Arguably the most strongly promoted approach by voucher advocates is a new form of government subsidy for private education, Education Savings Accounts (ESAs). Parents are provided a set sum which they can use for a variety of educational services including private school tuition and fees, online courses, extracurricular activities and private tutoring. Students enrolled in an ESA program are not allowed to concurrently attend a public school. This policy brief examines this emerging policy, considering similarities and differences with conventional voucher approaches, and examining the legal issues that the policy raises.