Presented by:
Robert Compton
Director of Student Services,
South Carolina Public Charter School District
rcompton@scpcsd.sc.gov
Adapted from a presentation created by: Rock Hill School District 3
Disclaimer
 Section 504 IS NOT special education; it’s a general
education responsibility
 Don’t think because “Robbie” oversees it means it’s a
special education thing.
 504 compliance and coordination falls under the
District’s Director of Student Services.
Section 504 School Expectations
 All South Carolina Public Charter School District
schools are required to follow the District’s Section 504
Policies and Procedures.
 These procedures include the identification of the
principal or his/her designee as the "Section 504 School
Coordinator," who is the building-level compliance
monitor and coordinator for Section 504 support.
 The District’s Section 504 Compliance Officer is Robbie
(me).
 The District’s Section 504 Compliance Officer cannot
serve on school 504 committees because this person is
part of the District’s grievance process.
Building Level 504 Coordinator
Roles and Responsibilities:
 Provide guidance and answer questions surrounding 504
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referral, evaluation, and implementation from
parents/guardians, students, and/or school staff
Attend professional development/training sessions
throughout the school year
Schedule and Lead meetings with parents/guardians and
relevant school staff
Responsible for data collection in preparation for meetings
Maintain school level 504 files for each student
Submit necessary paperwork to Zenobia Ealy in a timely
manner
What is Section 504?
 The Rehabilitation Act of 1973, commonly referred to as “Section
504,” is a federal statute that prohibits discrimination against
persons on the basis of their disability by institutions that
receive federal assistance.
 Section 504’s purpose is, among other things, to assure that
disabled students have educational opportunities and
benefits equal to those provided to non-disabled students.
 If a student is covered by Section 504, South Carolina Public
Charter School District Schools must provide protection and
accommodations as are necessary to ensure that the
eligible student has equal access to services, programs or
activities offered by our schools.
Section 504 is NOT
Special Education
IDEA

Student must have a disability
that falls into a defined
qualifying area and adversely
affect educational performance
 Must need specially designed
instruction
 Requires a comprehensive
evaluations, including
screenings, psycho-educational
evaluations and intervention
data
 Criteria of exclusion/narrow
eligibility
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Works well with RTI
Defined IEP team members
Parent consent required
Strict and specific timelines
Section 504
 Student must have* physical or
mental impairment that substantially limits a life function.
 Prevents discrimination, insures
equal access with
accommodations and services
 Requires relevant information
from a variety of sources
 Broadened eligibility
 Does not work well with RTI
 Decision by group of
“knowledgeable persons”.
 Parent consent recommended
 “Reasonable” timelines
Can’t Have Both…
It should be noted that students who qualify for special
education services under the
IDEA Act are automatically protected under Section 504.
Individualized Education Plans (IEPs) satisfy the
requirements of an accommodation plan.
Who Can Refer a Student?
 Section 504 Referrals can come from:
 A parent/guardian
 Eligible Adult Student
 School Staff (Teacher, Nurse, Administrator, Special
Area Teacher, or *RTI Team)
…who believes the student has a physical or mental
impairment that substantially limits one or more
major life activity.
*A student should NOT go through the RTI process if they are being
referred for a 504.
When Should a School Refer?
When someone thinks the students has a physical or
mental disability that substantially limits 1 or more life
functions
 Receive a doctor’s note or medical report
 Student returns after a serious illness or injury
 Student is suspected of having an impairment
 Student exhibits signs of a chronic health problem/has
absences due to illness
Who Should Serve on a 504 Team?
 School Level 504 Coordinator (required for initial)
 Parent/Adult Student
 Relevant School Staff
 Persons knowledgeable of the child
 Persons knowledge of meaning of evaluation data,
 Knowledgeable of accommodations/placement
options
 School Psychologist
Eligibility Requires Evaluation
Specific criteria ARE NOT required!
 Evaluation does not necessarily mean TEST; formal
testing is not required!
 Requires data from a variety of sources
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Not just a note from a doctor or 1 discipline report (etc.)
 Failing grades are not required
What does the 504 team need to “identify the specific nature
of the disability and identify the services necessary”?
Common Sources of Evaluation Data
 Student grades, disciplinary referrals, health information,
parent information, test scores, teacher comments, Special
ed. assessments and data
 The amount and the “weight” is determined by the 504
team, given the student’s individual circumstances
 Screenings (vision, hearing, S/L, health) are NOT required
 No medical diagnosis is absolutely required (if you have
other data…)
Section 504 Eligibility
(3 Part Process)
Had Enough?
 Let’s look at the process
 It really rather simple!
