Texas TEFA School Accountability and Testing Requirements 2026-27

By The School Choice Index editorial team Published: August 5, 2026 · Last verified: August 5, 2026 Official school-directory snapshot: report run August 2, 2026 · Approved-test list: updated April 28, 2026, rechecked August 5, 2026

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The Texas TEFA school accountability and testing requirements for 2026-27 come down to one rule with two conditions. If your child is in grades 3 through 12 and enrolled at an approved private school, they must take one approved test each year. It does not have to be the STAAR. If your child is in Pre-K through 2nd grade, or you're homeschooling on the $2,000 award, there's no TEFA annual-testing requirement. You get the score. You make sure Odyssey gets it. June 30, 2027 is the current outer legal deadline. The state does not publish your child's individual result, and Texas does not give TEFA private schools an A–F rating.^{[sb2][rules][odyssey-testing]}

That's the whole answer. Now here's the part almost nobody knows.

There's a number buried in the state's own list of participating schools that tells you more about how TEFA testing actually works than any FAQ will. We pulled the file and counted. Out of 1,163 school listings that serve 3rd grade or higher, exactly 23 disclose the STAAR. Twenty-three.^[directory]

We'll show you the full count in a minute. First, let's find out if any of this even applies to your kid.

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Does this apply to your child? Start here

Quick definitions, so nothing below is confusing:

• TEFA = Texas Education Freedom Accounts. The state's education savings account program, created by Senate Bill 2 in 2025. An education savings account (ESA) is a pot of state money a parent can spend on approved school costs.
• Odyssey = the private company the Comptroller hired to run the program day to day. Its official title is the certified educational assistance organization (CEAO). When you send test results somewhere, you're sending them to Odyssey.
• Norm-referenced test = a test that compares your child with a reference group. It often gives a percentile; Texas law requires the administrator to give you the percentile rank if one is available.
• Criterion-referenced test = a test that checks whether your child learned a specific set of standards. The STAAR is one of these.
• A–F rating = the letter grade Texas uses for public school districts, campuses, and open-enrollment charter schools. TEFA private schools don't get one through this program.^[ratings]

The money, so it's on the table early: $10,474 for the 2026-27 school year if your child attends an approved private school. Up to $30,000 if your child has a qualifying IEP on file with the Texas Education Agency by the end of the application period; the amount is based on what the local district would have received to serve that IEP. $2,000 for homeschool and other settings.^[tefa-home]

Check whether your child has to test this year → Use the table above, then search the official TEFA finder and confirm the grade-level test with the school.

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The thing we have to tell you first

Here's the honest limitation, and we'd rather you hear it from us than find out in March.

Texas does not give TEFA private schools an A–F rating, and current law does not require the state to publish assessment results school by school. There's no state academic report card for the private school you picked. The law requires statewide longitudinal reporting, but we found no requirement to publish results for each named participating private school.^[sb2]

If a state-issued letter grade is the thing that makes you feel safe, then TEFA may be the wrong tool and we'd rather you know now. Public schools and open-enrollment charter schools — which are public schools, tuition-free, and part of Texas's A–F system — give you that standardized public comparison. A child counted in a public school's attendance cannot remain in TEFA at the same time. That's not a loophole. It's the design.^{[rules][ratings]}

But here's why that trade exists, and why a lot of families take it on purpose.

Texas pairs the absence of a TEFA A–F rating with broad private-school autonomy. That is why a classical academy, a Montessori school, a dyslexia school, a Catholic school, and a bilingual microschool can participate without becoming versions of the same public-school model. Texas law says it out loud: state agencies and the program administrator cannot use TEFA to dictate a participating school's curriculum, admissions standards, religious practices, or institutional values (Tex. Educ. Code §29.368; 34 TAC §16.408).^[rules]

And the state didn't keep the one number that matters most to you. It gave it to you. Section 29.357(b) says the test administrator has to hand your child's result to you, with a percentile rank when the assessment produces one. Public-school parents receive individual results too; the difference here is that the private-school result is not converted into a TEFA school-level A–F rating.^[sb2]

That's the deal. Fewer standardized state comparisons, more control — and your child's result still lands in your hands.

If you'd rather have the letter grade: compare official Texas public-school and charter-school ratings.

Everybody still here? Good. Let's get you the details.

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What are the Texas TEFA school accountability and testing requirements for 2026-27?

Answer capsule: For 2026-27, Texas requires participating students in grades 3–12 at approved private schools to take one approved annual assessment, requires the parent to get that result to the program administrator, and requires participating schools to hold recognized accreditation and at least two years of operating history. The program is also subject to annual audits and state-auditor review. It does not place participating private schools in the Texas public-school A–F accountability system.

Most articles on this topic answer one question — "is there a test?" — and stop. That's why parents stay confused. Four different things get jammed into the word "accountability," and they're not the same thing at all.

Here's the split we use, and it makes everything else make sense:

Almost every argument you've read about TEFA is actually an argument about layers 3 and 4, dressed up as an argument about layer 1. Somebody says "TEFA schools have to test!" and somebody else says "TEFA has no accountability!" and both are describing a different layer. They can both be right.

One more piece of timing nobody mentions. The 2026-27 school year is a strange one. Public-school students are still under the STAAR system. House Bill 8, passed in September 2025, introduces major public-school assessment changes beginning in 2027-28, including replacement of STAAR with a system that may be called the Student Success Tool. TEFA schools, meanwhile, can choose from the program's current list of 26 approved assessments.^{[hb8][odyssey-tests]}

Interesting detail: during rulemaking, the Texas Association of School Boards asked the Comptroller to make TEFA schools use the same TEA-approved tests once HB 8 kicks in for 2027-28. The Comptroller said no, because the law lets each school pick. We'll come back to that.

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Who actually has to take a TEFA test?

Answer capsule: The TEFA annual testing requirement applies only to participating children in grades 3 through 12 who are enrolled at an approved participating private school. It does not apply to homeschool participants or to approved-private-school students below 3rd grade. Students with disabilities in grades 3–12 are generally still covered, with alternate assessments available.

