504manual 1

A Parent & Educator Guide
to
Free Appropriate
Public Education
(under Secti on 504 of the Rehabilitation Act of 1973)

J im Rich
Director of Special Services
Puget Sound ESD

J uly, 2010

Table of Contents

Introduction i

Acknowledgements ii

A Parent and Educator Guide to FAPE under Section 504 1 - 6

IDEA and Section 504 Comparison 7 - 10

Section 504 Process Flow Chart 11

Section 504 Process 12 - 13

Section 504 FAQs 14 29

Resources on Section 504 30

APPENDIX A Sample Section 504 Board Policy 31

APPENDIX B Sample Complaint Procedure 32

Sample Section 504 Complaint Form 33

Sample Section 504 Impartial Hearing Procedure 34

APPENDIX C Sample Section 504 Coordinator Job Description 35

Sample Section 504 Building Designee Job Description 36

APPENDIX D Sample Section 504 Forms

Referral Form 37
Notice of Action/Parent Consent 38
Parent Rights 39
Eligibility Form 40
Section 504 Plans 41 42
Section 504 Manifestation Report 43

APPENDIX E Sample Accommodations 44 65
i

Introduction

Section 504 of the Rehabilitation Act of 1973 continues to be a topic of interest for parents and
school districts in Washington State. Many questions have arisen regarding the relationship
between the ADA, Section 504, and the IDEA. School administrators have asked for examples
of Section 504 policies and procedures that meet the requirements of the law and can be
efficiently and effectively implemented.

To address these issues, after consulting with Region X Office for Civil Rights, Puget Sound
ESD has developed this document to assist school districts in serving their students with
disabilities in a way that assures a quality education that is in compliance with state and federal
laws. This document includes a parent and educator guide to FAPE under Section 504,
highlights of the major differences between Section 504 and the IDEA, provides sample policies
and procedures including forms, a detailed FAQ and sample accommodations.

This document was originally written in November 2002. It is being revised and updated now to
comply with the Americans with Disabilities Act Amendments Act of 2008, which became
effective on January 1, 2009, and broadly interprets who qualifies as a student with a disability
under Section 504.
ii

Acknowledgements
Various materials from school districts in the state of Washington and OSPI have been used in
the development of this reference document. Puget Sound ESD gratefully acknowledges the
following school districts for sharing with us their Section 504 materials for use in the
development of this publication:

South Kitsap School District
Highline School District
Kent School District
Mount Vernon School District
Issaquah School District.

This manual is distributed for informational and resource purposes only and does not represent
legal advice. Consult with your own counsel prior to taking any final action.

This manual or any part of the manual may be reproduced for educational purposes without
permission of the authors.

1
A Parent & Educator Guide to Free Appropriate Public Education
Puget Sound ESD, Office of Special Services, July, 2010

A Parent and Educator Guide
to
Free Appropriate Public Education
(Under Section 504 of the Rehabilitation Act of 1973)

Introduction
This guide describes the requirements of Section 504 of the Rehabilitation Act of 1973 as it
applies to a public school districts duty to provide a free appropriate public education (FAPE) to
students with disabilities. This guide is designed to assist parents and educators to understand
what Section 504 is, what it requires in terms of FAPE, and how it should be implemented.

What is Section 504?
Section 504 is a federal civil rights law that is designed to eliminate disability discrimination in
programs and activities that receive federal funds. Since all public school districts receive
federal funds, all public school districts must comply with Section 504. Under Section 504,
denying a disabled student a free appropriate public education constitutes disability
discrimination.

Who is a Disabled Student Under Section 504 for Purposes of FAPE?
A school-aged student is a disabled student under Section 504 for purposes of FAPE if the
student:

Has a physical or mental impairment
Physical or mental impairment means any physiological or psychological disorder or
condition. The definition of physical or mental impairment under Section 504 is broad,
includes students with life threatening health conditions (conditions that will put a student in
danger of death during the school day if a medication or treatment order and a nursing plan
are not in place), and is not limited to any specific diseases or categories of medical
conditions.

The determination of whether a student has a physical or mental impairment that
substantially limits a major life activity must be made on the basis of an individual inquiry. A
physical or mental impairment may be any physiological disorder or condition, cosmetic
disfigurement, or anatomical loss affecting one or more of the following body systems:
neurological; musculoskeletal; special sense organs; respiratory, including speech organs;
cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and
endocrine; or any mental or psychological disorder, such as mental retardation, organic brain
syndrome, emotional or mental illness, and specific learning disabilities. The list of specific
diseases and conditions that may constitute a physical or mental impairment is not exhaustive
because of the difficulty of ensuring the comprehensiveness of such a list.

2

That substantially limits
There is no single formula or scale that measures substantial limitation. A physical or mental
impairment substantially limits a major life activity for a student if the impairment
substantially limits the students ability to perform a major life activity as compared to the
students non-disabled age/grade peers. An impairment need not prevent, or significantly or
severely restrict, a student in performing a major life activity to be considered substantially
limiting.

As a general rule, a student with a physical or mental impairment who is able to participate in
or benefit from a districts education program, (e.g. attend school, advance from grade to
grade, and meet the standards of personal independence and social responsibility expected of
his or her age and cultural group) without the provision of special education or related aids or
services, is not a disabled student under Section 504 for purposes of FAPE.

One or more major life activities
Major life activities include functions such as caring for ones self, performing manual tasks,
walking, seeing, hearing, speaking, breathing, learning, and working. Major life activities
also include other general activities such as eating, sleeping, standing, lifting, bending,
reading, concentrating, thinking, and communicating. In addition, major life activities
include major bodily functions such as the functions of the immune system, normal cell
growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and
reproductive functions. The above list of major life activities is not exhaustive; a major life
activity or function not specifically listed above may be a major life activity. For example,
the ability to meet the standards of personal independence and social responsibility expected
of ones age and cultural group is a major life activity for a school-aged student. In addition,
the ability to participate in and benefit from school is a major life activity for a school-aged
student.

The meaning of disabled student under Section 504 was substantially
broadened by the Americans with Disabilities Amendments Act of 2008, which
became effective on January 1, 2009. Congress amended the ADA in 2008 in the
following specific ways to create clear, strong, consistent, enforceable standards to broaden
who qualifies as a disabled person under Section 504 and the ADA. Here is what the changes
mean for schools:

1. Interpret the term physical or mental impairment broadly: The term
physical or mental impairment is not limited to any specific diseases or categories of
medical conditions;

2. Interpret the term substantially limits broadly: An impairment need not
prevent, or significantly or severely restrict a student in performing a major life activity
to be considered substantially limiting. Compare a student to his or her non-disabled
age/grade peers to determine whether an impairment substantially limits a major life
activity for the student;

3

3. Interpret the term major life activities broadly: Just about any activity that is of
importance to a school-aged students daily life now qualifies as a major life activity
under Section 504 and an impairment that substantially limits one major life activity need
not limit other major life activities in order to be considered a disability under Section
504 or the ADA;

4. Disregard mitigating measures used by a student: Mitigating measures used by
a disabled student to manage his or her impairment or lessen the impact of his or her
impairment (e.g. medication, medical devices, related aids and services, etc.) should be
disregarded when determining whether a students impairment constitutes a disability
under Section 504 or the ADA;

5. Consider whether a temporary impairment is a disability: A temporary
impairment (with an actual or expected duration of six months or less) is a disability
under Section 504 and the ADA if it is severe enough that it substantially limits a major
life activity for a student. The duration (or expected duration) of the impairment and the
extent to which it actually limits a major life activity for a student should be the key
considerations; and

6. Consider whether an impairment that is episodic or in remission is a
disability: An impairment that is episodic or in remission (e.g. epilepsy, cancer, bipolar
disorder, etc.) is a disability under Section 504 and the ADA if it substantially limits a
major life activity for a student when active.

What is a Free Appropriate Public Education Under Section 504?
A free appropriate public education is an education that is designed to meet a disabled students
individual educational needs and is based upon procedures that satisfy Section 504s
identification, evaluation, placement, and due process requirements. An appropriate education
can consist of education in regular classes, education in regular classes with related aids or
services, special education, or a combination of such services. The definition of related aids and
services under Section 504 is broad and includes any service that a student needs to participate in
and benefit from a districts education program. Related aids and services include but are not
limited to the following: school health services; counseling; environmental, instructional and
behavioral accommodations; and transportation.

What Does Appropriate Mean?
Appropriate means designed to meet the individual educational needs of a disabled student as
adequately as the needs of non-disabled students are met. It does not mean that a district must
maximize a disabled students potential or provide the best education program that it can
design for a disabled student. It means that a district must provide sufficient individualized
services to enable a disabled student to receive educational benefit (i.e., not maximum benefit,
not minimal benefit, some benefit).

4

Who Can Refer a Student for a Section 504 Evaluation?
Any person can refer a student for evaluation under Section 504. Parents, guardians, and school
staff should refer a student for evaluation if they know or suspect that, due to a disability, the
student needs special education or related aids or services to participate in or benefit from a
districts education program.

What Should a District Do When it Receives a Section 504 Referral?
After receiving a Section 504 referral, a district should decide whether to evaluate the student
and must notify the students parent or guardian of its decision. As a general rule, a district
should evaluate a referred student if the district knows or suspects that the student, because of a
disability, is not attending school, advancing from grade to grade, meeting the standards of
personal independence or social responsibility expected of his or her age or cultural group, or
otherwise needs special education or related aids or services to participate in or benefit from the

What is an Evaluation Under Section 504?
Evaluations under Section 504 are individually designed. A Section 504 evaluation may be
broad (including aptitude and achievement data, medical and psychological data, social and
cultural information, and more) or narrow (medical data). A Section 504 evaluation may be
conducted by a district or conducted by an outside agency and reviewed by a district. It is the
responsibility of a district to determine the scope of each students Section 504 evaluation. As a
general rule, the scope of a students Section 504 evaluation should be broad enough to enable
the district to determine whether a student is disabled under Section 504 and, if so, what special
education and related aids and services the student needs to participate in and benefit from the

What Placement Procedures Does Section 504 Require?
Placement under Section 504 means services the regular or special education and related aids
and services that a student needs to receive FAPE. Placement decisions under Section 504 must
be documented, based upon a students evaluated needs, and made by persons knowledgeable
about the student, the meaning of the students evaluation data, and placement options. In
addition, placement decisions must ensure that disabled students are educated in the least
restrictive appropriate placement.

What Due Process Rights Do Parents and Guardians Have Under Section 504?
Section 504 gives parents and guardians the right to challenge district decisions regarding the
identification, evaluation and educational placement of their child. Under Section 504, a district
must notify a students parent or guardian before it takes any action regarding the identification,
evaluation, or placement of their child and provide the parent or guardian an opportunity to
challenge the action if they disagree. Any action includes a decision not to evaluate a student
and denial of placement. The minimum necessary due process rights include: prior notice of any
action; a right to inspect records; an impartial hearing with a right to representation by counsel;
and a review procedure.

5

Must Parents or Guardians Consent Prior to Initial Evaluations and Initial
Placements Under Section 504?
Yes. Under Section 504, a district must obtain parent or guardian consent in two circumstances:
before a childs initial evaluation (the first time a child is evaluated by any district) and before a
childs initial placement (the first time a child is placed on a Section 504 Plan in any district). If
a parent or guardian refuses consent to either initial evaluation or initial placement, a district
may, but is not required to, initiate a Section 504 due process hearing to override the refusal to
consent. A district must notify a parent or guardian, but need not obtain consent, before it re-
evaluates or significantly changes a students placement.

What is a Section 504 Plan?
A Section 504 plan is a written plan that describes the educational and related aids and services
that a district determines a disabled student needs to receive a FAPE. The content of a Section
504 Plan is fluid and may change within a school year or between school years as a students
needs and services change. A district must provide the services identified in a students Section
504 plan.

For a student whose only disability is a life threatening health condition, an individual health
plan or an emergency or nursing care plan may serve as the students Section 504 plan. The
process that a district follows to develop an individual health plan or an emergency or nursing
care plan to meet the needs of a disabled student must be based on evaluation and placement
procedures that satisfy the requirements of Section 504, and must provide procedural due process
to the students parent or guardian.

What Is a Section 504 Team?
A Section 504 team makes decisions regarding the evaluation and placement of students under
Section 504. For example, a Section 504 team determines the scope of Section 504 evaluations,
decides which students are disabled under Section 504, develops Section 504 Plans, and makes
manifestation determinations for purposes of disciplinary exclusion from school. A district
may have a district-level Section 504 team that makes district-level Section 504 decisions,
building-level Section 504 teams that make building-level Section 504 decisions, or a
combination of both district-level and building-level Section 504 teams.

Who Should Be on a Section 504 Team?
The membership of a Section 504 team will vary depending upon the needs of each student. For
example, a nurse may be on the Section 504 team of a student with a life threatening health
condition, and a psychologist may be on the Section 504 team of a student with a behavioral
disorder. The composition of a Section 504 team is fluid and may change within a school year or
between school years as a students needs and services change. A Section 504 team must consist
of at least two people and must include persons knowledgeable about the student, the meaning of
the students current evaluation data, and placement options.

How is Section 504 Enforced?
The U.S. Department of Education enforces Section 504 through the Office for Civil Rights
(OCR). OCR investigates individual complaints of disability discrimination, including
6

complaints that a district is denying a disabled student FAPE. OCR also provides training and
technical assistance to state education agencies, educational service districts, schools districts,
and parents. OCRs focus is on the process a district follows to identify, evaluate, and provide
an educational placement to a disabled student, and to provide procedural due process to the
students parent or guardian. Except in extraordinary circumstances, OCR will not review the
result of individual placement and other educational decisions, as long as a district complies with
Section 504s procedural requirements regarding identification, evaluation, placement, and due
process. The proper forum for pure educational disputes, in which a district has followed the
correct process to make an educational decision but the parents or guardian disagree with the
result of the decision, is a Section 504 due process hearing.

