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Parent Guide: TEA Releases Critical TEFA Update on School Voucher Eligibility for Students With Disabilities

  • Writer: Accessible Education
    Accessible Education
  • Nov 20
  • 10 min read

Updated: Dec 1

December 1, 2025 Update


⚠️ IMPORTANT: Final Rules Have Changed (December 2025)


The Texas Comptroller's final adopted rules for the TEFA program supersede the November 2025 TEA guidance discussed in this post. Most significantly:


  • Disability documentation requirements have changed: Medical certifications and SSI/SSDI letters are no longer accepted for lottery prioritization

  • The final rules require documentation aligned with 19 TAC §89.1040 (special education eligibility standards)

  • Several other program requirements have been clarified or modified


The Comptroller's final adopted rules are the official governing standard. Read our complete update here before taking action on your application.


November 20, 2025 Update

Illustration comparing TEFA eligibility steps for parents: one family using a physician’s diagnosis that provides lottery priority only, and another family using an EFA IEP that qualifies for both lottery priority and additional disability funding under Texas Education Savings Account (TEFA) school voucher rules.
Understanding TEFA’s two-step process is essential; priority access and disability funding are not the same, and the difference affects your child’s benefits.

The Texas Education Agency (TEA) released important guidance today that fundamentally changes what parents need to understand about accessing TEFA funds for children with disabilities. If you've been following the Comptroller's proposed rules, this announcement requires your immediate attention.


THE MOST CRITICAL THING YOU NEED TO KNOW


A doctor's note or disability benefits letter can help you get INTO the program, but it CANNOT get you the additional funding for students with disabilities.


Let us repeat this because it's the single most important clarification TEA provided today:


Getting Priority Access ≠ Getting Additional Funding


TEA has confirmed that there are two completely separate processes with two completely different definitions of what counts as a "child with a disability":


STEP 1: Getting Priority in the Lottery (If There Is One)


What qualifies: Under the Comptroller's proposed rules, these documents can give your child priority if there are more applicants than available spots:

  • A written certification from a licensed physician confirming a specific disability diagnosis

  • Proof of supplemental income due to disability (like SSI or SSDI determination letters)

  • An IEP


What this gets you: Priority selection if the program is oversubscribed. This means you're more likely to get a spot in the program.


What this does NOT get you: The additional funding designated for students with disabilities. You would only receive the base TEFA amount.


STEP 2: Getting the Additional Disability Funding


What qualifies: ONLY a formal school district evaluation and IEP process:


What this gets you: Access to the additional TEFA funds for students with disabilities (up to $30,000 total, compared to the base amount for students without disabilities)


Why This Matters So Much


Here's the scenario TEA anticipates will confuse many families:

  1. You have a letter from your child's doctor diagnosing ADHD, autism, dyslexia, or another disability

  2. You use this letter to gain priority access in the TEFA lottery

  3. You get accepted into the TEFA program, congratulations!

  4. But you only receive the base funding amount, not the additional funding for students with disabilities

  5. To get that additional funding, you must now go back and complete the full school district evaluation process


TEA explicitly warns that parents who use physician certifications or disability benefit letters for lottery priority will likely try to present this same documentation to access the higher funding, but it won't work.


Your local school district must still complete the full evaluation process and hold an ARD committee meeting to create the EFA IEP before your child can qualify for the higher funding amount.


In Plain English


Think of it like applying for a loan with two different interest rates:

  • Priority documentation (doctor's note/SSI letter): Gets you to the front of the line at the bank

  • District evaluation and EFA IEP: Actually qualifies you for the better interest rate (the additional funding)


You might get in the door first, but you won't get the full benefit without completing the second, more rigorous process.


What TEA Announced Today, November 20, 2025


TEA's correspondence and accompanying guidance documents provide the first official agency interpretation of Senate Bill 2's requirements for children with disabilities. Beyond the critical distinction above, here are the other key points:


The TEFA Program Timeline



The Official TEA Statement


TEA's guidance explicitly states that:

  • "The additional certifications or proof of supplemental income do not equate to the definition of a child with a disability for purposes of additional EFA funding."


And further clarifies:

  • "Eligibility for additional funding is strictly based on the child being evaluated by a school district and having a current IEP or a new EFA IEP."


