Every student identified with a disability takes one of two paths—obtaining either an individualized education program (IEP) or a 504 plan—that determines the support services they receive in school.
On the surface, IEPs and 504 plans are similar: They are both designed to ensure students with disabilites can access the same coursework and educational experiences as their peers. But, in reality, IEPs and 504s are strikingly different—from the students they serve and the services they can provide to how they are set up and how progress is tracked.
These are the key differences educators, school leaders, and administrators need to know.
What are the main differences between a 504 plan and an IEP?
Generally speaking, IEPs are more robust and have stricter legal requirements than 504 plans.
IEPs are more structured and deliver specialized instruction, requiring specific team members to craft the plan and set detailed goals. 504 plans, meanwhile, focus on accommodations within the general education classroom without altering standard curriculum or providing specialized instruction, said Steven Nathan Stevenson, an associate professor of mild/moderate educational needs at Kent State University in Ohio.
Section 504 regulations require a school district to provide a “free appropriate public education” (FAPE) to each student with a disability, “regardless of the nature or severity of the disability,” according to the U.S. Department of Education. Schools must provide aids and services designed to “meet the student’s individual educational needs as adequately as the needs of nondisabled students are met.”
A 504 plan focuses on removing barriers to learning, such as establishing testing accommodations, like extra time to complete an exam.
IEPs may include the same types of accommodations, but they also modify the actual curriculum, like ensuring a child receives reading intervention or speech therapy, Stevenson said.
“What it comes down to, really, is that an IEP has more teeth because it has things that have to be in there, by law,” said Meghan Burke, a professor of special education at Vanderbilt University. “It doesn’t mean that you couldn’t advocate for those things to go into a 504 plan, because anything could go into a 504 plan. It’s like the wild wild West.”
Who qualifies for an IEP vs. a 504 plan?
Qualification for an IEP depends on 13 federally designated disability categories under the Individuals with Disabilities Education Act (IDEA). Those include autism, deaf-blindness, emotional disturbance, speech or language impairments, traumatic brain injury, developmental delay, and intellectual disability, among others.
- AutismA developmental disability significantly affecting verbal and nonverbal communication and social interaction, generally evident before age three, that adversely affects a child’s educational performance.
- Deaf-blindnessA combination of hearing and visual impairments that cause severe communication and other developmental and educational needs that cannot be accommodated in special education programs solely for children with deafness or blindness separately.
- DeafnessA hearing impairment so severe that the child is impaired in processing linguistic information through hearing, with or without amplification.
- Emotional disturbanceA condition that exhibits one or more of the following characteristics over a long period of time that affects a child's academic performance: An inability to learn that cannot be explained by intellectual, sensory, or health factors; inability to build or maintain interpersonal relationships with peers and teachers; inappropriate behavior or feelings under normal circumstances; a general pervasive unhappiness or depression; a tendency to develop physical symptoms or fears associated with personal or school problems.
- Hearing impairmentAn impairment in hearing, whether permanent or fluctuating, that adversely affects a child’s educational performance.
- Intellectual disabilitySignificantly subaverage general intellectual functioning that manifested during the child's developmental period.
- Multiple disabilitiesConcurrent impairments (such as intellectual disability, blindness, or intellectual disability), that, combined causes such severe educational needs that they cannot be accommodated in special education programs solely for one of the impairments.
- Orthopedic impairmentA severe orthopedic impairment that adversely affects a child’s educational performance. These impairments could be caused by a disease, birth defect, or other cause.
- Other health impairmentHaving limited strength, vitality, or alertness—including a heightened alertness to environmental stimuli—that results in limited alertness to the educational environment.
- Specific learning disabilityA disorder in one or more of the basic psychological processes involved in understanding or using language that may present as an inability to listen, think, speak, read, write, spell, or to do mathematical calculations.
- Speech or language impairmentA communication disorder such as stuttering, impaired articulation, a language impairment, or a voice impairment.
- Traumatic brain injuryAn acquired injury to the brain resulting in total or partial functional disability or psychosocial impairment, or both.