Who Conducts a Section 504 Due Process Hearing?
A district should select a hearing officer who is impartial (e.g., has no professional or personal
interest that would bias his or her judgment of the case) and has some training in Section 504 and
how it applies to FAPE.

The Bottom Line
Once a district has determined that a student is a disabled student under Section 504 for purposes
of FAPE, the district must provide whatever services it decides the student needs to participate in
and benefit from the districts education program. As a general rule, a district is under no
obligation to provide a service that a students parent or guardian or doctor requests unless, in the
districts determination, the student needs the service to participate in and benefit from its
education program.
7

- IDEA AND SECTION 504
- A COMPARISON

COMPONENT IDEA SECTION 504

WHAT IS IT? A federal funding law and regulation. A federal civil rights law and
regulation.

WHAT IS ITS
PURPOSE?
To provide federal funds to state
education agencies and districts to
educate disabled students.
To eliminate disability
discrimination in all programs and
activities that receive federal funds.

WHO IS A
DISABLED
STUDENT?
Both regulations provide protections to disabled students but each regulation
defines disabled student differently. Section 504 defines disabled student
more broadly than does IDEA.

Defines disabled student as a child aged
3-21 who has one or more of 14 specific
disabilities (i.e., autism, deaf-blindness,
developmental delay, deafness,
emotional behavioral disability, hearing
impairment, mental retardation, multiple
disabilities, orthopedic impairment, other
health impairment, specific learning
disability, speech or language
impairment, traumatic brain injury, and
visual impairment, including blindness)
and, due to disability, needs special
education.
Defines disabled student as a
school-aged child who has a
physical or mental impairment that
substantially limits one or more
major life activities. The terms
physical or mental impairment,
substantially limits, and major
life activities are to be interpreted
broadly.

WHAT IS A
FREE
APPROPRIATE
PUBLIC
EDUCATION
(FAPE)?
Both regulations require a district to provide FAPE to each disabled student in
its jurisdiction but each regulation defines FAPE differently. Section 504
defines FAPE more broadly than does IDEA.

Defines FAPE as special education and
related services.

Students can receive related services
under IDEA only if they need related
services to benefit from special
education.
Defines FAPE as regular or special
education and related aids and
services that are designed to meet a
students individual educational
needs and are based upon
procedures that satisfy required
evaluation, placement, and due
process procedures. Students can
receive related aids and services
under Section 504 even if they are
not provided any special education.

8


WHAT DOES
APPROPRIATE
MEAN?
Both regulations interpret appropriate to mean designed to meet the
individual educational needs of a disabled student. An appropriate education
provides a disabled student sufficient individualized services to enable the
student to receive educational benefit (i.e., not maximum benefit, not minimal
benefit, some benefit).

HOW IS FAPE
DELIVERED?

Both regulations require that FAPE be delivered through an individualized
education program. Section 504 defines individual education program with
less specificity than does IDEA.

Requires a written individual education
program (IEP) with specific content
developed by specific participants at an
IEP meeting.
Requires a documented placement
decision, commonly called a
Section 504 Plan, developed by a
group of persons knowledgeable
about the student, the meaning of
the students evaluation data, and
placement options.

WHO CAN REFER
A STUDENT FOR
EVALUATION?
Both regulations contain a child find component, and allow any person (e.g.,
parents, guardians, school staff, etc.) to refer a student for evaluation.

WHAT SHOULD A
DISTRICT DO
WITH A
REFERRAL?
Both regulations require a district to decide whether to evaluate a referred
student and to notify a students parent or guardian of its decision. As a
general rule, under both regulations, a district should evaluate a referred
student if it knows or suspects that the student, because of disability, needs
special education or related aids or services to participate in or benefit from
the districts education program.

WHAT
EVALUATION
PROCEDURES
ARE REQUIRED?
Both regulations require that tests and other evaluation materials:
a. be validated for the specific purpose for which they are used;
b. be administered by trained personnel in conformance with the instructions
provided by their producer;
c. include those tailored to assess specific areas of educational need; and
d. be selected and administered to assure that the test results accurately
reflect whatever factors the tests purport to measure.

Requires that re-evaluations be
conducted at least every 3 years.
Requires periodic re-evaluations.
The IDEA schedule satisfies
Section 504.

Provides for independent educational
evaluations at district expense if a parent
or guardian disagrees with a districts
evaluation and either the district or a
hearing officer agrees.
Does not provide for independent
educational evaluations at district
expense. However, a district must
carefully consider any such
evaluations presented.

9


WHAT
PLACEMENT
PROCEDURES
ARE REQUIRED?
Both regulations require that, when interpreting evaluation data and making a
placement decision, a district must:
a. draw upon information from a variety of sources;
b. assure that all information is documented and considered;
c. ensure that the eligibility decision is made by a group of persons including
those who are knowledgeable about the child, the meaning of the
evaluation data and placement option; and
d. ensure that the student is educated with his/her non-disabled peers to the
maximum extent appropriate (i.e. in the least restrictive appropriate
environment).

Requires an IEP meeting before any
change in placement.
Requires a re-evaluation before
any significant change in
placement.

IS PARENT OR
GUARDIAN
CONSENT EVER
REQUIRED?
Both regulations require a parent or guardian to consent prior to a students
initial evaluation and initial placement. IDEA alone requires consent prior to
re-evaluations. Under IDEA parents can revoke consent for placement at
anytime.

WHAT DUE
PROCESS RIGHTS
DO PARENTS AND
GUARDIANS
HAVE?
Both regulations require a district to notify a students parent or guardian
before the district takes any action regarding the identification, evaluation or
placement of their child. IDEA procedures satisfy Section 504. Any action
includes a decision not to evaluate a student and denial of placement.

Requires written prior notice and
specific content to be included in the
notice.
Allows oral prior notice, but a
district is wise to provide notice in
writing.

WHAT KIND OF
GRIEVANCE
PROCEDURE IS
REQUIRED?
Requires each state education agency
(OSPI) to have a special education
grievance procedure, commonly called a
citizen complaint procedure.
Requires each district to have an
internal Section 504 grievance
procedure for parents and
guardians, students, and
employees.

WHAT KIND OF
HEARING
PROCEDURE IS
REQUIRED?
Both regulations require a district to provide an impartial due process hearing
procedure for parents or guardians who disagree with the identification,
evaluation, or placement of their child.

WHO CONDUCTS
A DUE PROCESS
HEARING?
Requires each state education agency
(OSPI) to conduct such hearings through
a state office of hearings.
Allows either state education
agencies or districts to conduct
such hearings (in WA, districts
conduct such hearings).

HOW IS IT
ENFORCED?
Enforced by the U.S. Department of
Education, Office of Special Education
Programs (OSEP).
Enforced by the U.S. Department
of Education, Office for Civil
Rights (OCR).

10


HOW IS IT
ENFORCED?
(cont.)
Each state education agency (OSPI)
monitors compliance through complaint
investigations and compliance reviews.
OSEP monitors compliance through
compliance reviews.
OCR monitors compliance through
complaint investigations and
compliance reviews. The state
education agency (OSPI) has
FAPE oversight responsibilities.
OSPIs FAPE oversight
responsibilities require it to take
action to correct a situation where
it has caused a district to violate
Section 504 (for example, through
a State policy), and where it has
knowledge of repeated, class (not
individual) violations of Section
504 by a district.

11

Section 504 Process Flow Chart

1. Refer the Student:
Complete Student Support Team Referral form.

2. Decide Whether to Evaluate the Student:
Does the SST know or suspect that, because of a disability, the student needs
special education or related aids or services to participate in or benefit from school?
Provide parent or guardian Notice of Action/Consent and Notice of Rights form.
Obtain consent for initial evaluation.

3. Evaluate the Student:
Evaluate the specific areas of the students educational needs.

4. Determine the Students Eligibility:
Review evaluation results and determine eligibility.
Complete the Eligibility Determination form.
Provide parents Notice of Action/Consent and Notice of Rights form.

5. Develop a Section 504 plan for the Student:
Develop a Section 504 Plan. May combine with eligibility meeting.
Assign a case manager to monitor implementation and student progress.
Provide parent or guardian Notice of Action/Consent and Notice of Rights form
and copy of Section 504 Plan.
Obtain consent for initial placement.

6. Annually Review the Students Section 504 Plan:
Review and revise the students Section 504 Plan.
Provide parent or guardian Notice of Action/Consent and Notice of Rights form.

7. Periodically Re-Evaluate the Student:
At least every three years.
Before any significant change in placement.
Provide parent or guardian Notice of Action/Consent and Notice of Rights.

12

Section 504 Process
1. Refer Student to the Student Support Team (SST)
Any person (e.g. a parent, guardian, school staff, or persons outside the school) can refer a
student for evaluation under Section 504. A concerned person should refer a student for
evaluation if the person knows or suspects that, due to a physical or mental impairment, the
student needs special education or related aids or services to participate in or benefit from the
districts education program. Referral can be made via an SST referral form.

2. Decide Whether to Evaluate the Student under Section 504
The SST reviews the referral, the students file, and consults with teachers, parent or
guardian, the student (if appropriate), and others who have relevant information. The SST
decides whether to evaluate the student under Section 504.

If the SST knows or suspects that the student is eligible as a disabled student under the
IDEA, is an English language learner, or has other needs, the SST refers the student for
evaluation under those processes.

If the SST knows or suspects that the student is eligible as a disabled student under Section
504, the SST provides the parents Notice of Action/Consent and Notice of Rights and refers
the student for evaluation. The parent or guardian must provide consent prior to an initial
evaluation.

If the referral information indicates that the student is not eligible as a disabled student under
Section 504, the SST provides the parents Notice of Action/Consent and Notice of Rights.

3. Evaluate the Student under Section 504
After the parent or guardian has been notified of the decision to evaluate (and has consented
if the evaluation is an initial evaluation), qualified persons evaluate the specific areas of the
students educational needs. The parent or guardian may also choose to have the student
independently evaluated, at their own expense.

4. Determine the Students Eligibility under Section 504
After the student has been evaluated, the students Section 504 Team reviews the evaluation
data and decides if the student is eligible as a disabled student under Section 504. At that
time, the Section 504 Team fills out the Section 504 Eligibility Determination Form. The
Section 504 Team must include persons knowledgeable about the student, the students
evaluation data, and placement options. In making its eligibility decision, the Section 504
Team must consider information from a variety of sources, including any relevant
information submitted by the parent or guardian. The student is eligible as a disabled student
under Section 504 if the student has a physical or mental impairment that substantially limits
a major life activity. For a school aged student, the ability to participate in or benefit from a
districts education program is a major life activity

13

If the Section 504 Team determines that the student is eligible as a disabled student under
Section 504, the Section 504 Team gives the parent or Notice of Action/Consent and Notice
of Rights and the Team meets to develop a Section 504 Plan for the student.

If the Section 504 Team determines that the student is not eligible as a disabled student under
Section 504, the Section 504 Team gives the parent or guardian Notice of Action/Consent
and Notice of Rights.

5. Develop a Section 504 Plan for the Student
After a student is determined eligible under Section 504, the students Section 504 Team
meets to develop a Section 504 Plan for the student. The Section 504 Plan can be developed
at the same time that eligibility is established. The Section 504 Plan describes what
educational or related aids or services the student needs to receive a free appropriate public
education. The Section 504 Team provides the parent or Notice of Action/Consent and
Notice of Rights and a copy of the students Section 504 Plan. The parent or guardian must
provide consent prior to an initial placement.

6. Annually Review the Students Section 504 Plan
A students Section 504 Team meets annually to review the students Section 504 Plan to
ensure that it is meeting the students needs. If the Section 504 Team decides that the
students Section 504 Plan needs to be revised, the Section 504 Team provides the parent or
guardian Notice of Action/Consent and Notice of Rights and a copy of the students revised
Section 504 Plan.

7. Periodically Re-evaluate the Student
A students Section 504 Team periodically re-evaluates the student to determine continued
eligibility and if the students educational needs have changed. Before a re-evaluation, the
Section 504 Team provides the parent or guardian Notice of Action/Consent and Notice of
Rights. Re-evaluations must occur at least every three years and before any significant
change in a students placement. Significant changes in placement include initiating or
discontinuing a service, significantly increasing or decreasing the amount of a service, and
certain disciplinary removals from school (e.g. long-term suspensions and expulsions).
14

Section 504 FAQs
What is discrimination under Section 504?
Discrimination occurs when a district, based on disability:
denies a disabled student the opportunity to participate in or benefit from an aid, benefit, or
service which is afforded to non-disabled students (e.g., denies credit to a student whose
absenteeism is related to his disability, expels a student for behavior related to his
disability, fails to dispense medication, or provide an individual health plan or nursing care
plan to a disabled student who cannot attend school without such services);
fails to afford a disabled student an opportunity to participate in or benefit from an aid,
benefit, or service that is equal to that afforded to non-disabled students (e.g., conditions a
disabled students participation in a field trip on the students parent or guardian attending
the trip, refuses to allow an otherwise qualified disabled student to try out for an
interscholastic athletic team);
fails to provide aids, benefits, or services to a disabled student that are as effective as those
provided to non-disabled students (e.g., fails to provide a disabled student necessary
environmental, instructional or behavioral accommodations or another related aid or
service, fails to provide a disabled student necessary study skills instruction or another
special education service);
provides different or separate aids, benefits or services than are provided to non-disabled
students unless there is a legitimate, nondiscriminatory reason for doing so (e.g. requires all
disabled students to use special education transportation, segregates all disabled students in
portable classrooms, requires all disabled students to use a different recess period);
denies a disabled student the opportunity to participate in programs or activities that are not
separate or different unless there is a legitimate and nondiscriminatory reason for doing so
(e.g., denies all disabled students the opportunity to eat meals in the school cafeteria,
prohibits all disabled students from participating in full day kindergarten, refuses to allow
any disabled students to enroll in regular physical education classes);
denies a disabled student the opportunity to participate as a member of a planning or
advisory board (e.g., denies disabled students the opportunity to participate in student
government);
otherwise limits a disabled student in the enjoyment of any right, privilege, advantage, or
opportunity enjoyed by others (e.g., denies all disabled students admission under school
choice);
aids or perpetuates discrimination by providing significant assistance to an agency,
organization, or person that discriminates on the basis of disability (e.g., sponsors a non-
district organization that excludes disabled students); and
selects the site or location of a facility that has the effect of excluding disabled students
from, denying them the benefits of, or otherwise subjecting them to discrimination under
any program or activity (e.g., selects an inaccessible facility in which to hold school plays,
concerts, or athletic competitions).

