IEP vs 504 Plan | What’s the Difference?

If you work in schools or have a student with a disability, you have probably heard of an IEP document or a 504 plan… or both! You may be wondering, “What’s the difference?” Many educators and parents are not clear on which students require which plan. While they both serve students with disabilities, they have some major differences that are important to know. This article will discuss IEP vs 504.

IEP vs 504 Plan Infographic

What is an IEP?

An IEP is an Individualized Education Program. IEPs are written for students who qualify for special education services through IDEA. In order to be eligible for special education, a student must have at least 1 of the 13 disability categories and their disability must negatively impact their education. These students require a specialized and individualized instructional program to ensure they receive a free and appropriate public education. IEPs are legally-binding documents that describe how the school will support the student throughout their K-12 education, and are updated annually by the case manager (typically the special education teacher) with the input of the IEP team.

For students who receive special education services and do not earn a high school diploma (typically students with moderate-severe disabilities), they are eligible to attend an adult transition program in their school district until they are 22 years old. While in their transition program, they will continue to have an IEP that is updated annually.

What is a 504 Plan?

Section 504 of the Rehabilitation Act of 1973 states that all entities receiving federal funding must ensure that people with disabilities are not discriminated against nor denied access. A 504 plan is created in K-12 schools for students who have a disability and require accommodations in order to access their educational environment. 504 plans are not updated annually, but are rather reviewed periodically (typically every 3 years). Students who do not qualify for an IEP or who do not require a specialized and individualized instructional program in order to participate in their educational setting may be eligible for a 504 plan.

IEP vs 504: Who are they for?

IEP

IEPs are for students with disabilities who require specialized instructional programs individualized to their unique strengths and needs in order to obtain a free and appropriate pubic education (FAPE). Here are some examples of student profiles who would require an IEP:

• Student with severe autism and who is nonverbal, thus requiring assistive technology to communicate
• Student with down syndrome who is unable to attend to academic tasks for extended periods of time or in general education settings
• Student with an intellectual disability who is 16 and cannot read phonetically nor perform simple 2nd grade level addition or subtraction calculations

Students who require IEPs are students who need more than basic accommodations in a general education setting in order to be successful at school. These students require a variety of services and supports in order to learn, which would be included in a specialized program. These specialized programs could include a special day class where a student is in a special education classroom for the entire day or a specific percentage of the day working on functional skills, or even resource room settings where a student spends a period or so a day in an academic support classroom with special education teachers.

504 Plan

504 Plans are for students with disabilities who require accommodations in order to successfully participate in general educational settings. Here are some examples of student profiles who would require a 504 Plan:

• Student with visual impairment who requires the accommodation of preferential seating to ensure they are close enough to the board to see
• Student with dyslexia who requires the accommodation of extended time on tests to ensure they have ample time to read and decode
• Student with ADHD who requires the accommodation of an alternative testing environment to ensure they are able to focus without distractions

Students with 504 plans attend general education classes, and are able to access the curriculum with the support of their defined accommodations. The materials and curriculum do not need to be altered in a way that changes the educational outcome in order for these students to meaningfully participate.

IEP vs 504: How the Documents Differ

A 504 plan contains accommodations to support the student with a disability in their current educational placement. An IEP document contains accommodations to support the student with a disability and a description of an individualized and specialized program to meet their needs. This program includes their:

• Special Education Eligibility and description of how their disability impacts their education
• Individual Transition Plan (for students 16 years and older) with post-secondary goals created from assessments and linked to annual goals
• Present Levels of Performance in a variety of domains including:
  • functional skills
  • pre-academic/academic skills
  • communication development
  • gross motor skills
  • fine motor skills
  • social-emotional skills
  • vocational skills
  • daily living/adaptive skills
  • health
• Special Factors including behavioral supports and assistive technology
• Statewide Assessment results
• Annual goals that are measurable, targeting the student’s deficits described in their Present Levels of Performance, and linked to their Individual Transition Plan post-secondary goals
• Offer of FAPE: Free and Appropriate Education
  • Related Services
  • Supplemental Aids and Supports
  • Educational Setting
• IEP Meeting Notes containing important information, discussions, and parent concerns
• Emergency Procedures Plan (in the case of a disaster restricting school accessibility such as COVID-19)

IEPs are updated and reviewed annually at the Plan Review IEP meeting, and special education eligibility is redetermined through assessments every 3 years and discussed at the Triennial Eligibility Evaluation IEP meeting. 504 plans are not renewed annually, but are reviewed and/or updated periodically (typically every 3 years) or upon parent request.

IEP vs 504: Beyond K-12 School

Neither IEP documents nor 504 plans carry over into college for students with disabilities. IDEA protections end at 12th grade (with the exception of adult transition programs for students with moderate-severe disabilities who did not earn a high school diploma), which is why colleges are not required to create or implement IEPs. The Rehabilitation Act of 1973 Subpart D applies to K-12 schools while Subpart E applies to post-secondary schools. Due to this distinction, colleges have different requirements for supporting students with disabilities. They are not required to provide or implement 504 plans, though they are still held accountable for providing accommodations and supports for students who are eligible under the Americans with Disabilities Act (ADA).

While colleges are not required to implement a student’s IEP or 504 plan, they may use the document’s contents for decision-making or choose to implement particular accommodations or supports that were defined in the IEP or 504. However, just because a student had an IEP or 504 plan in high school, that does not mean they will receive accommodations while in college. In order to receive accommodations at the college-level, the institution must find the student eligible for services. Once a student has enrolled in college, they must register with their university’s disability services office to pursue accommodations. It’s important to remember that it is the responsibility of the student, once in college, to notify the institution of their disability in order to receive appropriate accommodations.

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