IEP vs 504 Plan: What’s the Difference?

September 29, 2023
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IEP vs 504 plan – The difference between the two can be summed up as follows: IEPs and 504 plans provide accommodations for students with disabilities. However, an IEP requires K-12 students to receive specialized instruction. On the other hand, 504 plans serve K-12 students and beyond but only address the needs directly related to the student’s disability.

What Is an IEP?

An individualized education plan, or IEP, is a working document defined under the federal Individuals With Disabilities Education Act (IDEA) that provides an educational blueprint for children with disabilities.

IEPs are created by school administrators, teachers, parents, psychologists, and other professionals and outline the milestones and goals students must attain based on their unique capabilities. Students enrolled in special education services or programs have IEPs.

What Is a 504 Plan?

A 504 plan refers to Section 504 of the Rehabilitation Act of 1973 and states that any school or organization receiving federal funds is prohibited from discriminating against individuals with disabilities.

In school settings, any student with a learning disability can, for instance, sit at the front of the class, be allocated extra time to complete homework, assignments, or tests, or use learning materials in a format they understand. School administrators, teachers, parents, and specialists determine the accommodations students with disabilities receive under their 504 plan.

What’s the Difference?

IEPs focus on the educational supports students with disabilities receive and are available to individuals with specific intellectual or physical impairments or disabilities. These educational supports may include, but are not limited to, occupational and/or speech therapy.

On the other hand, 504 plans focus on ensuring that students with disabilities have equitable access to learning environments. They typically cover a broader range of disabilities and impairments, including, but not limited to, attention deficit disorders.

What’s the Advantage of Having an IEP or 504 Plan?

IEPs and 504 plans exist to help students with disabilities – ranging in severity from minor learning impairments to major intellectual, emotional, or physical disabilities – keep up with the curriculum and succeed in school. They allow students to thrive in a general education classroom while helping to minimize disruption to their learning.

How to Tell if a Student Needs an IEP vs 504 Plan

To identify whether a student needs an IEP vs 504 plan, schools will usually assess the child to determine which plan they qualify for based on the nature and severity of their disability or impairment.

While parents can pay for a private evaluation and present the report to the school administrator, schools are not obligated to adopt those recommendations. The school must carry out an independent evaluation of the student to determine their eligibility.

For a student to qualify for an IEP plan, the disability or health impairment must inhibit their ability to derive the full benefits of the education curriculum. Therefore, they would require specialized instruction.

On the other hand, to qualify for a 504 plan, the student’s disability or impairment must interfere with their ability to learn in a classroom without special accommodations that give them an equal opportunity to access learning.

What if a Parent Disagrees With the School’s Decision?

If a school finds that a student is not eligible for an IEP or a 504 plan, and the parent disagrees with this decision, they can take it up with the school district office or with various advocacy groups or organizations that deal with their state’s special education system.

What’s in an IEP?

IEPs must include information about the student and the specific educational program required to meet their unique needs. It must also include their current functional performance and academic achievement levels, describing how their disability interferes with their learning.

Who Qualifies for an IEP?

Any student with a disability that falls into one or more of the 13 categories listed in IDEA qualifies to receive free and appropriate education (FAPE). These categories are:

  • Autism
  • Deafness
  • Deaf-blindness
  • Intellectual Disability
  • Hearing Impairment
  • Emotional Disturbance
  • Multiple Disabilities
  • Other Health Impairment (OHI)
  • Orthopedic Impairment
  • Traumatic Brain Injury (TBI)
  • Speech or Language Impairment (SLI)
  • Specific Learning Disability (SLD)
  • Visual Impairment (VI)

What’s in a 504 Plan?

There are no minimum requirements for what is or can be included in a 504 plan. Schools have leeway to create customized accommodations that address the individual needs of students with disabilities.

Who Qualifies for a 504 Plan?

According to the provisions of section 504 of the Rehabilitation Act, any individual with a disability that significantly limits one or more of their major life activities qualifies for a 504 plan. Students with disabilities or medical needs that require specialized support from the school but not specialized instruction qualify.

Who Creates an IEP or 504 Plan?

By law, the following individuals must be involved in the creation process of an IEP:

  • The student’s parent or legal guardian;
  • The student’s teachers;
  • The student’s special education teacher;
  • A school psychologist or other professional qualified to discuss testing indicators and provide expert recommendations on test evaluations;
  • A representative from the local education agency (LEA);
  • A translator, if need be.

Likewise, the following individuals must be involved in developing a 504 plan:

  • The student’s parent or legal guardian;
  • The student’s teachers;
  • The school administrator;
  • The school nurse, counselor, or other relevant school personnel.

Can IEPs or 504 Plans Be Modified?

IEPs and 504 plans can be modified to fit the student's evolving educational needs. For this to happen, different standards have to be reevaluated and reviewed.

An IEP must be updated annually to determine student needs and the type of specialized instruction required.

On the other hand, 504 plans only require periodic re-evaluation, typically every three years or so but are often updated more frequently as a student’s needs change.

12 Critical Differences Between IEPs and 504 Plans

The main differences between an IEP and a 504 plan are as follows:

1. Coverage

An IEP falls under IDEA, while a 504 plan falls under Section 504 of the Rehabilitation Act.

2. Creation

An IEP is created by a team of experts, including the student's parent or legal guardian, teacher, and other professionals. A 504 plan is usually created by a smaller team, including the student’s parent or legal guardian, school administrator, teacher, and other relevant personnel.

3. Eligibility

To qualify for an IEP, a student must have a disability that requires them to receive specialized instruction. To be eligible for a 504 plan, a student needs to have a disability that affects their daily living and learning activities.

4. Evaluation

A team of experts must thoroughly evaluate an IEP, while a 504 plan requires a less comprehensive assessment to determine whether the student meets the eligibility requirements.

5. Implementation

The school district must implement an IEP. A 504 plan doesn't provide many options in case of violations.

6. Goals

IEPs include specific, measurable functional and academic goals, while 504 plans are more general.

7. Services

An IEP integrates specialized instruction and support, while a 504 plan includes accommodations to cater to the student’s unique needs.

8. Scope

An IEP addresses every aspect of the student’s education, while a 504 plan only focuses on the needs pertaining to the student's disability.

9. Review

IEPs must be reviewed annually, while 504 plans are reviewed once every three years or sooner if the student's needs have changed significantly.

10. Appeals

An IEP decision has a formal appeal process, while a 504 plan does not.

11. Funding

States receive extra funding from the federal government for IEPs, which isn’t the case for 504 plans.

12. Consent

The student's parent or legal guardian must provide written consent for the school to evaluate the child's eligibility for an IEP. Consent is also required for a student to be evaluated by the school district to determine their eligibility for a 504 plan.

Final Thoughts

Team collaboration is necessary to determine whether an IEP or a 504 plan is appropriate for the student.

If you’re looking for an efficient way to plan and coordinate your state and local K-12 assessments while tracking student accommodations and testing history, TestHound from Education Advanced can help you do just that.

Request a demo today to see it in action.

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  • Testhound, our test accommodation software, helps schools coordinate thousands of students across all state and local K-12 school assessments while taking into account dozens of accommodations (reading disabilities, physical disabilities, translations, etc.) for students.
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