When does an impairment substantially limit a students major life activity?
There is no single formula or scale that measures substantial limitation. A physical or mental
impairment substantially limits a major life activity for a student if the impairment
15

substantially limits the students ability to perform a major life activity as compared to the
students non-disabled age/grade peers. An impairment need not prevent, or significantly or
severely restrict, a student in performing a major life activity to be considered substantially
limiting.

As a general rule, a student with a physical or mental impairment who is able to participate in
or benefit from a districts education program (e.g. attend school, advance from grade to
grade, and meet the standards of personal independence and social responsibility expected of
his or her age and cultural group), without the provision of special education or related aids
or services, is not a disabled student under Section 504 for purposes of FAPE.

Can a district consider mitigating measures used by a student when
determining whether an impairment constitutes a disability for a student?
No. When determining whether an impairment constitutes a disability for a student, districts
should disregard the ameliorating effects of any mitigating measures that the student uses.
Mitigating measures include: medication; medical supplies; equipment or appliances; low-
vision devices (other than ordinary eyeglasses or contact lenses); prosthetics; hearing aids
and cochlear implants or other implantable hearing devices; mobility devices; oxygen
therapy equipment and supplies; use of assistive technology; environmental or instructional
accommodations; other related aids or services; learned behavior or adaptive neurological
modifications, etc.

Does a district need to develop a Section 504 plan for every student who has a
disability?
No. A district does not need to develop a Section 504 plan for every student who has a
disability. A district needs to develop a Section 504 plan for those students who, because of
disability, need accommodations or some other type of related aids or services, to participate
in or benefit from the districts education program.

Is a district required to develop a Section 504 plan for a student who has a
record of disability or is regarded as disabled?
No. A district is required to develop a Section 504 plan for those students who have a
physical or mental impairment that currently substantially limits a major life activity. The
fact that a student has a record of disability or is regarded as disabled does not trigger a
districts duty to provide FAPE. A districts duty to a student who has a record of a
disability or is regarded as disabled is to protect the student from discrimination (e.g., it
would be discriminatory for a district to prohibit a student who has a record of drug
addiction, but is not currently engaging in the illegal use of drugs, from participating in an
interscholastic athletic team, based on the students record of disability).

Does the language of the law still include " reasonable" accommodations for K-12
education? If so, please define " reasonable."
Reasonable accommodation is a Section 504 term related to employment not K-12 education.
A district is required to provide whatever services it determines a disabled student needs to
participate in and benefit from its education program, regardless of the cost of such services.
16

Is a district that operates a public general education preschool program required
to provide FAPE to disabled preschool students participating in the program?
No. A district that operates a public general education preschool program may not, on the
basis of disability, exclude qualified students with disabilities from participating in the
program, and must take into account the needs of disabled students in determining the aids,
benefits or services to be provided under the program. The district is not, however, required
to provide such students a FAPE.

Is a district required to provide FAPE to a student who has a disability but does
not need special education or related aids or services to participate in or benefit
from the districts education program?
No. A district is required to provide a FAPE to only those students who have a physical or
mental impairment that currently substantially limits a major life activity. A district is not
required to provide a FAPE to a student who has a disability but does not have a current need
for special education or related aids or services. A districts duty to such a student is to
protect the student from discrimination (e.g. disability harassment).

What are related aids and services under Section 504?
Related aids and services means any service that a disabled student needs to participate in
or benefit from a districts education program (e.g., if, without a specific related aid or
service, a disabled student is unable to participate in or benefit from a districts education
program, the aid or service in question is a necessary related aid or service for the student).
In contrast to IDEA, under which students are eligible to receive related services if and only
if they need related services to benefit from special education, students are eligible to receive
related aids or services under Section 504 even if they are not provided any special
education. Related aids and services include but are not limited to:
school health services
counseling services
environmental, instructional, and behavioral accommodations
transportation services
speech-language services
audiology services
physical and occupational therapy services
orientation and mobility services
provision of a modified schedule, grading system, or curriculum

What is a significant change in placement under Section 504?
A significant change in placement means a significant change in the type or amount of
educational or related aids or services that a district provides to a disabled student. A
significant change in placement may include but is not limited to:
initiating or terminating a service
significantly increasing or decreasing the amount of a service
17

disciplinary actions that exclude a student from school for more than 10 consecutive
school days in a school year
disciplinary actions that create a pattern of exclusion from school (e.g., cumulative
short-term suspensions that are each 10 school days or fewer in duration that create a
pattern of exclusion due to the length of each suspension, the proximity in time of the
suspensions, the total amount of time the student was excluded from school, and the
similarities of the behaviors that led to the suspensions)

Can a temporary health condition be a disability under Section 504 for purposes
of FAPE?
Yes, under certain circumstances. A temporary impairment constitutes a disability under
Section 504 if its severity is such that it substantially limits one or more major life activities
for a student for an extended period of time. The issue of whether a temporary impairment is
substantial enough to be a disability must be resolved on a case-by-case basis, taking into
consideration both the duration (or expected duration) of the impairment and the extent to
which it actually limits a major life activity for a student.

For example, though pregnancy is not considered a disability under Section 504, a district
may determine that a pregnant student, who cannot attend school for several months due to
pregnancy-related complications, is disabled under Section 504 for purposes of FAPE.

Can an impairment that is episodic or in remission be a disability under Section
504 for purposes of FAPE?
Yes, under certain circumstances. An impairment that is episodic or in remission constitutes
a disability under Section 504 for purposes of FAPE if it would substantially limit a major
life activity when active. For example, a district may determine that a student with epilepsy,
major depression, post traumatic stress disorder, cancer, or students that have other
impairments that are episodic or in remission, is disabled under Section 504 for purposes of
FAPE.

Can drug addiction be a disability under Section 504 for purposes of FAPE?
Maybe. A student who is drug addicted but is in recovery and is not currently engaging in
the illegal use of drugs, may qualify as a disabled student under Section 504 for purposes of
FAPE if the students drug addiction substantially limits the students ability to perform a
major life activity. Such a student may need a modified schedule, school counseling, or
another type of special education or related aid or service to participate in or benefit from the
districts education program. A student who is drug addicted and is currently engaging in the
illegal use of drugs, however, is excluded from the definition of a disabled student under
Section 504. A district is under no obligation to evaluate such a student under Section 504
regardless of the educational impact the drug addiction is having on the student. A district
may treat such a student in the same manner as it treats non-disabled students.

Can alcoholism be a disability under Section 504 for purposes of FAPE?
Yes. A student who is addicted to alcohol, regardless of whether the student is currently
using alcohol or is in recovery, may qualify as a disabled student under Section 504 for
18

purposes of FAPE if the students alcoholism substantially limits the students ability to
perform a major life activity. Such a student may need a modified schedule, school
counseling, or another type of special education or related aid or service to participate in or
benefit from the districts education program.

Does Section 504 protect a disabled student who engages in drug or alcohol
related misconduct at school?
No. A district may discipline a disabled student for the illegal use or possession of drugs or
alcohol at school or at a school-sponsored function in the same manner and to the same
extent as it disciplines non-disabled students. The procedures at 34 CFR 104.35 (regarding
manifestation determinations) and 104.36 (regarding procedural safeguards) are not required
for such disciplinary actions. The parent or guardian of the disabled student may challenge
the regular education issues raised by the disciplinary action (e.g., whether the student did
what he was charged with doing) at a regular education discipline hearing, but does not have
a right to challenge the disciplinary action under Section 504. For example, the parent has no
right to challenge the disciplinary action by asserting that the students drug or alcohol-
related misconduct was disability-related.

Can social maladjustment be a disability under Section 504 for purposes of
FAPE?
Maybe. A student with a social maladjustment (e.g., conduct disorder or oppositional
defiance disorder) may qualify as a disabled student under Section 504 for purposes of FAPE
if the students condition substantially limits the students ability to perform a major life
activity. Such a student may need medication administration, school counseling, a
behavioral intervention plan, or another type of special education or related aid or service to
participate in or benefit from the districts education program.

Is specific learning disability defined the same under Section 504 as it is under
IDEA?
The term specific learning disability is a special education funding category under IDEA.
The term specific learning disability is defined the same under Section 504 as it is under
IDEA; however, a student who is not diagnosed as having a specific learning disability as
that term is defined, but is diagnosed as having dyslexia, dysgraphia, dyscalcula, or another
type of processing disorder, may qualify as a disabled student under Section 504 for purposes
of FAPE if their condition substantially limits their ability to participate in or benefit from
school.

Can a district require a parent to provide a medical diagnosis before it will initiate
an evaluation of a student under Section 504?
No. Under Section 504, a district must evaluate a student if the district knows or suspects
that the student, because of a disability, needs special education or related aids or services to
participate in or benefit from its education program, regardless of whether the student has a
medical diagnosis. A district may provide a student medical diagnostic services, as a related
service, if the district believes that it needs a medical diagnosis to determine whether a
student has a medical condition.
19

Does a student with a medical diagnosis automatically qualify as a disabled
student under Section 504 for purposes of FAPE?
No. Not every medical diagnosis will substantially limit a students ability to perform a
major life activity. However, if a medical diagnosis does substantially limit a students
ability to perform a major life activity, the student may qualify as a disabled student under
Section 504 for purposes of FAPE. Such a student may need an individual health plan, an
emergency or nursing care plan, or another type of special education or related aid or service
to participate in or benefit from the districts education program.

Does a student with a life threatening health condition, as defined by state law,
automatically qualify as a disabled student under Section 504 for purposes of
FAPE?
Yes. Because state law, SHB 2834, defines life threatening health condition as a health
condition that puts a student in danger of death during the school day if a medication or
treatment order and a nursing care plan are not in place, by definition, a student with a life
threatening health condition has a physical or mental impairment that substantially limits a
major life activity, and qualifies as a disabled student under Section 504 for purposes of
FAPE.

Would a high school student with a serious illness who qualifies for
Home/Hospital Instruction on an intermittent basis throughout the school year
require a Section 504 plan?
Yes. An impairment that is episodic or in remission constitutes a disability under Section 504
for purposes of FAPE if it substantially limits a major life activity for the student when
active. If it is foreseeable that a students illness would require home/hospital instruction
throughout a school year on an intermittent basis, the district should develop a Section 504
plan for the student that includes home/hospital instruction.

What should trigger an initial evaluation under Section 504?
A district should evaluate a student if the district knows or suspects that, due to a disability,
the student needs special education or related aids or services to participate in or benefit from

For example, the following situations may trigger an initial evaluation under Section 504:
a student is failing to achieve passing grades
a student is failing to advance from grade to grade
a student is chronically absent from school
a student is returning to school after a serious illness or injury
a student is returning to school after alcohol or drug treatment
a student has a life threatening health condition
a student has a temporary impairment that will be substantially limiting for an extended
period of time
a student has an impairment that is episodic or in remission that is substantially limiting
when active
20

a student is failing to meet the standards of personal independence or social
responsibility expected of his or her age or cultural group
a student is expelled from school

Must a school district obtain parental consent prior to conducting an initial
evaluation?
Yes. Section 504 requires districts to obtain parental permission for initial evaluations. If a
district suspects a student needs or is believed to need special instruction or related services
and parental consent is withheld, Section 504 provides that districts may use due process
hearing procedures to seek to override the parents' denial of consent for an initial evaluation.

What can a school district do if a parent withholds consent for initial placement
under Section 504 after a student is determined eligible for services?
Section 504 neither prohibits nor requires a school district to initiate a due process hearing to
override a parental refusal to consent with respect to the initial provision of special education
and related services. Nonetheless, school districts should consider that IDEA no longer
permits school districts to initiate a due process hearing to override a parental refusal to
consent to the initial provision of services.

How much is enough information to document that a student has a disability
under Section 504 for purposes of FAPE?
At the elementary and secondary education level, the amount of information required is
determined by the multi-disciplinary committee gathered to evaluate the student. The
committee should include persons knowledgeable about the student, the meaning of the
evaluation data, and the placement options. The committee members must determine if they
have enough information to make a knowledgeable decision as to whether or not the student
has a disability. Section 504 requires that school districts draw from a variety of sources in
the evaluation process so that the possibility of error is minimized. The information obtained
from all such sources must be documented and all significant factors related to the student's
learning process must be considered. These sources and factors may include aptitude and
achievement tests, teacher recommendations, physical condition, social and cultural
background, and adaptive behavior. In evaluating a student suspected of having a disability,
it is unacceptable to rely on presumptions and stereotypes regarding persons with disabilities
or classes of such persons. Compliance with the IDEA regarding the group of persons present
when an evaluation or placement decision is made is satisfactory under Section 504.

