School Choice ESA Renewal: What Has to Be Refiled Each Year

The Arizona Department of Education's ESA page carries a footnote under its 2026-27 enrollment count (107,859, shown as of October 5, 2026): 7,000 students who were eligible to renew contracts "did not submit required information to complete the renewal process." The same note says the program expects many of them back during Quarter 1.

Read that twice and it tells you how renewal usually goes wrong. Those families did not lose eligibility. Nobody denied them. A piece of paper simply did not arrive by a date, and the account stopped receiving money while it waited.

Renewal is the part of an ESA that families plan for least, because the first year's application felt like the hard part. It is not one form. Depending on your state it is a signed contract, a fresh residency upload, a test score that someone else has to report, a school's confirmation that your child is enrolled, and an accept button you have to press after you have already applied. Miss any one of them and the program will often treat your child as brand new.

Scope: renewal for the 2026-27 program year in six programs (Arizona, Florida, West Virginia, Tennessee, Alabama, Iowa), read from statutes, administrative rules, handbooks and program pages on October 9, 2026. Almost every 2026-27 window below has already closed; the exception is Iowa's half-year application, open October 15 to November 15, 2026. The reason to read them now is that most of the same dates come back for 2027-28, and Florida, Arizona and, in part, West Virginia fix theirs in statute or rule. I am not a lawyer and have no role in any of these programs; the program's own portal and handbook outrank anything written here.

Four kinds of renewal paper, and you only control some of them

Across these six programs, a renewal draws on four kinds of paper. Not every state asks for all four.

1. Your own signature. A renewal contract, an agreement, a set of assurances, an accept-or-decline step. Only the parent can do this, and it is the piece most often forgotten because it feels like a formality.
2. Proof the child still qualifies. Residency, sometimes citizenship or lawful presence, occasionally income for priority placement.
3. Proof the year happened. Expense reports, test results, a teacher's academic review, a learning plan. This is where a renewal reaches backward into the year you just finished.
4. Somebody else's confirmation. A private school's admission confirmation, a county superintendent's record, a school's test report to the state. You cannot submit these for the third party. You can only check that they were sent.

The column people underestimate is the fourth. A renewal can be complete on your side and still stall because a form that travels school-to-state or teacher-to-county did not move.

Arizona: you earn the renewal during the year, then sign for it in June

Arizona's statute is short about this. A.R.S. 15-2402(F) says a parent "must renew the qualified student's Arizona empowerment scholarship account on an annual basis," and that the Department verifies the child is still a qualified student for the year being renewed. It also says the Department does not have to re-verify a qualifying disability every year.

The State Board's rule does the heavy lifting. A.A.C. R7-2-1506 (Cornell LII's reproduction, read October 9, 2026; it shows the rule last amended effective January 23, 2023) sets four conditions a parent must meet to be eligible to renew at all:

• expenses and documentation were submitted, or quarterly attestations filed, under R7-2-1508;
• any expenses that required Department approval were approved;
• the parent spent money to provide an education in at least reading, grammar, mathematics, social studies, and science for the contract year; and
• the parent does not owe the Department money for disallowed expenses.

That fourth condition is the bridge between renewal and reimbursement review. A purchase the Department disallowed in February becomes a renewal problem in June unless it is repaid or appealed. The rule says a parent with an unresolved appeal over a disallowed expense remains eligible to renew, so an open appeal protects you and an ignored notice does not. If you are holding a rejection you never answered, the fix is the same one covered in why ESA reimbursements get rejected, and it is worth doing before spring.

The calendar is in R7-2-1506(C): the Department provides renewal contracts on or before May 1 to each parent who meets the four conditions, each parent submits the contract on or before June 30, and the Department notifies the parent within 30 days of receipt. The rule says that notice may come through the online portal. Two less-known valves sit in the same section. Subsection (H) requires the Department, at the parent's written request, to extend the renewal timeframe by up to 30 days for hardship, "including an act of God or similar circumstance." Subsection (G) gives a parent whose contract the Department did not renew 30 days to request a hearing.

