Last updated: February 2026

The TEFA IEP requirements are becoming increasingly important for Texas families preparing for the 2026–2027 school year. To qualify for the highest levels of TEFA (Texas Education Freedom Account) funding—especially for students with special needs—families must have a completed IEP from a public school or public charter. Because the evaluation process can take months, many parents are starting now.

Students with special needs will be prioritized for TEFA awards, and may receive significantly higher funding amounts—but only if they have a completed IEP from a public school or public charter.

For students who may qualify, the evaluation process can take months. That’s why many families are beginning the IEP process now.

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Who Oversees TEFA in Texas?

The TEFA program is governed under state law but administered through two entities:

• Texas Comptroller of Public Accounts

The Comptroller establishes the rules, compliance standards, and funding calculations for TEFA. It is the final authority on eligibility, documentation, and oversight.

• Odyssey Education, Inc. (“Odyssey”)

The Comptroller selected Odyssey as the third-party program administrator. Odyssey will manage:

• The TEFA online application portal

• Eligibility verification

• Parent dashboards

• School onboarding and payment processing

• Customer support

Odyssey’s system will be the gateway through which families apply, upload documentation, and receive funding.

Although the Comptroller and Odyssey have not yet published the final application requirements, families do not need to wait to begin the IEP process—because the evaluation timeline is fixed by law.

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Why the IEP Timeline Matters

Texas follows a legally defined timeline for special education evaluations under Texas Education Code §29.004, which operates alongside federal IDEA requirements. The process includes:

1. 15 School Days — District Response Window

After a parent submits a written request for a special education evaluation, the school district has 15 school days to provide:

• A Notice of Evaluation, and

• Consent for evaluation

2. 45 School Days — Evaluation Window

Once the parent signs consent, the district has 45 school days to complete the evaluation.
This includes:

• Cognitive/academic testing

• Observations

• Review of outside documentation

• Parent input

3. 30 Calendar Days — ARD & IEP Finalization

After the evaluation is complete, the school must schedule an ARD meeting within 30 calendar days to:

• Determine eligibility

• Identify services

• Create the official Individualized Education Program (IEP)

• Assign the instructional setting code

In total, the process can take 90–105 days.

School holidays and summer breaks can extend the practical timeline even further.

This timing is important because TEFA funding levels will be based on the instructional setting code recorded in the IEP at the time of application.

It is expected that Texas will roll out TEFA IEPs in 2026 to meet the additional IEP demand that is expected. TEFA IEPs will meet the requirement for an IEP for TEFA funding, without covering all topics needed for public school SpED placement.

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How TEFA Funding for Special Needs Students Is Expected to Work

How IEPs Are Verified — and How Funding Levels Are Determined

As TEFA applications move forward, many families are discovering that having an IEP is only part of the picture.

For TEFA purposes, the state relies on public-school records maintained by the Texas Education Agency (TEA) to verify IEP status and to determine eligibility for additional special-education funding. Families may have strong evaluations, private reports, or out-of-state documentation, but TEFA decisions ultimately depend on what is on file with TEA.

This distinction is important. Some families may qualify for application priority but not for higher funding tiers, while others may qualify for additional funding once a current IEP with appropriate instructional codes is on file with TEA.

For families who are unsure how their child’s records will be evaluated, it is still worthwhile to apply. In some cases, families also choose to work with their local school district to ensure special-education records are current and accurately reflect service needs.

Students with documented learning differences may qualify for higher funding amounts. Families interested in online learning should review TEFA funding for online students, including how special needs documentation affects eligibility.

We will update this when official guidance is released.

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What About 504 Plans?

The state has not yet stated whether students with 504 Plans will receive priority consideration under TEFA, but current information indicates:

• 504 Plans do not include a PEIMS instructional setting code

• PEIMS codes are what TEFA will use to determine higher funding tiers

Therefore, even if 504 Plans are recognized for eligibility, they are unlikely to qualify for the enhanced TEFA amounts reserved for students with special needs.

Families who believe their child may qualify for special education services should consider requesting a full evaluation now.

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Private Schools Cannot Issue IEPs

Under federal and Texas law, only:

• Public school districts, or

• Public charter schools

…can complete the evaluation, determine eligibility, and issue an IEP.
Private schools—including The Tenney School—cannot create IEPs.

However, Tenney can:

• Provide documentation

• Give academic data

• Assist with evaluation requests

• Help families prepare for ARD meetings

Parents still direct evaluation requests to their home ISD.

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How to Request an Evaluation

Here is the recommended process:

1. Write a formal request for a special education evaluation.
   (Tenney can help families draft this letter.)

2. Submit the request to your home ISD.
   Even if your child attends private school, the home ISD must process evaluations.

3. Wait for the district’s response (within 15 school days).
   They must respond with consent or a written refusal.

4. Complete the evaluation (within 45 school days after consent).

5. Attend the ARD meeting (within 30 calendar days of evaluation completion).

6. Receive the IEP, which includes services and the PEIMS instructional setting code used for TEFA funding tiers.

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Why This Matters for Tenney Families

Many Tenney students thrive because the model provides:

• 1:1 instruction

• Flexible pacing

• Reduced anxiety and overwhelm

• Executive function support

• Strong teacher-student connection

• Options for on-campus and online learning

These are the same students who frequently qualify for special education services, even if they’ve never been evaluated before.

Families planning to use TEFA funds for:

• The Tenney School (on-campus)

• Tenney School Live (TSL)

• Hybrid or flexible pathways

…may want to begin the IEP process now to avoid bottlenecks when the application system opens.

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Stay Updated as TEFA Details Are Released

We are monitoring all official updates from:

• The Texas Comptroller, and

• Odyssey Education, Inc.

As soon as new information becomes available—including application dates, documentation requirements, and funding tiers—we will update this page and our TEFA guides.