Frequently Asked Questions regarding 504s
Initial Eligibility
FORMS
Required
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Optional
Invitation to Conference
Data Collection Tool
Evaluation/Eligibility
Determination
Individual Accomm Plan
Notice of Rights
Annual Review
3 Year Reevaluation
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Invitation to
Conference
Individual
Accomm Plan
Notice of Rights
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Invitation to Conference
Data Collection Tool***
Evaluation/Eligibility
Determination
Individual Accomm Plan
Notice of Rights
Data Collection
Tool
***Complete all that 504 team determines is necessary for reevaluation (see question #9 below).
1. Need a list of all qualified medical provider sources – example: nurse practitioner, clinical
psychologist, anyone who can write prescriptions? Now clarified on form-see current form
posted online
2. What is the expectation for us moving forward from today – should we be conducting an
evaluation on any student KNOWN to have a diagnosis? No-PSM or SST determines when
there is a need and whether additional data should be collected to consider eligibility. If a
student is not in PSM or SST and a diagnosis is presented the team must inquire about the
reason for presentation by the parent (ex: to have on file, to talk about a need for help, to
request a 504 or IEP). If their intent is concern or the staff have concerns over educational
need the team must convene to determine next steps.
3. What is a reasonable 504 caseload for 1 staff with many other significant responsibilities?
Administrator determines
4. Just an FYI – the old 504 forms are still accessible on the website under the Spec. Ed &
Related Services Manual –This has been taken care of.
5. What are some examples of strengths and needs for a 504 plan? This is child specific and
discussed/determined as part of a team meeting.
6. Define “General Ed Peers”. How does that fit when talking about High Poverty Schools? It
is the general population not school specific.
7. It may be helpful to have some examples or templates of completed forms to make sure we
use acceptable terminology, whether we are awarding eligibility or declining eligibility. Is this a
possibility? This would not be appropriate as it would create blanket eligibility determinations.
We train on process/procedures so teams can apply their knowledge to each individual case.
Updated 5.5.14
8. Does a 504 annual review require a new diagnosis? 504’s should be reviewed annually to
determine appropriateness of the accommodations. As with IDEA, annual reviews don’t require
an evaluation of gathered data or diagnosis. A current diagnosis is only required for initial
determination or when the team determines the need to reevaluate.
9. When is a 504 reevaluation required? The 504 team is to reevaluate (at least every 3
years) to determine if there is a need for additional/updated data to continue eligibility. As with
IDEA, if there is no need for additional/updated data to continue eligibility, the team documents
such and the reevaluation is complete (without new data). If the team determines the need for
an updated diagnosis to continue eligibility, the diagnosis must be within 1 year to be used for
eligibility consideration.
10. In past, we were told that any mods/accs put on a 504 must first have been tried and
proven helpful to student. What kind of documentation is needed to support this? If RTI
paperwork, how would “extended time” be considered an “intervention”? Yes, any
modifications should be provided as modifications, accommodations, or interventions prior to
being used on a 504 plan and data collected as to their impact. This would include extended
time, multiple test sessions, modified day (on very rare occasions), etc. In most cases this will
be documented as a part of RTi/SST paperwork.
11. What data should be collected prior to considering modified day? Modified day is an
intervention that should be used only on rare occasions and may be documented via RTi
paperwork as an intervention or may be part of a 504 accommodation plan-this is child specific.
Due to the restrictiveness of modified day, the student should have had numerous interventions,
an FBA/BIP, and the school should have exhausted all normal disciplinary actions prior to trying
modified day.
12. Does 504 Team complete data collection forms at initial & review meeting? It is a required
document for working through the initial eligibility process and can be a very useful tool for
conducting an annual review or re-eval.
13. When 504 student enters middle or high school , do you re-evaluate or just look at their
initial date to see when the 3 years is up? Re-evaluation is not required as part of transition but
is required at a minimum once every 3 years. More frequent evaluation is team determined and
child specific.
14. How long to have before EOGs? NC Testing procedures require that testing modifications
must be documented/implemented at least 30 days prior to testing.
15. Data Collection – If…No current RTi data non-interventions – Table the 504 eval process/
put in place RtI probes/interventions? Refer to Question #10
16. What if a student doesn’t take meds regularly and he is able to demonstrate success
w/meds, & but w/o meds the accommodations are not assisting the students ….do they qualify?
Updated 5.5.14
If the mitigating measure is not routinely used, ie: student is not routinely successful, the team
should consider the need for a 504 accommodation plan.
17. Do we consider all students with a diagnosis or wait for issues to be present? See
Question #2.
18. How do we define how much effort a student should be expending on homework? This
could be school and grade level specific. However, we should consider the discrepancy
between homework completion of the general population versus the individual student.
19. If a decision is being contested by a parent or staff how is a final decision reached? Good
rule of thumb if the team can’t reach consensus then defer the administrative designee to weigh
all information considered and guide the team toward making the decision that best meets the
needs of the student.
20. What other accommodations can be offered under 504? Transportation? Any non-routine
accommodations need to be discussed directly with your liaison.
21. Can the diagnosis be simply a note from a prescription pad? Yes. A release of information
should be obtained to verify an medical documentation received.
22. If in home therapy brings us a PCP that has NO MD signature /diagnosis. We CANNOT
accept. Must send parent back to doctor? What about psychologist? LPC? Refer to the
section of the Data Collection Tool regarding Medical Diagnosis Provided by Parent.
23. What is the process for when the diagnosis is not from a medical professional at an initial
request? See Question 24
24. Is Auditory processing a valid diagnosis for a 504? Yes by a qualified healthcare provider
who is credentialed to make that diagnosis (an Audiologist). If unsure, ask your Liaison.
25. When looking at a student’s performance in high school, is it okay to consider the level of
coursework (AP or Honors vs regular) in determining whether the disability substantially limits a
major life activity? You compare to the general population anytime considering eligibility for a
504 plan.
26. Does parent request for 504 have to be in writing? No
27. How does process differ for transitory 504s? A transitory impairment plan is no longer
considered a 504. Any need for a transitory impairment plan is managed through the testing
coordinator.
28. Is there a list of 504 coordinators on your website? It was shared as a googledoc with all
504 coordinators.
Updated 5.5.14
29. Who are required members of the 504 team? Our county procedure is 504 coordinator,
general education teacher, Adminstrative Designee and parent is to be invited. 504 coordinator
is not to serve a dual role as Administrative Designee. These required participant roles are
noted on the 504 invitation.
30. Target review date? Exactly 1 year or 1 day prior? Ex 2/14/14 5o 2/14/15 or 2/13/15?
Annually review-best practice is once every 12 months
31. Will there be additional training for coordinators on what can and cannot go on a plan?
(accommodations/BIP/etc) Yes, there will be a 504 coordinator follow up training.
32. Can we use a diagnosis from a Doctor who may be located out of state? Yes, as long as it
is current and the individual providing diagnosis meets guidelines.
33. Should Special Ed teachers continue to be 504 chairs or should the switch over be made?
Generally, it should be a gen ed function.
34. With reviews of existing 504 students, are we starting from scratch? No
35. Is an annual review a legal requirement or a best practice? Required per NHCO policy
38. Is the inability to attend school a “limit” to a major life activity? Yes
If so, are all homebound cases an accommodation for their educational needs? And requires a
504 Plan-No, there are several avenues that can lead to accessing hospital/homebound
services. If you have questions about a particular case consult your liaison.
Updated 5.5.14