Miss June 30 and subsection (D) applies. The Department "shall temporarily close the account and cease funding" until the parent submits the signed contract, and during the temporary closure the money stays in the account. That is the state the 7,000 students on the ADE footnote were in. It is recoverable. R7-2-1506(E) lets a parent submit the signed renewal contract at any point from July 1 to June 30 to reactivate the account, and the clock that ends in permanent closure is long: three academic years without renewal, then a notice by certified mail, email and phone, then 60 days. The statute repeats that sequence in A.R.S. 15-2402(H). The details of that last stage belong to what happens to an unspent balance.

The practical cost of a late Arizona renewal is not the balance. It is the quarter of funding that does not arrive while the account sits closed.

Florida: three deadlines between February and June, and only one of them is the application

Florida writes its renewal window into statute, three times over. Under s. 1002.395(6)(d)2., which covers private-school students, the scholarship-funding organization must run a renewal process that, for the 2025-2026 school year and thereafter, begins February 1 and ends April 30 of the prior school year, and must require parents to confirm the scholarship is being renewed or declined by May 31. Paragraph (6)(e)2. of the same section sets the identical window for PEP students, and s. 1002.394(11) does it again for the Unique Abilities scholarship. The private-school clause adds a student's renewal "is contingent upon an eligible private school providing confirmation of admission." Because those dates are in the statute, a family can put them on a 2027 calendar now without waiting for an announcement.

Step Up For Students' 2026-27 deadlines FAQ turns that into a schedule for all three scholarships (Private School, Unique Abilities, and PEP): renewal applications February 1 to April 30, accept or decline by May 31. Two lines in it deserve more attention than they get.

The first is the definition. Starting with 2026-27, "a renewal student is one who received Quarter 4 funding for the same scholarship last year and did not have the scholarship revoked." Switch scholarships, or leave before the fourth quarter, and you are not a renewal student no matter how many years you have been in the program.

The second is the penalty. "Missing any renewal deadline causes the student to lose renewal status and be treated as new." The FAQ also says a renewal student who accepts after the renewal deadline is considered new. Being new has a price you can count: for 2026-27, funds for renewal students arrived from the Department of Education to Step Up by August 1, 2026, and for new students and late renewals by September 1, 2026. A month of tuition or services, floated by the family or the school.

What the renewal actually requires depends on the scholarship:

• Private School Scholarship. Beyond the application and acceptance, the school has to complete the enrollment in Step Up's system and the parent has to approve it. For renewal students the 2026-27 deadline was June 15, 2026, extended to June 26; miss it and the July 15 date for new students applied (extended to July 24). Under s. 1002.395(7)(a), the parent must also have the child take the norm-referenced assessment the school offers.
• Personalized Education Program (PEP). The statute at s. 1002.395(7)(b)2. ties renewal to two things the parent produces: a student learning plan "revising the plan at least annually before program renewal," and results from a nationally norm-referenced test identified by the Department of Education, or a statewide assessment, provided "before the student's program renewal." Step Up's FAQ sets both for 2026-27: the 2026-27 learning plan by May 31, 2026, and prior-year assessments by May 31, 2026.

That PEP testing line catches families who think of themselves as homeschoolers. The district's annual evaluation and the scholarship's assessment are different deliverables going to different offices. The portfolio you keep for one does not satisfy the other, which is the same split covered from the homeschool side in what a portfolio reviewer accepts.

West Virginia: no reapplication, but three conditions and a teacher's signature

West Virginia changed the shape of renewal in 2025. W. Va. Code 18-31-8(a) (read October 9, 2026) says that effective January 1, 2025, a Hope Scholarship student "may continue participation in the program from school year to school year without reapplying." Subsection (b) then lists what the parent must still do every year:

1. submit proof of the student's continued West Virginia residency;
2. execute the parent agreement with the Board ahead of each school year; and
3. report to the county superintendent that the student met all attendance and academic requirements for the most recent school year.

The vehicle for all of this is the Continued Participation Confirmation, or CPC. The Hope Scholarship site set the 2026-27 window at January 5 to June 15, 2026. The Treasurer's January 21, 2026 announcement spelled out the stakes: a student who missed June 15 would be treated as a new application "subject to a lower funding amount," and any carryover in the account "would revert back to the state."

The site's new-application chart shows what "lower" means. A new application filed March 2 to June 15, 2026 received 100% of the scholarship; June 16 to September 15, 75%; September 16 to November 30, 50%; December 1 to February 28, 2027, 25%. A family that missed the CPC deadline by one day and applied fresh on June 16 landed in the 75% band.

