504 Plan vs IEP: What Every Teacher Needs to Know

A third-grade teacher sits across from two parents at a conference table. The student has been struggling with focus, losing homework, and falling behind in reading. The mother asks, "Should my child have a 504 or an IEP?" It is a reasonable question, and one that general education teachers hear more often than most preparation programmes train them for. Both plans protect students with disabilities in public schools. Both require the school to take documented action. But they originate from different federal laws, cover different populations, and provide fundamentally different levels of support.

Getting this distinction right matters. The wrong pathway can leave a student without the instruction they need, or burden a family with a process more intensive than their child's situation requires. This guide breaks down the legal foundations, eligibility criteria, services provided, and practical decision points so you can advise families and participate in team meetings with confidence.

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Two Different Laws

The IEP and the 504 Plan trace back to two separate pieces of federal legislation, each with a distinct purpose.

The Individuals with Disabilities Education Act (IDEA) is a funding statute. Congress allocates federal dollars to states and school districts specifically to provide a free appropriate public education (FAPE) to students with disabilities. In exchange for that funding, schools must follow detailed procedural requirements: formal evaluations, eligibility determinations, individualized education programmes, annual reviews, and triennial reevaluations. IDEA was first enacted in 1975 as the Education for All Handicapped Children Act and has been reauthorized several times, most recently in 2004. The Supreme Court clarified in Endrew F. v. Douglas County School District (2017) that an IEP must be "reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances." This raised the bar from the previous "merely more than de minimis" standard.

Section 504 of the Rehabilitation Act of 1973 is a civil rights statute. It prohibits discrimination against individuals with disabilities in any programme that receives federal funding, which includes virtually every public school in the country. Section 504 does not provide additional funding. It requires schools to ensure that students with disabilities have equal access to education. The Office for Civil Rights (OCR) within the U.S. Department of Education enforces Section 504 in schools.

The practical consequence of this legal distinction is significant. IDEA creates an entitlement to services. Section 504 creates a right to access. The US Department of Education (2023) reported that approximately 7.3 million students aged 3 to 21 received special education services under IDEA in the 2021-22 school year, representing roughly 15% of the public school population. A student with an IEP receives specially designed instruction tailored to their needs. A student with a 504 Plan receives adjustments to the general education environment that remove barriers to access.

Feature	IEP (IDEA)	504 Plan (Section 504)
Type of law	Federal education funding statute	Federal civil rights statute
Primary purpose	Provide specially designed instruction	Ensure equal access to education
Federal funding provided	Yes	No
Enforced by	State education agencies, OSEP	Office for Civil Rights (OCR)
Written plan required	Yes (detailed IEP document)	Recommended but not federally mandated

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Eligibility: Who Qualifies for Each?

The two plans use different eligibility standards, and the gap between them explains why some students qualify for one but not the other.

To receive an IEP under IDEA, a student must meet two criteria. First, they must have a disability that falls within one of 13 categories defined by federal law (see the full list below). Second, because of that disability, they must need specially designed instruction to make progress in the general education curriculum. Both conditions must be met. A student with a diagnosed disability who performs at grade level with standard classroom support does not qualify for an IEP, because the second criterion is not satisfied.

Section 504 uses a broader standard. A student is eligible if they have a physical or mental impairment that substantially limits one or more major life activities. Estimates from the National Centre for Learning Disabilities (2020) suggest that approximately 1 in 5 students in the US has a learning or attention issue, yet only around 14% of students are identified for special education services, indicating that a significant proportion receive support under Section 504 without an IEP. Major life activities include learning, reading, concentrating, thinking, communicating, and several others. The 2008 amendments to the Americans with Disabilities Act (which Section 504 references) expanded this definition and instructed schools to interpret "substantially limits" broadly.

The key insight for teachers: every student with an IEP is also protected under Section 504, because IDEA disabilities are a subset of the broader 504 definition. But many students who qualify for a 504 Plan do not meet the stricter IEP criteria. A student with ADHD who manages grade-level work when given preferential seating, movement breaks, and extended time on tests has a disability that substantially limits concentration (504 eligible), but does not need specially designed instruction (not IEP eligible). A different student with ADHD who is failing multiple subjects despite consistent accommodations may need an IEP evaluation, because the accommodations alone are not sufficient.

This creates a practical continuum. Some students move from a 504 Plan to an IEP as their needs increase. Others move from an IEP to a 504 Plan as they develop compensatory strategies and need less intensive support. The plans are not a hierarchy; they are different tools matched to different levels of need. Understanding how executive function affects classroom performance helps teachers recognise when a student's difficulties go beyond what accommodations can address.

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What Each Plan Provides

The clearest way to understand the difference between an IEP and a 504 Plan is to look at what each one actually delivers.

