Gov. Maura Healey rolls out her fiscal year 2027 state budget proposal on January 28, 2026, flanked by Lt. Gov. Kim Driscoll (left) and Administration and Finance Secretary Matt Gorzkowicz (right). Chris Lisinski/CommonWealth Beacon

DEPENDING ON WHO YOU ASK, there’s either a sea change underway in how Beacon Hill thinks about the billions of dollars now flowing into state coffers from the state surtax on high earners, or simply a natural evolution in thinking as budgeting grows more challenging.

In 2022, when voters approved the added levy on income over $1 million, backers of the so-called millionaires tax pitched it as a way to fund new programs in education and transportation. But a few years later, the approach is changing.

The annual budget bill Gov. Maura Healey unveiled last week plus a companion proposal would together spend nearly $4 billion collected from the surtax. And for the second year in a row, hundreds of millions of those dollars would go not toward brand new programs or one-time expansions, but perennial investments like MBTA support or state aid for K-12 schools.

It’s a subtle but impactful shift from the first few state spending plans that deployed surtax revenue, which mostly earmarked the extra resources for novel uses such as expanding free school meals to all students.

Opinions on the shift differ among both supporters and opponents of the surtax. Some contend the measure was intended to spur new investments, and that using its revenue for recurring needs is an act of budgetary misdirection. Others think all that matters is for education and transportation, the two areas tied to the constitutional amendment, to receive more money than they did before.

Jim Stergios, executive director of the Pioneer Institute, which opposed passage of the surtax, said voters “were sold a bill of goods.”

“This is completely not what it was supposed to do,” Stergios said on a recent episode of The Codcast.

Healey’s annual budget proposal would use $550 million in surtax money to pay for state aid to Massachusetts school districts, including all of the $241 million year-over-year increase required under the 2019 Student Opportunity Act funding reform law.

The Student Opportunity Act was enacted three years before voters approved the surtax, and Beacon Hill for years handled the growth it called for in state aid with existing resources.

That changed last summer, when lawmakers and Healey agreed to fund all of the 2026 budget’s $496 million increase in school aid using surtax dollars.

At the time, Massachusetts Teachers Association president Max Page told State House News Service we “certainly would hope that this much to fulfill the SOA wouldn’t be a part of next year’s budget.”

But next year’s budget is now here, and Healey wants to use even more surtax money for the statutorily required aid increase.

Page is giving that move a mixed review. On one hand, he said, school districts need the money, no matter where it originates. On the other, he said, the MTA would prefer for Beacon Hill to tap other funding sources so that the levy on high earners can be used “above and beyond what’s needed in the regular operating budget.”

“The most important thing is that we can fund what we need,” Page said in an interview. “However, for the long term, we absolutely do think that we should have the revenues we need so that the Fair Share funds can be used to build and not just keep us where we are.”

Administration and Finance Secretary Matt Gorzkowicz said last week that Healey’s team has grown comfortable with using the so-called millionaires tax as a permanent contributor to state spending on public schools. He suggested, in fact, that the state might have had trouble meeting its obligations to boost school spending under the Student Opportunity Act without the new revenue stream.

“Gov. Healey has made sure that surtax collected under the Fair Share Amendment goes to education and transportation, as the voters intended,” added Healey spokesperson Karissa Hand. “With this funding, we have been able to make new, transformative investments to lower costs and improve quality of life — like free community college, increased financial aid, free school meals, free regional transit service, and massive improvements to our roads, bridges, and the T.”

For some surtax supporters, all that matters is that Massachusetts uses the money to increase what it spends on education and transportation, not whether every cent of investment goes toward a program or service that did not exist before voters gave their blessing.

What’s more, after a certain point, what starts as a new investment — like free school meals — becomes recurring if Beacon Hill wants to keep it running.

Viviana Abreu-Hernandez, president of the Massachusetts Budget and Policy Center, said she does not have “a philosophical problem” with the millionaires tax funding school aid increases, given that the money is designed to improve education. Like the MTA, MassBudget supported the surtax before its passage.

“It’s more important to provide that funding to the school districts at a time in which the federal government has cut so much funding,” Abreu-Hernandez said.

When it comes to the MBTA, Healey has called for directing more than $1.1 billion in surtax money to the beleaguered transit system.

That investment, Healey officials say, should be sufficient to help the T navigate a projected budget gap in fiscal 2027 and some of a larger shortfall the following year.

Stergios, the Pioneer Institute leader, contended that using hundreds of millions of surtax dollars to close a structural budget deficit is “backtracking fully on the promise of what this surtax was supposed to do.”

“We should respect what the people said, so that means we should put it into modernization [and] improvements, not plugging holes that are entirely preventable,” he said.

The constitutional amendment itself does not set any explicit requirements on what kinds of programs are funded with surtax revenue, other than saying the money must be expended only “for quality public education and affordable public colleges and universities, and for the repair and maintenance of roads, bridges and public transportation.”

Doug Howgate, president of the business-backed Massachusetts Taxpayers Foundation that opposed the surtax’s passage, said he does not believe the governor’s push to use more than half a billion dollars of surtax revenue for school aid is “problematic from a policy standpoint.”

But it could set Beacon Hill up for a headache down the line, he argued. Revenues from the surtax have only been flowing for a few years, and there’s a chance they trend downward from volatility in the future, especially the portion of surtax money that comes from capital gains.

“At a certain point in time, we’re not going to have as much surplus resources to use,” Howgate said. “Have we then plugged in more than we’re going to be able to reliably expect?”

Chris Lisinski covers Beacon Hill, transportation and more for CommonWealth Beacon. After growing up in New York and then graduating from Boston University, Chris settled in Massachusetts and spent...