IEP vs 504 Plan: Key Differences Explained

Both Individualized Education Plans (IEPs) and 504 plans aim to ensure that students with disabilities get the support they need and deserve in order to succeed at school. While there are many commonalities between these two provisions, there are also major differences in terms of eligibility, evaluation, services, supports, and costs. This article offers a side-by-side comparison between IEPs vs 504 plans to help public schools and parents of children with disabilities navigate through this complex reality and provide the best available assistance and accommodations to students in need.

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IEP vs 504 Plan: What Each One Is

IEPs and 504 plans are both provisions of the public education system that offer accommodations and supports to children with physical or cognitive disabilities that negatively impact the education process and outcomes. The main goal of both programs is to ensure that all children have access to free appropriate public education (FAPE) in spite of existing medical conditions and health problems.

However, there are major important differences between the two programs, the most significant one being that IEPs are considered part of special education, while 504 plans are not. In addition, they cover different disabilities, provide different supports, go through different processes, and are regulated by different federal laws.

What Is an IEP?

An Individualized Education Plan (IEP) is a formal written document that specifies the special education instruction and accommodations that a public school needs to provide to a student with one or more of the 13 categories of qualifying disabilities to meet their unique needs for quality education.

IEPs are generally available to PreK-12 students at public schools and charter schools. They are highly personalized based on a detailed evaluation of each child to address their specific requirements in the most appropriate manner. Generally speaking, an IEP is equivalent to special education as it covers both content and accommodations.

IEPs are currently governed by the Individuals with Disabilities Education Act (IDEA) of 1990. This is a federal special education law that aims to provide FAPE to students with a wide range of disabilities. Indeed, IDEA defines the 13 categories of disabilities that qualify for an IEP.

What Is a 504 Plan?

A 504 plan is a formal, yet not necessarily written blueprint of the accommodations that a public school needs to make to remove barriers to education for children with a wide range of disabilities. That generally refers to physical and mental impairments that affect major life activities.

504 plans are accessible for PreK-12 students at schools that receive federal funding, which includes public schools, charter schools, and many private schools. They are less comprehensive than IEPs as they cover accommodations and supports but do not offer specialized content instruction, which leaves them outside the domain of special ed. They are also less individualized than IEPs.

Unlike IEPs, 504 plans are regulated by Section 504 of the Rehabilitation Act of 1973, which is a federal civil rights law that aims to protect people with disabilities from discrimination. This makes 504 plans a provision of the civil rights legal framework rather than the education regulatory system.

IEP vs 504 Plan: Eligibility

While both IEPs and 504 plans aim to support children with disabilities, they have distinct eligibility criteria. That’s because they are introduced and ruled by different laws. 

Who Is Eligible for an IEP?

As outlined in IDEA, there are a number of criteria that qualify a child for an IEP, including:

• Qualifying disability category: A child needs to have one or more of the 13 categories of qualifying disabilities listed in IDEA to be eligible for an IEP.
• Effect on education: A disability must have a negative impact on the education process, whether academically, behaviorally, or socio-emotionally.
• Age: Children aged 3-21 years have access to IEPs. This generally covers PreK-12 grade.
• Public education system: A student has to be enrolled in a public school or charter school. Private schools do not provide IEPs though the majority of them have other special education provisions, such as Individualized Service Plans (ISPs). Private school students who are found to have a qualifying disability are eligible for part-time or full-time transfer to a public school to receive adequate services and supports.
• Need for special education: A child has to require special education instruction and services to qualify for an IEP.

The 13 categories of qualifying disabilities comprise:

• Autism
• Deaf-Blindness
• Deafness
• Emotional Disturbance
• Hearing Impairment
• Intellectual Disability
• Multiple Disabilities
• Orthopedic Impairment
• Other Health Impairment
• Specific Learning Disability
• Speech or Language Impairment
• Traumatic Brain Injury
• Visual Impairment Including Blindness

A child needs to undergo a formal evaluation to confirm IEP qualification.

Who Is Eligible for a 504 Plan?

Although similar to an IEP, a 504 plan aims to support disabled students, the eligibility criteria are quite different. To qualify for a 504 plan, a child needs to have a physical or mental impairment that significantly disrupts one or more major life activities.

