School funding conversations can feel complicated—especially when you’re also trying to ensure students receive the right services, staff have manageable caseloads, and teams stay compliant with state and federal requirements. Tennessee’s new funding formula, the Tennessee Investment in Student Achievement (TISA), includes a key concept called Unique Learning Needs (ULNs). Understanding ULNs helps school teams connect student needs to supports, and it also helps district leaders plan responsibly for staffing, contracting, and service delivery.
At TinyEYE, we partner with schools to provide online therapy services (including speech-language therapy and other related services) when districts face staffing shortages or need flexible coverage. In this post, I’ll break down ULNs in plain language and highlight what matters most for special education leaders, English learner teams, and anyone supporting students with reading needs.
What are Unique Learning Needs (ULNs)?
In Tennessee law, a unique learning need is a learning need that requires a local education agency (LEA) to provide a student individualized services, interventions, accommodations, or modifications so the student can be successful.
In practice, ULNs are about identifying the supports a student needs—and documenting them appropriately. Every ULN must include two core components:
- An assessment to identify the need
- A plan to provide support in meeting the need
ULNs are organized into 10 progressive categories (ULN 1 through ULN 10). Higher ULNs reflect a higher level of support. Each ULN has a percentage weight that is multiplied by the state’s base funding amount to generate additional funds for students who need additional supports.
For the 2023-2024 school year, the base funding amount referenced in the quick guide is $6,860. ULN weights range from 15% (ULN 1) to 150% (ULN 10).
ULN weights (quick list)
- ULN 1: 15%
- ULN 2: 20%
- ULN 3: 40%
- ULN 4: 60%
- ULN 5: 70%
- ULN 6: 75%
- ULN 7: 80%
- ULN 8: 100%
- ULN 9: 125%
- ULN 10: 150%
How many ULN codes can one student generate?
Depending on a student’s needs, a student may generate up to four ULN-related codes:
- Primary option
- Secondary option
- Characteristics of dyslexia
- English learner status
It’s also possible for a student to generate some codes twice. The quick guide provides an example: a student with characteristics of dyslexia who also generates a special education option code 2 could generate funding under ULN 2 twice.
Students with Disabilities: ULNs and the IEP (what is changing—and what is not)
For students with disabilities, the Individualized Education Program (IEP) is the primary vehicle for capturing the assessment and plan:
- Assessment: Initial evaluation and annual reevaluation
- Plan: IEP
A key message from the Tennessee Department of Education is that nothing about how IEPs operate is changing due to TISA. Teams should continue to follow the same IDEA requirements and state special education rules they have always followed. ULNs are a way to apply existing data from compliant IEP processes to the funding formula.
From a district leadership perspective, that matters because your compliance foundation remains the same: timely evaluations, appropriate IEP development, service implementation, progress monitoring, and documentation.
How IEP service hours connect to ULNs: option codes crosswalk
In Tennessee’s state IEP system, IEP services and hours translate into special education option codes. Those option codes map to ULNs using business rules in the State Board’s TISA rule.
Here is the crosswalk summarized from the quick guide:
- Option 1 (consultation; direct services ≤ 1 hour/week; related services < 1 hour/week) maps to ULN 1
- Option 2 (direct services ≥ 1 but < 4 hours/week; or any one related service ≥ 1 but < 4 hours/week) maps to ULN 2
- Option 3 (direct services ≥ 4 but < 9 hours/week; or any one related service ≥ 4 but < 9 hours/week) maps to ULN 3
- Option 4 (direct services ≥ 9 but < 14 hours/week; or any one related service ≥ 9 but < 14 hours/week) maps to ULN 6
- Option 5 (direct services ≥ 14 but < 23 hours/week; or any one related service ≥ 14 but < 23 hours/week) maps to ULN 7
- Option 6 (ancillary services/attendant support to access less restrictive settings) maps to ULN 8
- Option 7 (direct services 23+ hours/week; or any one related service 23+ hours/week) maps to ULN 9
- Option 8 (self-contained/CDC with specific service totals and related service minimums) maps to ULN 9
- Option 9 (residential services, 24 hours/day) maps to ULN 10
- Option 10 (hospital/homebound, 3+ hours/week) maps to ULN 10
One important operational takeaway: students may have both a primary and a secondary option code based on their service needs, and both can generate funding in the formula when applicable.
How does an IEP produce funding for ULNs? (simple 3-step flow)
- Teachers and IEP teams document the services and hours needed for FAPE in the IEP.
- The IEP services/hours translate into special education option codes in the state IEP system.
