504 Plan: Who Qualifies, Accommodations and How to Get One

A 504 plan describes the supports a student with a disability needs to learn alongside classmates on an equal footing, such as extra time on tests, a seat near the front, breaks to check blood sugar or a plan for a food allergy. It comes from Section 504 of the Rehabilitation Act, a civil rights law, and it covers more students than special education does. This guide explains who qualifies for a 504 plan, whether a diagnosis is required, how to request one, common accommodations, and what happens with discipline, college entrance exams and college itself.

What is a 504 plan?

Section 504 bars disability discrimination by any school that receives federal funds, and it requires public schools to give each student with a disability a free appropriate public education. A 504 plan is the document schools commonly use to write down what that means for one student. The Office for Civil Rights (OCR) says a 504 plan describes a student’s placement: the regular or special education, related aids and services the student needs, and the setting where the student receives them.

Federal regulations do not actually require a written plan or set out what it must contain. OCR encourages schools to put it in writing to avoid misunderstandings, and most do. For how a 504 plan compares with an IEP under special education law, see edCircuit’s Special Education Guide.

About 1.6 million students, or 3 percent of public school students, were served only under Section 504 in 2020–21, according to OCR’s Civil Rights Data Collection, compared with 14 percent served under the Individuals with Disabilities Education Act (IDEA).

Who qualifies for a 504 plan?

A student qualifies if they have a physical or mental impairment that substantially limits one or more major life activities. Several points make that broader than many families expect, according to OCR:

• Learning does not have to be the limited activity. A student’s ability to learn does not need to be substantially limited. Major life activities include eating, sleeping, breathing, reading, concentrating and thinking, and major bodily functions such as the immune, digestive, neurological, respiratory and endocrine systems.
• Common examples. OCR says anxiety disorders and ADHD in many cases would qualify. A student with diabetes who needs insulin is substantially limited in an endocrine function, and a food allergy qualifies if it substantially limits eating, breathing or another major life activity.
• Good grades do not rule a student out. A student who earns good grades may still have a disability that substantially limits a major life activity.
• Medication does not count against eligibility. Since 2009, schools may not consider the effect of mitigating measures such as medication, assistive technology or learned coping strategies when deciding eligibility. Ordinary glasses and contact lenses are the exception.
• Conditions that come and go count if they would be substantially limiting when active. A temporary impairment counts only if it is severe enough to substantially limit a major life activity for an extended time.

Is a medical diagnosis required for a 504 plan?

No, and a diagnosis alone is not enough either. OCR says there is nothing in Section 504 that requires a medical diagnosis before a school decides a student has a disability, and schools cannot require parents to provide medical documentation before evaluating a student. If the school’s team decides a medical assessment is needed, the school must provide it at no cost to parents. In the other direction, a diagnosis does not automatically mean a student qualifies: the condition must substantially limit a major life activity. A doctor’s diagnosis can be one of the sources the team considers.

How to get a 504 plan

1. Ask for an evaluation. A parent can ask a principal, counselor, social worker or teacher to arrange an evaluation, OCR’s Section 504 resource guide says. Putting the request in writing is not required, but OCR notes it helps avoid misunderstandings and creates a record.
2. Give consent. Schools must get parents’ permission before an initial evaluation.
3. The school decides whether to evaluate. Parents do not have an absolute right to an evaluation on request, but the school must evaluate when it has reason to believe the student needs services because of a disability, and it may not delay an evaluation because the student is receiving intervention supports such as RTI or MTSS. If the school refuses, it must tell parents how to challenge that decision.
4. The 504 team decides. A group of people who know the student, understand the evaluation data and know the placement options decides eligibility and what the student needs, drawing on a variety of sources.
5. The plan is written and shared. Teachers must carry out 504 plans for the students they teach, and OCR stresses that teachers and staff need access to the plan.

How long does a 504 evaluation take?

Section 504 sets no deadline. OCR says it generally judges whether a school took a reasonable time by looking to the IDEA’s 60 days from parental consent, or to a state or district timeline where one exists.

Common 504 plan accommodations

There is no fixed list; every plan should fit the student. Examples from OCR and the American Diabetes Association:

OCR does not distinguish between “accommodations” and “modifications.” For nursing needs, the 504 plan records that the student needs nursing services, and the detailed instructions usually go in a separate individualized health plan.