Is educational testing required as a part of a Section 504 evaluation?
Maybe. Evaluations under Section 504 are individually designed. A Section 504 evaluation
may be broad (including educational testing) or narrow (limited to medical data). It is the
responsibility of the district to determine the scope of each students Section 504 evaluation.

21
What is the difference between a regular education intervention plan and a
Section 504 plan?
A regular education intervention plan is appropriate for a student who does not have a
disability or is not suspected of having a disability but may be facing challenges in school.
School districts vary in how they address performance problems of regular education
students. Some districts employ teams at individual schools, commonly referred to as
"building teams." These teams are designed to provide regular education classroom teachers
with instructional support and strategies for helping students in need of assistance. These
teams are typically composed of regular and special education teachers who provide ideas to
classroom teachers on methods for helping students experiencing academic or behavioral
problems. The team usually records its ideas in a written regular education intervention plan.
The team meets with an affected student's classroom teacher(s) and recommends strategies to
address the student's problems within the regular education environment. The team then
follows the responsible teacher(s) to determine whether the student's performance or
behavior has improved. In addition to building teams, districts may utilize other regular
education intervention methods, including before-school and after-school programs, tutoring
programs, and mentoring programs.

Can an IHP/emergency care plan serve as a Section 504 plan?
Yes. If an IHP/ emergency care plan is serving as a Section 504 plan for a student, the
district needs to remember to use its Section 504 process to develop and implement the
IHP/emergency care plan (for example, the district needs to base the students
IHP/emergency are plan on evaluation data and provide the students parent/guardian notice
of their procedural safeguards).

If a student is on an IEP and has a tube feeding procedure, should he or she also
be on a Section 504 plan?
No. If a student is eligible under IDEA a student must have an IEP. Any related aid or
services related to a tube feeding procedure should be included on the students IEP.

If a student has a peanut allergy, would the district be required to provide a
peanut free diet to the student?
Maybe. If a school provides food services (e.g. breakfast and lunch) to its general student
population, it needs to provide food services to disabled students that are designed to meet
their disability-related needs. Therefore, if a student with a severe food allergy has a
disability-related need for allergen-free food during the school day, a district may need to
provide such food to meet the students disability-related needs at no greater cost than non-
disabled students pay for comparable food. A case-by-case determination will need to be
made.

22
Regarding a young diabetic student whose parent does not show up to provide
care - no RN full time in school, no PDA, can the parent demand a full time nurse
in the school?
No. A school district has a duty to provide a diabetic student the school health services that
the district has decided the student needs to participate in and benefit from its education
program. If a student needs a full time nurse in their school and their school does not have a
full time nurse and the parent has not located a PDA, the district has a duty under Section
504 to place the student in a school with a full time nurse. It is acceptable under Section 504
for a district to centralize school health services in certain schools and to place students who
need those services in those schools.

Given the new law regarding re-entry to school after concussion, should those
students have Section 504 plans?
Maybe. A student with a concussion should have a Section 504 plan if the district has
determined that the students concussion is a disability and that the student needs special
education or related aids or services during the school day to participate in or benefit from

Can a district limit its duty to provide FAPE to a disabled student based on cost?
No. As a general rule, a districts FAPE obligation under Section 504 is not subject to cost
considerations. For example, a district generally may not refuse to provide necessary special
education or related aids or services to a disabled student because doing so would cause the
district a financial hardship.

Can a district refuse to provide special education services to a disabled student
because the student doesnt meet the eligibility criteria under IDEA?
No. A district cannot refuse to provide special education services to a disabled student who
needs special education services simply because the student doesnt meet the eligibility
criteria under the IDEA. However, as a practical matter, the only disabled students who are
likely to need special education services are students who are eligible for special education
under IDEA.

Can a district refuse to allow disabled students to participate in advanced
placement or International Baccalaureate classes or programs (accelerated
classes and programs) solely because the student has a disability or needs
special education or related aids or services?
No. A district that provides advanced placement or International Baccalaureate classes or
programs (accelerated classes and programs) must not discriminate against a student based
on disability in admission to such classes and programs. The district cannot categorically
deny admission to a student based on disability, or deny admission to a disabled student
solely because the student needs special education or related aids or services. The district
must provide disabled students an equal opportunity to meet any appropriate minimum
eligibility criteria for admission, consistent with the purpose of its accelerated classes and
programs and Section 504.
23

In addition, once a district admits a disabled student to its accelerated classes or programs, it
must provide the student with the related aids or services that the student needs to participate
in and benefit from the classes or programs. For example, if a students IEP or Section 504
Plan provides for Braille materials in order to participate in general education classes and he
or she enrolls in an accelerated or advanced history class, then he or she must be provided
Braille materials for that class. The same would be true for other needed related aids and
services such as extended time on tests or the use of a computer to take notes.

Can a district deny a disabled student admission under school choice solely
because the student has a disability or needs special education or related aids or
services?
No. A district that chooses to participate in school choice must not discriminate against a
student based on disability in admission. The district cannot categorically deny admission to
a student under school choice based on disability, or deny admission to a disabled student
solely because the student needs special education or related aids or services. The district
must consider and act upon applications for admission under school choice in a manner that
affords disabled students an equal opportunity to be admitted as compared to non-disabled
students.

A district that chooses to participate in school choice may develop criteria for admission by
nonresident students as long as the criteria are: (1) neutral on their face with respect to
disability; (2) educationally justified; (3) applied equally to both disabled and nondisabled
students alike; and (4) subject to modification when necessary to avoid discriminating against
a student on the basis of disability, unless the district can demonstrate that making the
modification would fundamentally alter the nature of the service, program, or activity in
question.

For example, it is permissible under Section 504 for a district to deny admission to a disabled
student under school choice if the grade level or school that the student needs is at capacity,
as long as it applies that reason equally to deny admission to both disabled and nondisabled
students alike, and the district can demonstrate that admitting the student would
fundamentally alter the nature of the education program in the grade level or school in
question. A resident districts refusal to release special education funds for a student is not a
legitimate reason to reject a disabled student under school choice.

Can a district that operates a multi-district online school program under school
choice deny a disabled student admission solely because the student has a
disability or needs special education or related services?
No. A district that operates a multi-district online school program under school choice must
not discriminate against a student based on disability in admission. The district cannot
categorically deny admission to a student based on disability, or deny admission to a disabled
student solely because the student needs special education or related aids or services. The
district must provide disabled students an equal opportunity to meet any appropriate
minimum eligibility criteria for admission, consistent with the mission of the online school
program and Section 504.
24

A district that operates a multi-district online school program under school choice may
develop eligibility criteria for admission as long as the criteria are: (1) neutral on their face
with respect to disability; (2) educationally justified; (3) applied equally to both disabled and
nondisabled students alike; and (4) subject to modification when necessary to avoid
discriminating against a student on the basis of disability, unless the district can demonstrate
that making the modification would fundamentally alter the nature of its online school
program.

For example, a district can establish specific reading, writing and math achievement criteria
for admission to its online school program, as long as the criteria are justified by the nature of
its online school program, applied equally to all applicants, and subject to modification when
necessary to avoid discriminating against a student on the basis of disability, unless the
district can demonstrate that making the modification would fundamentally alter the nature of
its online school program.

Can a district place a disabled student on a shortened school day?
Maybe. As a general rule, a disabled student has the right to the same length school day that
a district provides to the students nondisabled age/grade peers. Before shortening the length
of a disabled students school day as compared with the students nondisabled peers, a
district must determine, through evaluation and placement procedures that satisfy the
evaluation and placement requirements of Section 504, that the student needs a shortened
school day to meet his or her individual educational needs.

Any determination to provide a disabled student a shortened school day must be based on
current evaluation data documenting that shortening the students school day is necessary to
provide the student a FAPE. It would violate Section 504 for a district to base a
determination to provide a disabled student a shortened school day on factors such as the
category of the students disability, severity of disability, availability of special education or
related services, configuration of the districts service delivery system, availability of space,
administrative convenience, or any factor unrelated to the students individual educational
needs.

Can a district exclude a disabled student from a field trip?
Maybe. As a general rule, a district cannot exclude a disabled student from participating in a
field trip for which the student is otherwise eligible to attend unless the district has a
legitimate, nondiscriminatory justification for excluding the student. Any decision to exclude
a disabled student from participating in such a field trip is a placement decision, and must be
based upon procedures that satisfy the evaluation, placement, and due process requirements
of Section 504. It is not permissible under Section 504 to exclude a disabled student from a
field trip because:
the student needs related aids or services (e.g. the administration of medication or the
assistance of a school nurse) to participate in the field trip; or
the students parent or guardian is unable to attend the field trip, unless the participation
of the parents or guardians of non-disabled students is required.

25

Is a disabled student entitled to extended school year (ESY) services under
Section 504?
Maybe. A district must provide ESY services to a disabled student under Section 504 if the
district determines that the student needs ESY services to receive a FAPE.

Is a disabled student entitled to transition services under Section 504?
Maybe. A district must provide transition services to a disabled student under Section 504 if
the district determines that the student needs transition services to receive a FAPE.

How does Section 504 apply to the disciplinary removal of a disabled student
from school?
Section 504 protects disabled students from being improperly removed from school for
misconduct that is related to their disability. As a general rule, Section 504 and IDEA apply
to the disciplinary removal of disabled students in a similar manner. Before a district can
implement a disciplinary action that constitutes a significant change in placement (Refer to
What is a significant change in placement under Section 504?), it must evaluate the
student to determine whether the students misconduct was caused by, or had a direct and
substantial relationship to the students disability or was the direct result of the districts
failure to implement the students Section 504 plan. This type of evaluation is commonly
called a manifestation determination (Refer to What is a manifestation determination
under Section 504?). If a disabled students misconduct is a manifestation of his or her
disability, a district cannot implement a disciplinary action that constitutes a significant
change in the students placement. If a disabled students misconduct is not a manifestation
of his or her disability, a district can discipline the student in the same manner that it
disciplines non-disabled students for the same misconduct. Under Section 504, unlike IDEA,
a district does not have to provide a disabled student educational services during the period
of time the student is properly removed from school for disciplinary reasons.

What is a manifestation determination under Section 504?
A manifestation determination is an evaluation that answers two questions:
Is the misconduct in question related to the students disability?
This determination must be based upon evaluation data related to behavior, and must be
recent enough to afford an understanding of the students current behavior. Misconduct
is a manifestation of a disability if it is caused by the disability, or has a direct and
substantial relationship to the disability. Misconduct is not a manifestation of a
disability if it bears only a weak relationship to the students disability. A
determination that a student knows the difference between right and wrong does not
constitute a determination that the students misconduct was or was not a manifestation
of the disability. In addition, a district cannot make a categorical determination that
misconduct is or is not a manifestation of a disability based on a students IDEA
eligibility label.

Is the misconduct in question the direct result of the districts failure to implement the
Section 504 plan?
26

This determination must be based upon information from a variety of sources, including
aptitude and achievement tests, teacher recommendations, physical condition, social or
cultural background, and adaptive behavior. District staff does not need to use all of
the sources of information listed above in every instance. The point of the requirement
is to ensure that more than one source of information is used in making such a
placement decision. In addition, the district should examine the kinds of educational
placements that previously have been tried with the student and determine whether a
placement more restrictive than the current placement would manage the students
behavior. As a general rule, a district should not long-term suspend or expel a student
without first attempting to manage the students behavior by placing the student in a
more restrictive educational placement unless it has a legitimate reason for rejecting a
more restrictive placement as a viable placement option.

Is a district required to modify an eligibility requirement to enable a disabled
student to participate in an extracurricular activity?
Maybe. A district must provide disabled students an equal opportunity to participate in
extracurricular activities. This issue arises when a disabled student is denied participation in
extracurricular activities because he or she hasnt met the requirements for participation. As
a general rule, a district can impose eligibility requirements to participate in extracurricular
activities as long as they are neutral on their face with respect to disability, essential to the
activity in question, and applied equally to both disabled and nondisabled students alike. A
district may be required to modify an eligibility requirement if the requirement discriminates
against the student in question based on disability and modification of the requirement would
not fundamentally alter the nature of the activity in question.

For example, a district may establish a grade/credit eligibility requirement for participation in
an extracurricular activity. If a disabled student wants to participate in the activity and the
district determines that the student is unable to satisfy the eligibility requirement because of
his or her disability, the district must modify the requirement to enable the student to
participate unless doing so would fundamentally alter the nature of the activity. If the district
refuses to allow the student to participate in the activity because making the modification
would fundamentally alter the nature of the activity, the district must make a Section 504
grievance procedure available to the student to challenge his or her exclusion from the
activity on the basis of disability.

A district may also choose to modify an eligibility requirement to enable a disabled student
to participate in an extracurricular activity if a district determines that a disabled student
needs to participate in the activity to receive a FAPE.
27

If a district has reasonable cause to believe that a disabled student is ineligible to
participate in or continue in an interscholastic athletic activity under the rules and
regulations of the Washington Interscholastic Athletic Association (WIAA), does
the district have an independent responsibility under Section 504 to ensure that
applying the WIAA rule or regulation in question to the student does not subject
the student to discrimination on the basis of disability?
Yes, under certain circumstances. If a district has information that a WIAA rule or regulation
as applied to a specific student may subject the student to discrimination on the basis of
disability, it must take reasonable steps to ensure that application of the rule or regulation
does not discriminate against the student on the basis of disability. For example:

1. Make an initial determination about whether application of the rule or regulation to the
student subjects the student to discrimination on the basis of disability;
2. If the districts initial determination is YES, the district must assist the student to appeal
the ineligibility through WIAAs several levels of appeal, unless the district becomes
persuaded during an appeal that applying the rule to the student does not discriminate
against the student on the basis of disability;
3. If the districts initial determination is NO, the district must provide the student and his or
her parent or guardian an internal Section 504 grievance procedure to promptly and
equitably resolve the matter.
Is a district required to modify the curriculum in a general education class to
accommodate a disabled student?
Maybe. A district must modify the curriculum in a general education class if a disabled
student needs a modified curriculum to participate in or benefit from the class and the
necessary modification does not fundamentally alter the nature of the class. A district is
under no obligation to provide a curriculum modification that would result in a class that is
fundamentally different in nature. For example, if a student is enrolled in a lab science class
and the student cannot complete the lab requirement due to disability-related absences, the
district is under no obligation to modify the class by waiving the lab requirement if doing so
would fundamentally alter the nature of the class. The decision of whether a disabled student
needs a modified curriculum is a placement decision under Section 504.