We ran the numbers on this, because "grades 3–12" sounds like it covers almost everybody. It doesn't.

From the state's own Annual Demographic Report, released August 1, 2026 (a snapshot as of July 29):

Grade by grade, funded students: 3rd — 7,230 · 4th — 7,203 · 5th — 6,931 · 6th — 7,070 · 7th — 6,073 · 8th — 5,369 · 9th — 4,805 · 10th — 4,179 · 11th — 3,501 · 12th — 2,740.

A note on how we know we read it right. The report has four separate tables — grade, age, sex, and race. We added each one up on its own. All four land on exactly 85,344. Four for four. That's the check we run before we publish a number.

Now the part that matters: 55,101 is a ceiling, not a count. Homeschool participants in grades 3–12 are exempt, and the state's report doesn't split private-school kids from homeschool kids. So the real number of children facing a test this year is somewhere below 55,101. We're not going to pretend to a precision the data doesn't support.

And it lines up with something we found on the school side. In the official participating-schools file, 1,622 of 2,785 listing rows — 58.2% — serve only through 2nd grade. More than half the listings in that file never reach a tested grade.^[directory]

So when you read "TEFA students have to take a test," hold it loosely. More than a third of funded children are below 3rd grade, 58.2% of official school-listing rows stop below the tested grades, and homeschool participants are out entirely.

The categories that trip people up:

Pre-K and K–2. No TEFA testing requirement. But your school might test anyway — lots of them do their own reading and math screeners. That's a school policy, not a state rule. Different thing.

Homeschool and "other." No TEFA testing requirement, full stop. Odyssey's own guidance says it plainly: "Homeschool students are not required to take an assessment." Taking the $2,000 does not sign you up for a test.

Kids at a private school that didn't join TEFA. Careful here. Don't assume you automatically count as "homeschool/other." How Odyssey classifies your child's setting is what decides your award and your obligations. Ask before you guess.

Kids with an IEP or disability. Start from "yes, testing applies," then work from there. Odyssey lists six approved special-needs assessment options and says some students may be excused in special cases — but it has not published the exception criteria. Never skip a test on somebody's verbal say-so.^{[odyssey-tests][odyssey-testing]}

Look up your school and confirm your child's requirement → Search the official TEFA finder, then ask the school which assessment applies to your child's grade.

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Do Texas TEFA students have to take STAAR in 2026-27?

Answer capsule: No. The STAAR is one of several approved options, not a requirement. Senate Bill 2 lets a participating private school administer either a nationally norm-referenced assessment or an applicable state assessment, and the Comptroller declined a request during rulemaking to require participating private schools to give the same tests as public schools.

This is the single biggest misunderstanding about TEFA, and it costs families sleep for no reason.

The law gives schools two doors. Door one: a nationally norm-referenced test — the kind that tells you how your child compares to kids nationwide. Door two: the appropriate state assessment under Chapter 39, which is the STAAR. Each school picks. Not the state. Not you.

We didn't want to leave that as a legal reading, so we went and counted what the official directory listings disclose.

We pulled the official TEFA participating-schools workbook — the file the state publishes, footer stamped "Report Run as of 8/2/26" — and looked at the field where each listing discloses its general assessment or assessments.^[directory]

Of the 1,163 listings that serve at least 3rd grade:

Listings can disclose more than one assessment, so the counts add to more than 1,163 and the percentages do not total 100%.

Twenty-three. That's how many grade-3+ listing rows include STAAR. NWEA MAP appears roughly nineteen times as often.

What this proves and what it doesn't. It proves the official directory does not show STAAR as the default disclosure. It does not prove that only 23 legally distinct schools administer STAAR, that 2% of students take it, or that every disclosed assessment was actually used with a TEFA student. This is directory disclosure data. It is not a student headcount, a grade-by-grade schedule, or a compliance audit. We're not going to stretch it past what it can hold.

Three of those 1,163 listings had the testing field blank. That could be a school that hasn't filled it in, or a lag in the state's file. It's not proof anybody broke a rule, and we're not naming them.

If your school tells you STAAR is required, here's what to say. Ask one question: "Is that a TEFA rule or a school policy?" Then ask for it in writing, ask which grades it covers, and ask whether an approved alternative is available. A school is completely free to choose the STAAR — some do, and some have good reasons. Just know it's their call, not the state's mandate.

See what the state currently lists for your school → Search the official TEFA finder, then confirm the grade-level assessment with the school.

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Which tests are approved for Texas TEFA in 2026-27?

Answer capsule: Odyssey currently lists 20 general assessments and six additional assessments for students with special needs as approved options for the TEFA program, and states that more may be added with Comptroller approval. Appearing on the approved list does not mean a test is appropriate for every grade, subject, or student, so families should confirm which specific assessment their school will give.^{[odyssey-tests]}

Here's a thing that still surprises us. The official TEFA homepage does not display the full list.

Go to the official TEFA schools section right now. It says participating schools must give a nationally norm-referenced assessment in grades 3–12, then says: "More information will be forthcoming soon." We rechecked that page on August 5, 2026.^[tefa-home]

The list does exist. It's in Odyssey's help center, last updated April 28, 2026. It just isn't on the state page where many parents would expect to find it. So we're putting it here, in one place — because "approved" and "the right test for my kid" are not the same thing.^{[odyssey-tests]}

The 20 general approved assessments

The second and third columns are our analysis of the August 2 directory snapshot, not usage figures published by Odyssey. A listing may disclose multiple assessments and may not explain which one applies to each grade.^[directory]

The six approved assessments for students with special needs

1. Kaufman Test of Educational Achievement (KTEA)
2. BRIGANCE
3. Woodcock-Johnson
4. Peabody Individual Achievement Test
5. Wechsler Individual Achievement Test–II (WIAT-II)
6. STAAR Alternate 2^{[odyssey-tests]}

The observation nobody's made about this list. Read it again. The program list spans state assessments, college-readiness or admissions tests, adaptive diagnostics, achievement batteries, and individually administered assessments.