 All Necessary Paperwork for Section 504 is Located
on in the DropBox (SCPCSD 504 Documents)
Section 504 Referral Procedures
Step 1 – Parent Request
If a parent/guardian or adult student requests 504
consideration, he/she is directed to the school’s 504
Coordinator. The school’s 504 Coordinator :
 Completes the Referral for Section 504 form in an interview
with the parent/adult student
 Provides the parent/guardian/adult student with a copy of
Section 504 Rights
 Schedules a meeting with the parent/adult student and
relevant school staff *, then sends the parent/adult student
a Section 504 Meeting Invitation.
 The 504 Coordinator coordinates data collection in
preparation for the meeting.
Section 504 Referral Procedures
Step 1 – School Staff Request
If a school staff member wants to request 504 consideration
for a student the staff member contacts the school’s 504
Coordinator. The 504 coordinator does the following:
 Completes the Referral for Section 504 form with the
referring staff member.
 Schedules a meeting with relevant school staff* and
parent/guardian, then sends the parent a Section 504
Meeting Invitation. The student’s parent is also sent a
copy of Section 504 rights.
 The 504 Coordinator coordinates data collection in
preparation for the meeting.
Step 2 – Initial Mtg Held
An initial 504 meeting is held. At the initial 504 team
meeting:
 The Referral for Section 504 form and available data
are reviewed by the team.
 The team determines if additional information is
needed to help determine 504 eligibility.
 The Parent Permission for 504 Evaluation form is
completed by the team, and signed by the parent, if in
attendance.
Step 2 – Additional Data Not Needed
If additional data or information is not needed, the
meeting continues and the 504 team completes:
 The Section 504 Initial Evaluation & Periodic Re-
Evaluation form
 A Section 504 Plan, if applicable.
 Ensures 504 Parental Rights have been provided to the
parent, guardian, or adult student.
Step 2 – More Data Needed
If additional data or information is needed, this initial
meeting ends. The additional data is collected then the team
reconvenes. The 504 Coordinator will schedule the meeting
and send the parent/guardian a Section 504 Meeting
Invitation.
At this follow-up meeting, the team completes:
 The Section 504 Initial Evaluation & Periodic Re-Evaluation
form
 A Section 504 Plan, if applicable
 Ensure 504 Parental Rights have been provided to the
parent, guardian, or adult student.
What is Substantially Limits?
“Substantially Limits” is not clearly defined.
 The decision must be made on a case by case basis by a
school team. Teams should err on the side of
inclusion/eligibility.
 A disability is not substantially limiting if the student
is as successful as typically developing students in the
major life activity.
 A disability may be considered substantially limiting
if it prevents the student from participating in the
same activities as other students.
Don’t Forget: Mitigating Measures
 School districts must consider “mitigating measures” used by a
student in determining whether the student has a disability
under Section 504. Mitigating measures are devices or practices
that a person uses to correct for or reduce the effects of that
person’s mental or physical impairment. Examples include
corrective eyeglasses and medications. A person who experiences
no substantial limitation in any major life activity when using a
mitigating measure does not meet the definition of a person
with a disability and would not necessarily require
accommodations under Section 504. However, if a student’s
needs require storage and administration of medication during
the school day, such accommodations may be required for
purposes of providing access to school activities (IHP)
Section 504 Referral Process
 Step 3 – Accommodations Plan (if eligible)
 Develops the accommodation plan, that includes
statewide testing accommodations.
 The accommodations provided should allow for
the child to have the same equal access as their
non-disabled peers.
 Do not treat accommodations like a buffet.
Step 4 – After the Meeting
 Meet with school staff who interact with the student and
provide them with a copy of the accommodations plan.
(Remind them of Confidentiality)
 All school staff who will interact with the student must:
 Receive a copy of the accommodations plan
 Sign the receipt of accommodations form
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(This indicates they have received a copy of the
accommodations/actions and will provided what is necessary
to meet the student’s needs. This will also serve as an
additional form of documentation.)
504 Files
 504 Coordinators will maintain a 504 file for each
student. This file should contain all forms, data,
receipt of accommodations form, and reports.
 A copy of the most recent 504
Plan/evaluation/reevaluation needs to be sent to
Zenobia Ealy.
 zealy@scpcsd.sc.gov
 803-734-8325 (fax)
Manifestation Procedures
Students with Section 504 plans also require manifestation
determination meetings.
 All of these procedures apply except students with 504 plans do not
qualify for AES services. If the behavior/incident is not a manifestation
of the disability, appropriate disciplinary action can proceed and the
student can be treated like any other non-disabled student.