The academic condition has its own route and its own earlier date. For a student in an individualized instructional program, 18-31-8(a)(4) allows two ways to show progress. One is a nationally normed achievement test in reading, language and mathematics (plus science and social studies when available for the grade), with an overall mean at or above the fourth stanine or improvement over the prior year, reported to the county superintendent. The other is an annual review of the student's work by a certified teacher who determines the student is progressing "commensurate with his or her age and ability," also reported to the superintendent.

The program's Academic Progress Review Form puts a date on that: the parent submits it to the county superintendent "no later than June 8th annually," and failure "will result in loss of eligibility." It also asks teachers licensed outside West Virginia to attach a copy of their license, because county boards cannot verify out-of-state licensure. A family using a relative who teaches in Ohio, for example, needs that copy in the envelope.

Then the paper moves without you. Under 18-31-8(c), superintendents send the results to the Board and the Department of Education by June 15. The Treasurer's announcement says approved CPCs show as "Conditionally Eligible," and in early July Board staff check that the prior year's academic reporting was recorded by the county before switching the student to Approved. So the time to log in and look is early to mid-July.

One drafting oddity in subsection (d): if a parent misses the annual conditions, the Board notifies the parent that the account "will be closed in 45 calendar days," yet the same sentence closes the account if the parent "does not respond within 30 calendar days of receipt of notice." If you ever receive that notice, answer inside 30 days and do not count on the 45.

Tennessee: an abbreviated form that still wants the residency proof again

Tennessee is blunt about the basic question. Its 2026-27 EFS FAQs say families "must reapply for each recipient student every year." Current recipients file an abbreviated renewal application, which for 2026-27 opened December 9, 2025 at noon CT and closed January 30, 2026 at 4 p.m. CT, the same closing minute as new applications.

That shared deadline matters more than it looks. When applications outnumber available scholarships, the FAQ ranks awards by priority category, and Priority 1 is "Current EFS Recipient." The renewal is what holds that place. A family pushed into the new-application lane competes from a lower category, and after January 30 there was no 2026-27 lane at all.

The renewal form has four sections. Student information arrives prefilled. The eligibility section asks you to confirm whether the citizenship or lawful-presence documents on file are still current, and only if they are not do you upload new ones. Residency works the other way: current recipients "must upload two (2) proof documents from the approved list," and the FAQ adds, "Even if last year's proof documents are still current, you must upload two (2) proof documents again." The last section is assurances and a FERPA release.

Three smaller rules in the same document trip people:

• The renewal application is available only for students with an active EFS when the form is submitted. A 2025-26 application sitting in "Eligible" status is not active; that family files a new application, without the Priority 1 placement.
• Paper applications are not accepted for renewals. You need the existing account holder's credentials.
• An 18-year-old student must apply on their own behalf unless a power of attorney or conservatorship is in place, and if residency documents are in a parent's name, that parent has to be listed as an additional parent or guardian.

The academic piece is not yours to file. The FAQ says EFS-registered schools must ensure students in grades 3 through 11 take either the TCAP in math and English language arts or a nationally standardized achievement test aligned to the school's instructional plan, every year of enrollment, and report results for scholarship recipients to the Office of Research and Education Accountability. Ask the school in the spring whether that report has gone in.

Alabama: the shortest checklist, and no late lane

Alabama's CHOOSE Act asks the least of a renewing family. The program site defines a renewing parent as one whose student received CHOOSE Act funds for 2025-26, and for 2026-27 listed only three things: the existing FACTS application login and password, the name of the participating school for 2026-27 (not needed for home education students), and a birth certificate for any student being added.

The window opened December 15, 2025, when renewing families received an email from ClassWallet with the renewal link, and closed March 31, 2026. The site's sentence on lateness leaves no room: "If you do not complete the renewal application by March 31, 2026, your student will not be eligible for the 2026-2027 academic year." Award notifications began April 15.

Two quiet failure points. The renewal link came by email from the payment vendor, not from the state, so a spam filter can eat the whole renewal. And the site separately says a family who was awarded for 2025-26 but "did not complete the award affidavit in ClassWallet" counts as new. Accepting the award is its own step, as in Florida.

