What Is a 504 Plan?

What Is a 504 Plan?

A 504 plan is the document a school uses to set out how it will meet a student’s disability-related needs under Section 504 of the Rehabilitation Act of 1973. Section 504 is a civil rights law. It bars discrimination against people with disabilities in any program that receives federal money from the U.S. Department of Education, which includes public school districts, colleges and universities, and state and local education agencies.

For students in public elementary and secondary schools, Section 504 does more than ban unfair treatment. It requires the district to provide a free appropriate public education (FAPE) to every qualified student with a disability, whatever the nature or severity of the disability. Under Section 504, that means regular or special education and related aids and services designed to meet the student’s needs as well as the needs of students without disabilities are met.

In practice, a 504 plan might give a student extra time on tests, a modified attendance policy, counseling or speech therapy, or an aide. Under Section 504, an appropriate education can mean regular classes, regular classes with supplementary services, or special education and related services.

Section 504 isn’t a funding law. Schools get no extra federal money for it, unlike special education under IDEA. That’s one reason the two systems look different. The IEP guide covers special education, and IEP vs 504 compares them side by side.

Who Qualifies for a 504 Plan

To get services under Section 504, a student must have a physical or mental impairment that substantially limits one or more major life activities.

Major life activities include caring for yourself, walking, seeing, hearing, speaking, breathing, learning, working, eating, sleeping, standing, reading, concentrating, thinking and communicating. They also include major bodily functions, such as the immune, digestive, neurological, respiratory and endocrine systems. The list isn’t exhaustive.

Some rules from the Department of Education’s Office for Civil Rights (OCR) that often decide a case:

• Good grades don’t rule a child out. A student who earns good grades may still have a disability and need services because of it.
• No diagnosis is required. Nothing in Section 504 requires a medical diagnosis before a school finds a disability, and a school can decide without medical tests. But a diagnosis alone isn’t enough either; the condition has to substantially limit a major life activity.
• Medication and devices don’t count against you. The school must judge the condition without the benefit of medication, hearing aids, mobility devices, assistive technology and similar measures. Ordinary eyeglasses and contacts are the exception.
• Conditions that come and go can count. An impairment that is episodic or in remission qualifies if it would substantially limit a major life activity when active.
• Temporary conditions are decided case by case, based on how long the impairment lasts and how much it limits the student.

OCR has published guidance on specific conditions, including anxiety disorders and food allergies, showing how they can qualify when they substantially limit a major life activity. Every student with an IEP is also protected by Section 504.

Examples of 504 Plan Accommodations and Services

There’s no fixed menu. OCR says any aid or service a student needs to be educated as well as classmates without disabilities can be part of the plan. Examples OCR gives:

Type of support	Examples from OCR guidance
Changes to policies (reasonable modifications)	Additional time to take tests; changing the absence policy when absences are due to the disability
Related aids and services	Counseling, speech-language therapy, occupational therapy, physical therapy
Personal support	A one-on-one aide; clean intermittent catheterization
Technology	Assistive technology
Health and safety (food allergy example)	An allergen-safe food plan, giving epinephrine according to a doctor’s orders even under a no-medication policy, letting the student carry medication, allergen-safe places to learn and eat
Classroom setting	Education in regular classes with supplementary services, or special education where needed

Section 504 doesn’t limit services to a short list. If a student needs speech therapy to receive an appropriate education, the school can’t refuse it just because that service is usually provided under IDEA.

A 504 plan is different from an individualized health plan (IHP). An IHP holds medical information: medication orders, symptoms to watch for, and steps to take. A 504 plan sets out the education services and changes the student is entitled to. A student with a medical condition may have both.

How to Request a 504 Plan

Every school district that receives federal funding and has 15 or more employees must name a Section 504 coordinator. Look for that person’s name in the district’s notice of nondiscrimination or on its website, or check with the school office.

1. Write a request for an evaluation. Send it to the 504 coordinator and the principal, date it, and keep a copy. For example: “My daughter, [name], has been diagnosed with ADHD, and it is affecting her ability to concentrate and finish work in class. I am requesting an evaluation under Section 504 to determine whether she is eligible for services.”
2. Give consent. OCR requires the school to get parental permission before an initial evaluation.
3. The evaluation. A group of people who know your child, understand the evaluation data and know the placement options reviews information from several sources: test scores, teacher input, physical condition, social and cultural background, and behavior. A doctor’s diagnosis can be one of those sources, along with any outside evaluation you share.
4. The eligibility decision. That group decides whether your child has a disability under Section 504 and what services are needed.
5. The plan. The services are written into the 504 plan. Every teacher responsible for your child must follow it; a teacher who doesn’t can put the district out of compliance.
6. Reevaluation. The school must reevaluate periodically and before any significant change in placement. OCR treats removing a student from school for more than 10 school days as a significant change.

Schools can’t put off an evaluation because a child is getting general interventions such as RTI or MTSS. If the school knows or suspects a disability, it must evaluate.

