The guidance clarifies that if a public school contracts with an ESA student for fee-based services or classes, it does not assume FAPE responsibility, but Child Find obligations still apply. Districts may therefore see ESA families requesting evaluations or limited special education services. This points to ongoing needs for evaluation capacity, contracted specialists, and systems to track ESA students interacting with special education teams without full enrollment.

ESA students receiving fee-based services remain outside the district enrollment count but still fall under Child Find responsibilities.