Those measure genuinely different things. Two schools can both follow the rule perfectly and produce numbers you cannot line up next to each other without a defensible crosswalk. That's not a scandal — it's the direct result of the law letting each school choose. But it is why the testing rule does not automatically produce a clean school-to-school comparison, and you deserve to know that going in.

Two more things worth knowing:

Schools can give more than one. During rulemaking, Classic Learning Initiatives asked whether "an assessment" meant only one. The Comptroller confirmed it doesn't — one or several both work.^[rules]

TEFA money can pay for the test. Assessment costs are on the approved expense list in the program rules. That doesn't mean you'll be billed, and it doesn't mean any test purchase is automatically approved. It means the cost is eligible and must run through the program's approved payment process.^[rules]

See Odyssey's current approved test list → Open the official Odyssey list. We update this page monthly, but the official list is the source of truth and it can change.

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Who sends the test results to Odyssey, and when are they due?

Answer capsule: Under Texas law and the program rules, the participating parent is responsible for making sure the assessment result reaches Odyssey — either by submitting it directly or by authorizing and instructing the test administrator to submit it. Odyssey now publishes a school-portal upload process, and the rules require results by the end of the program year, making June 30, 2027 the current outer legal deadline for 2026-27.^{[sb2][rules][upload]}

This is the step families miss, and it's the one that's genuinely on you.

The school can be the pipe. You still own the handoff.

There's a small piece of drafting history behind that. The Comptroller's proposed rule originally let a parent instruct the school to release results straight to Odyssey. The Texas Catholic Conference of Bishops and the Texas Private Schools Association pushed back — they said it put a duty on schools that the statute didn't. The Comptroller agreed and rewrote the rule.

So the chain runs like this:

1. The school (or test administrator) gives the test.
2. They give you the result, including a percentile rank when the test produces one. That's your legal right under §29.357(b).
3. You send it to Odyssey — or you affirmatively authorize and instruct the administrator to send it.
4. You verify that Odyssey shows the assessment as Completed and save proof.^[upload]

And you do step 3 under a certification. The rules require participating parents to make the agreement and certification under penalty of perjury. That's not a scare tactic — it means the information and documentation you submit must be real and accurate.^[rules]

Odyssey's current school instructions say either the school or the parent may submit a test. In the school portal, the school selects Upload Test, chooses the assessment, enters the required information, uploads the documentation, confirms the submission, and looks for the status to change from Required to Completed. A school can view a parent-submitted assessment but cannot edit or remove it; only the submitting party can do that.^[upload]

The deadline, translated

The rule says results are due by the end of the program year. The rule defines the program year as July 1 through June 30. So for 2026-27:

June 30, 2027 is the current outer legal deadline.^[rules]

Two honest caveats:

One. Odyssey may publish an earlier operational deadline. We found no earlier statewide date in the official materials reviewed on August 5, 2026. If it adds one, follow that date, not this outer limit.

Two. We are not going to manufacture urgency here. There's no countdown. Odyssey has published the school-side upload screen and completion check, but we did not find a similarly detailed public parent-portal walkthrough or an accepted-file-format list. Submit soon after you receive the result and give yourself room in case the first try doesn't go smoothly.^[upload]

The Texas Association of School Boards specifically asked the Comptroller to spell out where tests may be given, when results are due, whether virtual schools can test at home and with what safeguards, and what happens if nobody complies. The Comptroller declined to put those details into the rule — pointing to Odyssey's contract, the suspension rules, and the parent certification. Odyssey later filled part of the operational gap by publishing the school upload steps.^{[rules][upload]}

Your submission checklist

Save this. Seriously.

• [ ] Test is on the approved list
• [ ] Right child, right grade, right school year
• [ ] Test date written down
• [ ] Full score report received — not just a summary email
• [ ] Percentile rank included, if the test gives one
• [ ] You know who is submitting: you, or the administrator you authorized
• [ ] Odyssey status shows Completed
• [ ] Confirmation from Odyssey saved
• [ ] Copy filed with your other TEFA paperwork

One more thing, because this is easy to lose track of. If your school says "don't worry, we'll send it" — great, and still get it in writing, and still verify the Completed status. The program agreement makes it your responsibility. A friendly promise from the front office isn't a receipt.

Save the 2026-27 result-submission checklist → One page, printable, no email required.

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Will my child's test scores be public?

Answer capsule: No. Under Senate Bill 2, a participating child's assessment results and percentile rank are confidential and not subject to disclosure under the Texas Public Information Act, and student records held by the Comptroller or the program administrator carry the same protection. The state may use assessment data in aggregate program reporting.

Two separate provisions lock this down.

Section 29.357(b) says a child's results and rank are confidential, aren't subject to the Public Information Act, and can only be shared as far as running the program requires. It also points to FERPA, the federal student privacy law.

Section 29.369(d) says student records held by the Comptroller or Odyssey are confidential too — and can be redacted from any public records response without even asking the Attorney General for permission first.

Put together: your child's individual result is private. The same law still requires statewide longitudinal reporting that includes assessment data, and we found no current requirement to publish a named-school assessment table. That is narrower — and more accurate — than saying no school-level information could ever be published.

The comparison that makes this concrete

We noticed something reading the state's Annual Demographic Report, and once you see it you can't unsee it.

That report groups funded students by the public school district of residence reported by the parent — 895 districts have at least one funded student, and the 335 with 30 or more are named. It also groups them by a parent-reported public-school campus — 6,883 campuses have at least one, and the 434 with 30 or more are named.^[annual]

It names zero private schools.

That does not prove every child left the named district or campus; the report describes parent-reported residence and campus fields, not a verified transfer history. What it does show is the reporting choice: the first demographic report gives geographic detail through public-system entities and no private-school outcome table.