- Option codes translate into ULNs based on TISA business rules.
This is one reason service-hour accuracy matters so much. When districts are short-staffed, service logs can fall behind, schedules may shift, and documentation can become inconsistent. Those are real-world pressures—but they also create compliance risk. A stable plan for delivering and documenting related services (including teletherapy when appropriate) can help protect both students’ services and district reporting accuracy.
English Learners (EL): assessment, planning, and ULN alignment
English Learners are students who qualify for English as a Second Language services using a department-approved assessment process. The quick guide highlights:
- Assessment: Home language, entry screener, WIDA
- Plan: An Individualized Learning Plan (ILP). Beginning in 2023-2024, the ILP moves into a state-hosted system to support consistent application and tracking.
TISA sets three tiers of English Learners based on EL status, years of services, and WIDA scores. The tiers progress from lower intensity supports to higher intensity supports.
EL tiers (overview)
- Tier 1 includes students in Transition Year 1 or 2 after exiting ESL services (T1/T2), students receiving indirect services after a waiver (W), or Long-Term English Learners (year seven or beyond without meeting exit criteria).
- Tier 2 includes students receiving direct services (coded “L”) who either have a most recent overall WIDA score above 3 or have received ESL services for more than 3 years.
- Tier 3 includes students receiving direct services (coded “L”) who have received ESL services for a maximum of 3 years and have a most recent overall WIDA score of 3 or lower.
EL tier to ULN mapping
- EL Tier 1 maps to ULN 2
- EL Tier 2 maps to ULN 4
- EL Tier 3 maps to ULN 5
For district leaders, this is a helpful planning lens: EL supports are not “one size fits all,” and TISA’s tier structure reinforces that intensity and duration of support matter. Just like special education, the expectation remains that teams follow legal requirements and best practices for identification, planning, and service delivery.
Characteristics of Dyslexia: what it is (and what it is not)
The “characteristics of dyslexia” designation is new in 2023-2024 and is captured in the same state system of record as IEPs and ILPs. Like IEPs and ILPs, it requires both an assessment and a plan.
- Assessment: A student’s composite score on a universal reading screener (URS) or an LEA’s Early Warning System, plus deficiencies in 50% or more of the grade-appropriate subtests outlined on the URS Minimum Matrix.
- Plan: ILP-D (Individualized Learning Plan – Characteristics of Dyslexia), which maps supports and requires agreement on the need by both the teacher and the parent/guardian.
Important notes from the quick guide:
- All students identified with characteristics of dyslexia are placed into ULN 2.
- Characteristics of dyslexia is not the same as a specific learning disability in reading.
- Students whose parent/guardian declines an ILP-D, or students who have (or later qualify for) an IEP for basic reading, reading fluency, or reading comprehension, do not also qualify for the characteristics of dyslexia ULN.
ADM values: why timing and changes matter
Once a student is categorized into a ULN, the student’s average daily membership (ADM) is used to determine the multiplier against the ULN weight and base amount. The ADM value applies from the time the student’s plan is in place under a given ULN until it is no longer assigned. If the student’s status changes during the year, the ULN and ADM value change as well.
From an operational standpoint, this reinforces the importance of timely plan implementation and accurate updates when services or eligibility change.
Monitoring and compliance: keep the basics strong
Tennessee will monitor identified subgroups for compliance with state and federal laws and regulations. This is already standard for students with disabilities and English Learners, and it will also apply to students served with an ILP-D for characteristics of dyslexia.
Monitoring reviews typically focus on:
- Appropriate identification practices
- Quality and completeness of service plans (IEPs, ILPs, ILP-Ds)
- Evidence that services were provided as planned
- Variations in identification rates and plan quality across schools or districts
As a special education director, I always encourage teams to view monitoring as a reason to build reliable systems, not as a reason to panic. When staffing shortages occur—especially in related services like speech-language pathology, OT, PT, counseling, or school psychology—districts can protect compliance by planning early, documenting consistently, and using qualified providers (including teletherapy) to maintain service continuity.
Where TinyEYE fits: supporting services when staffing is tight
ULNs are about matching supports to student needs. Districts still have to deliver what is written in the plan—whether that plan is an IEP, an ILP, or an ILP-D. When in-person hiring is difficult, online therapy services can help districts:
- Reduce missed sessions and compensatory service risk
- Stabilize schedules across multiple schools
- Support compliance with service minutes and documentation expectations
- Provide access to qualified clinicians when local shortages persist
The goal is always the same: students receive the services they need to access instruction and make progress, and districts can demonstrate that they implemented plans with fidelity.
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