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What Is the Difference Between an IEP and a 504 Plan?

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    What Is the Difference Between an IEP and a 504 Plan?

    Graphic: What is the difference between an IEP and 504 plan?

    IEP and 504 plans are both designed to meet the needs of learners with physical or mental disorders and disabilities. They outline how the student’s educational team accommodates their needs and provides optimal learning environments. An IEP falls under special education laws, and 504 compliance is required under civil rights law. 

    While there are similarities between these plans, essential differences may make students eligible for one and not the other. Below, we discuss both plans in-depth so you can understand what makes them different and how they are used in the K-12 school system.

    What Is an IEP?

    An Individualized Education Program (IEP) comes out of the Individuals with Disabilities Education Act (IDEA), an educational law governing the eligibility of children with disabilities for free education and special support. The document helps students with learning disabilities who need accommodations or modifications in the classroom. An IEP includes the following steps:

    • Referral: With informed consent from parents, a student can be referred for an evaluation to determine eligibility for specially designed instruction.
    • Evaluation: The evaluation is a comprehensive, individualized assessment of a student’s learning and functional capabilities.
    • Eligibility determination: After the evaluation, the district assesses the results to determine if a student has a disability requiring academic support.
    • IEP development: Based on the evaluation and eligibility determination, the student’s team develops the individualized education program.
    • IEP implementation: Educational professionals provide the necessary academic support as laid out by the IEP.
    • Annual review: IEPs and the student’s progress is reviewed once a year unless the IEP team and parents determine another review schedule or a student shows a lack of appropriate progress.
    • Reevaluation: Every three years, the IEP team reevaluates the student to ensure they still need the special education services.

    What Is a 504 Plan?

    A 504 service agreement is available to students who do not need or are not eligible for a special education plan or IEP. More specifically, a 504 is under Section 504 of civil rights law. It states that individuals cannot be discriminated against on the basis of disability. Subpart D of section 504  relates specifically to K-12 schools and makes provisions for students who need specific accommodations within the learning environment. It can be granted on an as-needed basis.

    Physical or mental disabilities involved with a 504 are often those that hinder major life activities such as:

    • Walking
    • Seeing
    • Hearing
    • Speaking
    • Breathing
    • Focusing

    A student could qualify for a 504 plan temporarily, such as while recovering from surgery. However, there can be cases where a student is receiving care from a doctor for conditions such as ADHD, depression, or behavioral concerns. Giving additional support to this student would fall under a 504. This agreement can also support students in wheelchairs, students who have sustained a concussion or other traumatic brain injury, or those with more chronic conditions.

    504 plans include accommodations for students and remove barriers to learning. Examples of accommodations found in a 504 include:

    • Environment changes: A student might be allowed to keep their camera off when participating in video calls or, especially in the case of concussions and brain injuries, teachers may reduce the amount of on-screen time a student has in their school day.
    • Instruction changes: Teachers might provide the student with additional resources, such as flashcards or practice problems, or reduce the amount of homework and classwork they need to complete.
    • Lesson presentation: Teachers may provide outlines of their lessons to make it easier for learners to follow along.
    • Tests and grades: Students may be allowed to take tests in a different medium, such as on paper rather than online, or receive extra time on their assignments.

    IEPs vs. 504 Plans

    IEP and 504 plans in Pennsylvania have some differences and similarities. 

    Some of the key differences between IEPs and 504 plans include:

    • Eligibility: A student must meet specific disability criteria to qualify for an IEP, while any disability that affects the child’s learning can qualify them for a 504 plan.
    • Goals and scope: 504 plans are focused on accommodations and removing barriers in a general education environment. IEPs provide specially designed instruction to allow the student to participate and be successful in the curriculum.
    • Applicable laws: 504 plans are governed by civil rights laws, specifically Section 504 of the Rehabilitation Act. IEPs are guided by the education law IDEA.
    • Content of the plan: IEPs must be formally documented and include information about the student’s abilities, annual learning objectives, the services the learner will receive, accommodations, modifications, and their participation in general education. Meanwhile, 504 plans do not require written goals like IEPs and generally focus on accommodations and the people responsible for them.

    While the two have many differences, they overlap in purpose and in other respects. Some of the main similarities of IEPs and 504 plans include:

    • Both require schools to provide access to a free and appropriate public education (FAPE).
    • Both are given to educators and service providers who are responsible for the student with the IEP or 504.
    • Federal and state guidelines apply to both.
    • Both incorporate annual reviews to assess the success of the plans.

    Who Creates an IEP or 504 Plan?

    A team of people creates an IEP or 504 plan. Who is involved depends on the type of plan it is. In general, there are stricter requirements for who is on the IEP team than on 504 teams.

    By law, the following people need to be involved on an IEP team and present at IEP meetings:

    • A parent or legal guardian
    • One of the student’s teachers
    • One of the student’s special education teachers
    • A school psychologist or other personnel who can discuss testing data who can provide expertise on test evaluations
    • A local education agency (LEA) representative
    • A translator, if needed

    The people and professionals involved with developing a 504 plan include:

    • A parent or legal guardian.
    • Teachers of the student.
    • School administrators.
    • Other relevant personnel, such as the school counselor and, occasionally, the school nurse.

    Both plans are developed at no charge for students and families. All public schools must accommodate all types of learners. Therefore, the teams have people that understand legal requirements and the curriculum, evaluate test data, have the authority to approve school resources, and are familiar with special education service options.

    Graphic: How to qualify for an IEP

    Which Students Qualify for Special Education Under an IEP?

    To qualify for an IEP, a student must meet eligibility criteria for at least one of the 13 disabilities stated by IDEA. These categories range from physical, mental, and health factors that make learning challenging for them. Among others, they include:

    • Visual, hearing, orthopedic, and other impairments.
    • Traumatic brain injuries
    • Autism
    • Specific learning disabilities
    • Intellectual disabilities

    For a full list of the 13 categories for IEP qualification, check out the Pennsylvania Department of Education’s information on IEPs and 504 plans. Besides meeting one of the 13 disability categories, students must need special education to qualify for educational benefits.

    The school district, parents, or a professional may determine when a student might be eligible for an IEP. If this is the case, their situation should be evaluated and reviewed carefully to give the student the best chance of learning well.

    Can IEPs or 504 Plans Be Modified?

    IEPs and 504 plans can be modified. However, different standards are reviewed and reevaluated. 

    For an IEP, the team must review it at least every year. The student must be reevaluated every three years to see if an IEP is still needed, or every two years if the student has an intellectual disability. With a 504, the plan is reviewed once a year.

    At Commonwealth Charter Academy, our IEP teams are dedicated to using the IEP as a common point of communication about your child, as it clarifies how your student will succeed the best. Once the IEP is amended to the cyber school setting, a parent can request to have an evaluation by a certified school psychologist. This can help answer any worries families may have throughout the year.

    Graphic: Learn more about CCA's special education program.

    Learn More About CCA’s Special Education Program

    CCA’s personalized education is perfectly suited to addressing your child’s unique needs. Our special education program allows students to fully integrate into our cyber school community from the safety and comfort of their own home, using up-to-date assistive technology. 

    The special education team at CCA ensures each student’s IEP is available to their teachers so they can personalize their learning plan. Alongside providing academic support from the school, CCA can connect parents and guardians with regional and local support for learners with unique needs.

    For more information about our special education program, see our policy statements. Enroll at CCA today for the best special education tailored to your child’s unique needs.


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    June 28th, 2022


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