Friday, October 17, 2025

ESA GUIDE for Parents: Arizona Empowerment Scholarship Account (ESA)

ESA GUIDE for Arizona parents | Arizona Empowerment Scholarship Account (ESA) Programs for parents with children on the autism spectrum and students with special needs 

Arizona Empowerment Scholarship Account (ESA) Program

Comprehensive Strategic Guide and Analysis for Special Education Families

The Arizona Empowerment Scholarship Account (ESA) program represents one of the most expansive educational choice initiatives in the United States, providing direct state funding to families for private educational expenses. For families with special education students, this program offers significantly enhanced funding and broader flexibility compared to general education students.

Key Highlights:

  • Universal Eligibility: All K-12 Arizona students now qualify (expanded 2022)
  • Special Education Premium: Students with disabilities receive $25,000-$43,000 annually vs. $6,000-$7,500 for general education
  • Current Scale: 94,966 students enrolled (as of October 2025)
  • Fund Flexibility: Covers tuition, therapies, curriculum, assistive technology, and more
  • No Income Restrictions: Available to all Arizona families regardless of household income

I. PROGRAM STRUCTURE & GOVERNANCE

A. Legal Framework

Statutory Authority:

  • Arizona Revised Statutes §15-2401 through §15-2406
  • Arizona Administrative Code R7-2-1501 through R7-2-1511
  • Constitutional basis: Upheld by Arizona Court of Appeals (Niehaus v. Huppenthal, 2014)

Administering Entities:

  • Arizona Department of Education (ADE): Program administration, application processing, compliance
  • State Board of Education (SBE): Policy oversight, appeals, handbook approval
  • Arizona Treasurer's Office: Fund disbursement
  • ClassWallet: Third-party financial platform for fund management
  • Arizona Ombudsman-Citizens' Aide (AZOCA): Issue resolution and complaint assistance

B. Program History & Evolution

Year

Milestone

2011

Program established for students with disabilities only

2014

Constitutionality upheld by Arizona courts

2016-2021

Gradual expansion to additional categories (military families, foster care, D/F schools)

2022

Universal expansion - All K-12 students eligible (HB 2853)

2025

94,966 students enrolled; projected to exceed $1 billion in annual spending


II. ELIGIBILITY REQUIREMENTS

A. Special Education Eligibility Categories

Primary Qualification Path: Student must have one of the following from an Arizona public school:

  1. Individualized Education Program (IEP) - Full special education evaluation
  2. Multidisciplinary Evaluation Team (MET) Report - Comprehensive evaluation
  3. 504 Plan - Accommodations for disabilities affecting education
  4. Independent Educational Evaluation (IEE) - From qualified examiner (MD, DO, psychiatrist, or psychologist)

Preschool Eligibility:

  • Ages 3-5 (or within 90 days of third birthday)
  • Must have current MET/IEP/504 from Arizona public school
  • Funding Range: $3,200-$9,000 annually depending on disability category

B. Disability Classifications & Funding Weights

Arizona recognizes 13 IDEA disability categories, each with different funding multipliers:

Disability Category

Approximate Annual Funding

Notes

Autism Spectrum Disorder (ASD)

$28,000

Highest funding category

Multiple Disabilities with Severe Sensory Impairment

$25,000-$43,000

Varies by severity

Emotional Disability

$20,000-$25,000

Requires ongoing clinical documentation

Intellectual Disability

$18,000-$22,000

Based on adaptive functioning needs

Multiple Disabilities

$18,000-$22,000

Two or more significant disabilities

Orthopedic Impairment

$15,000-$20,000

May include assistive technology costs

Other Health Impairment (OHI)

$12,000-$18,000

Includes ADHD, chronic conditions

Specific Learning Disability (SLD)

$10,000-$15,000

Most common category

Speech/Language Impairment

$8,000-$12,000

Lower weight, specific services

Developmental Delay (ages 3-9 only)

$8,000-$15,000

Must re-evaluate at age 10

Traumatic Brain Injury

$18,000-$25,000

Case-by-case determination

Visual/Hearing Impairment

$20,000-$30,000

Specialized equipment costs

Preschool Severe Delay

$8,000-$15,000

Preschool only; re-evaluate for K

Important: Funding amounts are 90% of what the state would allocate if the student attended public school, including disability weights.

C. Additional Eligibility Categories

Beyond special education, students qualify if they are:

  • Previous ESA participant
  • Child of active military parent
  • Child of military parent killed in line of duty
  • Residing on Indian reservation
  • Ward of juvenile court in prospective permanent placement
  • Sibling of current/previous ESA student
  • Attending or assigned to D/F-rated school
  • Child of legally blind, deaf, or hard of hearing parent
  • Universal: Any K-12 student (no special circumstances needed)

III. FUNDING STRUCTURE & AMOUNTS

A. Base Funding Formula

Calculation:

ESA Award = (State Base Per-Pupil Funding × 90%) + Disability Weight

2024-2025 Estimated Amounts:

  • General Education (K): $4,000-$5,000
  • General Education (Grades 1-12): $6,000-$7,500
  • Special Education: $8,000-$43,000 (varies by disability category)
  • Average across all ESA students: $9,782 (2023-24 data)

B. Disbursement Schedule

Funds distributed quarterly according to fixed schedule:

Quarter

Dates

Funding Window

Notes

Q1

July 1 - Sept 30

July 15-31

Contract must be signed; 3-5 weeks for account setup

Q2

Oct 1 - Dec 31

Oct 15-31

Funding adjustments may occur based on final calculations

Q3

Jan 1 - Mar 31

Jan 15-31

Mid-year evaluation period

Q4

April 1 - June 30

April 15-30

Final quarter; renewal contracts sent in May

Critical Timing Note: New contracts signed in Q2 (Oct-Dec) may reflect prior fiscal year funding factors until Q2 funding when adjustments occur.

C. Funding Continuity & Rollovers

  • Unused funds roll over to next fiscal year automatically
  • No expiration while student remains eligible
  • Exited contracts: Students who graduate high school/GED can use remaining balance for up to 4 years for postsecondary education
  • Students with disabilities: Can continue until age 22 if not graduated or earned GED

IV. APPLICATION PROCESS

A. Required Documentation

All Applicants Must Provide:

  1. Student Birth Certificate
    • Full color image showing all four corners
    • Must match applicant's legal name
    • Name change documentation if applicable
  2. Proof of Arizona Residency (Choose from Primary or Secondary lists)

Primary List (submit ONE):

    • Utility bill (water, electric, gas, cable, landline, internet) within 60 days
    • Physical address verification letter from fire/law enforcement (rural only) within 60 days
    • Tribal agency/Chapter House verification (reservation addresses) within 60 days
    • Military temporary on-base billeting facility within 60 days
    • Address Confidentiality Program (ACP) enrollment card

Secondary List (submit TWO if cannot provide Primary):

    • Social Security Administration documents (60 days)
    • Veterans Affairs Administration documents (60 days)
    • Arizona DES documents (60 days)
    • Arizona ADOT vehicle registration (60 days)
    • Property tax bill with name (1 year)
    • W-2, 1098, or 1099 tax documents (1 year)

Alternative:

    • Notarized Affidavit of Shared Residence (if no documents in applicant's name)
  1. Driver's License or Government-Issued ID

For Special Education Students - ADDITIONAL:

  1. Special Education Documentation (one of the following):
    • Complete IEP with signature page (at least one non-parent signature required)
    • Complete MET Report with signature page
    • 504 Plan (complete document)
    • Independent Educational Evaluation from qualified examiner with current license

For Other Special Categories: See specific documentation requirements at azed.gov/esa/eligibility-requirements

B. Application Steps

Step 1: Create ADEConnect Account

  • Visit: https://esaportal.azed.gov/Account
  • Set up email and secure password
  • One-time registration required

Step 2: Complete Online Application

  • Log in to ESA Applicant Portal
  • Fill out student and family information
  • Upload all required documents in one submission

Step 3: Document Review

  • 30-day processing timeline for complete applications
  • Incomplete applications receive email with specific missing items
  • Additional 30 days granted after submitting missing documents
  • Applications closed if documents not submitted within 30 days of notification

Step 4: Contract Issuance

  • Approved applications receive contract via ESA Parent Portal
  • Contract must be signed electronically
  • Email confirmation sent upon signing

Step 5: Account Setup & Funding

  • ClassWallet account created (3-5 weeks after contract signing)
  • ADE requests funding from State Treasurer
  • Treasurer approves and transmits to ClassWallet
  • Account holder receives email notification when funds available
  • Total timeline from contract to funding: 3-5 weeks

C. Application Status Outcomes

flowchart TD

    A[Submit Complete Application] --> B{30-Day Review}

    B -->|Approved| C[Contract Issued]

    B -->|Incomplete| D[Email: Missing Documents]

    B -->|Ineligible| E[Denial Notice with Appeal Rights]

    D --> F[Submit Missing Items]

    F --> G{30-Day Review}

    G -->|Complete| C

    G -->|Still Incomplete After 30 Days| H[Application Closed]

    C --> I[Sign Contract]

    I --> J[ClassWallet Setup - 3-5 Weeks]

    J --> K[Funds Available]


V. ALLOWABLE EXPENSES

A. Universal Expenses (All ESA Students)

1. Private School Tuition & Fees

  • Qualified schools (non-governmental, PK-12, Arizona-based or within 2 miles of border on Indian reservations)
  • Must not discriminate based on race, color, or national origin
  • Approved fees: application, enrollment, registration, facility, lab, book, supply, transportation, uniform, musical instrument rental, payment processing

2. Tutoring & Teaching Services

  • Providers must have high school diploma or higher from accredited institution
  • Arizona recognizes homeschool diplomas (A.R.S. §1-701)
  • Business accreditation attestation form accepted for multi-tutor businesses
  • Examples: Academic subjects, foreign languages, music, art, drama, cooking, physical education, swimming, martial arts, horseback riding, chess, driver's education

3. Curriculum & Supplemental Materials

Curriculum Requirements:

  • Student name
  • Course of study
  • Learning objectives
  • Teaching methods and lesson plans
  • Required supplemental materials list

General Education Supplemental Materials (No curriculum required as of July 2025):