We're not calling that a scandal. It is what the first-year reporting structure produced. But if you've been wondering why you cannot find a state scorecard for the private school you picked, that's your answer, and it is structural under the current law.

The same held in the official school-finder record structure we reviewed on August 5, 2026: participation information appeared, but academic-performance data did not. That can change, so it belongs on the update list rather than being treated as permanent.^[finder]

So what should you ask a school about privacy?

• How will you send me the result?
• Which staff can see my child's scores?
• Does the testing vendor keep the data, and for how long?
• Will you use the score for placement or re-enrollment decisions?
• How do I correct an error in my child's record?

That last one matters more than people think. Fix a wrong grade level or a misspelled name early, while it's easy.

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What testing accommodations will my child get if they have an IEP?

Answer capsule: TEFA itself does not guarantee the public-school accommodation package written into an IEP. A participating private school decides which TEFA testing supports it offers, while separate federal disability laws may still apply depending on the school, its religious status, and whether it receives federal financial assistance. Six special-needs assessments are approved, and Odyssey says schools can provide testing supports based on a child's IEP.^{[rules][odyssey-testing][idea][ada][section504]}

Read that answer capsule twice if your child has an IEP. It's the most important paragraph on this page for you.

Odyssey says schools can provide supports based on the IEP. Can. Not must. That word is doing a lot of work, and here's the law behind it.

During rulemaking, the Texas Catholic Conference of Bishops and the Texas Private Schools Association asked the Comptroller to clarify that the accommodations language in the proposed TEFA rule would not force private schools to provide every public-school accommodation. The Comptroller agreed that Senate Bill 2 does not create that program-specific requirement, and the disputed wording came out of the rule.^[rules]

Other groups pushed the other direction. CareerPath and several parents asked for exemptions or alternative measures for profoundly disabled students. One parent wrote something that stuck with us — that for her child, quality of life, independence, and communication improvements matter as much as academic gains, and a standardized test can't capture that. The Comptroller declined to change the rule, noting the state assessment chapter allows IEP-based alternatives.

So both sides of this asked for something and got a documented answer. Nobody's hiding the ball. But the TEFA result is: the school decides which program testing supports it offers.

That does not erase every other disability law. Parentally placed private-school students generally do not have an individual entitlement to the same IDEA free appropriate public education they would receive in a district, although federal equitable-services rules can provide services to some private-school students. ADA Title III generally applies to nonreligious private schools as public accommodations, while religious organizations are exempt. Section 504 applies to schools or programs that receive federal financial assistance. Those federal questions are separate from what TEFA itself requires.^{[idea][ada][section504]}

The supply problem nobody has published

Six special-needs tests are approved. Five of them — Woodcock-Johnson, KTEA, WIAT-II, BRIGANCE, and Peabody — are individually administered batteries that take a trained person and one-on-one time.

We went back through the state's participating-schools workbook, which has separate disclosure fields for those five batteries.

2,675 of 2,785 listing rows — 96.0% — disclose none of them.^[directory]

Only 110 listing rows disclose one or more. Of those: 80 disclose one, 18 disclose two, 9 disclose three, 2 disclose four, and 1 discloses all five. STAAR Alternate 2 appears in a separate field and is disclosed by 14 listings; counting all six approved special-needs options, 123 listings disclose at least one.^[directory]

That is not the same as saying only 110 schools can serve your child. A blank field may reflect incomplete directory data, a school may arrange testing through an outside professional, and a disclosure does not prove capacity, availability, admission, or fit. But if your child's IEP calls for one of those individually administered assessments, those listings are the place to start investigating.

Before you take anyone's word on an exemption

Odyssey has said some students may be excused in special cases. It has not published what those cases are. We looked.

Don't skip a test because someone told you your child is exempt. Ask Odyssey to confirm it in writing, and file that confirmation with your TEFA records. A verbal "you're fine" is not documentation.

One more separation to keep straight, because it's the most common and most painful mistake we see: qualifying for higher TEFA funding is not the same as keeping the same IDEA entitlement. Texas law requires a notice explaining that a participating private school is not subject to federal and state special-education service requirements in the same manner as a district or charter. Section 29.367 makes the program post the notice, provide it to applicants, and requires the private school to give it to the parent too.^[sb2]

If you haven't read that notice, go read it.

Before your next school meeting → Start with our Texas ESA autism-school guide, our Texas ESA dyslexia-school guide, or the 60-second school-path quiz. Then verify services in writing.

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So how are Texas TEFA private schools actually held accountable?

Answer capsule: TEFA accountability runs through five channels: entry requirements including accreditation, annual student testing and result submission, two formal audit mechanisms plus Comptroller oversight, compliance enforcement that can include suspension or permanent removal, and statewide reporting. These are meaningfully different from the public-school accountability system, which uses common state assessments and A–F ratings.^[sb2][rules]

Short version: the money and program rules are watched closely. The academic results are not converted into a comparable school-by-school state rating.

Most coverage of this topic blurs those two together, from both directions. People who like the program point to the audits. People who don't say "there's no oversight!" Both are describing different layers and talking past each other.

Here's the whole structure in one table. This is the piece we'd want if we were you.

The five layers, plainly

1. Getting in. Recognized accreditation, a campus operating at least two school years, a Texas location, and a commitment to test. The official TEFA page says private schools may apply on a rolling basis.^{[sb2][rules][tefa-home]}

Accreditation isn't nothing, by the way. It is an outside credential and an entry condition. It is just not a TEFA academic-outcome measure, and this page does not pretend every accreditor uses an identical review.

2. Testing. The annual assessment, results to the parent, parent to Odyssey.

3. Money. Two formal audit mechanisms plus Comptroller oversight. A contracted private audit firm must conduct an annual audit covering accounts, participant eligibility data, the program administrator, and providers. Separately, the State Auditor reviews Odyssey's compliance and must randomly audit 10% of program applications for eligibility. The Comptroller oversees the program and can request records.^[sb2]

There's a wrinkle here worth flagging: under §29.363(g), a participating school proves its financial soundness by showing a third-party audit or financial review consistent with its accreditation commission's standards. So the financial bar for the school is set by its accreditor, not by the state.