It’s important to note that Section 504 of the Rehabilitation Act does not offer a list of qualifying disabilities. This means that a student with any disability can be eligible. In many cases, children that do not qualify for an IEP are eligible for a 504 plan.

In terms of age, 504 plans apply to students up to 21 years, covering PreK-12 grade, similar to IEPs. By law, they are available at all schools that receive federal funding, meaning all public and charter schools and some private schools.

IEP vs 504 Plan: What Is Included

Individualized Education Programs provide significantly more services and modifications than 504 plans. The main reason for this is that the former aim to protect the education rights of disabled children in specific, whereas the latter take care of their civil rights.

What IEPs Include

IEPs provide the following services and supports to children with qualifying disabilities:

• Special education instruction personalized to the unique needs of the child
• Accommodations to the learning methods and environment
• Placement: Students with IEPs can be educated in a general education classroom, specialized class (resource room), special schools, homebound schooling environment, or hospital-bound instruction setting, based on their condition.
• Assistive technology
• Related services

IEPs are thorough and comprehensive documents that provide a range of modifications and adjustments for children with special needs.

What 504 Plans Include

504 plans are more limited in scope, covering:

• Modifications to the learning environment
• Assistive technology

It should be highlighted that 504 plans do not offer changes to the content and the instruction that the child is expected to cover as they do not fall under the category of special education. Students continue to access general education and extracurricular activities in the regular general education classroom as they do not qualify for special placement.

IEP vs 504 Plan: What the Document Covers

Both provisions require the formulation and implementation of a formal plan to achieve their goals. However, once again, there are major differences in the documents associated with the two. Generally speaking, IEPs are much more detailed and elaborate than 504 plans.

IEP Document Coverage

To begin with, an IEP document is a written document that outlines a wide range of details related to the needs of children with disabilities and the services that their school has to provide to them.

Specific information includes:

• Specially designed instruction
• Changes to the educational content
• Related services, such as speech-language therapy, occupational therapy, mental health counseling, and others
• Detailed information about each service, including the provider, the time frame, the duration, the frequency, and the location
• Accommodations to the learning environment including placement
• Assistive technology and tools to be provided by the school
• Engagement in general education classes and interactions with peers
• Participation in state and district tests and approved testing accommodations
• Current performance in education
• Measurable annual goals and mechanisms to monitor progress
• Necessary transition services to prepare the student for life after high-school graduation, as of the age of 14 years
• Starting date

Preparing an IEP document is the result of the collaborative efforts of an entire team of stakeholders including special education professionals, the parents, and others. It needs to be officially approved by the parents/legal guardians before it can be implemented.

504 Plan Coverage

Meanwhile, 504 plans are significantly less detailed and complicated. They don’t even need to be written documents.

What is included in a 504 plan covers:

• Modifications to the instruction method
• Accommodations to the learning environment
• Testing accommodations

The main difference between an IEP document and a 504 plan is that the former specifies both what and how a child learns, while the latter focuses on how a child is educated. Moreover, the second doesn’t have annual goals and doesn’t require tracking progress.

IEP vs 504 Plan: Evaluation and Reevaluation

Both IEPs and 504 plans start with a formal evaluation of a student who is known or suspected to have a disability that affects either their education or life activities, respectively. Still, the two processes are guided by different requirements and follow different procedures.

IEP Evaluations

An IEP evaluation can be requested by the child’s parents/guardians, teachers, or school staff or recommended by the child’s doctor. Under the Child Find policy of IDEA, school districts are legally obliged to actively search for potential candidates to ensure that all children receive FAPE.

To ask for an evaluation, parents need to submit a written letter to the school district. Parental approval needs to be obtained before an evaluation can be launched.

An IEP evaluation covers the following steps:

• Agreeing on the need for an evaluation
• Collecting data on performance at school
• Distributing questionnaires among teachers, parents/guardians, caregivers, and other relevant stakeholders to gather additional information
• Getting an assessment by a psychologist
• Classroom observation
• Additional testing by relevant specialists
• IEP meeting to present and discuss the results of the evaluation and come up with an IEP document

Furthermore, parents can request from the district to pay for an Independent Educational Evaluation (IEE) in case they don’t agree with the results of the school evaluation. The district is obliged neither to cover the cost nor to take the outcomes into consideration in case parents get the IEE themselves.

