Florida pays for education through the Florida Education Finance Program, or FEFP, a foundation formula with a base per-pupil allocation of $3,670 for fiscal 2005. Under the formula, the base student allocation is multiplied by a weighted student enrollment, which includes adjustments for different grade levels, English-language learners, special education students, and those in vocational education programs. The per-student allocation also is adjusted by a cost-of-living factor to reflect the variations in living expenses across Florida’s 67 school districts. Other adjustments to the formula include additional money for small districts, safe schools, and supplemental academic instruction, such as tutoring and after-school programs. The state also provides money to districts through six categorical programs that are outside the FEFP, which help support transportation, literacy programs, professional development, class-size reduction, technology, and instructional materials. Total spending for categorical programs in fiscal 2004 was about $1.8 billion. Plaintiffs lost a challenge to Florida’s school finance system in 1996 in Coalition for Adequacy and Fairness in School Funding v. Chiles. A case filed by the American Civil Liberties Union of Florida challenging the state’s use of state-financed vouchers to send students to private schools is currently working its way through the courts.