An IEP provides specially designed instruction (SDI). This means instruction that is adapted in content, methodology, or delivery to address the student's unique needs. SDI is not the same as accommodation. Accommodation changes the environment; SDI changes the teaching. A student receiving SDI in reading might work with a special education teacher using a structured literacy programme at their instructional level, rather than the grade-level curriculum their peers use. The IEP also includes related services (speech-language therapy, occupational therapy, counselling, or others as needed), measurable annual goals with progress monitoring, transition planning beginning at age 16, and procedural safeguards that protect family rights throughout the process. Rashid and Wong (2022) identified a consistent implementation gap in their systematic review: teachers frequently reported insufficient training in writing measurable IEP goals, which directly affected the quality of provision students received.

A 504 Plan provides accommodations and, in some cases, modifications to the general education environment. Accommodations change how a student accesses the same curriculum (extended time, preferential seating, audio versions of texts). Modifications change what the student is expected to learn (reduced number of spelling words, alternative assignments). The 504 Plan does not require measurable annual goals, though some districts include them voluntarily. It does not fund related services, though a school may still provide them as part of ensuring equal access.

The distinction between scaffolding and permanent support is relevant here. A 504 accommodation is ongoing support that removes a barrier. An IEP's specially designed instruction is intended to build skills so the student can eventually need less support.

Component	IEP	504 Plan
Specially designed instruction	Yes, required	No
Related services (speech, OT, counseling)	Yes, if needed	Not typically, but possible
Measurable annual goals	Yes, required	Not required (some districts include them)
Progress monitoring	Required, reported to parents	Not federally required
Transition planning	Required by age 16	Not required
Accommodations	Yes	Yes (primary tool)
Modifications	Yes, if appropriate	Yes, if appropriate
General education participation	Least restrictive environment required	Student remains in general education

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The 13 IDEA Disability Categories

To qualify for an IEP, a student must meet criteria in at least one of these federally defined categories. Each state may use slightly different terminology, but the categories themselves are set by federal law.

Autism includes a spectrum of developmental conditions affecting communication, social interaction, and behaviour. The impact must be educationally significant.

Deaf-blindness involves both hearing and visual impairments, creating communication and learning needs that cannot be met by programmes for deaf or blind students alone.

Deafness is a hearing impairment severe enough that the student cannot process linguistic information through hearing, with or without amplification.

Emotional disturbance covers conditions such as anxiety disorders, depression, and other emotional or behavioural conditions that adversely affect educational performance over an extended period.

Hearing impairment is a hearing loss, whether permanent or fluctuating, that adversely affects educational performance but is not covered under the deafness category.

Intellectual disability involves significantly below-average general intellectual functioning with concurrent deficits in adaptive behaviour.

Multiple disabilities means two or more concurrent impairments whose combination creates educational needs that cannot be met in a single disability programme.

Orthopedic impairment includes conditions caused by congenital abnormalities, disease, or other causes (such as cerebral palsy or amputations) that adversely affect educational performance.

Other health impairment covers conditions that limit strength, vitality, or alertness, including ADHD, epilepsy, diabetes, and sickle cell anemia, when they affect educational performance.

Specific learning disability is a disorder in one or more basic psychological processes involved in understanding or using language, which manifests as difficulty in listening, thinking, speaking, reading, writing, spelling, or mathematical calculations. Dyslexia is the most common specific learning disability identified in schools. Specific learning disability accounts for approximately 33% of all students receiving special education services under IDEA, making it the largest single eligibility category by far (US Department of Education, 2023).

Speech or language impairment includes communication disorders such as stuttering, impaired articulation, or language difficulties that adversely affect educational performance.

Traumatic brain injury is an acquired injury to the brain caused by an external physical force, resulting in partial or total functional disability.

Visual impairment including blindness covers impairment in vision that, even with correction, adversely affects educational performance.

Some conditions can fall under either pathway. A student with ADHD, for example, might receive a 504 Plan if accommodations are sufficient, or an IEP under "other health impairment" if they need specially designed instruction. The classroom strategies for managing ADHD often determine which pathway is appropriate. Similarly, a student on the autism spectrum might have a 504 Plan if their needs are primarily environmental, or an IEP if they require social skills instruction, communication support, or behavioural intervention.

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Common 504 Accommodations by Condition

A well-written 504 Plan matches specific accommodations to the functional limitations caused by the student's disability. The following examples represent common accommodations organised by condition. Effective accommodation design requires understanding how working memory and cognitive load interact with the student's disability.