  • Art supplies (paint, canvas, brushes, clay, colored pencils, markers, crayons)
  • Books (physical, audio, digital), magazines, workbooks
  • Educational games, puzzles, flash cards, kits
  • School supplies (paper, folders, binders, writing utensils, staplers)
  • Desk and chair for student (≤2 people capacity)
  • Small file drawer, desk organizer
  • Educational software and apps
  • Instrument accessories and maintenance
  • Manipulatives (math cubes, Legos, blocks, shapes)
  • Timers, clocks, rulers, compasses, protractors
  • Small activity table, school mat/rug (≤35 sq ft)
  • Bookcase (≤40 sq ft)
  • Dry erase boards and easels

Supplemental Materials Requiring Curriculum Documentation:

  • Gym/PE facility membership (student only, not family)
  • Sports league enrollment and camps (no travel/lodging/food)
  • Educational camp enrollment (no travel/lodging/food)
  • Home economics equipment (measuring cups, spatulas, sewing machines, baking equipment)
  • Instruments
  • Photography equipment
  • Physical education equipment
  • Playground equipment
  • Smart boards
  • Watches (analog/digital)
  • Tools for vocational education
  • Seeds/small saplings
  • Single tickets for educational venues (zoos, science/art museums, ballet, orchestra, plays)

4. Online Learning Programs

  • Non-public online schools and programs
  • Subscription must be individual student (not family subscription)
  • Contract-year subscriptions only
  • Subscriber should be student name with parent billing

5. Testing & Assessments

  • Nationally standardized achievement tests
  • Advanced Placement (AP) exams
  • College admission tests (ACT, SAT, PSAT)
  • Prep courses for college admission tests
  • Grade-level standardized testing

6. Postsecondary Education

  • Arizona community colleges
  • Arizona universities under Board of Regents
  • Accredited private in-state or online postsecondary institutions
  • Allowable: Tuition, fees, required textbooks, dual enrollment
  • Not allowable: Room and board, meals, meal plans, transportation

7. Public School Services

  • Individual classes (art, music, vocational education)
  • Extracurricular programs (sports, band, drama, debate)
  • Critical: Student must be enrolled as "Tuition Payer Code 2" (NOT "Payer Code 1")
  • Must obtain itemized invoice from school
  • Uniforms allowed only if specifically required by class/program

8. Computer Hardware & Technology

  • Personal computers, laptops, tablets
  • Calculators, microscopes, telescopes
  • Printers
  • Not allowed: TVs, phones, video game consoles, home theater equipment
  • Note: Educational headphones/earbuds allowed as supplemental material

9. Transportation

  • Public transportation within Arizona between residence and qualified school
  • Includes: commuter passes, taxi, ride-sharing (Uber/Lyft), public bus, vanpool

10. Insurance & Bonds

  • Insurance or surety bond payments related to ESA for allowable expenses

B. Special Education-Only Expenses

Students must have IEP, MET, 504, or IEE on file to access these categories:

1. Educational Therapies & Services

Must be provided by licensed or accredited practitioner. License copy required (not screenshots).

Therapy Type

Required Accreditation

Applied Behavior Analysis (ABA)

BCBA, BCBA-D, BCaBA

Cognitive Behavioral/Play Therapy

Licensed psychologist or counselor

Occupational Therapy (OT)

OT license (OT Assistants approved)

Physical Therapy (PT)

PT license (PT Assistants approved)

Speech Therapy

Speech-Language Pathologist license (SLP Assistants approved)

Aquatic Therapy

Aquatic PT license, OT license, or PT license

Art Therapy

AATA certification, OT license, or PT license

Music Therapy

AMTA, CBMT certification

Equine Therapy/Hippotherapy

EAGALA, NACPET, NARHA, PATH, OT/PT license, or Recreational Therapy cert

Vision Therapy

Pediatric/behavioral/developmental optometrist

Recreational Therapy

ATRA, NCTRC certification, or Recreational Therapy license

Social Group Therapy

CBT certification, licensed counselor, psychologist, school counselor, or special ed teacher

Relationship Development Intervention (RDI)

BCBA, BCaBA, licensed psychologist/counselor, or RDI certificate

Important Notes:

  • Virtual and in-person therapies both approved
  • Late, cancelled, or missed appointment fees NOT allowable
  • Can use private medical insurance in conjunction with ESA (must document uncovered amount)

2. Associated Goods & Assistive Technology

Must provide ONE of the following:

  • Documentation of enrollment in course of study supporting disability/educational need
  • Current IEP, MET, 504, or IEE indicating need for good/service
  • Letter from qualified examiner, qualified service provider, or certified special education teacher indicating need (must include license number and signature)

Examples:

  • Sensory items (weighted blankets, fidget tools, sensory chairs)
  • Assistive technology devices
  • Computer hardware/devices assisting in accessing educational materials
  • Braille-translated materials
  • Specialized educational software
  • Adaptive equipment

Pre-approval option: Can request via ESA Support Ticket (not required)

3. Paraprofessionals & Educational Aides

Distinct from tutors - these individuals assist the tutor, teacher, or parent

Required Credentials (one of the following):

  • Associate degree or higher (transcripts required)
  • 60+ college credit hours from accredited school (transcripts required)
  • Passing score on one of three tests:
    • ACT WorkKeys
    • ParaEducator
    • Praxis ParaPro

4. Educational & Psychological Evaluations

  • Can use ESA funds to obtain private psycho-educational evaluations
  • Must be from qualified examiner (licensed physician, psychiatrist, or psychologist)
  • Used for updating disability classification or obtaining IEE for ESA purposes
  • Note: Universal students (without disability) CANNOT use ESA to pay for initial evaluation

5. Vocational & Life Skills Education

Programs designed to help students develop skills for independent living and work:

  • Career and Technical Education Districts (CTEDs)
  • Vocational schools
  • Trade schools
  • Community colleges (vocational programs)
  • Life skills programs focusing on self-reflection, critical thinking, problem-solving, interpersonal skills

6. Medical Insurance

  • Can use ESA funds in conjunction with private medical insurance for educational therapies
  • Must document amount not covered by insurance on statement/invoice

VI. PROHIBITED EXPENSES

A. Statutory Prohibitions

Technology & Entertainment:

  • Televisions
  • Telephones (smartphones, cell phones)
  • Video game consoles and accessories
  • Home theater and audio equipment
  • Smartwatches with cellular service

Personal Items:

  • Clothing (except required uniforms)
  • Footwear
  • Backpacks, lunch boxes, water bottles
  • Jewelry and precious metals
  • Bedding

Food & Dining:

  • Food of any kind (including animal feed)
  • Ready-to-eat subscription boxes
  • Dining expenses
  • Day care fees

Travel & Lodging:

  • Hotel and lodging
  • Travel costs for teachers or tutors
  • Overnight accommodations for camps

Home & Property:

  • Land/real property
  • Large appliances (stoves, refrigerators, freezers, microwaves)
  • Home furnishings and fixtures (wall art, floor lamps, cabinets, nightstands)
  • Home improvement items (wood, piping, irrigation, concrete)
  • Lawn and landscaping equipment
  • Solar panels or systems
  • Outdoor shade structures
  • Swimming pools, saunas, ponds
  • Greenhouses >100 sq ft
  • Large chicken coops (>12 chickens)

Vehicles & Large Equipment:

  • Motorized vehicles
  • Motorized go-karts, scooters
  • Trailers of any kind
  • Multi-person kayaks
  • Trampolines >10 ft diameter

Fees:

  • Late payment fees
  • Cancellation fees
  • Returned payment fees
  • Non-educational school fees (parking passes, yearbooks, picture day, caps/gowns, fundraising requirements, PTA participation)
  • Amazon Prime or similar subscription fees
  • Consultation fees
  • Assembly/installation fees

Weapons & Safety:

  • Weapons and ammunition
  • BB guns, airsoft guns, paintball guns
  • Exception: Archery bows <35 lbs draw weight for archery instruction

Other:

  • Gift cards of any kind
  • Fundraising fees
  • Live animals (except life-cycle vouchers for educational purposes)
  • BBQ grills, smokers, fire pits
  • Bounce houses, water slides
  • Pizza ovens
  • Children's car seats
  • Commercial/industrial/professional-grade items

B. Non-Approved Therapies & Medical Services

Not allowable even for students with disabilities:

  • Acupressure and acupuncture
  • Chiropractic services
  • Craniosacral therapy
  • Dental exams or services
  • Eye exams, physical exams
  • Health exams, blood work, labs
  • Hyperbaric oxygen therapy
  • Massage therapy
  • Medical equipment, devices, or services
  • Medications, vitamins, supplements
  • Medical supplies (except those required by educational curricula)
  • Nutritionists
  • Reiki
  • Any primarily medical (not educational) service

C. Restrictions on Payments

Cannot pay with ESA funds:

  • Account holders (parents, stepparents, legal guardians)
  • The ESA student themselves
  • Family members providing services
  • Services occurring before contract was signed
  • Services occurring before July 1 of contract year (except pre-paid enrollment fees)
  • Expenses for other students (each ESA is individual)

Shared equipment exception: Can purchase allowable items that may later be used by other ESA siblings


VII. FUND MANAGEMENT SYSTEM

A. ClassWallet Platform

Overview:

  • Third-party financial management system
  • Administered by ClassWallet Inc.
  • Contract with Arizona State Treasurer
  • Secure digital wallet for each student

Access:

  • Through ESA Parent Portal
  • Desktop/laptop recommended (mobile limited functionality)
  • Toggle between multiple students via dropdown menu

Customer Support:

  • Phone: 1-877-969-5536
  • Hours: Monday-Friday 8am-8pm EST, Saturday 10am-4pm EST
  • Email: help@classwallet.com
  • Help site: classwallet.my.site.com/classwallet/s/

B. Four Spending Methods

1. Marketplace

  • Online vendors within ClassWallet platform
  • Items shipped directly to address on record
  • Auto-approval for many standard items
  • Wide selection of educational materials

2. Pay Vendor

  • Direct payment to registered schools and service providers
  • Must upload complete invoice
  • ESA reviews and approves
  • Vendor receives payment within 2-10 business days
  • Vendor receives notification with student name, date, amount
  • Advantage: No need to submit tutor credentials (already on file)

3. Debit Card

  • Physical ClassWallet debit card
  • Draws from ESA account balance
  • Can use at point of sale, PayPal, Square/Venmo
  • Receipt submission required: Quarterly deadlines (see below)
  • After 20 transactions, must upload receipts or card deactivates
  • Restrictions: Certain Merchant Category Codes (MCCs) blocked

Blocked MCCs:

  • MCC 8211: Schools, Elementary and Secondary (must use Pay Vendor for private school tuition)
  • Other codes restricted to prevent fraud
  • Full list available at azed.gov/esa/esa-support
  • Can request MCC exceptions via ESA Support Ticket

