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State changes CEP validation and direct certification processes; coding changes announced for 2025–26

5842389 · April 16, 2025

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Summary

Tennessee announced procedural changes for the Community Eligibility Provision (CEP), a new plan to procure software to support state match and direct certification, and upcoming student coding changes, including removal of the J code for 2025–26 and reintroduction of X and Y codes for applications.

Rhonda, senior compliance and data manager at the Tennessee Department of Education, said the agency will change how it validates Community Eligibility Provision (CEP) ISP (identified student percentage) calculations beginning in the 2025–26 school year.

Rather than waiting for an administrative review, the state will validate ISPs and free‑claiming percentages outside of the review process. Rhonda said the goal is to complete validations by Sept. 30 each school year so any necessary claim changes are limited and do not create large fiscal actions after administrative reviews. For districts newly electing CEP in 2025–26 the state will conduct a technical assistance review to validate the ISP; continued cycle operations will be validated on a rolling basis tied to reviews.

Rhonda also said the department is moving forward to procure software to implement a state match system for direct certification but had no additional details at the time of the call. She recommended districts use the April 1, 2025 enrollment and identified student snapshot for ISP calculation and noted the state provided an April Medicaid file with a March 31 as‑of date to aid matching.

Rhonda announced coding changes coming in 2025–26: the J code is being retired and SNAP and TANF direct‑certification codes will be SN and TO respectively; X and Y codes for free or reduced by application will be reintroduced. She said official guidance will be posted when available.

On CEP timing, Rhonda reiterated that LEAs electing CEP for 2025–26 must notify the state agency and submit site lists in TMAC by June 30, 2025, and that the ISP calculation must use counts “as of” April 1, 2025. “We use… the definition of enrolled and attending as of 04/01,” she said.

The department said further details will appear in regional meetings and in posted guidance when ready.