An Introduction to 504 Plans: What They Are and How They Can Help Students Succeed

Ahhh the ever mysterious 504 plan. In many schools and school districts if you ask a teacher or school personnel about one, it seems to be something that no one can ever really give you a straight answer about and a topic that many even may avoid, embarrassed that they have no idea how to answer questions about it. Then in other school districts, teachers are all too familiar with 504 plans and even frustrated at the number of students who have them, feeling they are overused and frequently do not work to the benefit of the student.

Regardless of how you feel about 504 plans as an educator, the overwhelming majority of parents (and many teachers) either are totally in the dark about them or feel like they are.  So, I wanted to take some time to shine some light on this topic to help everyone gain a better understanding of what a 504 plan is and the process in which a student may receive one along with potential pros and cons of them that have surfaced over the years.

What is a 504 plan? 

A 504 is a plan that a student with a disability can have in place at school to remove barriers they may face in learning. A 504 does not change the instruction that a student receives, but rather provides accommodations that support their learning and ensure they do not face discrimination based on their disability. Students with disabilities are protected from discrimination under Section 504 of the Rehabilitation Act of 1973. 

What is the difference between a 504 plan and an IEP?

You may be thinking, Isn’t that what special education services and IEPs are for?, and yes, you are correct.  However not all students with disabilities qualify for or need special education services.  But just because they may not need individualized instruction and services, doesn’t mean they don’t need other accommodations to help them be successful at school and have the same opportunities as their peers. So, what are the differences between an IEP and a 504 plan?

An IEP provides individualized instruction, meaning that the student receives instruction tailored to their individual needs by a special education teacher.  When an IEP is written, a special education teacher analyzes where the student is academically considering any gaps in their knowledge and writes long-term goals and short-term objectives based on skills that are the most crucial for students to master.  IEPs also provide special education students with accommodations, extra supports to their learning experience, and modifications, which can include changing the content, curriculum and/or expectations to better match the student’s abilities.  In addition, goals, objectives, accommodations and modifications are not only limited to academics but can also include communication, social/emotional, functional and physical deficits.  If a student is eligible to receive special education services in one or more of these areas, a provider in that field will also evaluate the student and write appropriate goals and objectives.  A student’s progress on IEP goals and objectives are tracked by the special education teacher and other corresponding providers and goal progress reports are sent home to parents at least as often as report cards are sent home.  IEPs are required by law to be reviewed and revised annually at an IEP meeting that includes parents and other members of the student’s “IEP Team.”

A 504 Plan provides accommodations only and does not change the instructional content, assignments or expectations. Instead, the accommodations are put in place to remove barriers a student may face due to a disability and provide them with equal access to learning and demonstrating their knowledge without altering the curriculum.  Before a 504 plan is written, the student is evaluated by knowledgeable persons, usually called a “504 Team” to determine if a student is eligible and, if so, what accommodations they need. A 504 Plan itself is usually just a straightforward document listing the student’s information along with the accommodations they should receive and the manner in which the accommodations should be implemented.  Classroom accommodations are carried out by the general education teacher and do not involve services from a special education teacher or any other provider.  Unlike IEP’s, there is no legal requirement to review 504 Plans annually and the regulations only state that they should be reviewed “periodically.”

What types of accommodations does a 504 plan include?

Since the goal of a 504 plan is to remove barriers a student with a disability may face in learning, the accommodations provided will depend on the needs of the student. With the vast and diverse range of disabilities that students can have, there is an endless number of possible accommodations that are possible. Here are some of the more common accommodations used on 504 Plans:

• Seating near the front of the classroom or near the teacher
• Extended time allowances for assignments and tests
• Allow assignments to be typed instead of written
• Increase distance between desks
• Break longer assignments into smaller parts
• Permit assignments to be corrected or resubmitted
• Allow breaks during tests
• Tests given in a quiet environment with limited distractions
• Allow and assign extra credit assignments if needed
• Give directions for assignments and tests both written and orally and clarify if needed.
• Verbal testing

Again, keep in mind that a 504 does not change the instruction a student will receive, and their coursework will be the same as their peers.

Examples of 504 plan accommodations in action

Example #1: Tyler is a bright student with ADHD.  He is able to learn and apply new skills at his grade level but struggles in the classroom to pay attention during instruction and maintain focus when completing assignments.  As a result, Tyler is easily distracted during class missing key parts of the teacher’s instruction.  When presented with work to complete based on the lesson he is unaware or confused about expectations and directions and has no idea what to do or how to do it.  In addition, many times Tyler’s work and assessments are incomplete because he either carelessly rushes through and skips parts of it or is not able to maintain focus and takes too long to complete it. The following accommodations could be put in place to help Tyler:

• Seating near the front of the classroom or near the teacher to increase focus
• Tests given in a quiet environment with limited distractions
• Extended time allowances for assignments and tests
• Provide a concrete representation of time allowed to complete assignments and tests (e.g. Sand timer, Time timer)