Prohibited Debit Card Actions:

  • Cash withdrawals (automatic card suspension)
  • Cash advances
  • Cashier's check purchases
  • Sharing card or login credentials with anyone (including schools/vendors)

4. Reimbursement

  • Pay out-of-pocket, submit for reimbursement
  • Must link bank account to ClassWallet (one-time verification)
  • Submit itemized receipts or invoices with proof of payment
  • Only purchases AFTER contract signature eligible
  • Can submit throughout contract year (final deadline: end of month after contract year ends)

C. Documentation Requirements

Invoice Requirements:

Must include:

  • Vendor/school name, address, contact information
  • Invoice date and number
  • Student name
  • Student grade level (for preschool/kindergarten at qualified schools)
  • Itemized description of services/charges with dates
  • Total charges
  • For therapists/qualified examiners: License number on invoice
  • For reimbursements: Proof of payment required

Receipt Requirements:

Must include:

  • Vendor name, address, contact information
  • Receipt date
  • Receipt/transaction/order/reference number
  • Itemized list of items/services purchased
  • Total amount charged
  • Must be generated by vendor's point-of-sale or receipt system (no handwritten notes)

Debit Card Receipt Deadlines:

Quarter

Purchase Dates

Receipt Upload Deadline

Grace Period

Q1

July 1 - Sept 30

October 31

15 days after notification

Q2

Oct 1 - Dec 31

January 31

15 days after notification

Q3

Jan 1 - Mar 31

April 30

15 days after notification

Q4

April 1 - June 30

July 31

15 days after notification

Consequences of missing deadline:

  1. Account suspension notification
  2. 15-day grace period to submit receipts
  3. Debit card deactivation if not submitted
  4. Possible account termination
  5. Repayment of undocumented purchases
  6. Referral to Attorney General for collections

Additional Documentation:

For specific purchases, may need to upload:

  • Curriculum (for supplemental materials requiring it)
  • Tutor/service provider credentials or business attestation form
  • Therapist license copy
  • Letter from qualified examiner/service provider/certified special ed teacher
  • IEP/MET/504/IEE documentation

VIII. COMPLIANCE & AUDITING

A. Audit Authority

Statutory Basis:

  • A.R.S. §15-2403(B) and A.A.C. R7-2-1508(A)
  • ADE may audit to ensure compliance with rules, policies, handbook, and state law
  • Can only audit last two fiscal years (including current year)
  • Risk-based auditing approach (formal notice to SBE required)

Annual Review Requirement:

  • ADE provides annual notice of review and audit procedures
  • Random reviews conducted
  • Specific purchases may be flagged for documentation requests

B. Key Compliance Principles

1. "Similarly Situated" Doctrine (A.A.C. R7-2-1507(C))

"The Department shall treat similar expenditures by similarly situated account holders in the same manner."

Example:

Student 1

Student 2

Item

Decision

ASD (autism)

ASD (autism)

Weighted blanket

Approved for both (similarly situated)

ASD (autism)

SLI (speech impairment)

Weighted blanket

Approved for Student 1 only (not similarly situated)

ASD (autism)

Universal (no disability)

Weighted blanket

Approved for Student 1 only (not similarly situated)

2. Prior Approval Protection

"The Department shall not request repayment for an expense it has approved for a specific ESA" (A.A.C. R7-2-1507(C))

Important Notes:

  • Applies to expenses explicitly approved by Department
  • Does not authorize spending contrary to statute
  • Does not protect against fraudulent submissions
  • Approval must be for your specific account

3. Core Contract Requirements

Account holders MUST:

  • Spend portion of ESA funds on: reading, grammar, mathematics, social studies, science (annually)
  • Not enroll student in public district/charter/online school concurrently
  • Not accept School Tuition Organization (STO) or tax credit scholarship in same fiscal year
  • Submit debit card receipts by quarterly deadlines
  • Not resell items purchased with ESA funds
  • Not pay themselves or the student with ESA funds
  • Not file homeschool affidavit (ESA contract serves as education proof)

C. Suspension & Termination Process

Suspension Triggers:

  • Missing debit card receipts
  • Unallowable purchases identified
  • Failure to spend on core subjects
  • Public school enrollment while on ESA
  • Concurrent STO scholarship acceptance
  • Fraudulent activity
  • Reselling ESA-purchased items
  • Self-payment violations

Suspension Process:

Day 0: ADE identifies issue

Day 1: Email notification of suspension with details

Day 1-15: Account holder has 15 business days to respond with:

  • Documentation showing purchase was allowable, OR

  • Proof of identity theft/fraud, OR

  • Repayment for unallowable purchase, OR

  • File appeal to State Board of Education

Day 16: If no response:

  • Termination letter sent (email + certified mail)

  • 30 calendar days to resolve or appeal

Day 46: If no response:

  • Account closed

  • Unused funds returned to State general fund

  • Outstanding amounts referred to SBE

  • SBE may refer to Attorney General for collections

Consequences of Termination:

  • All ESA accounts for that parent may be closed
  • Full audit conducted of closed account
  • Repayment required for all violations
  • May be barred from reapplying (especially for fraud)
  • Attorney General collection action possible
  • Criminal referral for substantial fraud

D. Repayment Procedures

When Repayment Required:

  • Unallowable purchases (not protected by prior approval)
  • Missing debit card receipts after grace period
  • Services not received
  • Fraudulent claims
  • Contract violations

Repayment Options:

  1. Immediate Repayment
    • Make payment to: Arizona Department of Education
    • Include: Student name, Application ID, brief explanation
    • Methods: Personal check, cashier's check, money order
    • Address: ADE, Attn: ESA Program, 1535 W. Jefferson St, Bin #41, Phoenix, AZ 85007
  2. Repayment Plan (Active Accounts Only)
    • Request through ESA support
    • ADE may approve installment schedule
    • Missing a payment triggers full balance referral to SBE
    • Account suspension lifted upon agreement
  3. Through Attorney General
    • After SBE referral for collections
    • Must work through AG's established procedures
    • Repayments credited back to ESA account (except fraud cases)

Important: Account reactivates upon successful repayment if still within contract year


IX. SPECIAL EDUCATION SERVICES & PUBLIC SCHOOL INTERACTIONS

A. Child Find Obligations

Federal Requirement (IDEA 20 U.S.C. §1412(a)(3); 34 C.F.R. §300.111(a)):

Public school districts must identify all children with disabilities in their geographic boundaries, including:

  • Private school students
  • Homeschooled students
  • ESA students

Which District is Responsible?

Student's Current Placement

Responsible District

Homeschooled

District where parent resides

For-profit private school

District where parent resides

Non-profit private school

District where private school is located

Charter school

Charter school itself (no geographic boundaries)

District Obligations:

  • Must either conduct evaluation, OR
  • Provide prior written notice refusing to conduct evaluation

Key Point: ESA parents can request evaluations from public schools at no cost, even while participating in ESA program.

B. Equitable Services

Federal Law (34 C.F.R. §300.137(a)):

"A parentally placed private school child with a disability does NOT have an individual right to receive some or all of the special education and related services that the child would receive if enrolled in a public school."

However - Equitable Services May Be Available:

Eligible Students:

  • Students with disabilities attending non-profit private schools
  • Homeschooled students with disabilities
  • Regardless of ESA participation

Not Eligible:

  • Students attending for-profit private schools
  • Federal regulation 34 C.F.R. §300.132(a) excludes students in state-funded voucher programs from individual equitable services rights

What Are Equitable Services?

  • Limited special education services provided by public school district
  • Determined through consultation with private school officials
  • No individual entitlement - services determined by district allocation
  • Examples: Speech therapy, counseling, specialized instruction (limited hours)

Important:

  • Parents may accept or decline equitable services
  • No impact on ESA eligibility or contract
  • Contact ADE Exceptional Student Services: 602-542-4013

Information: Visit azed.gov Exceptional Student Services website for details on equitable services

C. Obtaining or Updating Disability Evaluations

Three Pathways to Obtain Evaluation:

Option 1: Public School Evaluation (No Cost)

  • Contact appropriate school district (see Child Find table)
  • Request special education evaluation in writing
  • District has specific timelines to respond and evaluate under IDEA
  • Results in IEP, MET Report, or 504 Plan

Option 2: ADE Contracted Third-Party Evaluator

  • Contact ESA Program to inquire about contracted evaluators
  • ADE may have contracts with independent evaluators
  • Costs covered or subsidized

Option 3: County Superintendent's List

  • If ADE has no contracted evaluators
  • Contact county school superintendent's office
  • Request list of approved independent evaluators
  • May need to pay out-of-pocket and seek reimbursement

Option 4: Independent Educational Evaluation (IEE)

  • Hire qualified examiner: Licensed physician (MD/DO), psychiatrist, or psychologist
  • Obtain evaluation for ESA purposes
  • Can use ESA funds to pay (only if already classified as student with disability)
  • Must include examiner's current license showing it was valid at time of evaluation

Updating Disability Classification:

Process:

  1. Obtain new/updated evaluation (using any of 4 options above)
  2. Submit ESA Support Ticket via ESA Parent Portal
  3. Upload complete evaluation document
  4. Request account update to reflect new disability category
  5. ESA staff reviews (processing time varies)
  6. If approved, new contract issued in portal
  7. Sign new contract immediately to prevent funding delays

Important Notes:

  • Not all re-evaluations increase funding (may decrease based on new category)
  • Must highlight relevant sections showing disability/need in documentation
  • For students turning 10 with Developmental Delay, re-evaluation needed for continued disability status
  • For preschool students with Severe Delay moving to Kindergarten, re-evaluation needed for K-12 disability classification

Flowchart: Changing Disability Classification

Student needs evaluation/re-evaluation

        ↓

Choose evaluation pathway:

  • Public school (free)

  • ADE contracted evaluator

  • County superintendent list

  • Independent qualified examiner

        ↓

Obtain complete evaluation with:

  • Diagnosis/findings

  • Signature page (non-parent signature)

  • Current license of evaluator

        ↓

Submit via ESA Support Ticket:

  • Upload evaluation

  • Request classification update

        ↓

ADE reviews and approves/denies

        ↓

If approved: New contract issued

        ↓

Sign new contract immediately

        ↓

Funding adjustment (if applicable) in next quarter

D. Students with Disabilities Beyond Grade 12

Extended Eligibility (A.R.S. §15-2402(4)(n)):

Students with disabilities who:

  • Have not graduated high school, AND
  • Have not earned GED

May continue ESA until age 22

Process:

  • In spring of 12th-grade cohort year, ESA notifies account holder
  • Account holder indicates intention to continue
  • Student must still meet disability classification requirements
  • Can continue accessing disability-specific expenses

After High School Graduation or GED:

  • Student receives "Exited" contract if funds remain
  • Can spend remaining balance for up to 4 years
  • Only for postsecondary education expenses
  • No new funding provided
  • Must still follow all program rules

X. PRIVATE SCHOOL ENGAGEMENT

A. Qualified School Requirements

Definition (A.R.S. §15-2401): "A nongovernmental primary or secondary school or a preschool for pupils with disabilities located in Arizona serving PK-12th grades."

