What Is a 504 Plan? Eligibility, Process, and Common Questions

As an educational advocate, I often help families understand 504 plans—what they are, who qualifies, and how the process works. 504 plans, protected under Section 504 of the Rehabilitation Act of 1973, provide accommodations to ensure students with disabilities have equal access to education. If you’re exploring whether your child may need a 504 plan or have questions about the process, this guide covers everything you need to know, including answers to common questions.

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What Is a 504 Plan?

A 504 plan is a legal document that ensures students with disabilities receive accommodations to access learning on the same level as their peers. It removes barriers that may prevent a child from fully participating in school. To qualify, a student must have a physical or mental impairment that substantially limits one or more major life activities, such as:

• Learning, reading, concentrating, or thinking

• Walking, seeing, hearing, or breathing

• Communicating or interacting with others

• Performing daily tasks or managing emotions

504 plans do not provide specialized instruction (like IEPs) but offer accommodations such as:

• Classroom supports: Checklists, extra time on tests, or reduced homework load

• Health-related accommodations: Access to medication, water breaks, or modified PE requirements

• Assistive technology: Use of laptops, audiobooks, or speech-to-text programs

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How Does the 504 Process Work?

The 504 process typically involves five steps:

Referral or Request

• A parent, teacher, or school staff member can request a 504 evaluation if they suspect a student’s disability is affecting their access to education.

• Schools may also initiate the process if they observe learning or participation barriers.

  
  

Evaluation

• Schools review existing documentation (e.g., medical records, teacher observations, or past assessments).

• Formal testing is not required for 504 eligibility—existing records are often sufficient.

• If there is limited documentation, the school may conduct informal assessments or observations.

  
  

Eligibility Decision

• The 504 team—which may include parents, teachers, school counselors, and the school’s 504 coordinator—meets to determine eligibility.

• The team decides if the student’s disability substantially limits their ability to access education.

  
  

504 Plan Development

• If eligible, the 504 team creates a plan outlining the accommodations the school will provide.

• The plan is shared with all relevant staff to ensure consistent implementation.

  
  

Review and Reevaluation

• 504 plans are reviewed annually to confirm they remain appropriate.

• Families can request a meeting at any time if there are concerns.

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What Disabilities Qualify for a 504 Plan?

Section 504 has a broad definition of disability, making more students eligible compared to IEPs. Common qualifying conditions include:

Neurodevelopmental and Mental Health Conditions

• ADHD: Often impacts focus, attention, and executive functioning.

• Anxiety disorders: May affect participation, attendance, or emotional regulation.

• Depression or mood disorders: Can impact energy, motivation, or social interaction.

• PTSD or trauma-related conditions: Students with emotional regulation challenges may qualify.

  
  

Learning and Cognitive Disabilities

• Dyslexia, dyscalculia, or dysgraphia: Students with mild learning challenges may receive accommodations.

• Processing disorders: Auditory or visual processing difficulties that affect comprehension.

• Executive functioning challenges: Issues with organization, time management, or working memory.

  
  

Physical and Chronic Health Conditions

• Chronic illnesses: Diabetes, epilepsy, asthma, or Crohn’s disease.

• Mobility impairments: Conditions affecting movement (e.g., cerebral palsy, muscular dystrophy).

• Hearing or vision impairments: Students needing assistive technology or seating accommodations.

• Traumatic brain injuries (TBI): May require temporary or ongoing supports.

  
  

Temporary Disabilities

• Students with temporary disabilities may also qualify if their condition significantly impacts a major life activity, such as:

  • Recovery from surgery or injury (e.g., broken limbs).

  • Concussion symptoms affecting stamina or cognition.

  • Medical conditions requiring accommodations (e.g., modified PE).

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Common Questions About 504 Plans

1. Who Has to Be at a 504 Meeting?

There are no federal requirements about specific team members for 504 meetings, but best practices typically include:

• Parents or guardians (while not mandatory, schools are encouraged to include them)

• General education teacher(s)

• School counselor or psychologist

• 504 coordinator or administrator

• Specialists or nurses (if the student has medical needs)

Parents have the right to participate, and while their attendance is not legally required, schools should make reasonable efforts to include them.

2. Can the School Create a 504 Plan Without Parent Input?

Technically, yes—but it’s not best practice. Schools are not legally required to include parents in 504 meetings the way they are for IEPs. However, they must notify parents if a 504 plan is developed or revised. Even though parental input is not mandatory, collaboration is highly encouraged. If the school creates a 504 plan without your involvement, you have the right to:

• Request a meeting to discuss the plan.

• Review the accommodations and request modifications.

• File a grievance or request a due process hearing if you disagree with the plan.

  
  

3. Do Schools Have to Test for a 504 Plan?

No, formal testing is not required for a 504 plan. Unlike IEPs, which require a comprehensive evaluation, 504 eligibility can be determined using existing records. These may include:

• Medical records or diagnoses

• Previous school evaluations

• Teacher observations and reports

• Parent-provided documentation

In some cases, the school may conduct informal assessments (e.g., classroom observations, behavior rating scales), but they are not required to conduct formal evaluations.

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Key Differences Between 504 Plans and IEPs

It’s easy to confuse 504 plans with IEPs, but they serve different purposes:

• 504 Plans: Provide accommodations only (no specialized instruction) to remove barriers, ensuring students have equal access to learning. However, they do not modify the curriculum—students are still expected to meet the same academic standards as their peers.

• IEPs: Include specially designed instruction and related services tailored to the student’s unique needs. IEPs may include curriculum modifications, such as adjusted learning expectations or alternative assessments.

504 plans apply to public, private, and charter schools (as well as colleges), while IEPs are specifically for public schools, although they can be adjusted to an accommodations plan in college.

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Advocating for Your Child

If you believe your child may benefit from a 504 plan, it’s important to know your rights. Schools are required by law to provide reasonable accommodations to ensure students with disabilities have equal access to education. If you’re seeking detailed legal information on 504 plans, I recommend visiting Wrightslaw—a trusted resource on special education law.

For parent-friendly guidance and additional resources, check out the Parent Hub—a platform that offers practical support and information.

If you need help navigating the 504 process, advocating for accommodations, or understanding the differences between 504 plans, IEPs, and IFSPs, contact Alexa's ABCs for a free consultation to learn how she can help.