Individualized Education Programs (IEPs) and 504 Plans are both ways to help support students in the classroom with learning and/or behavioral needs through providing accommodations and support. In both options, families and caregivers should be actively involved in deciding these supports based on a child’s specific needs. 

IEPs and 504 Plans are designed, implemented, and reviewed differently. They are governed by different laws, have different eligibility requirements (with higher requirements for IEPs), and provide different levels of support. Read below to learn about some important ways in which IEPs and 504 Plans are similar and different:

What are they?

• IEP: A detailed written document that describes how a student will participate in a general education curriculum (if appropriate) and identifies special education and related services specific to a student’s disability and needs that the school will provide for free. 

• 504 Plan: A plan that outlines extra support for a student with a disability so they can learn alongside their classmates. 

What are the relevant laws?

• IEP: A federal special education law called Individuals with Disabilities Education Act (IDEA).

• 504 Plan: A federal civil rights law called Rehabilitation Act of 1973, specifically Section 504. This law aims at stopping discrimination against people with disabilities.

Who is eligible?

A child can qualify for an IEP if they are determined by the school to have one or more of the 13 disabilities listed in IDEA. Additionally, the disability must be shown to hinder the child's academic performance and/or ability to function in school.  They are:

• Autism Spectrum Disorder (ASD)

• Blind or Low Vision (BLV)

• Deaf or Hard of Hearing (DHH)

• Deaf-Blind (DB)

• Developmental Delay (DD) (ages 3 through 9 only)

• Emotional Disability (ED)

• Intellectual Disability (ID)

• Language or Speech Impairment (LSI)

• Multiple Disabilities (MD)

• Other Health Impairment (OHI)

• Orthopedic Impairment (OI)

• Specific Learning Disability (SLD)

• Traumatic Brain Injury (TBI)

A child can qualify for a 504 plan if they have any type of disability that limits a “major life activity.”  Examples include learning, walking, talking/communicating, seeing, hearing, and taking care of oneself. These requirements are broader and a child who qualifies for a 504 plan might not qualify for an IEP. 

What is in the plan?

An IEP is a very specific document that has to have certain elements. These include:

• The student’s present level of performance (PLOP) in school

• Measurable annual goals

• How progress will be measured and how often it will be reported to the parents

• The services and supports that will be provided, including modifications and accommodations

• Frequency, duration, and location services, including start and end dates

• A statement about a student’s participation in statewide/local testing

• Description of participation with nondisabled students in general education classes and other activities

• Weather the student needs an extended school year (ESY)

• After a student is 16 years old, information about transition planning

A 504 plan does not have a standard template, and does not even have to be a written document. Plans generally include:

• Description of the disability

• Accommodations and supports that will be beneficial

• Identification of who will be responsible for accommodations/services

• Who will review accommodations

How do I request one?

Parents or school personnel can request that a student be evaluated for an IEP. Parents should put their request in writing to a licensed school personnel. The school has 10 days to respond to the request with a written notice to parents indicating if they intend to conduct the education evaluation or not. If they plan on conducting the evaluation, the notice will include an evaluation timeline, description of the evaluation procedures, and how parents can get a copy of the report, or schedule a meeting to discuss results, prior to the CCC meeting.

Indiana requires that parents interested in having their child evaluated for a 504 plan eligibility put their request to the school in writing, and the school must respond to that request within 10 days.

Who is on the team?

In Indiana, an IEP team is called a case conference committee (CCC). The CCC team is made up of:

• A representative from the school 

• The student’s teacher of record or a teacher licensed in the area of the suspected disability

• At least one general education teacher (unless it is certain that the student will not participate in general education)

• A person able to describe the evaluation results (at times, this is a school psychologist)

• A parent of the student

In Indiana, school personnel may fulfill more than one role on the CCC. 

Rules for who creates a 504 plan are less specific than an IEP. Generally, the 504 team includes school personnel familiar with the student, who understand the evaluation results and special services options. 

What’s the evaluation, review, and revision process?

For initial IEPs, a multidisciplinary team (M-Team) conducts an educational evaluation. The M-Team must include a teacher licensed in, or another specialist with knowledge of, the area of the suspected disability. The M-Team might also include a general education teacher, special education teacher, school psychologist, speech language pathologist, or other qualified professional based on the student’s disability. 

• The IEP team/CCC must review the plan at least once a year to make sure the goals are updated and appropriate to the student’s progress.

• A child must be reevaluated by the M-Team every 3 years to determine if services are still needed, and inform progress and creation of new goals. Sometimes schools will ask parents to consent to skipping the evaluation. 

Evaluation for 504 plans are less defined. Some schools may follow the process for IEP evaluations and conduct an M-Team evaluation to determine what 504 supports are appropriate. Generally, the 504 plan is reviewed each year and reevaluations are done when needed. 

Other important considerations:

Accommodations change how a student learns the material without changing the standard of learning.

• With accommodations, a student will complete the same assignment or test as their peers, but they may have changes to the timing, formatting, setting, scheduling, response, presentation, or a combination of these.

• The accommodation does not alter in any significant way what the test or assignment measures.

Modifications change what a student is taught or expected to learn.

• Modifications can take many forms but the goal is to adjust assignments or tests in a way that changes the standard of what the assignment or test is supposed to measure.

• The curriculum can be modified to “retain specific standards that the student must meet to progress in the curriculum, while allowing for less depth of understanding of the concept” (504 Accommodations Guide).

Students with an IEP can have accommodations and modifications (if appropriate), but students with a 504 plan are only provided accommodations.

References and Resources:

• Indiana Department of Education

• Learn more about Indiana’s Article 7, which governs special education rules and regulations, through the Article 7 Companion Guide (Navigating the Course: Finding Your Way through Indiana’s Special Education Rules) or directly at Article 7.

• Learn more about IEPs and 504 Plans at Understood.Org.

• Explore the federal Individuals with Disabilities Education Act (IDEA) website. 

• U.S. Department of Education, Office for Civil Rights, Parent and Educator Resource Guide to Section 504 in Public Elementary and Secondary Schools (December 2016).