7.3.2 The 504 Plan

Once a student is determined to be eligible under Section 504, the school district must provide a “free appropriate public education” (FAPE) to that student regardless of the nature or severity of the student’s disability. Under Section 504, FAPE consists of the provision of regular or special education and related aids and services designed to meet the student’s individual educational needs as adequately as the needs of nondisabled students are met.1

A group of people knowledgeable about the student, commonly referred to as the “504 Team,” meet to determine what accommodations and services the student needs in order to meet the student’s individual educational needs. While Section 504 does not explicitly require that a parent be part of the team making these decisions, it is considered best practice to invite parents and encourage them to participate in 504 Team meetings.

While Section 504 does not explicitly require a written plan to document the provision of FAPE to an individual student (unlike the IDEA requirement of an IEP), Louisiana schools are required to create a written plan referred to as an Individual Accommodation Plan (“IAP”) or, more commonly, a “504 Plan.”2  The 504 Plan should outline all the modifications, accommodations, and specialized services that will be provided to help a student learn and participate in school activities. Examples of common accommodations and services include extended time, preferential seating, extra breaks throughout the day, separate setting for tests, access to audiobooks, large-print texts, calculators, tutors, note-takers, one-on-one aides, assistive technology, counseling services, speech therapy, and occupational therapy. This list is not exhaustive, and all accommodations and services must be individualized to the student’s specific needs. While in theory a 504 Plan could include any accommodation or service needed to provide FAPE, the 504 Plan form used in Louisiana is really just check-boxes of standard accommodations such as some of the ones listed above. Additionally, unlike an IEP, the form does not contain sections to put detailed information about the child nor does it contain goals or mechanisms for measuring student progress.

Finally, as under the IDEA, students with disabilities under Section 504 must be educated with their non-disabled peers to the maximum extent appropriate.3  Section 504 regulations explicitly state that a student with a disability must be placed in the general education setting unless the school district can demonstrate that educating the student with a disability “in the regular environment with the use of supplementary aids and services cannot be achieved satisfactorily.”4  Placement is determined by the 504 Team.

• 134 C.F.R. § 104.33(b)(1).
• 2A blank Individualized Accommodation Plan (or 504 Plan) template is available on the LDE’s website. La. Dep’t of Educ., Section 504 Individual Accommodation Plan (June 14, 2019).
• 334 C.F.R. § 104.34(a).
• 4Id.