Texas TEFA,
built into the dashboard.

What TEFA is and why it is the biggest US ESA wave

The Texas Education Freedom Account (TEFA) is the state's universal Education Savings Account program, signed into law in 2025 and launched for the 2026-27 academic year. It funds private school tuition, homeschool curriculum and tutoring, therapies, testing fees, and other approved expenses through a state-managed account that a participating family draws against.

Year 1 received 274,183 applications during the February 4 to March 31, 2026 window. Of those, only 95,935 were awarded in the inaugural cohort — roughly 153,000 students remain waitlisted across the program's priority tiers because demand exceeded the $1 billion Year 1 appropriation. The Texas Comptroller selected Odyssey as the Certified Educational Assistance Organization (CEAO) that administers the platform, vendor approvals, and reimbursement disbursements. Private-school funding releases in three tranches: 25% on July 1, 2026, 25% on October 1, 2026, and the remaining 50% on February 1, 2027. Homeschool students receive their full $2,000 allocation upfront on July 1, 2026.

TEFA's $10,474 per K-12 private school student award is currently the largest per-student award of any US ESA program. For most microschool operators in Texas, this single program changes the financial picture: tuition that would have been hard to collect quarterly becomes a quarterly disbursement from a single state-platform source.

Who can be a TEFA-approved vendor

Texas microschools, learning pods, and homeschool co-ops that operate under private-school or homeschool rules can register as TEFA-approved education service providers. The vendor approval process is run through Odyssey's vendor portal, not the Comptroller directly. Approval requires business formation documents, a W-9, proof of liability insurance, a tuition schedule, and (for full microschools) a facility lease or proof of right to operate at the address.

Independent operators do not need to register a separate ESA-specific entity. A Texas LLC or sole proprietorship that already operates the school can use its existing TIN to register with Odyssey.

Reporting cadence and operator obligations

TEFA disburses on a three-tranche schedule (25% / 25% / 50%). Operators submit quarterly invoices through Odyssey, accompanied by attendance records (Texas's instructional day count is 180 days), a quarterly progress note per student, and any expense-category documentation Odyssey flags during periodic spot reviews.

TEFA's final rules narrowed eligible expenses: standalone tutors, therapy services, and freelance teaching services were excluded from the approved categories. Technology purchases are capped at 10% of each account's allocation. There are no reimbursements — every transaction routes through Odyssey-approved payment channels.

For students in grades 3-12, parents are responsible for submitting nationally norm-referenced test results to Odyssey annually. The school does not run the testing; the parent does. Operators must keep dated records of every student's enrollment, attendance, tuition charged, ESA portion received, and out-of-pocket portion paid. Participating private schools must be accredited (TEPSAC or TEA-recognized) and operating for at least two years with a Texas location.

What CohortLedger does for Texas operators

CohortLedger is built around the TEFA quarterly money flow specifically. The dashboard tracks each TEFA-funded student's per-quarter share ($2,618.50 of the annual $10,474), the quarter's expected vs. received status, and any variance (Odyssey occasionally short-pays for processing fees, which CohortLedger surfaces on the bank reconciliation page).

The audit packet feature generates a state-reviewer-ready quarterly summary in one click: per-student tuition, attendance counts, compliance log, and certification timestamp. The vendor wizard pre-loads Odyssey's TEFA registration steps so new operators do not have to assemble the documentation list themselves. The compliance calendar fires reminders before each TEFA reporting deadline.