This presentation will discuss the developing requirements for providing equitable services to private schools, and the differing standards in the Elementary and Secondary Education Act (ESEA) and the Coronavirus Aid, Relief, and Economic Security Act (CARES). Topics covered include the legislative language of both statutes, administrative and regulatory guidance, outcomes of litigation, and how States and districts can navigate that disagreement. The presentation will also discuss the differences between the two in terms of fiscal requirements and allowable uses of funds, and expectations for changes going forward.