 If the behavior/incident IS a found to be related to the disability, and the
student will be over the 10 allowed days, the school may not discontinue
educational services. This means that the student MUST be returned to
the regular education program in which he/she was enrolled. In
addition, a re-evaluation MUST be initiated to determine the need for
additional accommodations under Section 504 (including a behavior
plan) or evaluation for eligibility under IDEA.
 Current drug and alcohol use/sale automatically cancels 504 protections.
What do I need to do NOW?
 Meet with the 504 Coordinator in your building from last year
 Obtain all student files
 Review the list of students to ensure you have the files for all
students in your building.
 Review the 504 plans to ensure you understand the needs of
the students
 Meet with staff members who interact with students and provide
them a copy of the accommodations plan. Also have them sign a
receipt of accommodations form.
 Should have taken place prior to school starting
Annual Review/Reevaluation
Suggested Timeline
All students with 504 Plans will have an annual
review each year before the end of the first 9th
weeks.
 Students who are 504 eligible had ever-changing
needs and requirements and plans should be
modified based on those needs.
 Changes (even if minor) document that the case has
been reviewed and the student’s needs have been
considered by the 504 team.
Transfers Into the District
 If a student has recently received, or is suspected of
having recently received, Section 504 support out-ofdistrict, then a referral for Section 504 services must
be initiated. Pending the completion of an evaluation
and final determination of the student’s need for an
annual Section 504 Accommodation Plan, interim
Section 504 services may need to be implemented for
the student.
Transfers
 Step 1: Acquire all 504 records from previous school district
 Step 2: Hold Interim Planning Meeting to determine:
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(a) whether the student has an identified physical or mental impairment;
(b) whether the student’s out-of-district accommodations are consistent with
federal and district Section 504 standards, appropriate and sufficient, and can be
implemented as written in this district; and
(c) whether additional evaluation components need to be completed
 Team can determine to implement the out-of-district 504
Accommodation Plan as written (complete district evaluation summary
and accommodation plan)
 Team can determine to modify the out-of-district 504 Accommodation
Plan (complete the district evaluation summary and accommodation
plan)
 Step 3: Within 30 calendar days, determine district/school eligibility
(based on current data)
 Requires completion of evaluation summary/determination and
accommodation plan
Reevaluations
 Prior to making any significant changes in a student’s
accommodation plan or educational placement, a
Section 504 reevaluation must be conducted to
determine the student's educational needs.
 Significant changes also include “exiting.”
 Forms/Documentation:
 Notification of Meeting (with procedural safeguards)
 Evaluation/Reevaluation Form
 504 Plan (if determined continued eligibility)
No Longer Eligible
 A student may only be exited from Section 504 support
under the following circumstances: (a) a temporary
impairment, which had educational implications for
the student (e.g., injuries sustained in an accident), is
no longer present, (b) the student's disability no
longer substantially limits his/her major life activities,
or (c) the student has been identified as eligible for
receiving special education and related services.
Sufficient documentation is required to complete the
exiting process.
 See process for “reevaluation” to exit the child
Needs more than a 504 Plan
 If the student’s needs are so extreme as to require
special education and related services, a referral to
special education must be considered.
 A 504 accommodation plan should not be developed
at this time.
 Remember a 504 Accommodation plan is the provision
of a FAPE. If services under IDEA are needed to
provide a FAPE, then a FAPE cannot be lessened to
what a 504 can provide.
Grievance
 Step 1: Voluntary Grievance Review at the Building
Level.
 File a written complaint with the site 504 Facilitator
and/or Principal detailing disagreement and request
that the 504 team review the plan in an attempt to
resolve the disagreement.
 The complaint shall be handled promptly, allowing no
more than five working days to elapse before a written
response is made by the 504 Coordinator or Head
Administrator and presented or mailed to the person
who issued the complaint.
Grievance Continued
 *Step 2: Grievance to the District’s 504 Compliance Officer
 *Step 3: Request Impartial Due Process Hearing
 *Step 4: File a complaint with the Office of Civil Rights
*Although complainants are always encouraged to attempt to
resolve concerns by other dispute alternatives, a complainant’s
request for a grievance review under Steps 1 and 2, above, is
optional and is not required before requesting an Impartial
Hearing or before filing a formal complaint with the Office of
Civil Rights
Robert Compton,
504 Compliance Officer
South Carolina Public Charter School District
3710 Landmark Drive, Suite 201
Columbia, SC 29204
803-734-8067 (o)
803-230-9593 (c)
803-734-8325 (fax)
rcompton@scpcsd.sc.gov