Example #2: Hunter is a 6th grade student with autism spectrum disorder.  As a younger child, cognitive developmental delays made it more difficult for him to process, comprehend and learn new information at the same rate as his neurotypical peers. As a result, Hunter was significantly behind peers in reading, writing and math and qualified for special education services in these areas.  Through years of hard work, great teachers and supportive parents, Hunter is now academically grade-level proficient.  In addition, Hunter has begun to advocate for himself and expressed to his parents that he no longer wishes to be pulled out for special education services. He feels he no longer needs the individualized instruction and when pulled out is missing other valuable classroom instruction and opportunities.  While his parents agree with Hunter’s points, they are concerned that Hunter may still need some supports in the classroom to be successful. After a review of Hunter’s progress and academic abilities, the IEP team agrees to dismiss Hunter from special education services, but still provide him with the following accommodations in a 504 plan:

• Extended time allowances for assignments and tests
• Permit assignments to be corrected or resubmitted
• Give directions for assignments and tests both written and orally and clarify if needed.
• Monitor independent work to check for understanding

Example #3: Maya is a student with a mild hearing loss. She's eager to learn and capable of comprehending & applying new skills, but she has trouble hearing soft voices and following conversations. Because of this, following along with classroom instruction and concentrating on academic tasks can be difficult, especially when background noise is present. The following accommodations could be put in place to help Maya:

• Seating near the front of the classroom or near the teacher
• Extended time allowances for assignments and tests
• Captioning on instructional videos
• Checks for understanding instruction, directions and expectations
• Tests taken in a quiet environment

Does my child qualify for a 504 plan?

If a student has a physical or mental disability that in some way prevents them from learning and progressing in their education, they may qualify for a 504 plan.  Section 504 of the Rehabilitation Act of 1973 has a very broad definition of disability defining it as, “a student who: (1) has a physical or mental impairment that substantially limits a major life activity; (2) has a record of such an impairment; or (3) is regarded as having such an impairment (U.S. Department of Education, Office for Civil Rights, Parent and Educator Resource Guide to Section 504 in Public Elementary and Secondary Schools (December 2016).  The “major life activities” referenced in the definition can include many physical and mental activities.  The Parent and Educator Resource Guide to Section 504 offers the following list as examples:

• Caring for oneself
• Bending
• Performing manual tasks
• Speaking
• Seeing
• Breathing
• Hearing
• Learning
• Eating
• Reading
• Sleeping
• Concentrating
• Walking
• Thinking
• Standing
• Communicating
• Lifting
• Working 

Some schools may have a more extensive list of “major life activities,” for you to reference or that they consider when evaluating a student, but also know that there is not a definitive list that can be used to disqualify a student from receiving a 504 plan.  In other words, the school cannot say that a student does not qualify because the “major life activity” that is impacted is not on their “list”.

How can I request a 504 plan for my child or student and what is the process for consideration?

A parent, teacher, other school staff member, health care provider or therapist can request that a student be evaluated for a 504 plan.  We recommend making a written request so that a record of the communication can be retained.  Once the request is made, the school must conduct, at no cost to the parent, an evaluation of the student to determine if there is a need in a timely manner.  The evaluation is usually completed by a group of knowledgeable people, often referred to as a “504 Team” and must consider multiple sources in making a decision. It is also important to note that a student’s grades alone cannot determine whether or not they are eligible for a 504 plan.  Again, referencing The Parent and Educator Resource Guide to Section 504:

“A student with a disability may achieve a high level of academic success but may nevertheless be substantially limited in a major life activity due to the student’s impairment because of the additional time or effort the student must spend to read, write, or learn compared to others.”

On the other hand, a student may have low academic achievement as indicated by their grades or GPA that is not related to having a disability.  

Are teachers and schools against 504 plans?

Many teachers and school administrators may have strong opinions about 504 plans and there are several reasons for this. Unlike special education services, schools do not receive additional funding for students with 504 plans, but the accommodations needed can be expensive or require additional staff members. Without additional resources, it can be difficult for the school or teacher to meet the demands of a 504 plan - sometimes multiple 504 plans for multiple students - while also ensuring quality instruction for the entire class. This doesn't mean that they are against 504 plans, but rather that they want to take special care to make sure that a 504 is the right option with the right accommodations for a student. 

When a 504 is not the right option. Since 504 plans do not provide individualized instruction, they do not help a student who is lacking or behind in a skill.  However, many times 504 plans are misused or overused in education when what a student actually needs is individualized instruction (i.e. an IEP).  If a student does not read at the same level as their peers and is significantly behind, no accommodation is going to magically fix that.  

When a 504 does not have the right accommodations. Finally, many 504 Plans have been put into place have accommodations that unfortunately enables a child’s overdependence on adults instead of enabling them to become a more independent learner.  For example, a child with ADHD that struggles with executive functioning skills who is provided with the accommodation of the teacher writing down all of their assignments for them in an agenda is not learning to become more independent but rather learning to be more dependent on adults and let others act as their executive functioning. Writing down the assignments themselves actually activates their nonverbal working memory and serves to further develop their executive functioning. A more appropriate accommodation would be to provide scheduled time each day to write down homework and assignments in an agenda.  

Overall, a 504 plan serves as a vital tool in ensuring that students with disabilities have equal access to education by removing barriers that may hinder their learning. While it may not provide individualized instruction like an IEP, it offers crucial accommodations tailored to the specific needs of each student. When used correctly, a 504 Plan can empower students and enable them to thrive academically.