Section 504 FAQ

Section 504 does not specifically define the term "substantial limitation." The basis for evaluating this criterion is the impact the impairment has on one or more of the student's major life activities. It is vital to understand that for a student to qualify for 504, the impairment must impose, to a "considerable" or "large degree," a limitation to one or more major life activities.
Language acquisition (ELL) is never a disability and cannot support a 504. ELL services do that. The exception would be if a speech/language pathologist diagnosed the child language-impaired even if he/she is ELL.
At least one member of the team, other than parent, takes on the responsibility of checking each accommodation in different educational settings and provides feedback to whomever is responsible for ensuring equal access.
Yes. This is a great idea. The 504 coordinator should also meet personally to go over the plan with each teacher. The best approach for organizing these meetings would be by grade level or subject area teams.
No. Every effort must be made to obtain parent/guardian consent. Home visits or phone conferences are recommended in these cases. In the case of a phone conference, the forms are sent home for signatures.
All team members should sign in sometime during the course of the meeting.

It is important that the team build consensus during both the eligibility and planning phases of the 504 process. When disagreements occur regarding student eligibility, the team should refer to the advice of the person on the team who has the most knowledge about the disability and its impact on the student at school. Once the eligibility is established, accommodations should be designed so that the classroom teacher(s) can implement them with fidelity while meeting the needs of the student.

Or does she/he need a diagnosis from a doctor?

No medical diagnosis is necessary; however, if the parent has doctor reports, then the team can request them. Attention issues don't automatically qualify a student for 504, but if the data presented at the eligibility meeting demonstrates that the attention issues consistently interfere with the child's access to education, the child may qualify.

The information below can be found on pages 8 and 9 of the TUSD 504 Information and Guidelines manual.

It is important that school and district personnel involved in identifying concerns initially engage in the Multi-Tier System of Support (MTSS) process for the individual student. MTSS is a system for efficient instruction; a method for evaluating the needs of all students and fostering positive student outcomes through carefully selected and implemented interventions. It may also be used to assist the school in identifying students who may require more intensive instructional services and or be eligible for a 504 plan. School based teams must be astute and aware of the rights of students with disabilities. 504 team meetings should be immediately convened when a student presents with a noticeable and/or documented disability. In these cases, the MTSS process must not delay the convening of the 504 process.
The information below can be found on page 9 of the TUSD 504 Information and Guidelines manual.

Under Section 504, schools have a responsibility to conduct evaluations of students whom they suspect are disabled and potentially in need of accommodations. The school-based 504 team should include people knowledgeable about the student, the meaning of the evaluation data, and the placement options. The team members must determine if they have enough information to make a knowledgeable decision as to whether or not the student has a disability. The team is required to review and examine a variety of sources in the evaluation process so that the possibility of error is minimized.
Staff development is essential to supporting teachers with effective classroom management strategies and targeted behavior interventions. Encourage conversations about decision making to include the expert advice of staff/faculty members who have a proven record of being successful in coaching and shaping the behavior of students exhibiting challenging behavior. PBIS, data collection, behavior contracts and the strategies listed below might also be useful.
  • Post classroom rules and review with students on a regular basis.
  • Create effective behavior modification plans.
  • Work collaboratively with parents to ensure that the behavioral interventions used at home and at school are monitored closely.
  • Stay consistent in setting behavioral expectations and following through on reinforcements/consequences.
  • Create a behavior contract for the child.
  • Ask the child to keep a daily journal to self-record behavior.
  • Allow the child to participate in group counseling sessions with the school counselor or school psychologist.
  • Implement a crisis intervention plan in case child is uncontrollable, impulsive, or dangerous.
  • Give the child advanced notice of transitions.
  • Create plans for handling unpredictable mood swings.
The team should revisit the 504 plan for the purpose of amending the document. The amendment would include decisions based upon accommodations related to behavioral challenges.
TUSD recommends that the plans are reviewed once a year.
Ensure that the teacher(s) have a copy of the 504 plan and implements the plan with fidelity. Once the student has been at the current school for a period of time, convene a 504 review and amend the plans as needed. Be sure to include the parent/guardian and student in all aspects of the decision-making process.
Here are some suggested accommodations for students with Oppositional Defiant Disorder:
  • Create rules that are clear, predictable, and administered fairly and consistently.
  • Use a picture schedule so that the student can easily see the order of the day [and accompanying visual cues], and predict when transitions will occur.
  • Avoid conflict by ensuring that academic work is on the student's instructional level—not too difficult, and not too easy.
  • Blend non-desirable academic tasks with student-chosen rewards for compliant behavior.
  • Utilize social stories and social skill lessons to ensure systematic instruction of appropriate anger management and conflict resolution skills. Role-play works well with children with and without the disorder.
  • Structure lessons so that the child is required to positively work in peer groups. While maintaining order and predictability, along with monitoring the cooperative group, allow the child a chance to use his or her developing social skills.
  • Stay busy, busy, busy! Transitions and time without specified tasks can be problematic, so adapt student schedules accordingly.
  • Ensure that positive peer social interactions do in fact occur—do not let the child be selected last for a team, or remain standing alone after everyone has already paired off for an activity.
More ideas can be found here.

No medical diagnosis is required; however, a medical diagnosis provides a good piece of information for planning conversations. A documented print disability diagnosis is required for Bookshare, an accessible online library.

Teams need to identify if a student has an impairment that substantially limits one or more major life activities, the team must also determine what reasonable accommodations, if any, are necessary to provide the student an equal opportunity to benefit from the school's programs and activities. The mental or physical impairment criterion includes any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more body systems: neurological; musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genitourinary; hemic and lymphatic; skin; endocrine; or any mental or psychological disorder.
Convene a 504 team meeting to determine student eligibility, document the determination on the 504 Eligibility Form using SYNERGY.
At this point in time, as technology transforms at a rapid pace, it is more beneficial for students to have their 504 team ask directed questions to guide the need and select types of accommodations. The team can then follow up with a trial implementation period, which would include data collection as part of the TUSD Assistive Technology process. See page 17 in the Section 504 Information and Guidelines manual for more information about the AT Consideration Process in TUSD. Additional resources for school teams can be found on the TUSD Exceptional Education Department website, and through the Arizona Department of Education website.
Intervention Central is a good web resource for locating effective tried-and-true interventions. 
Under Governing Board Policy IHBA, you have the option of formally or informally resolving any concerns you may have about your child's disability accommodations, Section 504 evaluation or Section 504 accommodations. Regulation IHBA-R - Complaints under Section 504 and ADA provides a description of the complaint process and contact information for where to file a complaint.
Posted/Revised Date
Frequently asked questions about Section 504 accommodations for students.
article, 2022-2023, school, tucson, register, exceptional education, section 504
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