Iowa: there is no renewal, only the annual application

Iowa skips the renewal concept. The Department of Education's ESA page tells returning applicants to "log in to the existing account to begin the application," and the application is the same annual one: full-year applications for 2026-27 opened April 16, 2026 and closed June 30, 2026 at 11:59 p.m. Families not approved for a full year can file a half-year application from October 15 to November 15, 2026, for $4,074 instead of $8,148. That window was created by House File 2754, signed May 12, 2026, and it is the one 2026-27 date in this article still ahead of you.

Residency is re-proved every cycle. The page says "Iowa residency is required to be established each year through the annual application process," and explains that the tax return is used "solely to verify Iowa residency through an automated process," even though income no longer affects eligibility. The same page adds a step for applications submitted from fall 2026 onward: a valid, government-issued ID, uploaded even when the tax return clears the automated check. Returning families should expect that upload on the 2027-28 application.

Iowa's version of the third-party confirmation is a payment, not a form. To receive and keep full-year funds, the student must be attending an accredited nonpublic school in Iowa and tuition and fees must be paid through the ESA portal by September 30, 2026. Miss that and the student is ineligible for full-year funds for 2026-27. Half-year participants face the same test with a later date, January 14, 2027. For a family that applied in April, that is the renewal's real last step, five months after the application.

Where renewals stall, in roughly the order they happen

Put the six programs side by side and the failures cluster in a few places.

The account is not in good standing. Arizona will not even send a renewal contract to a parent who owes money for disallowed expenses or skipped expense reporting. Florida's renewal status depends on fourth-quarter funding, which depends on everything going right through June. These are decided months before the renewal window, by how the year's claims went.

The renewal arrives in a place nobody checks. Alabama's link came from ClassWallet. Arizona's rule lets its renewal notice arrive through the online portal. Florida's acceptance step is a separate action after the application.

Somebody else's paper never moved. A Florida private school that did not finish enrollment, a West Virginia county that did not record the academic review, a Tennessee school that did not report scores. All of these sit outside your login, and all of them can block a renewal you completed correctly.

The documents expired quietly. Tennessee wants two current residency proofs every year. West Virginia wants proof of continued residency. A lease that ran out in March or a utility account moved into a spouse's name changes what you can upload. The document lists from the first application apply again here, and the same issued-date rules bite.

A switch reset the clock. Florida's renewal definition is tied to the same scholarship. Change from PEP to the Private School Scholarship and you apply as new.

The dates to write on next year's calendar, before anyone announces them

It is October 2026. The 2027-28 renewal season starts as early as December in some states. Here is what can go on a calendar today, and what you have to wait for.

Fixed in law or rule now:

• Florida: renewal application February 1 to April 30, 2027; accept or decline by May 31, 2027 (s. 1002.395(6)(d)2. and (6)(e)2.; s. 1002.394(11) for Unique Abilities). PEP families should expect the learning plan and prior-year assessment to be due around the same May date, but confirm the exact day when Step Up publishes its 2027-28 FAQ.
• Arizona: renewal contract arrives by May 1, 2027; return it by June 30, 2027 (R7-2-1506(C)), or ask in writing for a hardship extension of up to 30 days under R7-2-1506(H). Before then, make sure every quarter's expense reporting is in and no disallowed expense sits unpaid and unappealed.
• West Virginia: academic progress report to the county superintendent by June 8, 2027 (program form); superintendents forward results by June 15 (18-31-8(c)). The CPC window itself is set by the Board each year; 2026-27 ran January 5 to June 15.

Watch for the announcement, using last year's dates as a guide only:

• Tennessee opened renewals December 9 and closed January 30 last cycle.
• Alabama opened renewals December 15 and closed March 31 last cycle, with the link sent by ClassWallet email.
• Iowa opened April 16 and closed June 30, with the tuition payment deadline on September 30. The fall 2026 half-year window (October 15 to November 15) is new this year, so do not assume it repeats.

Then do one thing this week. Open your program's portal, find the account status line, and confirm it reads active, approved, or funded for 2026-27, not "temporarily closed," "conditionally eligible," or "eligible" without an award. If it reads anything else, the renewal you thought was finished is not, and the program's help line is the next call.