What is the Timeline for Developing a Section 504 Plan?

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My 6 year old daughter had her 3 year reevaluation. She has Childhood Apraxia of Speech and fine motor difficulty. She is doing well academically.
At the IEP meeting one month ago, it was decided that she no longer qualifies for an IEP.  The school suggested a 504 plan and said they would contact us for a meeting.

What is the timeline for a 504 Plan?

Young Girl Looking Sad 









The federal regulations do not mandate a timeline for Section 504 meetings or for implementation of a 504 plan. Your school district may have developed specific procedures for implementing a 504 plan, but I doubt it.

Since the federal regulations for Section 504 do not require parent participation in the process, the school may have already had the meeting – or not.

The school does not have to invite you to the meeting to develop a 504 plan.  However, the school must notify you that the plan was developed.  If you have not heard anything from the school, it is time to find out what, if anything, they have done.

Parent Participation in the IEP Process

You said “it was decided that she no longer qualified for an IEP.”  Who or what is the “it” who make this decision? Were you involved in that decision? Did the school base this decision on a comprehensive evaluation, similar to the evaluation she had to determine if she was eligible for special ed?

IDEA 2004 lists parents first as members of the IEP team. You should have input at any meeting when a school team makes a decision about her eligibility.

Key Differences in IDEA and Section 504

It is important to be aware of the difference between an IEP and a Section 504 plan.

IDEA provides more specialized services and safeguards for you and your child. You will find information about the key differences in these articles.



More information and articles are on this page – Discrimination: Section 504 and ADA.


Grades and Eligibility

Your daughter is doing well academically. Great!  However, IDEA does not mention grades as a criteria for special education eligibility.

  • Has your daughter met all her IEP goals?
  • Does she no longer have speech problems that require specially designed instruction to meet her unique needs?
  • Does she no longer have any fine motor needs?
  • How was your daughter’s progress determined?
  • Did the IEP team, including the parents, review objective test data?

The school is required to do a comprehensive evaluation (and assess all areas of suspected disability) before they can terminate your daughter’s eligibility from special ed.

  • Did the 3 year reevaluation provide this data in all areas?

It may be that your daughter no longer needs an IEP and is ready to exit special education.

Caution: Think carefully about terminating your child’s eligibility until you are convinced that she is functioning well and can continue to progress.

At her age, the next few years are critical for reading, writing, and communication skills.

  1. As a parent who tried to save my son’s iep… It was like fighting City Hall. “Too smart for his IEP”… “We don’t see that…so he is only acting autistic at home”… “We will not add his impulsive behavior in his new 504″…
    Why should meeting our child’s needs be so difficult?
    Our child was in a granted program for two and a half years with his IEP and qualifying for the Summer program. Then, after two and a half months he no longer has any needs that the school feels they are obligated to meet?
    Would never considered a least restrictive IEP!
    My question, when will the child come first?
    504…the school doesn’t even have to follow the plan. The school doesn’t even have to invite the parent to the meeting. 504… Civil Rights? Saftys in place?
    Schools are now a big business.

  2. I think it is critical to note that the 504 team must have someone knowledgeable about the child, which supports having the parent involved. We got a letter from the doctor stating that the parents should be on any 504 team meeting because we are the ones who are knowledgeable about how her disability impacts her. Key is they have to prevent discrimination, so if they are not already making appropriate accommodations and her ability to access her education is limited/impacted, they could be violating her rights as a child with a disability….I believe.

  3. I second the opinion of dad2luke. If the district feels that sufficient progress has been made, do a ‘trial run’ with minimal accommodations on the IEP. If the child is successful for a year or so, maybe a 504 is appropriate.

  4. I would be curious to know how this change in placement could benefit your daughter’s academic progress compared to the current IEP.

    A change in placement is an IEP team decision. If you have requested Prior Written Notice for why the placement change is being offered, it should detail any scientific data that supports that a 504 will address your daughter’s Individualized Education Plan.

    Wrightslaw has some great information that explains the difference between a 504 and an IEP.

    In my “opinion” as a fellow parent of a special need child, having a 504 is like asking a contractor to pour a side walk and not having an agreement of where the side walk will be located, when it should be completed and the cost of the service.

    Having an IEP for a special needs child is more than just a good


  5. As per the Wrights, I’d be very cautious about agreeing to exiting from an IEP. You are already seeing signs that your school district is not being very upfront with you about developing the Section 504 plan. My District used the Section 504 plan as an excuse to do nothing after exiting my son from his IEP. We fought for 3 years afterwards to get my son services under a 504 plan or an IEP. In the end he could not wait any longer and we had to privately place him.

    All the while he was suffering from social isolation, bullying and slowly losing interest in his academics. The District did not care one whit. All they were interested in was blenching their budget.

    Save yourself the trouble and be doubly sure that exiting from the IEP is a good idea. Having the IEP in place to provide minimal services might be a better idea.

  6. I agree with the Wrights, be very sure of your daughters needs. How will she be able to function in elementry school with the demands of writing and reading and the addtional social interactions needed. Accomodations help only so far in these areas.

    We were convinced by the distrct to move our dd to a 504 before she was ready and ended up having to fight to get her completly retested and a new IEP in place. It had a devistateing effect on my daughters emotional well being as well as lost academic time.

    I just wish I had found Wrights law sooner!!

    good luck with what ever you choose.

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