4. Staying in. Schools must stay in good standing. Lose eligibility or a program requirement and participation can be suspended — payments from student accounts stop. Suspension comes with notice and a 30-calendar-day response period. Permanent removal is possible at the Comptroller's discretion if the provider fails to respond or fully correct the problem; it is not automatic for every violation.^[rules]

One request the Comptroller turned down: TASB asked for a rule blocking a removed operator from coming back under a new business name. The Comptroller said the existing rules were enough and declined to add it.

5. Reporting. The annual demographic report (that's the one released August 1, 2026). Plus a longer-term longitudinal report we'll get to below.

Why "there's a test" isn't the same as accountability

A required test, by itself, doesn't create:

• A shared standard everyone is measured against
• Scores you can compare across schools using different tests
• Public school-level results
• A minimum passing score
• Any consequence for a school whose students score low

That's the honest description. Not an attack — a description.

Run the school accountability check → Use the seven questions below before you commit for the year, and see how school-choice accountability differs by state.

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What TEFA accountability does not include

Answer capsule: The TEFA statute and rules do not place participating private schools in the Texas public-school A–F rating system, do not require all participating schools to give the same assessment, and do not require the state to publish assessment results for each named participating school. No universal minimum passing score was identified in the law, rules, or current program guidance.

Four gaps. We'll name each one and tell you what it actually means for your family.

No A–F letter grade. A–F is a public-school system. Being "approved" for TEFA means a school cleared the entry gate — accreditation, two years operating, a testing commitment. It is not a performance rating, and any school that presents it as one is telling you something untrue.

No common test. Different schools, different tests. Which means comparing a raw score from a school using NWEA MAP against one using Iowa Assessments is not a comparison. Different scales, different norm groups, different purposes.

No required results by school name. Careful wording here, because the difference matters: the law requires statewide longitudinal reporting, and we found no requirement that anyone publish assessment results for each named private school. That is not the same as Texas banning every possible future school-level disclosure. Current law simply does not promise parents a named-school outcome table.

No passing score. We found no minimum score anywhere in Senate Bill 2, the final rules, or the current program guidance. Taking the test and sending the result is the requirement. Scoring at some level is not.

But don't over-read that either. A school can absolutely use scores for its own placement, tutoring, or re-enrollment decisions. That's the school's business, not the state's rule. If that could affect your child, ask about it before you enroll.

Who should walk away from TEFA over this?

We'll say it straight. If comparable, state-published school-performance data is the thing you need to sleep at night, TEFA cannot give you that under the current framework. Go look at public and open-enrollment charter options, where standardized public accountability data exists.

Everyone else — families who chose a private school for its approach, its size, its faith, its specialized program — you're trading the state's report card for the school's autonomy, plus your own score in hand. That's a defensible trade. It just means the homework shifts to you, which is what the rest of this page is for.

Not sure which path fits your family? Get a personalized Texas school path plan →

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What we found in the state's own list of TEFA schools

Answer capsule: The School Choice Index analyzed the official Texas TEFA participating-school workbook, report run August 2, 2026. The file contained 2,785 listing rows, of which 1,163 serve at least 3rd grade and 1,622 serve only through 2nd grade. NWEA MAP was the most commonly disclosed general assessment at 444 grade-3+ listings, followed by Iowa Assessments at 313, while STAAR appeared in 23.^[directory]

We did this because we couldn't find anyone who had, and because "which test will my kid take" is a question a parent can actually act on.

The headline numbers

• 2,785 total listing rows
• 1,163 serving 3rd grade or higher — the only listing rows the grade rule can reach
• 1,622 serving only Pre-K through 2nd grade — 58.2%
• 444 listing NWEA MAP
• 313 listing Iowa Assessments
• 23 listing the STAAR
• 3 grade-3+ listings with a blank testing field

The full test-by-test table is in the STAAR section above.

How we did it, so you can check us

• Source: the official TEFA participating-schools workbook published by the state. Footer reads "Report Run as of 8/2/26."
• Unit: one listing row. A row is not necessarily one legally distinct school or operator.
• Grade-3+ definition: we used the highest grade each listing reports serving. If that's 3 or above, it's in the 1,163.
• Test names: we normalized the school-reported testing field into standard labels.
• Multiple answers: a listing naming several tests counts in each one. That's why percentages exceed 100%.
• Blanks: counted, not guessed at.

What these numbers do and don't mean

They do support: STAAR is not the dominant directory disclosure. NWEA MAP and Iowa appear much more often. And the testing rule reaches a much smaller share of the directory than the phrase "grades 3–12" suggests, because most of these listings stop at 2nd grade.

They do not support: how many students take each test, which test a school uses in which grade, whether a disclosed assessment was actually administered to a TEFA participant, whether a school has current capacity, or whether any school is complying. A directory field is a disclosure. It's not an audit.

Pair this with the student-side number from earlier and you get the clearest picture available anywhere: 35.4% of funded students are below 3rd grade, and 58.2% of participating school listings don't teach a tested grade. The testing requirement is real, and it's narrower than almost everyone writing about TEFA has said.

Look up your school's current public record → Search the official TEFA finder, then confirm with the school directly.

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How do I check out a TEFA school before I commit?

Answer capsule: A school's presence in the official TEFA directory confirms current program participation, not academic quality or performance. Because Texas does not publish school-level outcome data for participating private schools, families should get grade-specific testing, results, and disability-support information from the school in writing before enrolling.

Since the state won't hand you a report card, here's the one you build yourself. Seven questions. Fifteen minutes on the phone.

1. Which approved test will my child take in 2026-27? If they cannot name it after the school's testing plan is final, that's information.