This means that to access additional funding, your child must have:


The Anticipated Confusion


TEA acknowledges that they expect confusion on this point. They anticipate that many parents will:

  1. Gain acceptance into TEFA using physician certifications or disability benefit documentation for lottery priority

  2. Present this same documentation to their school district, expecting to qualify for additional funding

  3. Be told they must still complete the full evaluation process


This is not the district being difficult; this is the explicit requirement under the law and TEA's interpretation of it.


The EFA IEP: A New Type of Document


TEA introduced a streamlined version of an IEP specifically for TEFA purposes called an "EFA IEP." This document:


Must Include:

  • FIIE findings of a disability condition and ARD committee determination of eligibility

  • Accommodations and modifications needed

  • Schedule and delivery of services (frequency, duration, and location)

  • Instructional arrangement code (which determines the funding level)


Does NOT Need to Include:

  • Present levels of academic achievement and functional performance

  • Annual IEP goals

  • Statements about statewide and district assessments


Important: Neither the public school nor the private school has any obligation to implement the services listed in the EFA IEP. This document exists solely to establish eligibility and calculate funding.


Your Rights to Request an Evaluation


TEA reinforced that parents have long-standing rights under IDEA to request special education evaluations from their local school district, regardless of where their child attends school. Here's what you need to know:


Which District to Contact:

  • You can request an evaluation from the district where your child lives, OR

  • The district where your child's eligible private school is located


  • The district has 15 school days to respond

  • After you provide informed consent, the district has 45 school days to complete the evaluation

  • The ARD committee must meet within 30 calendar days after the evaluation report to determine eligibility


Outside Documentation Matters: Districts must consider outside documentation you provide, such as private evaluations or medical diagnoses. Presenting this information may help avoid duplication of effort and could speed up the district's evaluation process.


Financial Incentive: Districts will receive $1,000 for each initial evaluation completed under House Bill 2, including for children not enrolled in public school. This funding may encourage timely compliance with evaluation requests.


How This Aligns with Our Previous Posts


What We Got Right


  • The Comptroller proposed allowing physician certifications and SSI/SSDI documentation for disability verification

  • There were concerns about whether medical documentation alone would be sufficient

  • An IEP could serve as documentation for the purposes of the application


What Needed Clarification


What wasn't clear from the Comptroller's proposed rules, and what we raised concerns about, was whether that medical documentation would be sufficient to access the additional funding designated for students with disabilities.


TEA has now definitively answered this question: No, medical documentation alone is not sufficient for funding eligibility.


The distinction between priority for enrollment and eligibility for additional funding was the central ambiguity in the proposed rules. TEA's guidance makes clear that these are separate determinations with separate requirements.


What This Means for Information Previously Shared


The core concern we raised in previous posts has been validated: families who secure lottery priority through physician notes or SSI letters will still need to complete the full district evaluation process and obtain an EFA IEP to access the higher funding level. TEA explicitly acknowledges it anticipates confusion from parents on this point.


Critical Information Parents Must Know


If Your Child Is Currently in Public School with an IEP


Your existing IEP will generally suffice for TEFA funding eligibility purposes. However, TEA is still finalizing rules about the specific requirements, so stay tuned for additional guidance in early 2026.


If Your Child Is in Private School or Homeschooled


This is where the most critical action is required. Even if you have a medical diagnosis, physician's letter, or disability benefits documentation, you will need to complete the district evaluation process to access additional TEFA funding. That medical documentation may help you get priority in the lottery, but it stops there.


Here's what to do:

  1. Submit a written request for evaluation NOW to either your home district or the district where your child's private school is located; don't wait for TEFA applications to open

  2. Provide any outside documentation you have (private evaluations, medical diagnoses) to potentially expedite the process, but understand this does not replace the district's evaluation

  3. Track the timelines carefully:

    • The district must respond to your request within 15 school days

    • The district must complete the evaluation in 45 school days after consent

    • ARD committee must meet within 30 calendar days after the evaluation is complete

    • Total timeline: At least 60+ school days from request to funding eligibility

  4. Know your rights. If the district misses deadlines or you disagree with their evaluation, you have access to IDEA dispute resolution procedures, including requesting an Independent Educational Evaluation (IEE) at public expense


Critical Point: You cannot skip this process by using your physician's letter or disability benefits documentation. TEA anticipates parents will try to do exactly this, and they are explicitly stating it won't work for funding purposes.