Condition	Common 504 Accommodations
ADHD	Preferential seating away from distractions; extended time on tests (typically time-and-a-half, as this is the most common accommodation ratio); scheduled movement breaks; chunked assignments with check-in points; visual timers; written and verbal directions; reduced items on worksheets; fidget tools. Elliott and Marquart (2004) found that extended time produced meaningful score gains for students with learning disabilities but not for non-disabled peers, confirming its validity as an equaliser rather than an unfair advantage
Anxiety disorders	Quiet or separate testing environment; advance notice of schedule changes; flexible deadlines during flare-ups; permission to leave classroom for self-regulation; reduced public speaking requirements; access to school counselor; modified attendance policy during acute episodes
Dyslexia (without SDI need)	Text-to-speech software; audiobook access; reduced copying from the board; spelling not penalized in non-spelling assessments; extended time for reading-heavy tasks; graphic organizers for written assignments; oral testing options
Physical disabilities	Elevator access; modified PE participation; ergonomic seating; extra time between classes; rest breaks as needed; accessible classroom layout; assistive technology for written work
Diabetes and medical conditions	Unrestricted bathroom access; permission to eat snacks in class; nurse access for blood sugar monitoring; modified attendance policy for medical appointments; water bottle at desk; make-up work without penalty after absences
Depression	Check-in with counselor or trusted adult; flexible assignment deadlines; reduced homework load during episodes; late arrival permission; modified grading for participation during acute periods; quiet workspace option

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The most effective 504 Plans are specific rather than generic. "Extended time" is vague. "Time-and-a-half on all timed assessments, administered in the resource room" is specific enough to implement consistently across teachers. Using graphic organizers as a 504 accommodation for writing tasks is another example where specificity matters: the plan should name which type of organizer and for which assignment types.

When designing accommodations, consider the executive function demands of your classroom routines. A student with ADHD may not need fewer problems on a worksheet so much as they need the problems broken into smaller groups with a brief check-in between each set.

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When to Recommend Each Pathway

Teachers are often the first to notice that a student is struggling, and are frequently asked for their opinion on which pathway to pursue. The decision is ultimately made by a team, but your classroom observations carry significant weight.

Start with this question: Is the student falling behind academically despite the accommodations currently in place? If the answer is yes, and the student appears to need instruction that is fundamentally different from what general education provides, an IEP evaluation is the appropriate next step. "Fundamentally different" means a different curriculum, a different pace of instruction, explicit teaching of skills that peers have already acquired, or pull-out services with a specialist.

If the student is keeping pace with grade-level content but needs environmental adjustments to access it fairly, a 504 Plan is likely sufficient. The student with ADHD who understands the material but struggles with test-taking conditions benefits from extended time and a quiet room, not from a different reading programme. The student with anxiety who can complete all assignments but shuts down during timed assessments needs a testing accommodation, not specially designed instruction. Agran et al. (2020) found that placement and plan decisions are frequently based on institutional habit rather than individual need, reinforcing the value of teacher observation data in guiding the team towards the correct pathway.

A common misconception is that a 504 Plan is "less than" an IEP, or that an IEP is always better. This is not accurate. A 504 Plan is the right tool when the barrier is environmental. An IEP is the right tool when the barrier is instructional. Applying differentiation strategies effectively in the general education classroom can sometimes resolve concerns before either formal pathway is needed.

One more important point: if you believe a student needs evaluation, put the request in writing. Schools have a legal obligation to respond to written referrals. A verbal suggestion in a hallway conversation does not carry the same weight.

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The Evaluation Process

The evaluation processes for IEPs and 504 Plans differ in formality, timeline, and scope.

An IEP evaluation is comprehensive. The school must obtain written parental consent before beginning. The evaluation team, which typically includes a school psychologist, special education teacher, and general education teacher, conducts psychoeducational testing, classroom observations, and reviews existing data. Most states require the evaluation to be completed within 60 calendar days of receiving consent, though some states use school days instead. The Government Accountability Office (GAO, 2020) reported that evaluation timeline compliance varied widely across districts, with rural and high-poverty districts showing the greatest delays. The evaluation must assess all areas of suspected disability and use a variety of assessment tools. No single test or criterion can be used as the sole basis for determining eligibility. Using formative assessment data that you have already collected in your classroom, such as running records, curriculum-based measures, and behaviour tracking logs, strengthens the evaluation team's ability to make an accurate determination.

A 504 evaluation is less formal. Schools can use existing data, including grades, standardized test scores, teacher observations, medical records, and parent input, to determine eligibility. Formal psychoeducational testing is not required, though a school may request it. There is no federally mandated timeline for completing a 504 evaluation, though schools are expected to act within a reasonable period.

For both pathways, referrals can come from parents or school staff. A parent can request an evaluation in writing at any time. A teacher, counselor, or administrator can also initiate the referral process. Schools cannot refuse to evaluate a student when there is reason to suspect a disability, even if the student is earning passing grades. Grades alone do not determine eligibility under either law.

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Procedural Safeguards: Parent Rights

Both IEPs and 504 Plans include protections for families, but the scope of those protections differs substantially.

