Differences between a 504 Plan and an Individualized Education Program (IEP)

What are the differences between a 504 Plan and an IEP?

Even for experienced educators, it can sometimes be confusing to determine if a student might qualify for services that are provided through a Section 504 Plan (504 Plan) or an Individualized Education Program (IEP). Both exist to address the needs of individuals with physical, medical and/or cognitive conditions that directly impact education.  

There are crucial differences between the two plans that may be provided to students. Taking a brief look at the original intent of and the way disabilities are defined in the statutes may help bring some clarity. 

The Rehabilitation Act of 1973, passed after the Elementary and Secondary Education Act of 1965 and before the Education for All Handicapped Children Act of 1975, is a civil rights act created to prohibit discrimination based on disability.

Specifically, Section 504 provides civil rights protections to all individuals with disabilities in programs that receive federal funding, which includes public schools. The Rehabilitation Act broadly defines a person with a disability as “A person who has a physical or mental impairment that substantially limits one or more major life activities, a person who has a history or record of such an impairment, or a person who is perceived by others as having such an impairment.” 

Major life activities include caring for oneself, walking, seeing, hearing, speaking, breathing, working, performing manual tasks, and learning. 

How does Section 504 apply to students in your classroom and school? 

Sec 504 applies when a disability substantially limits a major life function, including learning. When a student is being excluded from an activity due to disability a 504 Plan is needed to provide accommodations and supports to access both academic and extra-curricular activities. 

This is not an exhaustive list, but students who may be considered for a 504 plan could include those with health impairments, ADD/ADHD, HIV/AIDS, alcohol/substance abusers, students with temporary physical disabilities or mental health issues, and students returning to school post-operative.  

You may have students with physical or mental health issues that impact the student’s ability to participate in instruction and learning opportunities, some examples include: 

• A student with chronic asthma misses instruction due to numerous absences and hospitalizations.  

• A student with diabetes requires snacks at regular intervals and leaves class on a scheduled basis for injections.  

• A student dealing with trauma or mental health issues that misses instruction due to needed counseling sessions. 

The 504 Plan developed for any given student MUST address services needed to access and participate in the learning process offered to grade-appropriate peers. If an impairment does not limit learning, a health plan may be more appropriate.  

In 1975, Congress passed the Education for All Handicapped Children Act in response to its perception that most of our nation's handicapped children were excluded from schools; and for those attending school, their needs were not being met. Throughout all the subsequent revisions, the intent has remained the same, to provide a free appropriate public education (FAPE) in the least restrictive environment (LRE) for students with disabilities who meet the criteria outlined in the statute. 

How does this statute apply to students in your classroom and school? 

Under the Individuals with Disabilities Education Improvement Act of 2004 (IDEA) a student must have a specific disability as defined in law and must need special education services. An Individualized Education Program (IEP) must be developed by an IEP team and in place for each student with a disability identified under IDEA. The plan includes measurable learning goals, accommodations and/or modifications, how progress will be measured, and related services, as applicable. 

You may have a student in your classroom for whom you provided alternative learning strategies. After monitoring and collecting data on student progress, you find student progress is slow or lacking. At this point, a review of the specific disabilities as defined in IDEA and a brief conversation with a special education teacher in your building will help you sort out whether the student should be referred for evaluation as a student with a disability in need of an IEP. 

The thirteen specific disabilities listed in IDEA include:  

• Autism 

• Deaf-Blind 

• Deafness 

• Emotional Disturbance 

• Hearing Impairment 

• Intellectual Disability 

• Multiple Disabilities 

• Orthopedic Impairments  

• Other Health Impaired 

• Specific Learning Disability 

• Speech or Language Impairment 

• Traumatic Brain Injury 

• Visual Impairment including Blindness 

Special education services include: 

• Specially designed instruction to meet the unique needs of a child with a disability 

• Accommodations (changes in access to curriculum and instruction – the ‘how’ of learning) and/or modifications (changes to the curricular expectations for age/grade level peers – the ‘what’ of learning) to access content and provide opportunities to learn 

• Related services – developmental, corrective, and other supportive services as are required to assist a child with a disability to benefit from special education 

As you think about a student who is not progressing as expected, consider referral for a 504 Plan when the student does not require specialized instruction but does need the assurance of equal access to public education; consider referral for a special education evaluation under IDEA and the creation of an IEP when the student requires specialized instruction to have access to and progress in the educational curriculum. 

For More Information

“Key Definitions in Part B of IDEA: Defining and Understanding FAPE.” (n.d.). Center for Parent Information and Resources

“Key Definitions in Part B of IDEA: Defining and Understanding LRE.” (n.d.). Center for Parent Information and Resources

“Special Education and Your Child: FAQs for Multilingual Families.” (2020). National Education Association  

 “What is a 504 plan?” (2023). Understood.org 

Additional Resources 

Center for Parent Information and Resources

U.S. Department of Education. About IDEA  

U.S. Department of Education, Office of Civil Rights: Protecting Students with Disabilities  

U.S. Department of Education. Sec.300.320 Definition of individualized education program 

U.S. Department of Education. Sec.300.34 Related services

U.S. Department of Education. Sec.300.39 Special education

U.S. Department of Education. Sec.300.8 Child with a disability