Is a district required to modify the grading system in a general education class to
accommodate a disabled student?
Maybe. A district must modify the grading system in a general education class if doing so is
necessary to provide a disabled student an equally effective system to assess the students
performance in the class. The decision of whether a disabled student needs a modified
grading system is a placement decision under Section 504.

28

Can a report card for a student with a disability identify special education or
related aids or services being provided to the student or otherwise indicate that
the student has a disability?
Yes. Report cards are provided to parents to indicate their childs progress or level of
achievement in specific classes, course content, or curriculum. Consistent with this purpose,
it is permissible under Section 504 for a report card to indicate that a student is receiving
special education or related services, as long as the report card informs parents about their
childs progress or level of achievement in specific classes, course content, or curriculum.
For instance, a report card for a student with a disability may refer to an IEP or a Section 504
Plan in order to report on the students progress on the specific goals in the IEP or Section
504 plan.

Can special notations, including asterisks or other symbols, appear on a report
card for student with a disability who received accommodation in general
education classes?
Yes. Accommodations are generally understood to include aids or adjustments that are part
of an IEP or Section 504 Plan that enable the student with a disability to learn and
demonstrate what the student knows. In general, accommodations do not affect course
content or curriculum. Examples may include sign language interpreters in the classroom,
the provision of materials in alternate formats, or extra time on tests. Accordingly, to the
extent that the use of notations, asterisks, symbols, or other coding on a report card to
indicate that a student with a disability received accommodations is part of the information
given to parents about their childs progress or level of achievement in specific classes,
course content, curriculum, the IEP or Section 504 Plan, it is permissible under Section 504.

Can a transcript for a student with a disability indicate that the student has a
disability, has been enrolled in a special education program, or has received
special education services?
No. Section 504 prohibits unnecessary disclosure of disability status to third parties. A
students transcript generally is intended to inform postsecondary institutions or prospective
employers of a students academic credentials and achievements. Information that a student
has a disability, or has received special education or related services due to having a
disability, does not constitute information about the students academic credentials and
achievements. Notations that are used exclusively to identify a student as having a disability
or identify education programs for students with disabilities unnecessarily discloses the
students disability status to a third party. Identifying programs as being only for students
with disabilities also would be viewed as unnecessary disclosure of disability status.
Therefore, it would be a violation of Section 504 for a students transcript to indicate that a
student has received special education or a related service or that the student has a disability.

29
Can special notations, including asterisks or other symbols, appear on a
transcript for a student with a disability who received accommodations in general
education classes?
In general, no. Because the use of accommodations generally does not reflect a students
academic credentials and achievement, but does identify the student as having a disability, it
would be a violation of Section 504 for a students transcript to indicate that the student
received accommodations in any classes. For example, a notation indicating the use of
Braille materials is not related to whether that student mastered all the tenth grade objectives
for her literature class. The only purpose of such a notation is to identify that student as
having a visual impairment. Because accommodations are generally understood to include
aids and adjustments to enable a student with a disability to learn and demonstrate
knowledge, this notation would identify the student as having a disability and therefore
would unnecessarily disclose the students disability status to third parties.

Can a transcript for a student with a disability indicate that a student received a
certificate of attendance or similar document rather than a regular diploma?
Maybe. A transcript for a student with a disability may indicate receipt of a certificate of
attendance or a similar document, rather than a regular diploma, under certain
circumstances. These circumstances are where this does not disclose that a student has
received special education or related services, does not otherwise specifically disclose that a
student has a disability (for example, because certificates of attendance are available to both
students with disabilities and students without disabilities), is not used for the purpose of
identifying programs for students with disabilities, and is consistent with the purpose of a
student transcript -- to inform postsecondary institutions and prospective employers of a
students academic credentials and achievements.
30
Resources on Section 504

US Department of Education, Office for Civil Rights: www.ed.gov/ocr

Sound Options Mediation: www.somtg.com

Office of the Superintendent of Public Instruction (OSPI): www.k12.wa.us
Special Education: www.k12.wa.us/specialed
Health Services: www.k12.wa.us/LearnTeachSupp/healthservices

LRP Special Education Connection: www.specialedconnection.com

Educational Service Districts:
Puget Sound ESD: www.psesd.wednet.edu
Northwest ESD: www.esd189.org
North Central ESD: www.ncesd.org
Olympic ESD: www.oesd.wednet.edu
ESD 113: www.esd113.k12.wa.us
ESD 112: www.esd112.wednet.edu
ESD 101: www.esd101.net

Council of Educators for Students with Disabilities: www.504idea.org

Gorn, Susan. What Do I Do WhenThe Answer Book on Section 504. LRP 1998
31
APPENDIX A

Sample Section 504 Board Policy

Policy #

Section 504 Compliance

It is the policy of the __________________ School District to provide a free and appropriate
public education to each student within its jurisdiction, including students with disabilities,
regardless of the nature or severity of the disability.

It is the intent of the District to ensure that students who are disabled within the definition of
Section 504 of the Rehabilitation Act of 1973 are identified, evaluated, and provided with
appropriate educational services.
32
APPENDIX B
Sample Complaint Procedure

Worki ng wi th Parent Concerns and Compl ai nts under
Secti on 504 of the Rehabili tation Act of 1973

The best solutions to parent concerns often occur at the school level. Therefore, the District
encourages parents to attempt to resolve concerns by working with the building principal,
building Section 504 coordinator, and other appropriate staff to reach a joint resolution of the
issue. However, regardless of whether a parent attempts to resolve the issue at the building level,
a parent may file a formal complaint under Section 504 through the following process:

Parent completes and submits a Section 504 Complaint Form to the
District Section 504 coordinator. The Section 504 Complaint Form is
available at each schools office. The complaint should be as detailed as
possible and describe why the parent believes that their concerns raise an
issue under Section 504.

The District Section 504 coordinator will conduct an investigation of the
allegations(s). If the District Section 504 coordinator is the subject of the
complaint, the Superintendent will appoint an impartial investigator. The
parent and the District staff will have an opportunity to provide evidence,
including documents and witnesses.

The District Section 504 coordinator will issue a written decision about
the complaint within 30 calendar days of receipt of the complaint, and
provide a copy of the decision to the parent. The written decision will
contain suggested resolutions to the parents concerns.

If the parent is not satisfied with the resolution of his/her complaint, the
parent may request a review of the complaint by the Superintendent. The
Superintendent will respond to the parents request for review within 10
days of receiving the request.

If the parent is still dissatisfied after the Superintendents review, or at
any time during the Districts complaint resolution process, the parent
may file a complaint by writing to:
U.S. Department of Education, Office for Civil Rights
915 Second Avenue, Room 3310, Seattle, WA 98174-1099
or 206-607-1600 or www.ed.gov/ocr
33

APPENDIX B

Sample Section 504 Complaint Form

Date Your School

Your Name Your Phone

Your Address

Person discriminated against/relationship to you

Please describe your concerns and why you believe they raise an issue under Section 504.
Include a description of what happened, when and where it happened, and who was involved.
(Feel free to attach additional pages if necessary)

Explain the steps you have already taken to resolve the issue, if any.

Describe what resolution to your concerns you would like to see.

Please attach any documents or other information you think will help with the investigation of
your complaint.
34

APPENDIX B

Sample Section 504 Impartial Hearing Procedure

1. The parent requests an impartial hearing by filing a written request with district Section
504 Coordinator. The district Section 504 Coordinator is: .

2. The Section 504 Coordinator arranges for an impartial hearing officer.

3. Either the Section 504 Coordinator or the hearing officer gives notice of the time and
place of the hearing at least 10 calendar days before the hearing. Either party may
request that the hearing be rescheduled.

4. The hearing officer holds a telephone conference with the parties to clarify the issues at
least 7 calendar days before the hearing.

5. The parties will provide any documents or other evidence they plan to present at the
hearing to the other party and the hearing officer at least 5 business days before the
hearing.

6. Both parties have the right to accompanied and advised by counsel or other
representative. The parents have the right to open the hearing to the public.

7. The parties will not communicate with the hearing officer about any issue of fact or law
unless the other party has notice and opportunity to participate in the communication.

8. The parents present their arguments and evidence first, followed by the school district.

9. The hearing will be recorded by mechanical device or by certified court reporters. The
parties have the right to request a verbatim record of the hearing.

10. The hearing officer will issue a decision in writing after considering the whole record, but
not more than 45 calendar days after the district received the hearing request.
35
APPENDIX C

Sample Section 504 Coordinator Job Description

Duties and Responsibilities:

Facilitates the implementation of the school board approved Section 504/ADA policy.

Develops, continually revises and ensures the implementation of consistent Section 504
procedures.

Provides ongoing training and support to district staff regarding Section 504 and the
implementation of the Section 504 procedures.

Collects and maintains all Section 504 data (Section 504 plans, lists of eligible students,
discipline records) for future reference.

Continually monitors the reduction of architecture barriers for individuals with disabilities.

Facilitates the provision of reasonable accommodations for district employees with
disabilities.

Serves as a daily resource to district administrators, building level teams, and community
members regarding Section 504/ADA issues.

Coordinates Section 504 /ADA grievance procedures.

Serves as the school districts liaison to the Office for Civil Rights. (OCR complaint
resolution and corrective action plan implementation).

Advises the district superintendent and school board regarding Section 504/ADA compliance
issues and needs.
36
APPENDIX C

Sample Section 504 Building Designee Job Description

Duties and Responsibilities:

Maintains compliant building records and documentation for all eligible students and
provides copies to the District Section 504 coordinator.

Ensures the implementation of Section 504 procedures in the building.
-Coordinates referrals
-Determines appropriate Section 504 team composition
-Facilitates evaluation/eligibility determination
-Provides notices and consents
-Develops Section 504 plans
-Monitors the implementation of Section 504 plans
-Schedules annual reviews of each Section 504 student
-Assures that Section 504 plans move with the student to the next level or new school

Serves as a daily resource to the building administrators, teachers, and community members
regarding Section 504 issues.

Advises the school administrator regarding discipline issues and procedures for Section 504
eligible students being considered for suspension or expulsion.

Serves as a liaison between the school building and other District staff regarding Section 504
issues.

Attends periodic District Section 504 training meetings.
37
APPENDIX D
Sample Section 504 Referral and Recommendations

Referral Date
Student Sex DOB Age
Last First M.I.
Address Parent/Guard./Surrogate
Street City State Zip
School Teacher(s) Grade

Telephone
Home Mother's Work Father's Work

English Proficient YES NO Home Language
Screened by ESL YES NO

Referral made by Position

This referral and function of the Section 504 Team have been discussed with the
Parent/Guardian/Surrogate
YES NO Date

Description of Teacher/School/Parent concern(s)
(circle one)
Provide information to substantiate concern(s) (i.e., pre-referral data, disciplinary information,
screening instruments, observations, anecdotal data, reports, examples of student's work)

Describe interventions already used in attempting to resolve concern(s):

TO BE COMPLETED BY THE SECTION 504 TEAM
Date of Section 504 Team Meeting
Recommendations
Refer for Comprehensive Evaluation under IDEA
Screen by ESL
Screen/evaluate for Section 504 eligibility
Other, Specify

Section 504 Team member responsible to inform Parent/Guardian/Surrogate of
recommendations (circle one):

Name/Position

38
APPENDIX D
Sample Notice of Action/Consent

To: Date:
(Parent/adult student/guardian)
Student's name: DOB

Student ID No.

I. Notice of Action The purpose of this written notice is to inform you that we are:
proposing to initiate
a/an
refusing change

Mark all items below that apply:
evaluation Section 504 plan disciplinary action
eligibility reevaluation other:

Description of the proposed or refused action:

Reason why we are proposing or refusing to take action is:

Date:
(Name of building Section 504 coordinator.)

II. Parent Consent (Only required for initial evaluation and initial placement.)

Yes, I do consent to an initial evaluation for my child.
No, I do not consent to an initial evaluation for my child.

Yes, I do consent for initial placement for my child for a Section 504 plan.
No, I do not consent for initial placement for my child for a Section 504 plan.

Signature: Date:
(parent/adult student/guardian)
Signature: Date:
(parent/adult student/guardian)
Section 504 Coordinator Telephone:

Copies to:
1) Parents/adult student/guardian
2) School Section 504 file
3) District Section 504 coordinator

39

APPENDIX D

Section 504 Notice of Parent/Guardian and Student Rights
This is a notice of your rights under Section 504. These rights are designed to keep you fully
informed about the districts decisions about your child and to inform you of your rights if you
disagree with any of those decisions.