Requirements:

  • Must not discriminate based on race, color, or national origin
  • Located in Arizona (exception: within 2 miles of border on Indian reservations)
  • Can be religious or secular
  • No state licensure or accreditation required
  • Sets own admission standards
  • Establishes own curriculum and policies

Schools Cannot:

  • Share, refund, or rebate ESA funds to account holders or students (A.R.S. §15-2402(J))
  • Keep debit cards on behalf of parents
  • Access parent ClassWallet accounts
  • Require disclosure of ESA award amounts

B. Tuition Payment Process

Step 1: Obtain Complete Invoice from School

Invoice must include:

  • School name, address, contact information
  • Invoice date and number
  • Student name
  • Grade level (for preschool/kindergarten)
  • Itemized charges: tuition, fees (with descriptions)
  • Total amount due
  • Payment due date

Step 2: Choose Payment Method

Option A: Pay Vendor (Recommended if school is registered)

  • Upload invoice in ClassWallet Pay Vendor section
  • Select school from vendor list
  • ESA reviews and approves
  • School receives payment in 2-10 business days
  • School receives payment notification with student name/amount

Option B: Debit Card

  • Use if school accepts card payments
  • Must verify school's MCC is not blocked
  • Submit paid invoice/receipt by quarterly deadline
  • School may charge 2% processing fee

Option C: Reimbursement

  • Pay school directly with personal funds
  • Upload paid invoice (showing payment received)
  • Receive reimbursement to linked bank account

Step 3: Documentation & Compliance

  • Keep copies of all invoices and payment confirmations
  • Upload to ClassWallet as required
  • Note payment date and method

C. School Registration as ClassWallet Vendor

Benefits for Schools:

  • Direct payment from ADE (no parent intermediary)
  • Predictable payment timeline (2-10 business days)
  • Automated payment notifications
  • Simplified reconciliation

Registration Process:

  1. Visit azed.gov/esa/esa-support (Vendor section)
  2. Click vendor registration link
  3. Complete ClassWallet vendor application
  4. Provide: Business information, tax ID, banking details, contact information
  5. ADE reviews registration
  6. Approval typically within 2-4 weeks
  7. Listed in ClassWallet Pay Vendor directory

ClassWallet Processing Fee:

  • 2% fee charged to vendor (not directly to parent)
  • Vendors may pass fee to parents as processing charge
  • Must be disclosed on invoice if charged

Alternative: Schools can remain unregistered and accept debit card or reimbursement payments (but longer payment timeline for parents)

D. Uniform Requirements

Allowable if:

  • Purchased from or through the qualified school, OR
  • School provides list of recommended/required vendors

Must be:

  • Specific uniform requirement (not general clothing)
  • Documented on school invoice or requirement list
  • Used for educational purposes

XI. TUTORING & SERVICE PROVIDER ENGAGEMENT

A. Individual Tutors

Minimum Qualification:

  • High school diploma or higher degree
  • From state, regional, or national accredited organization
  • Arizona recognizes homeschool diplomas (A.R.S. §1-701)

Documentation Required:

  • Copy of diploma, degree, or full transcripts
  • Cannot be screenshots
  • Must be legible
  • Cannot be expired (if time-limited credential)

Payment Methods:

Option 1: Register as ClassWallet Vendor

  • Provides credential once during registration
  • Parents can pay via Pay Vendor (no repeated credential uploads)
  • Receives payment within 2-10 business days
  • 2% processing fee

Option 2: Accept Debit Card Payment

  • Parent uploads tutor credential with each receipt submission
  • Immediate payment to tutor
  • Parent responsible for quarterly documentation

Option 3: Reimbursement

  • Parent pays tutor directly
  • Parent uploads receipt + credential
  • Parent receives reimbursement

Invoicing Best Practices:

  • Include all required invoice elements (see Section VII.C)
  • Itemize by date and subject
  • Include license/credential number if applicable
  • Specify exact services provided

B. Multi-Tutor Businesses

Two Options for Accreditation:

Option 1: Business Accreditation

  • Submit documentation of business accreditation from state, regional, or national organization
  • Covers all tutors under business umbrella

Option 2: Business Attestation Form

Complete and submit "Tutoring/Teaching Services Business Accreditation Attestation Form"

Form Requirements:

  • Company name, address, phone, email
  • Attestation that:
    • For academic tutoring: All tutors have high school diploma or higher from accredited organization
    • For non-academic tutoring: All tutors have high school diploma or higher OR certification in area of instruction
  • Signature of company representative
  • Date

Available at: azed.gov/sites/default/files/2025/02/ESA_Tutoring_Teaching_Services_Attestation_Fillable_Form.pdf

Key Benefit: One-time submission covers all tutors; parents don't need individual credentials

C. Therapy Providers (Special Education Only)

Strict Licensure Requirements

Must provide copy of current, valid license:

  • Not screenshots of website
  • Actual license document or verification from state board
  • Must show license number and expiration date
  • Must be current at time services provided

For Foreign Credentials:

  • Must be translated to English
  • Must be evaluated for U.S. degree equivalence
  • Evaluation by qualified credential evaluation service
  • Translator and evaluation costs not covered by ESA

Payment Process:

Best Practice: Register with ClassWallet

  • Upload license once during registration
  • Parents pay via Pay Vendor without repeated uploads
  • Faster payment processing

Alternative: Direct Payment

  • Parent uploads license copy with each transaction
  • Required for debit card and reimbursement methods

Documentation:

  • Session notes or progress reports helpful but not required
  • Invoice must itemize dates of service
  • License number should appear on invoice

Coordination with Insurance:

  • Can use ESA + private insurance
  • Invoice must show insurance payment and balance due
  • ESA can cover co-pays and amounts not covered by insurance

XII. CURRICULUM & HOMESCHOOL GUIDANCE

A. Educational Requirements

Mandatory Subjects (A.R.S. §15-2402(B)(1)):

Account holders MUST spend a portion of ESA funds annually on:

  • Reading
  • Grammar
  • Mathematics
  • Social studies
  • Science

Verification:

  • Audited during compliance reviews
  • Must show purchases/receipts in each subject area
  • Can be curriculum, tutoring, online programs, or qualified school
  • No minimum amount specified per subject

Recommended but Not Required:

  • Art, music, physical education
  • Foreign languages
  • Vocational education
  • Life skills

B. Homeschool Affidavit - CRITICAL RULE

DO NOT file homeschool affidavit with county superintendent while on ESA

Why:

  • A.R.S. §15-2402(B)(5) prohibits filing homeschool affidavit
  • ESA contract serves as proof of education
  • Double-filing may cause legal complications

If Already Filed:

  • Contact appropriate county superintendent's office immediately
  • Request withdrawal of homeschool affidavit
  • Provide copy of signed ESA contract as education proof

Classification:

  • ESA students are NOT classified as "homeschoolers" under Arizona law
  • ESA is distinct category
  • Different reporting and requirements

C. Curriculum Development & Documentation

When Curriculum Required:

Curriculum documentation needed for supplemental materials that:

  • Are not on the "general education supplemental materials" list
  • Require justification for educational purpose
  • Include: gym memberships, sports leagues, educational camps, instruments, specialized equipment

Curriculum Components:

Must Include:

  1. Student Information
    • Student name
    • Student ESA Application ID number
    • Grade level or age
  2. Course of Study
    • Subject area (e.g., Art, Physical Education, Music, Science)
    • Overall goals and learning objectives
  3. Method of Teaching
    • Instructional approach
    • Lesson plans (can be brief)
    • Activities and exercises
    • Timeline or schedule
  4. Required Supplemental Materials
    • List of materials needed to achieve learning objectives
    • How materials support curriculum
    • Scope and sequence showing material integration

Example: Parent-Provided Curriculum for Art

Student Name: [Student Name]

Application ID: [######]

Subject: Art

 

Learning Objectives:

• Understand and identify warm colors and cool colors

• Explore how colors affect mood and emotion

• Apply color theory in creative projects

 

Method of Teaching/Lesson Plans:

 

Lesson 1: Discovering Warm and Cool Colors

Activities:

1. Discussion: Introduce warm colors (red, orange, yellow) and cool colors (blue, green, purple)

2. Color Exploration: Using crayons, draw pictures using warm colors on one side of paper and cool colors on other side

3. Reflection: Students share drawings and discuss how colors make them feel

 

Lesson 2: Nature's Colors

Activities:

1. Leaf Collection: Collect variety of fall leaves

2. Observation: Analyze leaves and categorize into warm and cool color groups

3. Watercolor Painting: Create background divided into warm and cool color zones

4. Leaf Rubbing: Create leaf rubbings focusing on capturing colors

 

Required Supplemental Materials:

• 9 x 18 inch white paper

• Crayons (warm and cool colors)

• Variety of fall leaves

• Watercolor paints

• Wide paint brush

• Newspaper

Submission:

  • Upload via ClassWallet when submitting purchase
  • Can upload multiple curricula for different subjects
  • Update annually or as needed
  • Can reuse curriculum for multiple purchases in same subject

Template Available: azed.gov/sites/default/files/2025/02/Parent_Provided_Curriculum_Fillable_Form.pdf

D. Online Curriculum & Programs

Allowable Online Programs:

  • Complete online schools (non-public)
  • Individual course subscriptions
  • Educational software and apps
  • Video-based learning platforms

Requirements:

  • Must be individual student subscription (not family plan)
  • Contract-year subscriptions only
  • Subscriber name should be student with parent billing

Examples:

  • Time4Learning
  • Khan Academy (if subscription-based)
  • Teaching Textbooks
  • IXL
  • ABCmouse (age-appropriate)
  • Outschool classes
  • EdX courses

Documentation:

  • Submit invoice/receipt showing student name
  • Must indicate educational purpose
  • If family subscription, must show itemized breakdown per student

