504 Regulations: A Review

Section 504 of the Rehabilitation Act was first introduced in 1973 to ensure that handicapped students received a free and appropriate education (FAPE) without discrimination.

While the law has remained largely unchanged over the years, the need for 504 regulations is as relevant as ever. Here are some key 504 guidelines:

When in doubt, follow IDEA timelines

504 law does not include specific timeframes for when evaluations or plan reviews must be completed. Instead, the law uses broad language that plans must be reviewed “periodically”. Commonly, the Office of Civil Rights (the governing entity for 504) encourages that school districts follow the timelines specified in the Individuals with Disabilities Education Act (IDEA) for consistency and best practice.

Document, Document, Document

Even though 504 plans are not as extensive as IEPs, school districts must record how the student’s disability affects a major life activity and how the district will provide FAPE. A common mantra is “If it’s not documented, it didn’t happen”. This is especially true when recording the specific service(s) or accommodation(s) the student will receive, including frequency, location, and method of delivery. Clear documentation ensures that all parties know exactly what will (or will not) be provided to the student or on behalf of the student.

Follow Through (Ensure Compliance)

Once documentation is complete, districts must take the plan and put it into action. The first step of implementing a 504 plan is to provide a copy of the 504 plan or 504 Summary to parents, applicable staff members, and even the student, so that everyone is aware of how the plan should be implemented. After the initial plan is shared, many districts self-monitor compliance on an ongoing basis by asking staff to complete accommodation checklists or service delivery logs (documenting when and how accommodations or services were provided on specific dates). While additional documentation or “checks” in the process are not required by Section 504 law, many districts consider this best practice and an assurance that the student is receiving FAPE.

For additional 504 information, check out these resources:

U.S. Department of Education: FAQs About 504  https://www2.ed.gov/about/offices/list/ocr/504faq.html#safeguards

U.S. Department of Education: Office of Civil Rights - Overview of the Laws https://www2.ed.gov/policy/rights/guid/ocr/disabilityoverview.html

Understood.org: The Difference Between IEPs and 504 Plans https://www.understood.org/en/school-learning/special-services/504-plan/the-differencebetween-ieps-and-504-plans


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