You have the right to:
Have your child participate in and benefit from the districts education program without
discrimination based on disability.
An explanation of your and your childs rights under Section 504.
Receive notice before the district takes any action regarding the identification, evaluation, or
placement of your child.
Refuse consent for the initial evaluation and initial placement of your child.
Have your child receive a free appropriate public education. This includes your childs right
to be educated with non-disabled students to the maximum extent appropriate. It also
includes the right to have the district provide related aids and services to allow your child an
equal opportunity to participate in school activities.
Have your child educated in facilities and receive services comparable to those provided to
non-disabled students.
Have your child receive special education services if she/he needs such services.
Have evaluation, educational, and placement decisions for your child based upon information
from a variety of sources, by a group of persons who know your child, your childs
evaluation data, and placement options.
Have your child be provided an equal opportunity to participate in non-academic and
extracurricular activities offered by the district.
Have educational and related aids and services provided to your child without cost except for
those fees imposed on the parents/guardians of non-disabled children.
Examine your childs education records and obtain a copy of such records at a reasonable
cost unless the fee would effectively deny you access to the records.
A response to your reasonable requests for explanations and interpretations of your childs
education records.
Request the district to amend your childs education records if you believe that they are
inaccurate, misleading, or otherwise in violation of the privacy rights of your child. If the
district refuses this request, you have the right to challenge such refusal.
Request mediation or an impartial due process hearing to challenge actions regarding your
childs identification, evaluation, or placement. You and your child may take part in the
hearing and have an attorney represent you. Hearing requests can be made to the districts
Section 504 coordinator.
Ask for payment of reasonable attorneys fees if you are successful on your claim.
File a local grievance or a complaint with the U.S. Department of Education Office for Civil
Rights (206-607-1600 or www.ed.gov/ocr) or file a complaint in federal court.

The person in this district who is responsible for ensuring that the district complies with
Section 504 is: .
40
APPENDIX D

Sample Section 504 Student Eligibility Form

Name: Date of Meeting:
Date of Birth: School: Grade:
1. Describe the nature of the concern:

2. What is the mental or physical impairment?

3. Describe how the impairment substantially limits the students ability to participate in or
benefit from the districts educational program:

4. Student is eligible under Section 504? Yes No

If no, Team recommendations:

If yes, recommended accommodations/services: ___________________________

Participants Name Title Date

41

APPENDIX D

SAMPLE SECTION 504 PLAN

Students Name: Date:

Section 504 Disability: Birthdate:

School: Grade:

DESCRIBE THE ACCOMMODATIONS THAT WILL BE IMPLEMENTED:

Instructional:

Environmental/Accessibility:

Behavioral/Social:

Assessment/Testing:

Implementation Date: Review Date:

Signature Date Agree/Disagree

Case Manager

Principal/Designee

Teacher

Parent

(Parent-Signature acknowledges consent for proposed plan/placement)

42

APPENDIX D
Sample 2

SECTION 504 Plan

Students Name: Date:
School: Grade: Birthdate:
Section 504 Disability:
(A student with a Section 504 disability is a student who has a physical or mental impairment
that substantially limits one or more major life activities. The terms physical or mental
impairment, substantially limits, and major life activities are to be interpreted broadly.)

Description of Services and Accommodations: The specific services and
accommodations that the student needs to participate in and benefit from the districts education
program include (e.g. list all instructional, environmental/accessibility, behavioral/social, and
assessment/testing/WASL services and accommodations that the student needs):

Implementation Date: Review Date:

Position Signature Date
Case Manager:
Teacher:
Admin/Designee:
Other, specify:
Parent:
Signature acknowledges consent for proposed
plan/placement.

Distribution: Original Special Services; Canary Parent; Pink School
Attachment: Notice of Action and Section 504 Parent/Student Rights
43
APPENDIX D
Sample
SECTION 504 MANIFESTATION REPORT

This form should be used whenever long term suspension or expulsion is being considered as a
consequence for serious misbehavior purportedly committed by a student with an identified
Section 504 disability. The process is twofold: 1) to review the appropriateness of the Section
504 plan and if it was implemented and 2) to determine if the students misbehavior was a
manifestation of his or her Section 504 disability.
Student Name: Birth Date: I.D.
Meeting Date: School: Disability:
Part I
Describe the alleged incident/behavior that initiated this meeting:

Was the conduct in question the direct result of the districts failure to implement the students
Section 504 plan?

Yes_____ No_____

Was the conduct in question caused by, or did it have a direct and substantial relationship to the
students disability?

Yes _____ No______

If the answer to either of the above questions is yes, then the behavior is a manifestation of the
disability.

Signatures of participants:

44
APPENDIX E

ACCOMMODATION EXAMPLES FOR SPECIFIC DISABILITIES
Here are some examples of accommodations and services that might be considered for specific
disability profiles. Please keep in mind that these examples are not intended to be all-inclusive
or mandatory. Do not use these examples as a checklist as accommodations are to be made on
a case-by-case basis specific to individual need. Please also remember that the mere presence of
these conditions does not automatically qualify a student for a Section 504 plan. The disability
must significantly limit one or more life functions before a Section 504 plan is to be considered.
Additionally, this disability must impact the student so that he or she is not afforded access and
benefit of programs and services equal to that of non-disabled students.

ALLERGIES
EXAMPLE: The student has severe allergic reactions to certain pollens and foods. For purposes
of this example the condition substantially limits the major life activity of breathing and may
interfere with the student's ability to get to school or participate once there.

Possible Accommodations and Services:
Avoid allergy-causing substances: soap, weeds, pollen, food
In-service necessary persons: dietary people, peers, coaches, laundry service people, etc.
Allow time for shots/clinic appointments
Use air purifiers
Adapt physical education curriculum during high pollen time
Improve room ventilation (i.e., when remodeling has occurred and materials may cause an
allergy)
Develop health care and/or emergency plans
Address pets/animals in the classroom
Involve school health consultant in school related health issues
Train for proper dispensing of medications; monitor and/or distribute medications; monitor
for side effects

ARTHRITIS
EXAMPLE: A student with severe arthritis may have persistent pain, tenderness or swelling in
one or more joints. A student experiencing arthritic pain may require a modified physical
education program. For purposes of this example, the condition substantially limits the major
life activity of learning.

Provide a rest period during the day
Accommodate for absences for doctors' appointments
Provide assistive devices for writing (e.g., pencil grips, non-skid surface,
typewriter/computer, etc.)
Adapt physical education curriculum
Provide locker assistance
Provide modified eating utensils
Develop health care plan and emergency plan
45

APPENDIX E
Provide for accommodations for writing tasks: a note taker, a computer or tape recorder for
note-taking
Make available access to wheelchair/ramps and school van for transportation
Provide more time for massage or exercises
Adjust recess time
Provide peer support groups
Arrange for instructional aide support
Install handle style door knobs (openers)
Record lectures/presentations
Have teachers provide outlines of presentations
Issue Velcro fasteners for bags
Obtain padded chairs
Provide a more comfortable style of desk
Adjust attendance policy, if needed
Provide a shorter school day
Furnish a warmer room and sit student close to the heat
Adapt curriculum for lab classes
Supply an extra set of books for home use and keep a set at school
Let student give reports orally rather than in writing
Provide an awareness program for staff and students
Monitor any special dietary considerations
Involve school health consultants in school health related issues
Provide post-secondary or vocational transition planning

ASTHMA
EXAMPLE: A student has been diagnosed as having severe asthma. The doctor has advised the
student not to participate in physical activity outdoors. For purposes of this example, the
disability limits the major life activity of breathing.

Adapt activity level for recess, physical education, etc.
Provide inhalant therapy assistance
for side effects
Remove allergens (e.g., hair spray, lotions, perfumes, paint, latex)
Make field trips that might aggravate the condition non-mandatory and supplement with
videos, audiotapes, movies, etc.
Accommodate medical absence by providing makeup work, etc.
Adjust for administration of medications
Provide access to water, gum, etc.
Adapt curriculum expectations when needed (i.e., science class, physical education, etc.)
Develop health care and emergency plans
Have peers available to carry materials to and from classes (e.g., lunch tray, books)
Provide rest periods
Make health care needs known to appropriate staff
46

APPENDIX E
Provide indoor space for before and after school activities
Have a locker location which is centralized and free of atmosphere changes
Adapt attendance policies, school day duration, or 180-day requirement, if needed
Place student in most easily controlled environment

ATTENTION DEFICIT DISORDER (ADD) AND
ATTENTION DEFICIT HYPERACTIVE DISORDER (ADHD)
EXAMPLE: The student does not meet eligibility requirements under IDEA as emotionally
disturbed, learning disabled, or other health impaired. A doctor regards the student as having
ADD, and for purposes of this example, the disability limits the major life activity of learning.
The student, because of his disability, is unable to participate in the school's programs to the
same degree as students without disabilities and therefore is substantially limited by the
disability.

Seat the student away from distractions and in close proximity to the teacher
State classroom rules, post in an obvious location, and enforce consistently
Use simple, concise instructions with concrete steps
Provide seating options
Tolerate (understand the need) excessive movement
Provide a peer tutor/helper
Teach compensatory strategies
for side effects
Monitor for stress and fatigue; adjust activities
Adjust assignments to match attention span, etc.
Vary instructional pace
Vary instructional activities frequently
Provide supervision during transitions, disruptions, field trips
Model the use of study guides, organizing tools
Accommodate testing procedures; lengthy tests might be broken down into several shorter
administrations
Provide counseling and prompt feedback on both successes and areas needing improvement
Initiate frequent parent communication
Establish a school/home behavior management program
Provide training for staff
Have the student use an organizer; train in organizational skills
Establish a nonverbal cue between teacher and student for behavior monitoring
Assign chores/duties around room/school
Adapt environment to avoid distractions
Reinforce appropriate behavior
Have child work alone or in a study carrel during high stress times
Highlight required or important information/directions
Provide a checklist for student, parents, and/or teacher to record assignments of completed
tasks

47

APPENDIX E
Use a timer to assist student to focus on given task or number of problems in time allotted;
stress that problems need to be done correctly.
Have student restate or write directions/instructions
Allow student to respond in variety of different modes (i.e., may place answers for tests on
tape instead of paper)
Give student opportunity to stand/move while working
Provide additional supervision to and from school
Adapt student's work area to help screen out distracting stimuli
Grade for content integrity not just neatness/presentation
Schedule subjects which require greater concentration early in the day
Supply small rewards to promote behavior change
Avoid withholding physical activity as a negative reinforcer
Allow for periodic, frequent physical activity, exercise, etc.
Determine trigger points and prevent action leading to trigger points
Provide for socialization opportunities, such as circle of friends

BIPOLAR DISORDER
EXAMPLE: The student was diagnosed as having a bipolar disorder, however the severity
(frequency, intensity, duration considerations) of the condition did not qualify the student for
IDEA. A properly convened Section 504 committee determined that the condition did
significantly impair the major life activity of learning and fashioned a Section 504 plan for the
student.

Break down assignments into manageable parts with clear and simple directions, given one at
a time
Plan advanced preparation for transitions
Monitor clarity of understanding and alertness
Allow most difficult subjects at times when student is most alert
Provide extra time on tests, class work, and homework if needed
Strategies in place for unpredictable mood swings
Provide appropriate staff with training on bipolar disorder.
Create awareness by staff of potential victimization from other students
Implement a crisis intervention plan for extreme cases where student gets out of control and
may do something impulsive or dangerous
Provide positive praise and redirection
Report any suicidal comments to counselor/psychologist immediately
Consider home instruction for times when the students mood disorder makes it impossible
for him to attend school for an extended period

CANCER
EXAMPLE: A student with a long-term medical problem may require special accommodations.
Such a condition as cancer may substantially limit the major life activities of learning and caring
for oneself. For example, a student with cancer may need a class schedule that allows for rest
and recuperation following chemotherapy.
48

APPENDIX E

Adjust attendance policies
Limit numbers of classes taken; accommodate scheduling needs (breaks, etc.)
Send teacher/tutor to hospital, as appropriate
Take whatever steps are necessary to accommodate student's involvement in extra-curricular
activities if they are otherwise qualified
Adjust activity level and expectations in classes based on physical limitations; don't require
activities that are too physically taxing
for side effects
Provide appropriate assistive technology
Provide dietary accommodations
Provide a private area in which to rest
Shorten school day
Arrange for home tutoring following treatment
Send additional set of texts and assignments to hospital schools
Tape lessons. Accept the fact that the lessons and content-area tests may not be appropriate;
the student is learning many life lessons through this experience
Adjust schedule to include rest breaks
Provide counseling; establish peer group support
Adapt physical education
Provide access to school health services
Provide awareness training to appropriate staff and students
Develop health care emergency plan to deal with getting sick at school
Offer counseling for death and dying to peers/teachers/staff
Furnish a peer tutor
Provide student with a student buddy for participation in sports
Initiate a free pass system from the classroom
Provide lessons using mastery learning techniques
Provide individual school counseling
Begin friendship groups for the student
Provide teachers with counseling, emphasizing positive attitudes
Have a health plan for care of mediport/any other intravenous lines and medical needs
Plan ongoing communication about school events
Notify parents of communicable diseases in school
Designate a person in school to function as liaison with parents as a means of updating
changing health status

CEREBRAL PALSY
EXAMPLE: The student has serious difficulties with fine and gross motor skills. A wheelchair
is used for mobility. For purposes of this example, the condition substantially limits the major
life activity of walking. Cognitive skills are intact.

49

APPENDIX E
Provide assistive technology devices
Arrange for use of ramps and elevators
Allow for extra time between classes
Assist with carrying books, lunch trays, etc.
Provide for physical therapy as appropriate. Such therapy needs to relate directly to "life
skills"
Train for proper dispensing of medications; monitor and/or distributed medications; monitor
for side effects
Adapt eating utensils
Initiate a health care plan that also addresses emergency situations
Train paraprofessionals in the case of this student (i.e. feeding, diapering, transporting to and
from the wheelchair)
Adapt assignments
Educate peers/staff with parent/student permission
Ensure that programs conducted in the basement or on second or third floor levels are
accessible
Ensure that bathroom facilities, sinks and water fountains are readily accessible.
Provide post-secondary or vocational transition planning.