XIII. FINANCIAL PLANNING & OPTIMIZATION

A. Award Maximization Strategies

1. Disability Classification Optimization

Action: Ensure evaluation captures all applicable disabilities

  • Students may qualify for multiple disability categories
  • Primary category determines funding weight
  • Re-evaluation every 3 years recommended
  • Can request change in classification if circumstances change

Example:

  • Student initially classified as SLD (Specific Learning Disability): ~$12,000/year
  • Re-evaluation reveals ASD (Autism Spectrum Disorder) + ADHD: ~$28,000/year
  • Annual increase: $16,000

2. Timing of Contract Signing

Strategic Timing:

  • Sign contract in Q1 (July) to access full year's funding
  • Q2 signings may experience funding adjustments
  • Earlier signing = earlier access to funds

3. Preschool Early Intervention

Opportunity:

  • Children age 3-5 with disabilities qualify
  • Early intervention services expensive
  • ESA can cover therapies, specialized preschools
  • $8,000-$15,000 annually for preschool ages

Action: Obtain evaluation as early as age 3 (or within 90 days of third birthday)

4. Fund Rollover Strategy

Key Insight: Unused funds roll over indefinitely

Strategic Applications:

  • Build balance in early years for expensive later needs
  • Save for high school (dual enrollment, AP exams, college prep)
  • Accumulate for postsecondary education (exited contract)
  • Plan for age 18-22 continuation (students with disabilities)

Example:

  • Years K-5: Spend $15,000/year, receive $25,000/year
  • Accumulation: $10,000 × 6 years = $60,000
  • High school years: Use accumulated funds for intensive college prep, dual enrollment, private tutoring

5. Combining Resources

Allowable Combinations:

  • ESA + Private insurance (for therapies)
  • ESA + Public school services (individual classes, labeled as Tuition Payer Code 2)
  • ESA + Scholarships from private organizations (not STOs)
  • ESA + Family contributions
  • ESA + 529 college savings plans (for postsecondary)

Not Allowable:

  • ESA + School Tuition Organization (STO) scholarships (same fiscal year)
  • ESA + Public school enrollment as Payer Code 1

B. Budget Allocation Models

Model 1: Private School + Therapies (Common for Special Ed)

Category

Annual Cost

% of $28,000 Award

Private school tuition

$12,000

43%

Speech therapy (2x/week)

$8,000

29%

Occupational therapy (1x/week)

$4,000

14%

Curriculum & materials

$2,000

7%

Testing & assessments

$1,000

4%

Educational technology

$1,000

4%

Total

$28,000

100%

Model 2: Homeschool + Intensive Therapies (Special Ed)

Category

Annual Cost

% of $28,000 Award

ABA therapy (15 hrs/week)

$15,000

54%

Curriculum & materials

$3,000

11%

Online programs

$2,000

7%

Tutoring (math, reading)

$4,000

14%

Occupational therapy

$3,000

11%

Educational supplies & technology

$1,000

4%

Total

$28,000

100%

Model 3: Hybrid Approach (General Ed)

Category

Annual Cost

% of $7,000 Award

Part-time private school (3 days/week)

$4,000

57%

Online learning programs

$1,000

14%

Tutoring (specialized subjects)

$1,200

17%

Curriculum & materials

$500

7%

Educational experiences (museums, camps)

$300

4%

Total

$7,000

100%

Model 4: Dual Enrollment Focus (High School)

Category

Annual Cost

% of $7,500 Award

Community college courses (12 credits)

$3,600

48%

Online high school

$2,000

27%

AP/SAT prep courses

$800

11%

Required textbooks

$600

8%

Testing fees (AP, SAT)

$500

7%

Total

$7,500

100%

C. Tax Implications

Federal Tax Treatment:

  • ESA funds do NOT constitute taxable income (A.R.S. §15-2401)
  • No Form 1099 issued
  • No reporting required on federal tax return

State Tax Treatment:

  • Arizona: Not taxable income
  • No state reporting required

Important Distinction:

  • 529 Education Savings Plans: Different tax treatment
  • Coverdell ESA: Different from Arizona ESA program
  • Private scholarships: May have different tax implications

Records to Keep:

  • ESA does not change tax filing requirements
  • Maintain records for audit purposes (not tax purposes)
  • Keep documentation for 2 years minimum

XIV. PRIVACY, SECURITY & DATA PROTECTION

A. FERPA Protections

Family Educational Rights and Privacy Act (FERPA):

  • Arizona law A.R.S. §15-1045 incorporates FERPA protections
  • ESA records likely constitute "education records"
  • Personally identifiable information protected

Protected Information:

  • Student name, date of birth, address
  • Disability classifications and evaluations
  • Educational records and progress
  • Financial information (award amounts, purchases)
  • Family contact information

Who Can Access:

  • Account holder (parent/stepparent/legal guardian)
  • Designated advocates (with written permission)
  • ADE staff (for program administration)
  • SBE (for appeals and oversight)
  • Auditors (for compliance)

Who Cannot Access:

  • Private schools (without parent consent)
  • Service providers (without parent consent)
  • Other family members (without designation)
  • Public (AZOCA opinion I20-010)

B. Advocate Designation

Advocates Defined:

  • Friends, family members, consultants who assist with ESA navigation
  • May participate in calls/emails with ADE
  • May help prepare documents

Formal Designation Required:

  • Account holder must submit written notification to ADE
  • Must specify advocate name and contact information
  • Account holder must be present for all communications
  • Advocates cannot submit documents independently

Process:

  1. Send written notice to ESACallCenter@azed.gov
  2. Include: Advocate name, relationship, phone, email
  3. Specify scope of assistance
  4. Update as needed

Limitations:

  • Advocates cannot sign applications or contracts
  • Advocates cannot access ClassWallet accounts
  • Advocates cannot receive confidential information directly
  • Account holder maintains full responsibility

C. Information Security Best Practices

ClassWallet Account Security:

Critical Rules:

  • NEVER share login credentials with anyone
  • NEVER share ClassWallet password
  • NEVER give debit card to schools or vendors
  • NEVER share debit card PIN

Recommended Practices:

  • Use strong, unique password
  • Enable two-factor authentication if available
  • Log out after each session
  • Monitor account regularly for unauthorized transactions
  • Report suspicious activity immediately

Personal Information Protection:

Do Not Share with Third Parties:

  • ESA Application ID number
  • Student social security number
  • Date of birth
  • Award amounts
  • ClassWallet account details

Limited Sharing Necessary:

  • Schools need: Student name, grade, invoice requirements
  • Tutors need: Student name, subjects, schedule
  • Therapists need: Student name, disability information (relevant to services)

Identity Theft Protection:

  • Report suspected fraud immediately
  • File police report if identity theft suspected
  • Notify ADE ESA Program
  • Dispute unauthorized charges with ClassWallet
  • May need to freeze credit (for parent and student)

Document Security:

  • Store evaluation documents securely
  • Shred old financial documents
  • Use secure file sharing for sensitive uploads
  • Avoid sending sensitive info via unencrypted email

D. Public Records Requests

Arizona Public Records Law:

  • Some ESA records may be subject to public records requests
  • Attorney General Opinion I20-010: ESA contracts and certain documents likely not public records under FERPA
  • ADE will protect information to maximum extent allowed by law

What May Be Public:

  • Aggregate program statistics
  • Total enrollment numbers
  • Average award amounts (not individual)
  • Policy documents and handbooks

What Should Remain Private:

  • Individual student information
  • Specific disability classifications
  • Award amounts for individuals
  • Purchase histories
  • Family contact information

XV. DISPUTE RESOLUTION & APPEALS

A. Appeal Rights

State Board of Education (SBE) Appeals:

Grounds for Appeal:

  • Denial of application
  • Account suspension
  • Account termination
  • Repayment determination
  • Disagreement with ADE decision

Appeal Process:

Step 1: Receive notice from ADE

        (Denial, suspension, termination)

        ↓

Step 2: Submit written appeal to SBE

        Timeline: Within timeframes specified in notice

        (Usually 15 days for suspension, 30 days for termination)

        ↓

Step 3: SBE reviews appeal

        May request additional information

        May schedule hearing

        ↓

Step 4: SBE issues decision

        Options: Uphold ADE, reverse ADE, modify ADE decision

        ↓

Step 5: If unfavorable - Superior Court appeal

        Must file within 35 days of SBE decision (A.R.S. §41-1993)

How to File Appeal:

  • Visit: azsbe.az.gov/empowerment-scholarship-account-esa-program
  • Download appeal form
  • Submit via email or mail to SBE
  • Include: Copy of ADE notice, supporting documentation, detailed explanation

SBE Contact:

  • Arizona State Board of Education
  • 1535 W. Jefferson St.
  • Phoenix, AZ 85007
  • Phone: 602-542-5057

B. Arizona Ombudsman-Citizens' Aide (AZOCA)

Role:

  • Independent state agency
  • Investigates complaints against state agencies
  • Mediates disputes
  • No cost to families

When to Contact AZOCA:

  • Communication breakdowns with ADE
  • Unresolved issues after attempts to resolve with ESA program
  • Concerns about fairness or process
  • Need for neutral third-party assistance

What AZOCA Can Do:

  • Investigate complaints
  • Facilitate communication
  • Recommend solutions
  • Issue findings

What AZOCA Cannot Do:

  • Overturn ADE decisions (use SBE appeals)
  • Provide legal advice
  • Act as attorney
  • Force specific outcomes

Contact AZOCA:

  • Phone: 602-277-7292
  • Web: azoca.gov
  • Complaint form available online
  • No cost, confidential assistance

C. Internal ADE Resolution Process

Before Appeals - Resolution Steps:

Step 1: ESA Support Ticket

  • Submit ticket via ESA Parent Portal
  • Clearly explain issue
  • Attach relevant documentation
  • Receive response within 3-5 business days (typical)

Step 2: Phone Call to ESA Call Center

  • 602-364-1969
  • Monday-Friday, 8am-5pm
  • Request to speak with supervisor if needed
  • Document call: date, time, representative name, outcome

Step 3: Email to ESA Call Center

  • ESACallCenter@azed.gov
  • Put "Escalation Request" in subject line
  • Include account details (Application ID, student name)
  • Summarize previous attempts to resolve

Step 4: Request Executive Review

  • If unresolved after Steps 1-3
  • Send email to ESA Program leadership
  • Reference previous tickets/calls
  • Request formal review