2. Is that test used for my child's exact grade? A school listing the SAT isn't testing your 4th grader with it.

3. Who gives it, where, and who pays? On campus or off? Their staff or a proctor? Is the cost in tuition or extra?

4. What accommodations or alternate assessments do you offer? Ask even if your child doesn't have an IEP. The answer tells you a lot about the school.

5. When will I get the full result, and does it include a percentile? You have a legal right to the result and any available percentile. Ask when, not whether.

6. Will you submit it to Odyssey, and how will I get proof? Remember: it's your responsibility either way.

7. How do you use these results to improve teaching — and what evidence can you share? This is the outcome question. In TEFA's first year, some schools may not have a prior TEFA cohort to show you. Ask what baseline they use now, what progress they will track, and what year-over-year information they plan to share.

Copy and paste this email

Subject: TEFA assessment process for [grade] Hi — I'm confirming how the TEFA testing process works before we finalize enrollment. Which approved assessment will students in [grade] take this year, and when will it be given? Who administers it, and is the cost included in tuition? When will I receive the complete result, and will it include a percentile rank if the assessment produces one? Who sends it to Odyssey, and how will I verify that the status is Completed? For students with an IEP or a documented disability, what testing supports or alternate assessments are available? How does the school use assessment results to adjust instruction, and what progress information will families receive? Thanks so much.

Warning signs worth taking seriously

• The school can't name the test it uses.
• The school says STAAR is required by TEFA and can't separate state law from school policy.
• The school won't explain how you get the result.
• Someone tells you parents don't get the scores. (You do. It's the law.)
• The school promises to submit results but has no confirmation process.
• The school treats "TEFA approved" as a state seal of academic quality.
• Someone says your child is exempt without written confirmation from Odyssey.
• The school's answer flatly contradicts what the official directory shows.

Any one of these deserves a follow-up question. Two or more, and we'd slow down.

Copy the school-verification email → Send it while the school office is open and keep the answer with your enrollment records.

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What happens if results don't get submitted, or a school falls out of compliance?

Answer capsule: The program rules allow the Comptroller to suspend a participating child's account or a provider's participation when a program requirement is not met. Suspension notice must state the problem, the corrective action required, and a 30-calendar-day response period. Permanent account closure or provider removal is possible at the Comptroller's discretion if the problem is not fully corrected.^[rules]

Let's separate the two, because families worry about the wrong one.

If a family misses a step. The account gets suspended — not the child. The Comptroller made that distinction on purpose during rulemaking: a child in private school doesn't have to stop attending. Payments from the account pause while the problem gets sorted.

You get written notice saying what's wrong and what to do. You get 30 calendar days to respond and comply. After that, the Comptroller may permanently close the account, temporarily reinstate it with conditions, or fully reinstate it. The rule also allows resolution before the 30 days expire when the response and corrective action are complete.^[rules]

One important limit: a decision permanently closing a participant's account under §16.405 is appealable under §16.409. Other decisions under §16.405 are final and not appealable. A §16.409 appeal must be filed within 30 calendar days, and the Comptroller's appeal decision is final. Handle problems early, in writing.^[rules]

If a school falls out of compliance. Participation can be suspended immediately, stopping payments from TEFA accounts to the school. After notice and the response period, the Comptroller may remove the provider, reinstate it with conditions, or reinstate it fully. Permanent removal is possible when the provider fails to respond or fully comply; it is not automatic in every case.^[rules]

What to keep in a folder, physical or digital:

• The school's assessment notice
• The full score report
• The percentile page if it's separate
• Your authorization, if the administrator submitted for you
• Your Odyssey submission confirmation
• Any written disability determination
• The school's answers to your verification questions

We're not going to tell you one late document ends your award. The rules create authority and a process, not an automatic guillotine. But documentation is cheap and reconstructing a paper trail in April is not.

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What about homeschool and hybrid families?

Answer capsule: Participating homeschool students are not required to take an assessment under current Odyssey guidance. The annual testing requirement applies to participating students in grades 3–12 who are enrolled at approved private schools.^{[odyssey-testing]}

The $2,000 award does not come with a testing string. Odyssey states it directly: "Homeschool students are not required to take an assessment."

You can still buy tests with TEFA funds if you want them — assessment costs are an approved expense. An eligible expense isn't a requirement. Plenty of homeschool families test annually because it's useful to them. That's a choice, not a rule.^[rules]

Here's the connection nobody has drawn

Ever wonder why homeschoolers get $2,000 and private school students get $10,474?

We read the full rulemaking record looking for the answer, and it's right there. A long list of groups — Every Kid, the Texas Public Policy Foundation, the American Federation for Children, ExcelinEd, the Texas Home School Coalition, Outschool, microschool operators — asked the Comptroller to give full funding to microschools, learning pods, online courses, and tutors.

The Comptroller declined those requests and repeatedly pointed to statutory differences between the categories, including that the other providers are not subject to the private-school package of accreditation, operating history, annual assessment, and result-sharing requirements.^[rules]

Sen. Brandon Creighton and Rep. Brad Buckley, the bill's authors, filed comments supporting the distinction reflected in the statute and rules.^[rules]

So testing is central to the line between the two funding tiers, but it is not the whole line. The higher private-school award is tied to a provider category with recognized accreditation, Texas location, two years of campus operation, annual testing, and result sharing. The $2,000 category does not carry that same package. Once you see that, the program's shape makes a lot more sense.^[rules]

The gray zone: hybrids, microschools, and co-ops

This is where families get tripped up. The word "homeschool" in everyday use doesn't always match how the program classifies you. What decides it:

• Is your child enrolled at an approved participating private school?
• How does Odyssey classify your child's setting?
• Is the provider receiving private school tuition through the program?
• Is your child in grades 3–12?

And a real warning: if your child attends a private school that did not join TEFA, don't assume you're automatically in the homeschool/other bucket. Confirm your classification with Odyssey. It affects both your award and your obligations, and it's not something to guess at.

Need the award side too? Use our Texas TEFA award amount calculator, then confirm your setting with Odyssey before spending.