CHRONIC INFECTIOUS DISEASES
(i.e., Acquired Immune Deficiency Syndrome (AIDS)
EXAMPLE: The student frequently misses school and does not have the strength to attend a full
day. For purposes of this example, the student has a record of a disability, which substantially
limits the major life activities of learning. Please review applicable District policies.

In-service staff and students about the disease, how it is transmitted and how it is treated
(Consult appropriate District policies)
Apply universal precautions
Administer medications following medication administration protocols, train for proper
dispensing of medications; monitor and/or distribute medications; monitor for side effects
Adjust attendance policies
Adjust schedule or shorten day
Establish routine communication with health professionals, area nurse, and home
Develop health-care and emergency plan
Consult with doctor, parents, teachers, area nurse, and administrators
Train appropriate teachers on medical/emergency procedures
Provide two-way audio/video link between home and classroom via computer, etc.
Arrange for an adult tutor at school or home
Adapt assignments and tests
Provide an extra set of textbooks for home
50

APPENDIX E
Provide staff training on confidentiality
Provide education and support for peers regarding issues of death and dying
Provide transportation to and from school if needed as a related service
Tape books or provide a personal reader
Arrange to communicate with a home computer with e-mail
Notify parents of communicable disease in the classroom
Arrange for participation in a support group
Provide for post-secondary employment transitions for secondary students
Foster supportive community attitudes regarding the District's need to provide education to
HIV positive/AIDS students
Develop and promote a nondiscriminatory classroom climate and supportive student attitudes
Promote the most supportive, least restrictive educational program
Initiate a "Kids on the Block" AIDS program
Videotape classroom teaching
Provide a peer support group to encourage communication
Involve school health consultant in school-related health issues

CYSTIC FIBROSIS
EXAMPLE: This student is a new enrollee at your school and has an extensive medical history.
He has significant difficulty breathing and will often be absent due to respiratory infection.
While medical needs can be easily documented on a health plan, his educational needs also need
to be accommodated. For purposes of this example, learning is the major life activity that is
substantially impaired.

for side effects
Create a health care plan for management of acute and chronic phases
Promote good communication between parents, hospital, home, and school on school
assignments
Shorten the school day
Adapt physical education activities
Apply universal precautions, correct disposal of fluids
Recognize need for privacy for good coughing
Educate staff and peers

DEAF/HEARING IMPAIRMENT
EXAMPLE: A student was diagnosed with a substantial hearing impairment at a very early age.
Therefore, he has both a hearing loss and a mild speech impediment. He compensates through
both lip reading and sign language. Academic abilities test in the average range.

Allow for written direction/instructions in addition to oral presentation
Ensure delivery of instruction facing the student to allow lip reading
Provide visual information as primary mode of instruction
Allow for provision of interpreter services
51

APPENDIX E
Install acoustical tile, carpeting
Seat in a location with minimal background noise
Provide paper and pencil/pen to write/draw requests when needed
Facilitate acquisition of TDDs and related assistive technology
Allow for extra time between classes

DIABETES
EXAMPLE: A sixth grader with juvenile diabetes requires accommodation to maintain optimal
blood sugar. His mom provides the crackers and juice to be used at "break" time and before
physical education class. She asks that teachers remind him to eat at a certain time of the
morning if he does not pay attention to the beeper on his watch. The youngster is very self
sufficient; while he is able to monitor his own blood sugar now, he prefers to do this privately.
Therefore, mom asks that the equipment and a notebook/log be stored in a nearby file cabinet
and the youngster be allowed to go into the hall with the equipment to check his blood sugar
twice a day. She also asks that his teacher allow him to use the bathroom as needed.

Health care plan for management of condition in the school setting and in emergencies
Educate staff to signs/symptoms of insulin reaction/hypoglycemia; hunger, shakiness,
sweatiness, change in face color, disorientation, drowsiness
Do not leave the child alone if he/she is feeling poorly; walk to the office or clinic with the
student.
for side effects; communicate systematically and frequently with parents
Adapt physical education activities
Store equipment and documentation in a readily accessible location for student, parent, and
area nurse or clinic aid
Accommodate food access/meal schedules rigorously
Allow access to bathroom facilities

DRUGS AND ALCOHOL
EXAMPLE: The student has used drugs and alcohol for many years. This problem has affected
the major life activities of learning and caring for oneself. The student is presently not using
drugs or alcohol and is in a rehabilitation program. If the student is not using drugs or alcohol,
he or she could qualify for accommodations or services under Section 504.

Provide copies of texts and assignments to treatment facility
Arrange for periodic home-school contacts
Establish daily/weekly assignments monitoring system
Communicate with treatment facility; pursue transition services available through the
treatment facility
Provide/arrange for counseling
Establish peer support group
52

APPENDIX E
Dismiss from school for treatment without punitive measures
Ensure strong link with school counselor
Arrange for access to treatment at private or public facilities.
Integrate a student assistance program into the classroom
In-service faculty/staff with parent/student permission
Provide ongoing support around chemical dependency in conjunction with other agencies
for side effects

EMOTIONALLY DISTURBED
EXAMPLE: An emotionally disturbed student may need an adjusted class schedule to allow
time for regular counseling or therapy. For purposes of this example, the condition substantially
limits the individual's major life activity of learning.

for side effects
Maintain weekly/daily journals for self-recording of behavior
Establish home-school communication system
Schedule periodic meetings with home and treatment specialists
Provide carry-over of treatment plans into school environment
Assist with inter-agency referrals
Utilize behavior management programs
Develop contracts for student behavior
Post rules for classroom behaviors; teach expectations
Provide counseling, social skills instruction
Reinforce replacement behaviors
Educate other students/staff/school personnel
Foster carryover of treatment plans to home environment
Reinforce positive behavior
Schedule shorter study/work periods according to attention span capabilities
Be consistent in setting expectations and following up on reinforcements/consequences

ENCOPRESIS/ENURESIS
EXAMPLE: A student who will urinate or defecate in clothes. Not to be confused with physical
incontinence, but only to a needed behavior change (i.e. toilet training, bowel/bladder retraining).

Possible Accommodations:
Maintain low key responses
Have a change of clothes available at school in the clinic or alternative location
Plan a consistent response to events; send student to clinic or alternative location for clean-up
and change of clothes; while wearing latex/rubber gloves, place soiled clothes in a plastic
bag; call parent and make arrangements for soiled items to be returned home
53

APPENDIX E
Observe for consistent trigger events
Support bowel/bladder retraining program that is recommended by the physician

EPILEPSY
EXAMPLE: The student is on medication for seizure activity, but experiences several petit mal
seizures each month. This condition substantially limits the major life activity of learning.

Call parent and document the characteristics of each seizure
Assess breathing after seizure
for side effects
Train staff and students and prepare an emergency plan
Anticipate recovery process should a seizure occur. Move seating/clear space during seizure.
Do not insert objects into the student's mouth during seizure; administer no fluids if student is
unconscious. Turn the unconscious student on his or her side to avoid aspiration of vomit.
Provide rest time and return to academic considerations following seizure.
Arrange a buddy system, especially for field trips
Avoid portable chalk boards or furniture that would topple over easily
Provide an alternative recess, adapt activities such as climbing and/or swimming
Plan for academic make-up work
Alter door openings to allow access from the outside (i.e., bathroom stall doors that swing
both ways)
Observe for consistent triggers (e.g., smells, bright light, perfume, hair spray)

HEARING IMPAIRMENT
EXAMPLE: A parent is hearing impaired and requests, access to school sponsored activities.
The District makes accommodations by providing interpreter services for the parent to
participate effectively in school-sponsored events or meetings about the student.

Provide an interpreter for those school events where accommodations may be necessary/are
requested
Make alternative arrangements for home-school contacts/communication
Assist with locating peer or support groups
Use written notes for communication
Arrange with phone company for assistive devices on public phones
Provide information on assistive technology; acquire assistive equipment for school use
Provide in-house TDD or relay services to receive/communicate efficiently

LEARNING DISABILITIES
Individual profiles of learning strengths and weaknesses will vary. THE EXAMPLE: The
student has a learning disability that impacts her ability to read. She has more difficulty with
54

APPENDIX E

word decoding and spelling than reading comprehension. Thus, completing reading tasks is
difficult and slow. She is currently a student receiving special education services.

Provide lower-readability materials covering course context
Provide extended time on tests
Arrange for student/volunteer readers
Provide information on accessing materials through recordings for the Blind and Dyslexic
(i.e., books on tape)
Allow access to spell checkers and/or word processing
Provide information on accommodations for college-entrance/qualifying exams (i.e., PSAT)
Written directions in addition to oral
Clearly sequenced instruction
Visual graphs/charts/diagrams to support instruction
Provision of computer access
Seating toward the instructor
Support/suggestions relative to post-secondary/career options
Support in the use of organizational/time-management strategies
Support in the use of strategies to assist memory and problem-solving
Use of multi-sensory instructional methods (i.e., visual graphs and charts to accompany oral
presentation)

LEUKEMIA
EXAMPLE: The student has recently been diagnosed with leukemia and requires frequent
hospitalization. The condition substantially limits the major life activity of learning and caring
for oneself.

Involve area nurse in assessing current limitations and development of health plan
Provide homebound instruction if needed
Provide the student with an adjusted school day
Make needed accommodations during physical education/recess
Have medical services and medication available at school. Train for proper dispensing of
medications; monitor and/or distribute medications; monitor for side effects
Support the proper diet as per physical recommendation
With parent/student permission, have area nurse to educate teachers/staff/peers
Notify parents of existing communicable diseases at school (i.e., chicken pox, flu, strep
throat, etc.)
Consult with medical staff about individual needs and/or concomitant factors

55

APPENDIX E

ORTHOPEDICALLY IMPAIRED
EXAMPLE: The student has limited mobility and uses a wheelchair. This condition
substantially limits the major life activity of walking.

Develop a health care and emergency plan
Implement an adaptive physical education program
Provide physical therapy at school
Correct problems with physical accessibility of facilities/pathways between buildings
Provide extra time to get to class
Supply a set of textbooks for home
Provide a copy of class notes from a peer
Practice emergency exit from school building
Ensure that access to programs held in the basement or on second or third floors is
handicapped accessible
Ensure that bathroom facilities, water fountains, sinks, etc. are readily accessible

STUDENT WITH SPECIAL HEALTH CARE NEEDS
EXAMPLE: The student has a special health care problem and requires clean intermittent
catherization twice each day. This procedure empties the bladder and helps prevent urinary tract
infections and possible wetting. The school is required to provide trained personnel to perform
the procedure or to provide the student a private location to perform the procedure. The
condition is substantially limiting in the major life activity of caring for oneself.

Apply universal precautions
Provide trained personnel to perform special medical procedures. Train for proper
dispensing of medications; monitor and/or distribute medications; monitor for side effects
Provide student with private location and time to perform procedures
Involve area nurse, parents, teachers, and staff in periodic review
Allow preferential seating as indicated by need
Adapt recess, physical education, and transportation
Adjust classroom environment
Develop health care and emergency plan
If necessary, adapt attendance policy
Establish health alert system whereby every staff member involved with this student is aware
of the health problem and of proper procedures
Provide a beeper/paging system for trained personnel
Make available homebound services/instruction if needed
Provide school counseling
Arrange for in-service to other students and staff with parent/student permission

56

APPENDIX E

TEMPORARILY DISABLED
EXAMPLE: A student was in an automobile accident and will be homebound and/or
hospitalized for an extensive period. The student is considered temporarily disabled under
Section 504 and should receive accommodations if this disability substantially limits a major life
activity for the period of time it does so.

Provide duplicate sets of texts
Provide assignments to hospital school
Tape lessons
Provide homebound instruction
Schedule periodic home-school meetings
Arrange for student to leave class early to get to next class
Provide access to elevators
Excuse from or adapt physical education program
Arrange for a friend to assist student in getting from class to class, provide help with getting
lunch tray
Establish a student support network
Provide a cordless telephone/beeper/pager
Provide an interactive system -- computer, e-mail, TV
Arrange for peer notes
Change seating arrangements to accommodate needs
Adapt assignments depending on disability
Allow more time for test completion
Allow shortened days; adjust attendance policy
In-service staff and class and prepare an emergency care plan
Switch programs /classes to an accessible classroom on the main floor
Test verbally
Provide peer assistance for social involvement (i.e., to keep child informed of social
activities)
Furnish life-skill assistance
Provide area nurse services

TOURETTE'S SYNDROME
EXAMPLE: The student exhibits inappropriate gestures and sounds in the classroom and
hallways. The condition is substantially limiting in the major life activities of learning and
caring for oneself.

Provide student with a means of catching up on missed lessons
Pair with a fellow student for study if indicated
Educate other students about associated outbursts/gestures/tics
Arrange for frequent parental interaction if indicated
Monitor administration/side effects of medication
57

APPENDIX E

Implement a behavior management program if indicated; cue student about inappropriate
behaviors
Provide supervision for transition activities, during periods of "acting out"
Provide alternative/larger work space or appropriate space for the child to act out if indicated
Teach compensatory strategies
Adapt assignments if indicated
Provide peer/teacher in-service with parent/student permission

TRAUMATIC BRAIN INJURY
EXAMPLE: The student sustained a brain injury in an automobile accident. Many academic
and motor skills have been lost from the injury. The student does not qualify for special
education under IDEA. The condition is substantially limiting to the major life activities of
learning and performing manual tasks.