By law, formal IEP reevaluations need to take place at least once every three years (triennial reevaluations). In addition, an IEP review needs to be organized a minimum of once per year to measure progress and make necessary adjustments to the plan.

504 Plan Evaluations

Federal laws provide less specific guidelines for the 504 plan evaluation process than for IEP evaluations, and many of the decisions are left to districts. Nevertheless, formal 504 plan evaluations are required by federal law and need to happen after the explicit approval of parents/guardians. They can be requested by parents, teachers, other school personnel, and physicians.

The evaluation can be based on a range of factors including:

• School records
• Standardized test results
• Classroom observation
• Interviews with the student, the parents, and teachers
• Additonal formal assessments

It should be noted that IEEs do not apply in case of 504 plans.

According to the relevant federal law, reevaluations have to be conducted periodically, but the required frequency is not specified and can be determined by the district. In general, triennial reevaluations are the norm, just like with IEPs.

IEP vs 504 Plan: Team

To cover all relevant aspects and ensure appropriate services and supports, IEPs and 504 plans are prepared by a team of involved stakeholders. Nonetheless, an IEP team is significantly more structured and larger than a 504 plan team.

IEP Team

The team that is involved in the IEP process needs to include:

• Parents/guardians: By law, parents need to be present on the IEP team.
• General education teacher(s)
• Special education teacher(s)
• School district representative, referred to as a local education agency (LEA) representative
• Evaluation expert, usually a school psychologist
• Student, if appropriate: The child has to be a part of the team after the age of 16 years, but they can join earlier if this is deemed appropriate.
• Translator, if needed

Additional professionals who can attend the IEP meetings include IEP advocates, private tutors, doctors, related service providers, and even family and friends.

504 Plan Team

At the same time, the regulations concerning the composition of the 504 plan team are less specific.

Team members can include:

• Parents/guardians: The student’s parents might be a part of the team, but they don’t have to be from a legal standpoint.
• General education teacher(s)
• Special education teacher(s)
• School principal
• School psychologist
• School nurse
• Guidance counselor
• Special education advocate though 504 plans are not officially considered special ed

The team makeup is very fluid and can include the specialists that make the most sense to the particular situation. It’s usually smaller than an IEP team.

IEP vs 504 Plan: Parental Involvement

Parents can play a major role in both IEPs and 504 plans as they have unique perspectives on their child’s condition, education strengths and challenges, and needs. Moreover, they have the right to be involved in their child’s education and to make sure that their rights and interests are protected according to all legal provisions. Indeed, parents are usually the best advocates for their own children, whether with disabilities or not.

However, parents’ participation in IEPs and 504 plans differs, at least in theory.

Parents’ Role in IEPs

Parents/guardians have an official role in the IEP process that is stipulated by federal law.

The following legal provisions apply to parents’ participation in the process, including both rights and responsibilities:

• Parents have the right to request an IEP evaluation of their child by sending a written letter to the district.
• Parents have to officially agree to an evaluation before it can be performed.
• Parents can request an Independent Educational Evaluation, but the school district doesn’t have to grant it.
• Parents are equal members of the IEP team.
• Parents are consulted during the evaluation to provide insights and information.
• Parents need to attend IEP meetings. They can request a translator which the school has to provide, if needed.
• Parents can invite advocates, doctors, and other relevant specialists to the IEP meetings, but the school has to approve attendance.
• Parents must approve the IEP document before it can be implemented by the school.
• Parents have the right to request additional meetings and reevaluations if they believe there have been significant changes in their child’s condition or the IEP plan is not producing the expected results.
• Parents have to approve any adjustments to the IEP document before they can be applied.

In sum, parents are considered a major part of the team and the process and need to be involved throughout.

Parents’ Role in 504 Plans

Similarly, parents have an established role within the 504 plan process.

Their inclusion covers the following:

• Parents can submit a written request for an evaluation to the school district.
• Parents need to give permission before an evaluation can be initiated.
• Parents can provide insights during the evaluation process.
• Parents can be members of the team but don’t have to be.
• Parents don’t need to be invited to meetings, but most schools choose to invite them.
• Parents can participate in the preparation of the 504 plan but don’t have to.