Reviews, transfers and discipline

• Reevaluation. Section 504 requires periodic reevaluation, with no fixed schedule, and a reevaluation before any significant change in placement.
• Changing schools. If a new district’s team finds an incoming 504 plan appropriate, it must carry it out; if not, it evaluates the student.
• Discipline. OCR treats a removal of more than 10 consecutive school days, or a pattern of shorter removals adding up to more than 10, as a significant change in placement. Before the 11th day, the school must reevaluate the student to decide whether the misconduct was caused by or related to the disability, known as a manifestation determination. Section 504 prohibits disciplining a student for behavior the school knows is a manifestation of the disability.
• Shortened days. A shorter school day is generally not allowed unless the 504 team decides the student needs it.

504 plans and the SAT, ACT and AP exams

A 504 plan does not carry over automatically to College Board exams. College Board says students with an IEP or 504 plan must still have accommodations approved by its Services for Students with Disabilities. Most requests go through the school’s SSD coordinator, and when the request matches accommodations in the plan, no additional information may be needed. A new request can take up to seven weeks, so College Board suggests applying in the spring before a fall PSAT or SAT. Once approved, accommodations apply to the PSAT, SAT and AP exams until one year after high school graduation.

ACT says a current, valid 504 plan that documents accommodations a student routinely uses is sufficient documentation for the same accommodations on the ACT.

Do 504 plans apply in college or private school?

College: A 504 plan does not follow a student to college. Colleges must provide academic adjustments, such as extended time on tests, note-takers or screen-reading software, but not a free appropriate public education, and students must identify themselves and ask. The Education Department says a 504 plan may help show what has worked but is generally not sufficient documentation on its own, and neither the high school nor the college must pay for a new evaluation. Students should contact the college’s disability office as early as possible.

Private school: Section 504 applies only to private schools that receive federal funds. All public schools, including charter and magnet schools, are covered.

What if you disagree with the school?

• Impartial hearing. Parents who disagree with the school’s decision can request an impartial hearing, with the right to participate, to be represented by a lawyer and to a review procedure. Section 504 does not require mediation.
• OCR complaint. A complaint must ordinarily be filed within 180 days of the discrimination, though OCR can grant a waiver for good cause. OCR generally does not evaluate the content of a 504 plan; disagreements about what a plan should contain go to a hearing.
• Lawsuit. Families may sue without first filing with OCR.
• No retaliation. Schools may not retaliate against families who raise concerns.

OCR’s capacity has shrunk. Staff cuts reached an estimated 299 of 575 positions and seven of 12 regional offices closed, The Conversation reported in a piece republished by PBS NewsHour in September 2026, which means longer waits for families who file complaints.

What is the 504 plan lawsuit?

The case known as Texas v. Kennedy challenges a 2024 Section 504 rule issued by the Department of Health and Human Services for the programs it funds. It does not challenge the Education Department’s school regulations, and the states dropped their claim that Section 504 itself is unconstitutional in 2025. As of late July 2026, three states remained in the suit, AJMC reported. Students’ rights to 504 plans in school are unchanged.

For teachers and school leaders

• Make sure every teacher can see the 504 plans for their students and knows what each requires.
• Do not wait for a diagnosis or for intervention supports to run their course before evaluating a student you suspect has a disability.
• Track removals for students with 504 plans, and reevaluate before the 11th day.
• Name your district’s Section 504 coordinator, required in districts with 15 or more employees, and provide translated plans to parents who need them.
• Start College Board accommodation requests early for juniors and seniors.

For how an IEP is written and reviewed, see edCircuit’s guide to the IEP meeting.

Frequently asked questions

What is a 504 plan? A plan, under Section 504 of the Rehabilitation Act, that sets out the accommodations, aids and services a student with a disability needs to have equal access to school.

What qualifies a student for a 504 plan? Any physical or mental impairment that substantially limits a major life activity, such as learning, concentrating, eating, breathing or a major bodily function.

Is a medical diagnosis required for a 504 plan? No. Schools cannot require one before evaluating, and a diagnosis alone does not guarantee eligibility.

Can a student with ADHD get a 504 plan? Often, yes. OCR says ADHD in many cases is an impairment that substantially limits a major life activity.

Does a 504 plan carry over to college? No. College students must ask the college for academic adjustments, and may need new documentation.

How long does it take to get a 504 plan? Section 504 sets no deadline; OCR looks to IDEA’s 60 days or state timelines to judge whether a school was reasonable.

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