltimore County and other jurisdictions where poverty-qualified tracts lack qualifying schools.
4. Strengthen grantee coverage in the 119 fully eligible but unserved tracts through strategic recruitment and multi-community collaborative applications.
5. Monitor border tracts in the 25-35% poverty range for eligibility stability across future ACS releases.