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What happens if my child goes back to public school?

Answer capsule: A child cannot continue as a TEFA participant while enrolled and counted in a Texas public school or open-enrollment charter school. Senate Bill 2 also provides that a child returning from TEFA is excluded from the receiving public school's performance evaluation for the first school year after leaving the program.^[sb2][rules]

Two things you should know before you make the move.

Tell Odyssey right away. And here we have to flag a real conflict in the source documents.

• The statute says notice within 30 business days.
• The rules use 30 calendar days in the participant agreement.

Those aren't the same length of time. We're not going to pick one for you and we're not going to pretend the conflict isn't there. Notify Odyssey as soon as the enrollment changes. Don't plan around either outer limit. Stop requesting distributions for expenses incurred on or after the child becomes ineligible.^[sb2][rules]

Your child won't count in the new school's accountability evaluation the first year. Under §29.3611, a child returning from TEFA is excluded from the receiving district's or charter's performance evaluation for the first school year after leaving. The district or charter also receives an additional allotment equal to 0.1 of the basic allotment for that year.^[sb2]

Read that narrowly, though. It means the child isn't in that year's accountability calculation. It does not mean your child skips instruction, testing, services, or enrollment. They're a regular student from day one.

Bring these with you: assessment results, school records, any IEP or evaluation paperwork, instructional records, and withdrawal and enrollment documents. Public districts and open-enrollment charter schools are required to provide records on a parent's request for submission to a private school too — §29.369 covers that.^[sb2]

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Why is TEFA accountability built this way?

Answer capsule: The structure reflects specific choices the Texas Comptroller made while adopting the program rules in December 2025 after receiving roughly 300 public comments. The rulemaking record documents which accountability measures organizations requested, which changes were accepted, and which were declined.^[rules]

We think this section matters more than it looks, because it answers the "did anyone even think about this?" question. They did. On the record. Here's who asked for what.

That's not a leak. It's a published government document, and the organizations are named in it. If you've been told "nobody considered accountability," this table is the answer. If you've been told "TEFA has the same accountability as public school," this table is also the answer. The record is what it is, and it's why we'd rather show it than characterize it.^[rules]

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When will we know how TEFA students are actually doing?

Answer capsule: Senate Bill 2 requires the Comptroller, working with the Texas Education Agency and the program administrator, to produce an annual longitudinal report that includes assessment data and covers a period of at least five years. A full five-year comparison cannot exist in the first program year, and the law does not publish a specific date for the first academic-outcome report. The State Auditor must review and verify the report's validity.^[sb2]

Here's the timeline problem, and it's built into the law.

Section 29.371 requires an annual longitudinal report. It must use appropriate analytical methods, comply with FERPA, cover at least five years, and publish the data analyzed and the methodology used. It goes on the program website and to the Commissioner of Education, assessment data included. The State Auditor must check that it's valid, and can go collect data directly if the numbers don't add up.

That's a serious piece of research design. A complete five-year longitudinal comparison cannot exist in year one. What the law does not make clear is whether the Comptroller will publish preliminary annual academic data before a full five-year window exists.

The report that came out August 1, 2026 is a different one — the demographic report required by §29.3715. We opened it. It contains counts by tier, income, grade, age, sex, race, district of residence, and campus of residence.

It contains zero academic-outcome data. Not because anyone hid anything. Because that's not what that demographic report is designed to publish.^[annual]

One footnote worth knowing: §29.370 lets the Comptroller accept gifts, grants, and donations to pay for the §29.371 report. A privately funded evaluation of a public program isn't unusual, but it's the kind of thing worth watching when the first report lands.

What to watch for, and roughly when:

• August 1, each year — the demographic report. Statutory deadline.
• Any preliminary assessment-data release — no fixed first date was identified.
• The first full longitudinal report — it must address a period of at least five years.
• 2027-28 — major public-school Student Success Tool changes begin, which changes the comparison landscape again.^[hb8]

We check for all of them. When the first report with test data shows up, this page gets updated after the methods and denominators are checked — not merely after the headline is copied.

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What's still unknown as of August 5, 2026

Answer capsule: The law and core testing duty are in force, and Odyssey has published a school-side upload process. Several operational details remain incomplete, including a detailed public parent-upload walkthrough, any earlier statewide operational deadline, the criteria for special-case testing exceptions, and grade-by-grade assessment assignments for each school.^{[upload][odyssey-testing]}

We'd rather show you the gaps than paper over them. This is our live watch list.

None of these stop you from doing the right thing this year: find out if your child has to test, get the school's answer in writing, and save the result and the Completed status or other submission proof.

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What we actually verified

We think you should know exactly what we read and what we didn't.

Read in full, at the original source:

• The enrolled text and official bill analysis for Senate Bill 2, 89th Legislature (2025) — Education Code Chapter 29, Subchapter J, start to finish
• The adopted rules preamble for 34 TAC §§16.401–16.410, filed December 12, 2025, covering roughly 300 public comments
• Odyssey's approved-assessment article, updated April 28, 2026
• Odyssey's testing and reporting requirements article, updated February 25, 2026
• Odyssey's test-score upload article, updated June 2, 2026
• The official TEFA homepage and school requirements, rechecked August 5, 2026
• The TEFA Annual Demographic Report 2026-27, released August 1, 2026
• Texas Education Agency guidance on House Bill 8 assessment changes
• Federal guidance on parentally placed private-school students, ADA Title III, and Section 504

Calculated ourselves, with the method shown above:

• The grade-band split of funded students: 55,101 in grades 3–12, 30,243 in Pre-K–2
• Cross-checked the report's grade, age, sex, and race tables independently — all four total exactly 85,344
• The participating-school directory analysis: 2,785 listing rows, 1,163 serving grade 3+, 1,622 stopping below grade 3, and the assessment disclosure counts
• The special-needs disclosure counts: 110 listing rows disclosing at least one of five individually administered batteries, and 123 disclosing at least one when STAAR Alternate 2 is included

What we could not confirm, stated plainly:

• The exact publisher or product identity Odyssey means by "Milestones" and "ARK Assessments." We list the names because the program does and do not describe them beyond that.
• A detailed public parent-portal upload walkthrough and accepted file-format list
• Whether Odyssey will set an earlier operational deadline than June 30, 2027
• The criteria for special-case disability exceptions
• Which disclosed assessment applies to each grade at each school
• Whether any school in the directory is actually in compliance — a directory is a disclosure, not an audit

Our positioning, so you know who's talking: The School Choice Index is an independent comparison and research resource for U.S. school choice programs. We are not affiliated with the Texas Comptroller, the Texas Education Agency, Odyssey, or any participating school. Nothing here is legal advice.

