What CEN does and what your school does
Updated September 28, 2026 · 5 min read
- Related guides:
- The compliance calendarHow scholarships are awarded and paidRegistering your school with CEN SGO
- Tool:
- State tracker
The compliance work behind the credit, and who carries each part.
In brief
- CEN SGO carries the compliance work: state listing, separate accounts, donor acknowledgments, income checks, awards, payments, reports and the audit.
- Your school does six things: sign the agreement, confirm enrollment, share the campaign, report changes, apply awards and name a contact.
- Your team never walks a parent through tax rules or handles a family's income documents.
- Your enrollment confirmations feed CEN's reports, so accuracy and speed matter.
Who does what
| Task | Who | What it involves |
|---|---|---|
| State listing | CEN | Registers in each state that joins and stays on the state's list each year |
| Partner agreement | Both | Your school signs. CEN sets up your account |
| Giving page | CEN | Builds and hosts your page. Every donation through it is tagged to your fund |
| Marketing kit and training | CEN | Writes the materials and trains your team on the portal |
| Campaign | Your school | Shares the kit with parents, alumni and church partners |
| Separate accounts | CEN | Holds qualified contributions apart from all other money |
| Donor acknowledgments | CEN | Sends each donor an acknowledgment with a donor number |
| Donor tax questions | CEN | Answers them, so your staff don't have to |
| Family applications | CEN | Runs the application in the portal and answers family questions |
| Income verification | CEN | Checks every family's household income and size each year |
| Awards | CEN | Makes every award under the federal priority order |
| Enrollment confirmation | Your school | Confirms each scholarship student is enrolled |
| Payment | CEN | Pays your school directly |
| Applying awards | Your school | Credits each award to the family's tuition account |
| Student changes | Your school | Reports withdrawals, transfers and grade changes |
| Reports and audit | CEN | Files state and federal reports and completes the annual audit |
| Contact | Your school | Names one person for CEN to work with |
What CEN does
Certification
CEN applies in each state that joins, answers the state's checks and stays on its list each year. A state's list is due by January 1. (Source: §25F(g)(1)) Treasury expects states to verify each SGO themselves rather than take its word. (Source: Notice 2025-70)
Separate accounts
Qualified contributions sit in accounts kept only for them. Your school's fund is tracked inside those accounts, which is how the portal shows your balance. (Source: §25F(c)(5)(B))
Acknowledgments and donor numbers
Every donor gets a written acknowledgment within one business day, with a donor number made by the IRS method. CEN reports donations to the IRS under those numbers. (Source: Treasury guidance preview, June 2026)
Verification
CEN checks household income and family size for every applicant, every year. Families upload their documents to CEN, not to your school. (Source: §25F(d)(1)(F))
Awards
CEN makes every award, starting with last year's recipients and then their brothers and sisters. (Source: §25F(d)(1)(D))
Payment
CEN pays your school directly, on the schedule in your partner agreement, with a record of which student each payment covers.
Reporting and audit
CEN files state and federal reports and completes the annual audit. Your enrollment confirmations are part of the record behind them. (Source: Treasury guidance preview, June 2026)
What your school does
- Sign the agreement. Once, at the start. Usually the head of school.
- Confirm enrollment. For each scholarship student, before CEN pays. Usually the business manager or registrar.
- Share the campaign. Through the year, on the kit's calendar. Usually the advancement lead.
- Report changes. As soon as a student withdraws, transfers or changes grade. Usually the business manager.
- Apply awards. When each payment arrives. Your business office.
- Name a contact. One person CEN can reach, plus a backup.
One scholarship, step by step
Family applies
In CEN's portal
CEN verifies and awards
Income check, priority order
School confirms enrollment
Business manager
CEN pays the school
With a per-student record
School credits the account
Business office
Example. A family at your school applies in the spring. CEN checks their prior-year income and awards a scholarship. In August your business manager confirms the student is enrolled. CEN pays the school, and your business office credits the family's tuition account. In November the student withdraws. Your business manager reports it in the portal the same week, and CEN takes it from there.
Common mistakes
- Collecting income documents from families yourself. Send families to CEN's portal.
- Telling a family whether they'll get a scholarship. CEN makes every award.
- Confirming enrollment for a student who hasn't enrolled.
- Leaving a withdrawal unreported until the end of the term.
- Explaining tax rules to donors. Point them to CEN.
Next step
Schools pageQuestions about this guide? See them on the FAQ page
Sources: §25F(g)(1); Notice 2025-70; §25F(c)(5)(B); Treasury guidance preview, June 2026; §25F(d)(1)(F); §25F(d)(1)(D); §25F(d)(1)(C)






