Arizona's Empowerment Scholarship Accounts (ESAs) are nothing more than school vouchers. While the vouchers are primarily used for private education, they can be used for home-schooling with very little oversight. These funds can be used to pay for tuition and other fees at any private school, including parochial schools. From the Secular Coalition for America Policy Guide (2013): "Public funds should not support parochial schools, either directly or indirectly through voucher programs. Vouchers provide citizens with direct funding to apply to private school tuitions. Scholarship funds and other tax deduction programs fund private religious institutions indirectly by allowing taxpayers to claim tax credits on their personal income taxes, reducing the amount paid to the state and shifting the money to the private school of the taxpayer’s choice. Both programs allow for the public funding of religious educations. Seventy-six percent of private schools in America have a religious affiliation, serving 80 percent of private school students; 57 thus, vouchers are primarily subsidies for religious schools. In 2001, in Zelman v Harris, a closely divided Supreme Court rejected an Establishment Clause challenge to vouchers. The Secular Coalition believes Zelman was wrongly decided and stresses that the Court ruled only on the constitutionality of voucher programs, rather than their wisdom or unintended consequences in a pluralistic nation. Private schools receiving public funds through voucher programs are not subject to all federal civil rights laws and do not face the same public accountability standards public schools must meet, including those in Title IX, Individuals with Disabilities Education Act, and Americans with Disabilities Act. Although a portion of publicly funded vouchers pay for staffing costs, private school employment practices are not subject to anti-discrimination laws."