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Texas TEFA testing and accountability FAQ

Do all TEFA students have to take a test? No. The annual requirement applies to participating students in grades 3–12 at approved private schools.

Does a 2nd grader have to test? No TEFA requirement applies below 3rd grade. Your school may test anyway under its own policy.

Do homeschool TEFA students have to test? No. Odyssey states homeschool participants are not required to take an assessment.

Is the STAAR required? No. It's one of 20 general approved options. In the August 2 official directory snapshot, 23 of 1,163 grade-3+ listing rows disclosed it.

Can I choose my child's test? Not as a right. The law gives the school discretion among allowed assessments. Some schools will offer options if you ask.

Can TEFA money pay for the test? Yes. Assessment costs are an approved education-related expense when purchased through the program's approved process.

Is there a passing score? We found no minimum score in the statute, the rules, or current program guidance. The requirement is to take the test and report the result.

Can a low score end our award? We found no score-based cancellation rule. Your obligation is testing and reporting, not hitting a number. Your school may use scores for its own decisions, which is separate.

Are individual results public? No. Individual results and percentile ranks are confidential. The state may still use protected data in statewide or longitudinal reporting.

Are TEFA private schools rated A–F? No. Participating private schools are not placed in Texas's public-school A–F system through TEFA.

Who sends results to Odyssey? The parent makes sure Odyssey receives them — either directly or by authorizing and instructing the test administrator.

How do I know a submission worked? Odyssey's school guidance says the assessment status changes from Required to Completed after successful submission.

When are results due? June 30, 2027 is the outer legal deadline for 2026-27, based on the rules' program-year definition. Follow any earlier date Odyssey publishes.

What if my school's directory listing is blank? Ask the school. A blank public field can mean incomplete directory data. It's not proof of a problem.

Can a special-needs student be excused? Odyssey has said some may be excused in special cases, but has not published the criteria. Get any exception confirmed in writing before skipping the assessment.

Can a school be kicked out of TEFA? Yes. Schools can be suspended and may be permanently removed at the Comptroller's discretion if they fail to respond or fully correct a violation.

Does an IEP guarantee the same accommodations at a private school? No. TEFA does not guarantee the same public-school IEP package. Separate IDEA, ADA, and Section 504 rules may apply differently depending on the school.

Does taking TEFA money make a private school act like a public school? No. Participating schools keep substantial control over curriculum, admissions, and institutional or religious practices.

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What to do this week

Answer capsule: Families should confirm whether the testing requirement applies to their child, obtain the school's specific assessment plan in writing, and save both the result and proof it reached the program administrator. Directory participation status should not be treated as a measure of school quality.

Three steps. That's it.

1. Find out if the rule applies to your child. Grade and setting decide it. Two minutes.

2. Get the school's answer in writing. Which test, which month, what supports, how you get the result. Use the email above.

3. Save the score and the receipt. Together, in one place, where you'll find them in a year.

And one thing to let go of: the idea that current Texas law gives you a TEFA school report card that will make this decision for you. It doesn't. What you have instead is your child's own result, with a percentile when available, plus the seven questions the school has to answer if it wants your trust.

Honestly? For a lot of families, that's the better instrument. It's just the one that asks something of you.

### Still not sure which path is right for your family? Take our free 60-second school choice matching quiz. Answer a few questions about your child, your area, and what you're looking for, and get a personalized Texas school path plan — no email required to see your results.

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The School Choice Index is an independent comparison and research resource for U.S. school choice programs. Program rules, approved assessment lists, directory records, and operational deadlines can change. Confirm current requirements with the Texas Comptroller's TEFA program and Odyssey before acting.

Sources

^[sb2]Texas Senate Bill 2, enrolled version, 89th Legislature (2025), including Education Code §§29.357, 29.358, 29.3611, 29.363, 29.367–29.3715.

^[rules]Texas Comptroller adopted TEFA rules, 34 TAC §§16.401–16.410, adopted December 2025.

^{[odyssey-tests]}Odyssey, “What Tests are Currently Approved for the Texas Education Freedom Accounts (TEFA) Program?”, updated April 28, 2026.

^{[odyssey-testing]}Odyssey, “Are There Testing and Reporting Requirements for Students?”, updated February 25, 2026.

^[upload]Odyssey, “How to Upload Student Test Scores”, updated June 2, 2026.

^[tefa-home]Texas Education Freedom Accounts official website, rechecked August 5, 2026.

^[annual]Texas Education Freedom Accounts Annual Demographic Report: 2026-27, issued August 1, 2026; data snapshot July 29, 2026.

^[directory]Texas Comptroller, TEFA Participating Schools workbook, report run August 2, 2026; calculations by The School Choice Index, August 5, 2026.

^[finder]Official Texas TEFA participating-school finder, rechecked August 5, 2026.

^[hb8]Texas Education Agency, House Bill 8: Student Assessment, rechecked August 5, 2026.

^[ratings]Texas Education Agency, TXschools.gov accountability ratings, rechecked August 5, 2026.

^[idea]U.S. Department of Education, Questions and Answers on Serving Children with Disabilities Placed by Their Parents in Private Schools.

^[ada]U.S. Department of Justice, ADA Title III.

^[section504]U.S. Department of Education, Section 504.

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