Provide extended school year/time
Furnish memory/organizational aids
Provide alternative testing
Initiate tutoring programs
Arrange an emergency plan
Monitor for seizure activity
In-service staff and peers with student/parent permission
Monitor fatigue/mental exhaustion
Provide frequent short breaks during periods of intense concentration
Shorten the instructional day if indicated
Provide strategies for organizing/sequencing tasks

TUBERCULOSIS
EXAMPLE: The student is suspected of having active tuberculosis and must stay home until
diagnostic tests are completed. The disease is no longer infectious, but the student is still weak.
The condition is substantially limiting to the major life activity of learning.

Provide home tutor, as necessary
In-service staff on the need for confidentiality to limit the stigmatization of him or her
Have the medical evaluator provide feedback to staff
for side effects
In-service staff and students about the disease, how it is transmitted, and how it is treated
Work with community agency or health department to provide medication and health
education materials

58

APPENDIX E

Work with community agency or health department to test students and staff for exposure
and/or infection and to determine when the student can return to school
Provide therapy and dispense medications if student is diagnosed with active TB; observed
for side effects; arrange for parents to give medication on holidays and weekends

VISUAL IMPAIRMENT
EXAMPLE: A student has a progressive medical disorder, which results in increasing loss of
visual acuity. He now requires both enhanced lighting and enlarged print materials in order to
read.

Preferential seating
Adaptations to the physical environment (i.e., consistent room arrangement, removal of
obstacles to path of entry)
Copies of text/reading materials for adaptation
Modified writing tools (i.e., dark felt tip pens)
Perkins Brailler
Slate and stylus
Raised lines on writing paper
Dark lined writing paper
Lighting aids
Low vision devices including magnifiers, monocular glass, closed-circuit TV
Desktop slantboard
Enlarged print materials; textbooks, workbooks, worksheets
Braille textbooks/reading materials
Books on tape
Audiotape recorder, tapes and organizational location (headphones if needed)
Oral instead of written tests
Standardized tests (i.e., CAT, SAT) in large print or Braille
Tactile maps
Computer with enlarged print screen/adaptations
Speech synthesizer for input and output
Screen reading device
Optical Character Recognition System Scanner
Mobility devices (i.e., white cane)
Abacus

WEIGHT: DIAGNOSIS OF OBESITY, ANOREXIA, AND BULIMIA
EXAMPLE: A student has an extreme eating disorder that may require special accommodations.
Obesity may be considered a disability under Section 504 where it substantially impairs a major
life activity or is regarded by others as doing so.

59

APPENDIX E
Provide special seating modifications
Make dietary modifications per physician recommendation
Adapt physical education program per physician recommendation
Allow extra time to get to classes
Educate peers
Adapt rest rooms
Provide opportunities for socialization and peer counseling/interaction
Ensure privacy for self-care
Provide counseling involving the area nurse
Provide for elevator privileges per physician's recommendation
Arrange for counselor/area nurse to supervise peer counseling to deal with esteem issues,
peer attitudes, teasing, etc.
Address busing concerns to ensure room on buses for seating
Arrange to provide opportunities for the individual to participate in intramural and extra-
curricular events
Make any class location changes that may be needed

Resource:
Jefferson County Colorado School District
60

APPENDIX E

CLASSROOM AND FACILITY ACCOMMODATIONS

As local districts develop policies and procedures for guiding the referral and identification of
students determined to be disabled under Section 504, it is critical that information concerning
this law and its impact on local school districts be shared with principals and building-level staff.
The intent of Section 504 is to accommodate for differences within the regular education
environment. For this to be accomplished, all staff must be provided with awareness activities
and given specific information concerning the districts procedures for dealing with Section 504
referrals.

As individual students are identified, the classroom teacher may need specific training in the area
of the identified disability (e.g., training from the school nurse on a danger signs of an impending
asthma attack, training from a physical therapist on correct positioning of a wheelchair-using
student at this/her desk, etc.) The following classroom/facility accommodations are presented as
examples of ways in which Section 504 disabilities may be successfully addressed within the
regular education environment.

The following information provides examples of ways in which the needs of children with
disabilities (or Section 504 disabilities) may be accommodated in the regular classroom
environment.

AREA OF CONCERN ACCOMMODATIONS
Parent/student/teacher
communications
Develop a daily/weekly journal.
Develop parent/student/school contacts.
Schedule periodic parent/teacher meetings.
Provide parents with duplicate set of texts.

Staff Communications Identify resource staff.
Network with other staff.
Schedule building team meetings.
Maintain ongoing communication with building
principal.

School/community/agency
communication
Identify and communicate with appropriate personnel
working with student.
Assist in agency referrals.
Provide appropriate carryover in the school
environment.

Instructional day Allow student more time to pass in hallways.
Modify class schedule.

Modification of
classroom/building climate to
accommodate student needs

Plan for evacuation for wheelchair-using students.
Schedule classes in accessible areas.
61

Building health/safety procedures Administer medication.
Apply universal precautions.
Accommodate special diets.

Difficulty sequencing and
completing steps to accomplish
specific tasks (e.g., organized
paragraphs, division problems,
etc.)
Break up task into workable and obtainable steps.
Provide examples and specific steps to accomplish task.
Shifting from one uncompleted
activity to another without closure
Define the requirements of a completed activity (e.g.,
Your math is finished when all 6 problems are complete
and corrected; Do not begin on the next task until it is
finished).

Difficulty following through on
instructions from others
Gain students attention before giving directions. Use
alerting cues. Accompany oral directions with written
directions.
Give one direction at a time. Quietly repeat directions to
the student after they have been given to the rest of the
class. Check for understanding by having the student
repeat the directions.
Place general methods of operation and expectations on
charts displayed around the room and/or on sheets to be
included in students notebook.

Difficulty prioritizing from most
to least important
Prioritize assignments and activities.
Provide a model to help students. Post the model and
refer to it often.

Difficulty sustaining effort and
accuracy over time
Reduce assignment length and strive for quality (rather
than quantity).
Increase the frequency of positive reinforcement (catch
the student doing it right and let him know it).
Difficulty completing
assignments
List and/or post (and say) all steps necessary to complete
each assignment.
Reduce the assignment into manageable sections with
specific due dates
Make frequent checks for work/assignment completion.
Arrange for the student to have a study buddy with
phone number in each subject area.
Difficulty with any task that
requires memory
Combine seeing, saying, writing and doing--student may
need to subvocalize to remember.
Teach memory techniques as a study strategy (e.g.,
mnemonics, visualization, oral rehearsal, numerous
repetitions).
62

Difficulty with test taking Allow extra time for resting, teach test-taking skills and
strategies, and allow student to be tested orally.
Use clear, readable and uncluttered test forms. Use test
format that the student is most comfortable with. Allow
ample space for student response. Consider having lined
answer spaces for essay or short answer questions.
Confusion from non-verbal cues
(misreads body language, etc.)

Directly teach (tell the student) what nonverbal cues
mean.
Model and have student practice reading cues in a safe
setting.
Confusion from written material
(difficulty finding main idea from
a paragraph, attributes greater
importance to minor details)
Provide student with copy of reading material with main
ideas underlined or highlighted.
Provide an outline of important points from reading
material.
Teach outlining, main idea/details concepts.
Provide tape of text/chapter
Confusion from spoken material,
lectures and audio-visual material
(difficulty finding main idea from
presentation, attributes greater
importance to minor details)
Provide student with a copy of presentation notes.
Allow peers to share notes from presentation (have
student compare own notes with copy of peers notes).
Provide framed outlines of presentations (introducing
visual and auditory cues to important information).
Encourage use of tape recorder.
Teach and emphasize key words (the following the
most important point. etc.).
Difficulty sustaining attention to
tasks or other activities (easily
distracted by extraneous stimuli)
Reward attention. Break up activities into small units.
Reward for timely accomplishments.
Use physical proximity and touch. Use earphones and/or
study carrels, quiet place, or preferential seating.
Frequent messiness or sloppiness Teach organizational skills. Be sure student has daily,
weekly and/or monthly assignment sheets, list of
materials needed daily, and consistent format for papers.
Have a consistent way for students to turn in and receive
back papers, reduce distractions.
Give reward points for notebook checks and proper
paper format.
Provide clear copies of worksheets and handouts and
consistent format for worksheets. Establish a daily
routine; provide what you want the student to do.
Arrange for a peer who will help with organization.
Assist student to keep materials in a specific place (e.g.,
pencils and pens in pouch).
Be willing to repeat expectations.
63

Poor handwriting (often mixing
cursive and manuscript and
capitals with lower-case letters)
Allow for a scribe and grade for content, not
handwriting.
Allow for use of a computer or typewriter.
Consider alternative methods for student response (e.g.,
tape recorder, oral reports, etc.).
Dont penalize student for mixing cursive and
manuscript (accept any method of production).
Difficulty with fluency in
handwriting (e.g., good
letter/word production but very
slow and laborious)
Allow for shorter assignments (quality vs. quantity)
Allow alternate method of production (computer, scribe,
oral presentation, etc.).
Poorly developed study skills

Teach study skills specific to the subject area
organization (e.g., assignment calendar), textbook
reading, note taking (finding main idea/detail, mapping,
outlining, skimming, summarizing).
Poor self-monitoring (careless
errors in spelling arithmetic,
reading)
Teach specific methods of self-monitoring (e.g., Stop-
Look-Listen).
Have student proofread work when it is cold.

Low fluency or production of
written material (takes hours on a
10 minute assignment)
Allow for alternative method for completing assignment
(oral presentation, taped report, visual presentation,
graphs, maps pictures, etc.) with reduced written
requirement.
Allow for alternative method of writing (e.g., typewriter,
computer, cursive or printing, or a scribe).

Apparent inattention
(underachieve, daydreaming, not
there)
Get students attention before giving directions, tell
student how to pay attention, (Look at me while I talk;
watch my eyes while I speak.) Ask student to repeat
directions.
Attempt to actively involve student in lesson (e.g.,
cooperative learning).

Difficulty participating in class
without being interruptive,
difficulty working quietly

Seat student in close proximity to the teacher.
Reward appropriate behavior (catch student at being
good).
Use study carrel if appropriate
Inappropriate seeking of attention
(clowns around, exhibits loud
excessive or exaggerated
movement as attention-seeking
behavior, interrupts, butts into
other childrens activities, needles
others)
Show student (model) how to gain others attention
appropriately.
Catch the student when appropriate and reinforce.
64

Frequent excessive talking Teach student hand signals and use to tell student when
and when not to talk.
Make sure student is called upon when it is appropriate
and reinforce listening.
Difficulty making transitions
(from activity to activity or class
to class); takes an excessive
amount of time to find pencil,
gives up, refuses to leave
previous task; appears agitated
during change
Program student for transitions. Give advance warning
of when a transition is going to take place (Now we are
completing the worksheet, next we will) and the
expectation for the transition (and you will need).
Specifically say and display lists of materials needed
until a routine is possible. List steps necessary to
complete each assignment.
Have specific locations for all materials (pencil pouches,
tabs in notebooks, etc.).
Arrange for an organized helper (peer).
Difficulty remaining seated or in
a particular position when
required to
Give student opportunities to get up and move around.
Allow space for movement.
Frequent fidgeting with hands,
feet or objects; squirming in seat
Break tasks down into small increments and give
frequent positive reinforcement for accomplishments
(this type of behavior is often due to frustration).
Allow alternative movement when possible.
Inappropriate responses in class
often blurted out; answers given
to questions before they have
been completed
Seat student in close proximity to teacher so that visual
and physical monitoring of student behavior can be done
by the teacher.
State behavior that you do want (tell the student how
you expect him to behave).
Agitation under pressure and
competition (athletic or
academic)
Stress effort and enjoyment for self, rather than
competition with others.
Minimize timed activities; structure class for team effort
and cooperation.
Inappropriate behaviors in a team
or large group sport or athletic
activity (difficulty waiting turn in
games or group situations)

Five the student a responsible job (e.g., team captain,
care and distribution of the balls, scorekeeping, etc.);
consider leadership role.
Have student in close proximity to teacher.
Frequent involvement in
physically dangerous activities
without considering possible
consequences

Anticipate dangerous situations and plan for in advance.
Stress Stop-Look-Listen.
Pair with responsible peer. (Rotate responsible students
so that they dont wear out!)
Poor adult interactions
Defies authority
Sucks up
Hangs on

Provide positive attention.
Talk with student individually about the inappropriate
behavior (What you are doing is, A better way of
getting what you want or need is).
65

Frequent self-putdowns, poor
personal care and posture,
negative comments about self and
others, low self-esteem
Structure for success.
Train student for self-monitoring, reinforce
improvements, teach self-questioning strategies (What
am I doing? How is that going to affect others?)
Allow opportunities for the student to show his strength.
Give positive recognition.
Difficulty using unstructured time
recess, hallways, lunchroom,
locker room library, assembly
Provide student with a definite purpose during
unstructured activities (The purpose of going to the
library is to check out, the purpose ofis).
Encourage group games and participation (organized
school clubs and activities).
Losing things necessary for task
or activities at school or at home
(e.g., pencils, books, assignments
before, during and after
completion of a given task)
Help student organize. Frequently monitor notebook
and dividers, pencil pouch, locker, book bag, desks. A
place for everything and everything in its place.
Provide positive reinforcement for good organization.
Provide student with a list of needed materials and their
locations.
Poor use of time (sitting, staring
off into space, doodling, not
working on task at hand)
Teach reminder cues (a gentle touch on the shoulder,
hand signal, etc.).
Tell the student your expectation of what paying
attention looks like: (You look like you are paying
attention when).
Give the student a time limit for a small unit of work
with positive reinforcement for accurate completion.
Use a contact, timer, etc., for self-monitoring.

Resource:
Anchorage School District Attention Deficit Disorders, Suggested Classroom Accommodations for Specific
Behaviors

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