All in all, parents of children with 504 plans have fewer rights and legal protections than parents of children with IEPs, but they can still be actively involved in the process to bring the best possible outcomes.

IEP vs 504 Plan: Progress Monitoring and Review

From a legal point of view, there are considerable differences between IEPs and 504 plans when it comes to goals, tracking progress, and reviews.

IEP Goals, Progress, and Review

Annual goals are a must-have component of an IEP. They have to be reasonable, attainable, and measurable. Goals can include academics, behavior, and the socio-emotional state of the child. Moreover, the document needs to specify the ways in which progress will be tracked and reported to the parents and the rest of the team.

Monitoring progress has to start as soon as the IEP begins to be implemented, and results need to be reported to involved stakeholders on a regular basis.

In addition, IEPs are subject to annual reviews where progress towards annual goals is discussed, new annual goals are set, and necessary adjustments to the document are made.

504 Plans Goals, Progress, and Review

On the contrary, 504 plans don’t need to have annual goals though they might. No progress monitoring and reporting is demanded, but in some cases it is performed to make sure that the plan is achieving outcomes. Finally, reviews are not required for compliance purposes, but most schools conduct annual reviews to ensure relevance and efficacy.

IEP vs 504 Plan: Costs and Funding

While both IEPs and 504 plans are free for students and their families, funding comes from different sources.

IEP Cost and Funds

Parents do not need to pay anything for an IEP. IEPs are covered by special education funds. State funds should provide 40% of the total cost of the program, under IDEA, but this is not the case, so special education has traditionally suffered from underfunding.

Additional sources of funds include state funding, district funding, and private funds. Medicaid can cover the cost of medical-related services listed on the IEP document, such as therapies and counseling.

504 Plan Cost and Funds

Families are not meant to carry the financial burden of 504 plans either. However, special education funding is not eligible for this, and the extra costs need to be covered by general education funds. That’s why 504 plans are available in all schools that receive federal funding.

IEP vs 504 Plan: Dispute Resolution

Applicable laws provide parents of children with IEPs and 504 plans access to similar options and mechanisms to resolve disputes with the school or the district.

IEP Dispute Resolution

All involved parties should put effort into ensuring a smooth, problem-free process that brings the best possible results for the child. However, there are occasions when parents and the school cannot reach an agreement and additional mechanisms need to be invoked to resolve the impasse.

Dispute resolution options available to families of students with IEPs include:

• Negotiations between the parents and the school
• Mediation moderated by a third party
• Due process complaint and hearing, which is a legal process and requires a special education attorney, not simply an IEP advocate
• State complaint which requires submitting a letter to the State Department of Education to report a violation on behalf of the school
• Complaint to the Office for Civil Rights of the U.S. Department of Education
• Lawsuit 

All these mechanisms require the involvement of different federal, state, and local authorities and other parties to ensure that the rights of children with disabilities are properly protected and upheld.

504 Plan Dispute Resolution

The dispute resolution options at disposal to the parents of children with 504 plans are comparable to those with IEPs.

Specific options include:

• Negotiations
• Mediation
• Impartial hearing where a hearing officer is presented with the case to make a decision that can be appealed
• Filing a complaint to the Office for Civil Rights of the U.S. Department of Education
• Lawsuit which is an expensive process that generally requires hiring a specialized lawyer

As a first step, parents should always try to discuss the matter with school representatives and try to find a solution in a peaceful manner. However, if this proves impossible and the family believes that the civil and education rights of their child are compromised, they should resort to one of the above-listed mechanisms.

Bottom Line

Both IEPs and 504 plans aim to provide children with disabilities with adequate and appropriate education at no additional cost to the family. While the first does this from an educational legal point, the second works from a civil rights perspective. IEPs are more comprehensive and more rigidly structured, including modifications to the content, the instruction, and the learning methods. Meanwhile, 504 plans focus on learning environment accommodations as well as assistive technology and tools. Teachers, school admins, and parents of students with known or suspected impairments need to be familiar with the similarities and the differences between the two provisions to ensure that children are offered the instruction, accommodations, related services, and supports that they need to thrive at school.

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