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:
- Individualized
Education Program (IEP) - Full special education evaluation
- Multidisciplinary
Evaluation Team (MET) Report - Comprehensive evaluation
- 504
Plan - Accommodations for disabilities affecting education
- 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:
- Student
Birth Certificate
- Full
color image showing all four corners
- Must
match applicant's legal name
- Name
change documentation if applicable
- 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)
- Driver's
License or Government-Issued ID
For Special Education Students - ADDITIONAL:
- 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:
- Account
suspension notification
- 15-day
grace period to submit receipts
- Debit
card deactivation if not submitted
- Possible
account termination
- Repayment
of undocumented purchases
- 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:
- 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
- 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
- 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:
- Obtain
new/updated evaluation (using any of 4 options above)
- Submit
ESA Support Ticket via ESA Parent Portal
- Upload
complete evaluation document
- Request
account update to reflect new disability category
- ESA
staff reviews (processing time varies)
- If
approved, new contract issued in portal
- 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:
- Visit
azed.gov/esa/esa-support (Vendor section)
- Click
vendor registration link
- Complete
ClassWallet vendor application
- Provide:
Business information, tax ID, banking details, contact information
- ADE
reviews registration
- Approval
typically within 2-4 weeks
- 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:
- Student
Information
- Student
name
- Student
ESA Application ID number
- Grade
level or age
- Course
of Study
- Subject
area (e.g., Art, Physical Education, Music, Science)
- Overall
goals and learning objectives
- Method
of Teaching
- Instructional
approach
- Lesson
plans (can be brief)
- Activities
and exercises
- Timeline
or schedule
- 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:
- Send
written notice to ESACallCenter@azed.gov
- Include:
Advocate name, relationship, phone, email
- Specify
scope of assistance
- 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:
- Gather
all required documents before starting application
- For
special ed: Obtain current IEP/MET/504 or schedule evaluation
- Review
residency documentation requirements carefully
- Complete
application in single session if possible
- Upload
clear, complete images (all four corners visible)
- 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:
- Sign
contract immediately upon receipt
- Set
up ClassWallet account (desktop/laptop required)
- Link
bank account for reimbursements
- Order
ClassWallet debit card
- Review
allowable expenses thoroughly
- Begin
researching schools/service providers
Phase 3: Initial Spending (Months 3-6)
Priority Actions:
- Secure
private school placement (if using)
- Schedule
evaluations/assessments (if needed)
- Identify
and vet tutors/therapists
- Purchase
core curriculum
- Set
up online learning programs
- 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:
- Apply
immediately - Don't wait for semester end
- Obtain
required documents while still enrolled (IEP/MET if special ed)
- Submit
complete application - 30-day processing begins
- Upon
approval: Sign contract immediately
- Withdraw
from public school only after ClassWallet is funded (3-5 weeks after
signing)
- 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:
- Contact
public school - Ask if they accept ESA students for individual classes
- Specify
Tuition Payer Code 2 - Critical enrollment status
- Obtain
itemized invoice from school showing:
- Student
name
- Class
description
- Tuition
amount for that class only
- School
contact information
- Pay
via ClassWallet using invoice
- 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:
- Check
Arizona licensure - Many providers maintain multiple state licenses
- Verify
compact agreements - Some professions have interstate compacts
- 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
- 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:
- ESA
funds: $28,000 toward tuition
- Family
contribution: $7,000 out-of-pocket
- Private
scholarships: Non-STO scholarships (allowed)
- School
financial aid: If school offers (not STO-based)
- 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:
- Insufficient
funds in ClassWallet account
- MCC
restriction - Vendor's merchant category code is blocked
- Transaction
limit - Daily/weekly limits exceeded
- Card
not activated or expired
- Incorrect
PIN entered
Immediate Solutions:
- Check
balance - Log into ClassWallet, verify funds available
- Verify
MCC - Contact ClassWallet to check if vendor's MCC is blocked
- Alternative
payment: Pay out-of-pocket, submit for reimbursement
- 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:
- Obtain
new evaluation from public school or qualified examiner
- Submit
ESA Support Ticket with complete evaluation attached
- Request
classification update
- ADE
reviews (1-3 weeks typical processing)
- New
contract issued reflecting updated classification and funding
- Sign
new contract immediately
- 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:
- Exited
Contract - Can use funds for postsecondary education for up to 4 years
- Allowable
uses:
- Community
college tuition and fees
- University
tuition (AZ Board of Regents schools)
- Accredited
private postsecondary tuition
- Required
textbooks
- Course-related
fees
- Quarterly
documentation still required if using debit card
- Cannot
use for: Room, board, meals, non-academic expenses
Process:
- Notify
ESA program of graduation
- Receive
Exited contract
- Sign
Exited contract
- Continue
using funds per program rules
- 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):
- Contact
ClassWallet: 1-877-969-5536 - Report fraud, freeze card
- Document
transactions: Screenshot all unauthorized charges
- Contact
ADE: ESACallCenter@azed.gov - Report suspected fraud
- File
police report - Obtain case number
- Dispute
charges with ClassWallet fraud department
Follow-Up Actions (Days 2-7):
- Submit
ESA Support Ticket with:
- Description
of fraud
- Screenshots
of unauthorized transactions
- Police
report copy
- Timeline
of discovery
- Request
new card through ClassWallet
- Review
all transactions from past 90 days
- 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:
- Obtain
comprehensive evaluations every 3 years to ensure proper
classification
- Stack
services strategically - combine therapies, tutoring, and curriculum
for comprehensive support
- Build
provider networks - develop relationships with quality licensed
therapists and specialists
- Document
thoroughly - maintain clear records of needs, recommendations, and
progress
- Plan
long-term - use fund rollovers to prepare for intensive high school
and transition years
- 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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