Keeping a 504 Plan Working

A plan only helps if it’s followed. A few habits make that more likely:

• Get a copy of the plan and read it with your child, in words your child understands, so your child knows what to expect in class and can speak up.
• Check in early each school year and after any schedule change. New teachers need to know the plan exists and what it requires.
• Write things down. If an accommodation isn’t being provided, email the teacher and the 504 coordinator with the date and what happened. Keep replies.
• Ask for a meeting when needs change. A new diagnosis, a hospital stay or a drop in grades can all be reasons to look at the plan again.

When Discipline Is Involved

Section 504 requires the school to reevaluate before a significant change in placement. OCR counts an exclusion from school of more than 10 school days as a significant change. It also counts moving a student to a different type of program, or ending or significantly cutting a related service. If your child faces a long suspension or a program change, ask the 504 coordinator in writing when the reevaluation will happen.

Your Rights if You Disagree With the School

Section 504 requires every district to have procedural safeguards for parents:

• notice explaining decisions about evaluation and placement;
• the chance to review your child’s records;
• an impartial hearing, where you can take part and be represented by a lawyer;
• a review procedure after the hearing.

If you disagree with what’s in the plan, such as which services your child gets, the route is a due process hearing under the district’s procedures. OCR generally does not review the content of an individual 504 plan.

If the problem is discrimination or a process failure, such as refusing to evaluate, ignoring the plan or retaliating against you, you can file a complaint with OCR:

• Deadline: within 180 days of the discrimination, unless OCR extends the time.
• How: through OCR’s online Complaint Assessment System or its fillable PDF complaint form, both linked from ed.gov’s file a complaint page.
• Retaliation: schools can’t intimidate, threaten or punish anyone for using Section 504 rights.

You can also file a private lawsuit without going to OCR first. For help weighing your options, contact your state’s Protection and Advocacy agency. The federal Administration for Community Living lists 57 of them, one in every state and territory, offering information, advocacy and representation. Find yours in the state guides, such as California or Florida.

504 Plans After High School

Section 504 still protects students in college, but there’s no FAPE and no 504 plan. Colleges must provide academic adjustments and auxiliary aids and services so students with disabilities have an equal opportunity, unless a change would fundamentally alter the program or impose an undue burden. Students ask through the college’s disability services office.

At work, the ADA’s workplace accommodation rules take over, and your rights under the ADA explains the wider law. For young adults planning for work, vocational rehabilitation can help, and SSI for children explains federal disability payments for children.

Frequently Asked Questions

Can a Student With Good Grades Get a 504 Plan?

Yes. The U.S. Department of Education says a student who earns good grades may still have a disability that substantially limits a major life activity and may need services because of it. Grades alone don't rule a child out.

Does a Temporary Injury Qualify for a 504 Plan?

Sometimes. OCR says a temporary impairment counts only if it's severe enough to substantially limit a major life activity for an extended period, decided case by case. The school weighs how long the impairment lasts and how much it limits the student.

Can the School Delay a 504 Evaluation While Trying Interventions?

No. Section 504 prohibits delaying or denying an evaluation of a student known or believed to have a disability because the student is receiving RTI, MTSS or similar supports.

What Is the Difference Between a 504 Plan and a Health Plan?

An individualized health plan (IHP) holds medical information, such as medication orders and what to do if symptoms appear. A 504 plan sets out the education services and changes the student is entitled to. A student can have both.

Does a 504 Plan Follow My Child to a New District?

The new district should review the plan. If a knowledgeable group there finds it appropriate, the district must carry it out. If not, it must evaluate your child and decide what program is appropriate.

Do 504 Plans Apply in College?

Section 504 still applies, but colleges don't write 504 plans. They must provide academic adjustments and auxiliary aids so students have an equal opportunity, unless a change would fundamentally alter the program or impose an undue burden. Contact the college's disability services office.

More on Rights and Daily Life

• ADA RightsWhat the ADA covers and how to file a complaint
• Workplace AccommodationsReasonable accommodations at work: asking, the interactive process and examples
• What Is an IEPIndividualized education programs under IDEA: eligibility, evaluation, the team and your rights
• IEP vs 504IEPs and 504 plans side by side: laws, eligibility, services and protections
• HousingFair housing protections, reasonable accommodations and federal housing help
• Parking PlacardsDisability parking placards and plates: who qualifies and each state's application

This guide explains official rules in plain language. It isn't legal advice, and only the agency that runs a program can decide your case.

Sources

1. U.S. Department of Education OCR: Section 504 FAPE frequently asked questions
2. U.S. Department of Education OCR: Disability discrimination FAQs
3. U.S. Department of Education OCR: Disability discrimination, overview of the laws
4. U.S. Department of Education OCR: File a complaint
5. eCFR: 34 CFR Part 104, Section 504 regulations
6. eCFR: 34 CFR 100.7, complaint timing (applied to Section 504 by 34 CFR 104.61)