Step 5: Consider Ombudsman or Appeal

  • If internal resolution unsuccessful
  • Evaluate whether formal appeal appropriate
  • Consider AZOCA assistance

Documentation Best Practices:

  • Keep copies of all correspondence
  • Note dates, times, names of ADE staff
  • Save email confirmations
  • Screenshot important information
  • Organize chronologically

XVI. STRATEGIC RECOMMENDATIONS

A. For Families New to ESA

Phase 1: Application (Weeks 1-4)

Priority Actions:

  1. Gather all required documents before starting application
  2. For special ed: Obtain current IEP/MET/504 or schedule evaluation
  3. Review residency documentation requirements carefully
  4. Complete application in single session if possible
  5. Upload clear, complete images (all four corners visible)
  6. Submit application early in fiscal year if possible (July preferred)

Common Pitfalls to Avoid:

  • Incomplete birth certificate images
  • Expired utility bills
  • Missing signature pages on evaluations
  • Applying without current disability documentation

Phase 2: Contract & Setup (Weeks 5-8)

Priority Actions:

  1. Sign contract immediately upon receipt
  2. Set up ClassWallet account (desktop/laptop required)
  3. Link bank account for reimbursements
  4. Order ClassWallet debit card
  5. Review allowable expenses thoroughly
  6. Begin researching schools/service providers

Phase 3: Initial Spending (Months 3-6)

Priority Actions:

  1. Secure private school placement (if using)
  2. Schedule evaluations/assessments (if needed)
  3. Identify and vet tutors/therapists
  4. Purchase core curriculum
  5. Set up online learning programs
  6. Establish routine for receipt documentation

Best Practices:

  • Start with Pay Vendor for tuition (easiest method)
  • Use Marketplace for standard educational materials
  • Save debit card for point-of-sale purchases
  • Document everything immediately
  • Create folder system for receipts

B. For Families with Special Education Students

Maximizing Benefits:

1. Comprehensive Evaluation Strategy

  • Schedule comprehensive evaluation every 3 years
  • Ensure evaluation tests for all relevant disabilities
  • Consider private IEE if public school evaluation inadequate
  • Document all therapist recommendations for equipment/services

2. Therapy Optimization

  • Research therapy providers before funds arrive
  • Verify licensure before engaging services
  • Request invoices with clear itemization
  • Coordinate with private insurance for maximum coverage
  • Consider group therapy options (more affordable)

3. Equipment & Technology Planning

  • Create list of assistive technology needs
  • Obtain letters of recommendation from therapists
  • Research before purchasing (ensure quality and fit)
  • Consider equipment that grows with student
  • Plan for technology refresh cycle (3-5 years)

4. Associated Goods Documentation

  • Keep all IEP/MET/504 documents current
  • Request therapist letters for sensory items
  • Highlight specific recommendations in documents
  • Submit pre-approval requests for expensive items

5. Transition Planning (Age 18-22)

  • Begin vocational assessment at age 14-16
  • Explore CTED programs
  • Research trade schools and community colleges
  • Build life skills curriculum
  • Plan for supported employment if appropriate

C. For Homeschooling Families

Curriculum Development:

Year-Round Planning:

  • Q1 (July-Sept): Plan annual curriculum, order materials
  • Q2 (Oct-Dec): Assess progress, adjust as needed
  • Q3 (Jan-March): Mid-year evaluation, plan spring activities
  • Q4 (April-June): Testing, prepare for next year

Record Keeping:

  • Maintain portfolio of work samples
  • Document field trips and educational experiences
  • Track hours (not required but helpful)
  • Keep reading logs
  • Save completed assignments

Community Resources:

  • Join ESA homeschool co-ops
  • Participate in field trip groups
  • Share vendor/tutor recommendations
  • Attend ESA Parent Advisory Committee meetings

Compliance Focus:

  • Ensure coverage of five core subjects
  • Document spending in each subject area
  • Keep curriculum current and detailed
  • Maintain organized ClassWallet records

D. For Families Using Private Schools

School Selection Criteria:

Educational Fit:

  • Academic philosophy alignment
  • Special education support (if needed)
  • Class sizes
  • Teacher credentials
  • Curriculum approach

ESA Compatibility:

  • Registered as ClassWallet vendor (preferred)
  • Experience with ESA families
  • Clear invoicing practices
  • Reasonable payment timelines
  • Transparent fee structure

Financial Considerations:

  • Total cost vs. ESA award
  • Payment schedule compatibility with quarterly funding
  • Additional fees beyond tuition
  • Scholarship opportunities (non-STO)

Red Flags:

  • Requests to hold debit card
  • Asks for ClassWallet login
  • Requests disclosure of award amount
  • Unclear or changing fee structures
  • Resistance to providing proper invoices

Relationship Management:

  • Provide only necessary information
  • Use Pay Vendor for all tuition payments
  • Keep copies of all invoices
  • Communicate payment timelines early
  • Address issues promptly

XVII. COMMON SCENARIOS & SOLUTIONS

A. Scenario: Mid-Year Public School to ESA Transition

Situation: Student currently in public school (October), family wants to transition to ESA

Action Plan:

  1. Apply immediately - Don't wait for semester end
  2. Obtain required documents while still enrolled (IEP/MET if special ed)
  3. Submit complete application - 30-day processing begins
  4. Upon approval: Sign contract immediately
  5. Withdraw from public school only after ClassWallet is funded (3-5 weeks after signing)
  6. Begin ESA spending - Q2 funding already distributed, access Q3 funds in January

Financial Impact:

  • Q1 funds: Not available (student was in public school July-Sept)
  • Q2 funds: Available if contract signed before December 31
  • Q3-Q4 funds: Full amount available
  • Total year 1: Approximately 50-75% of annual award

Key Considerations:

  • Cannot spend ESA funds while enrolled in public school as Payer Code 1
  • Must completely withdraw from public school district
  • Summer school at public school triggers violation if enrolled before withdrawal

B. Scenario: Concurrent Public School Class Enrollment

Situation: ESA student wants to take one class at local public high school (e.g., chemistry lab)

Proper Process:

  1. Contact public school - Ask if they accept ESA students for individual classes
  2. Specify Tuition Payer Code 2 - Critical enrollment status
  3. Obtain itemized invoice from school showing:
    • Student name
    • Class description
    • Tuition amount for that class only
    • School contact information
  4. Pay via ClassWallet using invoice
  5. Ensure student not enrolled in public school's student information system as regular student

Common Mistakes to Avoid:

  • Enrolling as full-time public school student (Payer Code 1)
  • Not obtaining proper invoice
  • Taking multiple classes without proper documentation
  • Accepting "free" public school enrollment (violates ESA contract)

Consequence of Improper Enrollment: Account termination and repayment of entire year's ESA funds

C. Scenario: Therapy Provider Not Licensed in Arizona

Situation: Family finds excellent ABA therapist licensed in California but providing telehealth to Arizona student

Analysis:

  • Arizona requires licensure from Arizona or license verification
  • Out-of-state telehealth providers must comply with Arizona regulations
  • Some therapy boards have reciprocity agreements

Solutions:

  1. Check Arizona licensure - Many providers maintain multiple state licenses
  2. Verify compact agreements - Some professions have interstate compacts
  3. Request pre-approval via ESA Support Ticket with:
    • Provider's out-of-state license
    • Explanation of why this provider necessary
    • Confirmation provider is compliant with Arizona telehealth laws
  4. Consider alternative: Find Arizona-licensed provider offering similar services

Best Practice: Prioritize Arizona-licensed providers to avoid complications

D. Scenario: Private School Tuition Exceeds ESA Award

Situation: Special ed student with $28,000 ESA award, private school tuition is $35,000

Funding Options:

  1. ESA funds: $28,000 toward tuition
  2. Family contribution: $7,000 out-of-pocket
  3. Private scholarships: Non-STO scholarships (allowed)
  4. School financial aid: If school offers (not STO-based)
  5. Payment plan: Negotiate with school

Payment Strategy:

  • Use all four quarterly ESA disbursements toward tuition
  • Family pays difference directly to school
  • School invoice should show total tuition and payments from all sources
  • For ESA reimbursement: Submit invoice showing ESA-eligible portion

Important: Cannot accept STO scholarship in same fiscal year as ESA contract

E. Scenario: ClassWallet Debit Card Declined at Educational Vendor

Situation: Debit card declined at bookstore; purchase is allowable expense

Possible Causes:

  1. Insufficient funds in ClassWallet account
  2. MCC restriction - Vendor's merchant category code is blocked
  3. Transaction limit - Daily/weekly limits exceeded
  4. Card not activated or expired
  5. Incorrect PIN entered

Immediate Solutions:

  1. Check balance - Log into ClassWallet, verify funds available
  2. Verify MCC - Contact ClassWallet to check if vendor's MCC is blocked
  3. Alternative payment: Pay out-of-pocket, submit for reimbursement
  4. Contact ClassWallet: 1-877-969-5536 for technical support

Long-term Solutions:

  • If MCC is blocked but vendor sells allowable items: Submit ESA Support Ticket requesting MCC approval
  • Use Pay Vendor or Marketplace when possible to avoid MCC issues
  • Keep personal credit card as backup for reimbursement method

F. Scenario: Changing Disability Classification Mid-Year

Situation: Student classified as SLD ($12,000 award), new evaluation shows ASD ($28,000 award) in January

Process:

  1. Obtain new evaluation from public school or qualified examiner
  2. Submit ESA Support Ticket with complete evaluation attached
  3. Request classification update
  4. ADE reviews (1-3 weeks typical processing)
  5. New contract issued reflecting updated classification and funding
  6. Sign new contract immediately
  7. Funding adjustment appears in Q3 (January funding)

Financial Impact:

  • Q1-Q2: Received $6,000 (SLD rate for 6 months)
  • Q3-Q4: Receive remaining at ASD rate: $22,000
  • Total Year 1: $28,000 (full ASD annual award, prorated)
  • Year 2 and beyond: Full $28,000 annually

Important: Not all re-classifications increase funding; some may decrease based on new category

G. Scenario: Student Graduates High School with $15,000 Remaining Balance

Situation: Student graduates in May, has $15,000 unused ESA funds

Options:

  1. Exited Contract - Can use funds for postsecondary education for up to 4 years
  2. Allowable uses:
    • Community college tuition and fees
    • University tuition (AZ Board of Regents schools)
    • Accredited private postsecondary tuition
    • Required textbooks
    • Course-related fees
  3. Quarterly documentation still required if using debit card
  4. Cannot use for: Room, board, meals, non-academic expenses