IDEA provides the most strong procedural safeguards in special education law. Parents must receive prior written notice before the school proposes or refuses to change the identification, evaluation, or placement of their child. They have the right to give or withhold consent at each stage. They can request an Independent Educational Evaluation (IEE) at public expense if they disagree with the school's evaluation. If a dispute arises, parents can pursue mediation, file a state complaint, or request a due process hearing before an impartial hearing officer. IDEA also includes the "stay-put" provision: during any dispute, the student remains in their current placement until the matter is resolved.

Section 504 safeguards are less extensive but still meaningful. Parents must receive notice of any actions the school takes regarding identification, evaluation, or placement under 504. They have the right to examine relevant records. If they disagree with the school's decisions, they can request an impartial hearing at the local level. They can also file a complaint directly with the Office for Civil Rights. However, 504 does not include a stay-put provision, does not require consent for evaluation (only notice), and does not guarantee the right to an independent evaluation at public expense.

For teachers, the practical takeaway is straightforward. Document your observations carefully and consistently. Attend meetings prepared with data. If a parent raises concerns about their child's plan, direct them to the school's 504 coordinator or the special education department, depending on which plan is in place. Know the difference so you can point families towards the right resource.

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For International Readers: UK Equivalents

Structural Learning serves a global audience, and many of our readers work in UK schools. The US and UK systems address similar needs through different legal frameworks. The table below provides approximate equivalencies; the systems are not identical, but understanding the parallels is useful for teachers who move between systems or collaborate internationally.

US Term	UK Equivalent	Purpose
IEP (Individualized Education Programme)	EHCP (Education, Health and Care Plan)	Legally binding plan providing specialist services and instruction for students with significant needs
504 Plan	SEN Support	School-level adjustments and accommodations within the general education setting
MTSS/RTI (Multi-Tiered System of Supports)	Graduated Approach (Assess, Plan, Do, Review)	Tiered intervention framework used before or alongside formal plans
IDEA (federal law)	Children and Families Act 2014 / SEND Code of Practise	Primary legislation governing provision for students with disabilities
FAPE (Free Appropriate Public Education)	SEND provision duty	Legal requirement to meet the educational needs of students with disabilities

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The UK's EHCP process shares many features with the US IEP: formal assessment, legally binding provisions, annual review, and a right of appeal. SEN Support in the UK, like the 504 Plan, operates at the school level with less formal documentation requirements. UK readers looking for a comprehensive guide to the SEND framework should see our full article on special educational needs and our guide to the Graduated Approach.

One notable difference is that the UK's Graduated Approach (Assess, Plan, Do, Review) is embedded as a required first step before escalating to an EHCP, whereas in the US, MTSS/RTI is widely used but not federally required as a prerequisite for IEP evaluation. Understanding how to build SEND-friendly learning environments is central to both systems. UK teachers can also benefit from our guide to EHCP annual reviews, which explains the UK equivalent of the IEP annual review process in detail.

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Practical Tips for Classroom Teachers

You do not need to be a special education expert to be effective at supporting students with IEPs and 504 Plans. You need to know what the plan says, implement it consistently, and document what happens.

Read every plan at the start of the year. This sounds obvious, but surveys of general education teachers consistently show that many do not read their students' accommodation plans thoroughly. Set aside time during the first week to review each plan, note the specific accommodations, and flag anything you are unsure how to implement. Contact the case manager or 504 coordinator with questions before the student encounters a situation where the accommodation should have been in place.

Document your implementation. Keep a simple log of when and how you provide accommodations. This protects you professionally and provides data for the team. When an accommodation is not working, your documentation is the evidence the team needs to revise the plan. A spreadsheet with dates, accommodation provided, and brief notes on student response is sufficient.

Communicate with families proactively. Do not wait for the annual review to share concerns. If a student with a 504 Plan is struggling despite accommodations, contact the family and the 504 coordinator. If a student on an IEP is exceeding their goals, share that success. Parents are required members of both IEP and 504 teams; they should not be learning new information for the first time at a meeting.

Speak up when accommodations are not working. Plans can and should be amended when the data shows a need. If a student's extended time accommodation is not helping because the real barrier is reading fluency rather than processing speed, say so. Your observations matter. Teachers who understand metacognitive strategies can help teams identify whether the barrier is a skill gap, a strategy gap, or an environmental mismatch.

Know the difference between accommodation and modification. An accommodation changes how a student accesses the same material (text-to-speech, extra time, preferential seating). A modification changes what the student is expected to do (fewer problems, different reading level, alternative assignment). Both have their place, but they are not interchangeable, and using the wrong term in a meeting can cause confusion.

Next time you sit down to review a student's plan, identify one accommodation you have not been implementing consistently. Put it in place tomorrow and track whether it changes the student's performance over the next two weeks.

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