The ABCs of 504 Plans

Patricia Dean’s son, now 21, was born with cystic fibrosis which can cause numerous complications. A simple cold can quickly turn into a full lung infection requiring emergency care. He doesn’t have developmental or learning delays, so he didn’t qualify for specialized instruction in school.

Before her son started kindergarten, Dean contacted her neighborhood school district in northeast Phoenix to request a 504 plan, which stayed with him all through grade school, middle school, high school and college. The team changed over the years, but they usually met at the beginning of each school year to address questions and share information, and again in May to review the plan and see if changes were needed for the coming year.

Dean’s son’s 504 plan included time to take medication or clear his airway, along with bathroom breaks and allowances for food in the classroom when needed with medication. During flu season, Dean sent in extra supplies to help with classroom cleaning goals. The schools also adjusted attendance requirements so he wouldn’t be penalized for excessive absences due to health issues. If her son was sick or hospitalized during the school year, he had the option to complete shorter assignments.

Dean’s son graduated in 2019 and attended Arizona State University before transferring to Belmont University, a private college in Tennessee. She credits a collaborative approach for the success of his 504 plan, which also helped teach her son to advocate for himself when he started college. “We weren’t looking for anything outrageous,” she said, “but we wanted him to have what he needed to be successful.”

Students in public schools can be covered by 504 or IEP plans at no charge. While states receive additional funding for students with IEPs, they don’t receive funding for students with 504 plans. Also, IEP plan meetings must happen annually, and reevaluation is required every three years.

While 504 plans don’t have a specific timeline for review or even require that the plans be written down, best practices usually include at minimum a written plan with periodic review. Anyone who comes into contact with the student, including substitute teachers and bus drivers, will ideally be familiar with a child’s 504 plan accommodations.

To qualify for a 504 plan, a student needs to meet a definition set out by law which has three parts. The student must have a physical or mental impairment that substantially limits one or more major life activities. Having an impairment alone doesn’t qualify a student for a 504 plan; there must be a substantial limitation in one or more life activities. Also, 504 plans could be episodic or go into remission – for example, a student who goes into remission from cancer might no longer need a 504 plan.

After high school, a student’s 504 plan or IEP can be used to help develop accommodations at the college level or even in the workplace, said Tonya Haley, 504 coordinator with the Tucson Unified School District. While those documents are usually not called 504 plans in college or beyond, they are still enforced by Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Amendment Act (ADAAA).

Sandra Cortez-Brown has seen both sides of 504 plans as a parent and a school employee. As front-office administrator at an alternative school in the Flagstaff Unified School District, Cortez-Brown stores medications like EpiPen and communicates with school staff about student accommodations. Personally, her daughter started on a 504 plan and then progressed to an IEP at a charter school in Flagstaff when her needs included changes to instruction methods. Her daughter now attends Northern Arizona University.

She reminds parents that they can call a meeting anytime to review their child’s 504 plan. “It can be hard to follow up just one time per year,” she added. “If we see that the parent has buy-in, we at the school know we need to stay on top of it. Even short communication from the parent helps, whenever you can.”

While they might have different names, most colleges have disability resource offices. A student with a disability can contact the office at their college before attending to create an accommodation plan.

For example, Jarrett Stoll, disability resources coordinator at Coconino Community College, says a 504 plan, IEP or documentation from a medical provider can be used to create what they call a Letter of Accommodation to list needed supports for students at the college. While the accommodations might not be exactly the same as what the student had in high school, accommodations are required to be reasonable and appropriate.

Wendy Swartz has four adult children attending Pima Community College in Tucson, and all have plans with the college’s Access and Disability Resources department. In high school, her daughter had a 504 plan for ADHD and type 1 diabetes. The plan included extra time to complete tests and breaks to check her blood sugar, along with allowances to retake tests if her blood sugar was off before a test.