Process:

  1. Notify ESA program of graduation
  2. Receive Exited contract
  3. Sign Exited contract
  4. Continue using funds per program rules
  5. Funds remain available until depleted or 4 years post-graduation

H. Scenario: Identity Theft - Unauthorized ClassWallet Transactions

Situation: Account holder discovers unauthorized transactions on ClassWallet debit card

Immediate Actions (First 24 Hours):

  1. Contact ClassWallet: 1-877-969-5536 - Report fraud, freeze card
  2. Document transactions: Screenshot all unauthorized charges
  3. Contact ADE: ESACallCenter@azed.gov - Report suspected fraud
  4. File police report - Obtain case number
  5. Dispute charges with ClassWallet fraud department

Follow-Up Actions (Days 2-7):

  1. Submit ESA Support Ticket with:
    • Description of fraud
    • Screenshots of unauthorized transactions
    • Police report copy
    • Timeline of discovery
  2. Request new card through ClassWallet
  3. Review all transactions from past 90 days
  4. Change passwords for ClassWallet and ESA Portal

Protection from Liability:

  • If identity theft documented, not responsible for repayment
  • Must cooperate with investigation
  • May need affidavit of fraud
  • Account will not be suspended/terminated for verified fraud

XVIII. VENDOR & PROVIDER DIRECTORY GUIDANCE

A. Finding Qualified Providers

Private Schools:

  • Arizona School Choice: azschoice.com (directory of private schools)
  • National Association of Private Schools: member directories
  • Local ESA parent groups: Facebook groups, co-ops
  • ClassWallet vendor directory: Schools registered for ESA payments

Tutors & Teachers:

  • Wyzant, Care.com, Tutor.com: Online platforms (verify credentials)
  • Local homeschool co-ops: Member recommendations
  • University education departments: Student teachers, recent graduates
  • Retired teachers: Often available for private tutoring
  • ClassWallet vendor list: Pre-verified credentials

Therapists (Special Education):

  • Arizona Department of Health Services: License verification
  • Psychology Today: Provider directory with specialties
  • Autism Society of Greater Phoenix: Provider recommendations
  • FEAT (Families for Effective Autism Treatment): ABA provider lists
  • Insurance provider directories: Many accept ESA + insurance

Online Programs:

  • Time4Learning, IXL, Khan Academy, Outschool
  • Teaching Textbooks, Saxon Math
  • Discovery K12, Easy Peasy All-in-One Homeschool
  • Verify individual subscriptions available

B. Vetting Providers - Due Diligence Checklist

For All Providers:

  • [ ] Verify credentials/licenses current and valid
  • [ ] Check reviews from other ESA families
  • [ ] Confirm experience with student's age/needs
  • [ ] Verify ClassWallet registration status
  • [ ] Confirm invoice/payment procedures
  • [ ] Check BBB rating (for businesses)
  • [ ] Request references
  • [ ] Verify insurance coverage (for therapists/facilities)

For Private Schools:

  • [ ] Visit campus, observe classes
  • [ ] Review curriculum and teaching philosophy
  • [ ] Meet teachers and administrators
  • [ ] Ask about ESA experience and family count
  • [ ] Review fee schedule comprehensively
  • [ ] Understand admission/withdrawal policies
  • [ ] Check student-teacher ratios
  • [ ] Review disciplinary policies
  • [ ] Understand special education support (if applicable)

For Therapists:

  • [ ] Verify state licensure (not just certification)
  • [ ] Check for disciplinary actions via state board
  • [ ] Confirm experience with student's specific needs
  • [ ] Request treatment approach explanation
  • [ ] Discuss goals and progress measurement
  • [ ] Clarify cancellation policies and fees
  • [ ] Understand documentation provided
  • [ ] Verify ability to coordinate with other providers

Red Flags:

  • Refusal to provide credentials
  • Requests for full payment in advance
  • Lack of clear policies
  • Poor communication
  • Credential issues or expiring licenses
  • No professional liability insurance
  • Pressure tactics or urgency
  • Requests for access to ESA account

XIX. ANNUAL PROGRAM CYCLE

A. Fiscal Year Timeline

Q1: July - September (Planning & Setup)

Key Activities:

  • New applications processed (peak season)
  • Contracts signed (new and renewals)
  • ClassWallet accounts funded (July 15-31)
  • School year begins (early August typically)
  • Annual curriculum planning
  • Private school enrollment deadlines

Action Items:

  • Apply early in July if new to program
  • Sign renewal contracts immediately
  • Enroll in private schools before deadlines
  • Order curriculum and materials
  • Schedule therapy assessments
  • Plan annual budget and spending

Q2: October - December (Adjustment & Rhythm)

Key Activities:

  • Q2 funding (October 15-31)
  • Funding adjustments occur for Q2 contracts
  • Mid-fall assessments
  • Holiday break planning
  • Year-end spending decisions

Action Items:

  • Review Q1 spending and adjust budget
  • Submit Q1 debit card receipts by October 31
  • Address any funding adjustment surprises
  • Schedule winter therapy sessions
  • Purchase holiday educational gifts
  • Begin planning for Q3 expenses

Q3: January - March (Mid-Year Evaluation)

Key Activities:

  • Q3 funding (January 15-31)
  • Mid-year student assessments
  • Spring enrollment planning
  • Testing season preparation (AP, SAT, ACT)

Action Items:

  • Evaluate curriculum effectiveness
  • Submit Q2 debit card receipts by January 31
  • Schedule mid-year evaluations/IEP updates
  • Register for spring/summer programs
  • Order testing prep materials
  • Plan summer educational activities

Q4: April - June (Year-End & Transition)

Key Activities:

  • Q4 funding (April 15-30)
  • Renewal contracts sent (May typically)
  • Year-end assessments
  • Summer planning
  • Final spending before fiscal year ends

Action Items:

  • Ensure all core subjects addressed
  • Submit Q3 debit card receipts by April 30
  • Sign renewal contract for next year
  • Complete required testing
  • Finalize summer schedules
  • Submit Q4 receipts by July 31
  • Evaluate year's successes and needed changes

B. Multi-Year Planning Strategies

Year 1 (Establishment):

  • Focus: Learning program, establishing routines
  • Goals: Find quality providers, effective curriculum
  • Spending: May underspend as you learn system
  • Strategy: Conservative, build knowledge

Years 2-3 (Optimization):

  • Focus: Refine approach, maximize effectiveness
  • Goals: Optimize provider mix, improve outcomes
  • Spending: More strategic, better allocation
  • Strategy: Use data from Year 1 to improve

Years 4+ (Maturity):

  • Focus: Long-term planning, college prep
  • Goals: Build skills for independence, transitions
  • Spending: Strategic rollover planning
  • Strategy: Accumulate funds for major expenses

High School Planning (Grades 9-12):

  • Dual enrollment strategy (begin Grade 10)
  • AP/SAT/ACT preparation (Grade 11)
  • College application support (Grade 12)
  • Vocational exploration (ongoing)
  • Accumulated funds for intensive senior year prep

Special Education Extended Planning (Ages 18-22):

  • Transition assessment (age 14-16)
  • Vocational training (ages 18-20)
  • Life skills intensive (ages 20-22)
  • Supported employment preparation
  • Independent living skills development

XX. RESOURCES & CONTACT INFORMATION

A. Primary Program Contacts

Arizona Department of Education - ESA Program

  • Website: azed.gov/esa
  • Email: ESACallCenter@azed.gov
  • Phone: 602-364-1969
  • Hours: Monday-Friday, 8:00 AM - 5:00 PM (some evening hours - check website)
  • Mail: 1535 W. Jefferson Street, Bin #41, Phoenix, AZ 85007
  • ESA Support Ticket: Via ESA Parent Portal
  • Executive Director: John Ward

ClassWallet (Financial Platform)

  • Phone: 1-877-969-5536
  • Hours: Monday-Friday 8:00 AM - 8:00 PM EST; Saturday 10:00 AM - 4:00 PM EST
  • Email: help@classwallet.com
  • Help Center: classwallet.my.site.com/classwallet/s/
  • Website: classwallet.com

Arizona State Board of Education (Appeals)

  • Website: azsbe.az.gov/empowerment-scholarship-account-esa-program
  • Phone: 602-542-5057
  • Address: 1535 W. Jefferson Street, Phoenix, AZ 85007
  • Appeals: Submit via website or mail

Arizona Ombudsman-Citizens' Aide

  • Website: azoca.gov
  • Phone: 602-277-7292
  • Toll-free: 1-800-872-2879
  • Complaint Form: Available on website

B. Special Education Resources

ADE Exceptional Student Services

  • Phone: 602-542-4013
  • Website: azed.gov/specialeducation
  • Topics: IDEA, IEPs, evaluations, equitable services

Arizona Statewide Parent Information Network (AzSPN)

  • Phone: 602-265-4868
  • Website: azspn.com
  • Services: Free training and support for special ed families

Pilot Parents of Southern Arizona

  • Phone: 520-324-3150
  • Website: pilotparents.org
  • Services: Special education advocacy and support

Raising Special Kids

  • Phone: 602-242-4366 (Phoenix); 520-773-0179 (Flagstaff)
  • Website: raisingspecialkids.org
  • Services: Parent training, resources, support

C. Legal & Statutory Resources

Arizona Revised Statutes (ESA Statutes):

  • A.R.S. §15-2401 (Definitions)
  • A.R.S. §15-2401.01 (Qualified student definition; expansion)
  • A.R.S. §15-2402 (ESA accounts; funds)
  • A.R.S. §15-2403 (Administration; appeals; audits; rules)
  • A.R.S. §15-2404 (State control over nonpublic schools; prohibition)
  • A.R.S. §15-2405 (Parent oversight committee)
  • A.R.S. §15-2406 (Quarterly reports)

Available at: azleg.gov (Arizona State Legislature website)

Arizona Administrative Code (ESA Rules):

  • R7-2-1501 through R7-2-1511
  • Available at: azsos.gov (Arizona Secretary of State - Administrative Rules)

Handbook:

  • 2025-2026 ESA Parent Handbook: azed.gov/sites/default/files/2025/06/ESA%202025-2026%20Handbook.pdf

D. Community & Support Groups

Facebook Groups:

  • "Arizona ESA Families"
  • "Arizona ESA Homeschoolers"
  • "Arizona ESA Special Needs Support"
  • Search "Arizona ESA" for local and specific-interest groups

ESA Parent Advisory Committee:

  • Information: azed.gov/esa/esa-parent-advisory-committee
  • Purpose: Provide feedback to ADE on ESA policies
  • Meetings: At least 3 times per academic year
  • Application: Available on website

Homeschool Organizations:

  • Arizona Families for Home Education (AFHE): afhe.org
  • Catholic Homeschoolers of AZ: azcatholic homeschool.com
  • Local co-ops: Search by city/region

E. Helpful Tools & Forms

Available at azed.gov/esa/esa-support:

  • Application checklist
  • Parent-provided curriculum template
  • Tutoring/teaching services business attestation form
  • Affidavit of shared residence
  • FAQ documents (by topic)
  • MCC code list
  • Vendor registration information
  • Sample invoices and receipts
  • Video tutorials

XXI. FREQUENTLY ASKED QUESTIONS

Financial Questions

Q: What happens to unused funds at the end of the year? A: Unused funds automatically roll over to the next fiscal year. They remain in your account as long as your student is eligible for ESA.