Funding Amounts and Limitations


  • The additional funding is based on what the public school district received or would have received in state special education funding for your child

  • Total TEFA funding is limited to $30,000 per child with a disability (including the base amount)

  • If your child is homeschooled, total funding is limited to $2,000 per school year


Important Timeline Considerations


Applications for TEFA are expected to open in early 2026. If you believe your child may qualify for additional funding as a student with a disability, you should consider requesting an evaluation now to ensure the process is complete before applications open.

Given the mandatory timelines (15 days + 45 days + 30 days = 60+ school days (not calendar days) from initial request to eligibility determination), starting early is crucial.


What We Still Don't Know


TEA's guidance is interim communication because formal rules have not been finalized. Several details remain unclear:


Rules Still Under Development


  • The exact contents and requirements of the EFA IEP are subject to change through TEA's rulemaking process, which includes a public comment period

  • The Comptroller's final rules regarding alternative documentation for lottery priority are still proposed and subject to change

  • The secure web portal process that districts will use to submit evaluations and EFA IEPs to TEA is still being developed


Resources Coming Soon


TEA indicated that additional resources will be released in the coming weeks, including:

  • A parent video overview

  • A frequently asked questions (FAQ) document

  • More detailed information about the portal submission process


Why This Matters


TEA's guidance confirms what some advocates feared and others welcome: the pathway to accessing TEFA funds for children with disabilities is more complex than simply having a medical diagnosis. Families will need to navigate the formal special education evaluation process, even if their child has never attended public school.


This creates both opportunities and challenges:


Opportunities:


Challenges:


What You Should Do Now


If You Have a Child with a Disability and Are Considering TEFA


Understand the two-step process:


STEP 1 - Lottery Priority (if needed):

  • Gather physician certifications or disability benefit documentation

  • This helps you get accepted into the program if there's a lottery

  • You'll receive base TEFA funding


STEP 2 - Additional Funding Qualification:


Do not assume Step 1 documentation will suffice for Step 2 funding. TEA's guidance makes clear these are separate processes with separate requirements.


Action Steps for All Parents


  1. If you're considering TEFA and believe your child has a disability: Contact your school district in writing to request an evaluation as soon as possible. Don't wait for applications to open; the timeline could take 60+ school days.

  2. Gather ALL documentation: Collect private evaluations, medical diagnoses, AND any letters from physicians or disability benefit determinations. You may need different documents for different purposes.

  3. Understand what each document does:

    • Physician letter/SSI documentation = Lottery priority only

    • District evaluation + EFA IEP = Additional funding eligibility

  4. Learn your rights: Familiarize yourself with IDEA timelines and dispute resolution procedures. You may need to advocate for your child throughout this process.

  5. Stay informed: Watch for additional guidance from TEA and final rules from the Comptroller's office, expected in early 2026.

  6. Ask questions: If your district is unclear about its responsibilities or timelines, reference TEA's November 20, 2025, correspondence and guidance documents.


Final Thoughts


Today's guidance from TEA resolves the single biggest question about TEFA for students with disabilities: What documentation actually qualifies a child for the additional funding?


The answer is definitive: physician certifications and disability benefit letters help with lottery priority, but only a formal school district evaluation and IEP process qualify your child for additional funding.


This creates a critical two-track system that parents must understand:

  • Track 1 (Priority): Medical documentation gets you in the door

  • Track 2 (Funding): Educational evaluation gets you additional money if your child qualifies for special education


Many families will complete Track 1 and mistakenly believe they've completed everything needed. They haven't. TEA explicitly anticipates this confusion and has warned districts that parents will present their physician certifications, expecting to access higher funding, only to learn they must complete the full evaluation process.


If you're serious about accessing TEFA funds for a child with a disability, start the evaluation process now. Don't wait for applications to open. Don't assume your medical documentation is sufficient. Understand that while physician letters and disability benefits documentation have value for lottery prioritization, they are explicitly insufficient for funding

qualification.


We'll continue monitoring developments and providing updates as TEA releases additional guidance and finalizes its rules. The rulemaking process will include opportunities for public comment, and parent voices will be critical in shaping the final implementation of this program.


The bottom line: To access additional TEFA funding for your child with a disability, there is no shortcut around the formal school district evaluation and IEP process, regardless of what other documentation you possess.


Confused About TEFA School Vouchers or Whether Your Child Qualifies?


Get clarity on TEFA school voucher requirements, understand the evaluation process, and get expert help preparing for the next steps. Learn more about our Special Education and Section 504 Advocacy Services or request a free consultation. 


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