Her other three children had IEPs and now need support from home to access and organize their college assignments and communicate with college staff. College students must sign FERPA forms to allow parents access to information. While they’ve had mixed success, her students are all doing well this year. She hopes they will transfer to the University of Arizona later to complete bachelor’s degrees.

Colleges expect students to contact the disability resources office and advocate on their own, although parents can request to attend these meetings with their student. Swartz recommends that students or parents bring a list of suggested accommodations to these meetings, because the student will usually need to identify what support they think they’ll need in college. Students with specific medical needs might be able to find sample 504 plans online specific to their conditions. For example, the American Diabetes Association provides sample 504 plans for students with diabetes-related health care needs.

If a parent wants the school to consider implementing a 504 plan for their child, they can contact their child’s teacher to request a meeting to discuss their concerns. A meeting will usually include the child’s teacher and the school’s 504 plan coordinator. Other team members could include the school nurse or psychologist, depending on the child’s needs. Ideally, the team will devise a plan to help the student successfully access schoolwork.

Sometimes a student starts with a 504 plan, and will later need an IEP as they get older or their educational needs change. For example, Beth Bovee’s son started with a 504 plan for dyslexia. His school used information from a private evaluation and diagnosis to write his plan. Accommodations included shorter spelling tests and not being required to read out loud in class.

As the school year progressed, the team planned a meeting to determine if he should be reevaluated by the school, but these plans were postponed due to COVID. The meeting and evaluations happened in fall 2020, and her son began receiving IEP services that December.
Also, a student who doesn’t qualify for an IEP could still receive accommodations through a 504 plan. For example, Haley notes, a student with autism could have accommodations listed in a 504 plan such as sensory breaks or additional time for work or tests. “It would be specific to that child’s needs,” she added.

While they strive to make each plan individual, common accommodations seen in 504 plans include extra time to complete assignments, breaks during the school day for toileting needs or visiting the nurse, visual schedules, structured calendars or checklists, said Alicia Zelvis, director of exceptional student services with the Phoenix Elementary School District. Other accommodations can include audio books or voice recognition talk-to-text software or overlays for text that adapt print size or style.

In some cases, a chronic illness form can provide needed support instead of or along with a 504 plan or IEP. This form can also start the conversation about whether a 504 plan or IEP is needed. An EpiPen for allergies or time to take medication for type 1 diabetes could be addressed with a chronic illness form. A 504 plan could also be developed in conjunction with the form, Zelvis noted, to address accommodations like longer breaks, trips to the nurse’s office or longer transition times.

While private schools are not required to offer special education services or provide 504 plans, they might use similar documents that list accommodations for students with disabilities. Parents at private schools can contact the teacher to request a chronic illness form and bring documentation from their child’s doctor to encourage the private school to start the process.

What can parents do if they question how the school is carrying out their child’s 504 plan? They can start by contacting their school’s 504 plan coordinator to request a meeting. They can also contact their district’s 504 plan coordinator. Beyond that, if they have unaddressed concerns, they’d need to file a complaint with the Office of Civil Rights (OCR). OCR oversees violations to 504 plans, while students with IEPs receive protection from the Individuals with Disabilities Education Act (IDEA), and the Arizona Department of Education handles IEP complaints.
One common misconception is that a 504 plan can make a student do their work or guarantee good grades. “A 504 plan helps the student access a Free and Appropriate Public Education (FAPE) like an average student their same age,” Haley said. A 504 plan also does not guarantee that a student will progress to the next grade level.

Parents also need to know that a medical professional’s recommendations won’t automatically transfer to a 504 plan. “It’s important for parents to have the understanding that even though a medical professional may make recommendations, the school might have a structure to meet needs that’s different from what the medical professional suggests,” Zelvis said. “Even though it might not look exactly like what the professional recommended, it could still be a good solution. The school’s 504 plan coordinator will work with the parents to determine the best course of action for their child. Ultimately the plan is developed with input and guidance from many to help each child achieve success.

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