Q: Can I use ESA funds from one child to pay for another child's expenses? A: No. Each ESA is for that specific student only. However, you can purchase allowable items that one student uses, and later those items can be used by ESA siblings.

Q: How do I check my current balance? A: Log into your ClassWallet account. Your dashboard shows your current available balance, pending transactions, and spending history.

Q: What if my private school costs more than my ESA award? A: You can supplement with personal funds. The school should invoice you for the total amount, and you pay what you can from ESA, with the remainder from personal funds.

Q: Can I pay myself to homeschool my child? A: No. Account holders and the ESA student cannot be paid with ESA funds under any circumstances.

Application & Eligibility Questions

Q: How long does the application process take? A: 30 days from submission of a complete application. If documents are missing, you'll receive notification and have 30 additional days to submit them, followed by another 30-day review.

Q: Can I apply mid-school year? A: Yes. You can apply any time during the fiscal year (July 1 - June 30). You'll receive prorated funding for remaining quarters.

Q: What if my child doesn't have a disability but has an IEP? A: If your child has an IEP from an Arizona public school, they qualify as a student with a disability under ESA, even if you don't believe the disability significantly impacts their learning.

Q: Can preschool students apply? A: Yes, if they have a disability and are ages 3-5 (or within 90 days of third birthday) with a current MET, IEP, or 504 plan.

Q: We're moving to Arizona. When can we apply? A: You must be Arizona residents at the time of application. Establish residency first, then apply with Arizona residency documentation.

Program Rules Questions

Q: Can my child attend public school part-time and use ESA? A: Yes, but only for individual classes as Tuition Payer Code 2. Your child cannot be enrolled as a regular public school student (Payer Code 1).

Q: Can we accept a scholarship from our private school? A: Yes, if it's a private scholarship from the school or a non-profit organization. You cannot accept School Tuition Organization (STO) or tax credit scholarships in the same fiscal year as ESA.

Q: Do I need to file a homeschool affidavit if I homeschool using ESA? A: No. You must NOT file a homeschool affidavit. Your ESA contract serves as proof your child is being educated.

Q: What testing is required? A: No state-mandated testing is required for ESA students. However, you must spend ESA funds on reading, grammar, mathematics, social studies, and science annually.

Q: Can we travel internationally for educational purposes? A: You can use ESA funds for educational programs, but NOT for travel expenses, lodging, or meals. The program itself must be allowable (e.g., language immersion program tuition).

Special Education Questions

Q: Will my child lose their IEP if we leave public school for ESA? A: Your child's IEP eligibility doesn't expire, but the public school no longer has an obligation to provide most services. The IEP document remains valid for determining ESA disability classification.

Q: Can we still get speech therapy from our public school? A: Possibly. Students attending non-profit private schools or homeschooling may be eligible for limited equitable services. Contact your district's special education office.

Q: How do I prove my child needs a weighted blanket or sensory items? A: Provide documentation from your child's IEP, MET, 504 plan, IEE, or a letter from a qualified examiner, service provider, or certified special education teacher indicating the need.

Q: Can I use ESA for my child's medical needs? A: Only if they're educational in nature. Medical services, devices, and supplies are generally not allowable, except educational therapies from licensed practitioners and items supporting educational needs.

Q: What if my child ages out of a disability category? A: At age 10, Developmental Delay classification expires. Have your child re-evaluated for another disability category if appropriate. Without re-evaluation, they continue in ESA but at general education funding rates.

ClassWallet & Payment Questions

Q: Why was my debit card declined? A: Common reasons: insufficient funds, restricted merchant category code (MCC), daily limit exceeded, card not activated, or incorrect PIN. Contact ClassWallet at 1-877-969-5536.

Q: How long does reimbursement take? A: Typically 5-10 business days after approval. Ensure your bank account is linked and verified in ClassWallet.

Q: What if I forget to upload receipts by the deadline? A: You have a 15-day grace period after ADE notifies you. After that, your debit card will be deactivated and you may need to repay those expenses.

Q: Can I have multiple debit cards for different family members? A: Each ESA student has one debit card. You cannot have multiple cards per student. If you have multiple ESA children, each has their own card.

Q: What if a vendor isn't registered with ClassWallet? A: You can pay with your debit card or out-of-pocket (reimbursement), or encourage the vendor to register at classwallet.com.


XXII. CONCLUSION & STRATEGIC SUMMARY

Key Success Factors

1. Documentation Discipline

  • Maintain organized record-keeping system
  • Upload receipts immediately after purchases
  • Meet all quarterly deadlines without exception
  • Keep copies of all important documents for 2+ years

2. Strategic Planning

  • Plan annual budget across all four quarters
  • Build rollover reserves for large future expenses
  • Diversify spending across educational approaches
  • Re-evaluate and adjust quarterly

3. Compliance Vigilance

  • Understand and follow all program rules
  • Never commingle ESA with prohibited activities (public school, STO scholarships)
  • Submit complete invoices and receipts
  • Respond promptly to ADE communications

4. Provider Relationships

  • Vet all providers thoroughly before engagement
  • Maintain professional boundaries
  • Protect personal and financial information
  • Document all services received

5. Continuous Improvement

  • Assess student progress regularly
  • Adjust curriculum and services based on results
  • Participate in ESA community for shared learning
  • Stay informed of program updates

Maximizing Value for Special Education Students

The ESA program offers unprecedented flexibility and funding for special education students in Arizona. To maximize benefits:

  1. Obtain comprehensive evaluations every 3 years to ensure proper classification
  2. Stack services strategically - combine therapies, tutoring, and curriculum for comprehensive support
  3. Build provider networks - develop relationships with quality licensed therapists and specialists
  4. Document thoroughly - maintain clear records of needs, recommendations, and progress
  5. Plan long-term - use fund rollovers to prepare for intensive high school and transition years
  6. Leverage all resources - combine ESA with insurance, equitable services, and community supports

The disability funding premium ($8,000-$43,000 vs. $6,000-$7,500 for general education) represents a significant state investment in your child's specialized educational needs. Strategic utilization of these funds can dramatically improve educational outcomes and life trajectory.

Final Recommendations

For Optimal ESA Experience:

Apply early (July) for maximum funding access Document everything immediately - don't let receipts pile up Use Pay Vendor for tuition and registered providers when possible Build relationships with quality private schools and service providers Join ESA communities for support and shared knowledge Stay informed - read ADE emails, check website regularly Plan quarterly - don't spend all funds early in year Protect your account - never share login credentials Respond promptly to ADE requests for information Think long-term - this is a marathon, not a sprint

The ESA program represents a powerful tool for educational customization and family empowerment. Used strategically and compliantly, it can transform your child's educational experience and outcomes.


APPENDICES

Appendix A: Quick Reference Tables

Disability Categories & Approximate Funding (2024-25)

Category

Code

Approx. Annual Funding

Autism Spectrum Disorder

ASD

$28,000

Multiple Disabilities - Severe Sensory

MD-SS

$25,000-$43,000

Emotional Disability

ED

$20,000-$25,000

Intellectual Disability

ID

$18,000-$22,000

Multiple Disabilities

MD

$18,000-$22,000

Traumatic Brain Injury

TBI

$18,000-$25,000

Visual/Hearing Impairment

VI/HI

$20,000-$30,000

Orthopedic Impairment

OI

$15,000-$20,000

Other Health Impairment

OHI

$12,000-$18,000

Specific Learning Disability

SLD

$10,000-$15,000

Speech/Language Impairment

SLI

$8,000-$12,000

Developmental Delay (ages 3-9)

DD

$8,000-$15,000

Preschool Severe Delay

PSD

$8,000-$15,000

Important Deadlines Tracker

Action

Deadline

Consequence of Missing

Q1 debit card receipts

October 31

15-day grace, then card deactivation

Q2 debit card receipts

January 31

15-day grace, then card deactivation

Q3 debit card receipts

April 30

15-day grace, then card deactivation

Q4 debit card receipts

July 31

15-day grace, then card deactivation

Appeal suspension

15 business days from notice

Account termination

Appeal termination

30 calendar days from notice

Permanent closure

Renewal contract signing

Date specified in contract

Non-renewal, account closes

Reimbursement submissions

End of month after contract year

Cannot be reimbursed

Appendix B: Sample Budget Templates

Templates and additional resources available at: azed.gov/esa/esa-support

Appendix C: Acronyms & Definitions

Common ESA Acronyms:

  • ABA - Applied Behavior Analysis
  • ADE - Arizona Department of Education
  • AZOCA - Arizona Ombudsman-Citizens' Aide
  • BCBA - Board Certified Behavior Analyst
  • CTED - Career Technical Education District
  • ESA - Empowerment Scholarship Account
  • FERPA - Family Educational Rights and Privacy Act
  • IEE - Independent Educational Evaluation
  • IEP - Individualized Education Program
  • MCC - Merchant Category Code
  • MET - Multidisciplinary Evaluation Team
  • OT - Occupational Therapy
  • PT - Physical Therapy
  • SBE - State Board of Education
  • SLD - Specific Learning Disability
  • SLP - Speech-Language Pathologist
  • STO - School Tuition Organization

Document Version: 2025-2026 School Year Last Updated: October 2025 Source Materials: ADE ESA Parent Handbook 2025-2026, Arizona Revised Statutes, Arizona Administrative Code

Disclaimer: This analysis is for informational purposes only and does not constitute legal advice. Families should refer to official ADE documentation and consult with appropriate professionals for specific situations. Program rules and policies are subject to change by legislation, administrative rule, or court decision.

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