Section 504 Support
Region 17 Education Service Center
Frequently Asked Questions
2. Do I have to provide services to my Section 504 students while they are working from home? Yes--OSEP Guidance provided March 12, 2020, stated that "if schools provide any educational services to the general student population during a closure, students with disabilities must have equal access to such services."
3. What quality of services must be provided during closure? Schools must ensure that, to the greatest extent possible, each student with a disability can be provided special education and related services identified in the student's IEP developed under IDEA, or a plan developed under Section 504.
4. How do we provide the accommodations for our Section 504 students? Each student's plan should be reviewed on an individual basis and justifiable rationale for judging whether an accommodation can or cannot be provided whether through virtual learning or packets sent home. You will send the accommodations with the packets for your 504 students, or if you are working virtually, then apply those accommodations during your virtual lessons. If the accommodation is not applicable, then don't use it and document why it was not used. For example, preferential seating at home is probably not an applicable accommodation.
5. What if an evaluation was not completed, do the timelines still apply? Be sure to communicate with the parents in writing what you are continuing to work on and why you can't continue the assessment. Document the date that you had to stop the evaluation, and what was tried to meet the timeline. The completion may be delayed due to the health and safety of the students, parents, and staff. As soon as it is safe and schools resume, you will complete the evaluation as soon as possible.
6. What if a student misses some or all of services during this time? Carefully document all missed services and/or accommodations in the student's file and explain why. Document the student's performance and progress in distance learning activities. If student is refusing to participate, document that information and any efforts made to rectify the situation.
7. What else should we be providing parents besides accommodation and services information? Parents should be given some way of communicating back to the school/504 person whether they have concerns or want to give input or get guidance. They should be given the contact information including a phone number, email, and even possible "office" times.
Section 504 Resources
Section 504 of the Rehabilitation Act of 1973 Guidance (PDF) April 2 2020
Special Education Privacy and FERPA considerations for virtual instruction (PDF) April 2 2020
ARD Committee Considerations During COVID-19 (PDF) April 2 2020
Evaluation Considerations During COVID-19 (PDF) April 2 2020