- Visual impairmentAn impairment in vision that, even with correction, adversely affects a child’s educational performance.
By contrast, any physical or mental disability that “substantially limits one or more major life activities,” such as “walking, seeing, hearing, speaking, breathing, learning, and working” can qualify a student for a 504 plan, according to Section 504 of the Rehabilitation Act of 1973. There is no strict list of qualifying conditions. Examples include diabetes, anxiety or depression, chronic or major illnesses or injuries, contagious diseases, allergies, asthma, epilepsy, or ADHD, according to the Education Department. Minor or temporary injuries, like a broken arm, generally do not qualify.
IEPs cover children from birth through age 22, whereas 504 plans do not have an age limit, Burke noted.
Which laws cover them?
The federal Individuals with Disabilities Education Act (IDEA) covers IEP requirements and explicitly gives families the right to sue schools that don’t provide appropriate special education services.
Conversely, 504 plans fall under Section 504 of the Rehabilitation Act of 1973—a federal civil rights law that protects students from discrimination.
How is progress tracked?
IEPs are updated and reviewed more routinely than 504 plans, and they must include specific, measurable annual goals. 504 plans typically lack annual goals or routine progress checks.
Meanwhile, IEPs must document the student’s current academic skills and challenges, detail what services the school will provide (and their frequency), and outline any curriculum adaptations or modified learning expectations. The IEP and the student’s progress must be reviewed at least once per year.
Who creates the plan?
The legal protocols are vastly different for developing IEPs and 504 plans.
IEPs are strictly mandated, and require the involvement of the student’s parent or caregiver, at least one general education teacher, at least one special education teacher, a school psychologist (or another specialist who can interpret evaluation results), and a district-level administrator who has the authority to approve services for the student and authorize district spending on those services.
The rules for who’s involved in developing 504 plans are more flexible, Burke said. The team could include the student’s parent, general education and special education teachers, and the school principal, but none of those people are required to be involved, Burke said. The development of a 504 plan could be as simple as an informal meeting between a parent and a school staff member. A school cannot conduct an initial evaluation for the need for a 504 plan, nor implement a 504 plan without parents’ consent, according to the Education Department.
How are the services funded?
For IEPs, the federal government provides state grants to support IDEA compliance.
There’s no contemporary nationwide data that accurately captures the per-pupil cost of providing special education services.
While Congress pledged in 1975 to cover up to 40% of the average extra cost of special education services, it made this funding discretionary rather than mandatory. Congress has never appropriated the full 40%.
Federal funding currently covers only about 12%, according to the National Center for Learning Disabilities, a nonprofit organization focused on providing resources and shaping policies with children with disabilities. Districts must cover the remaining costs out of state and local budgets.
Students with 504 plans are not counted in districts’ tally of students eligible for coverage by IDEA, which is used for funding formulas.
The federal government does not provide dedicated funds to states and schools to cover the costs of Section 504 accommodations or services.
“Anything that goes into a 504 plan, the cost of that is absorbed by the school,” Burke said.
How are disputes over IEPs resolved?
If a parent or caregiver has a problem or complaint about their student’s IEP or its implementation, they can request a formal meeting at any time to discuss with school leaders. Families can also file formal complaints with their state education departments or the federal Office for Civil Rights (OCR), if they believe their child is being discriminated against because of their disability.
In each complaint, parents need to outline the decision or treatment they disagree with and, if possible, how the school violated the student’s special education rights under IDEA, federal regulations, or state policies, Burke said. Complaints typically have to be filed within one year of the original event.
How are disputes over 504 plans resolved?
For 504 plan disputes, families can file a grievance in writing directly with the school district or request a due process hearing with district leaders to discuss a student’s accommodations.
If the family and school district cannot reach a resolution, the family may also file an OCR complaint online, Burke said. OCR complaints must be filed within 180 days of the alleged violation.
OCR complaints—whether for an IEP or 504 dispute—will only focus on whether the school violated federal civil rights law. They usually don’t address the content of a 504 plan or question individual education decisions or placement.
How are students identified for IEPs and 504s?
Identification processes vary by state and condition.
Generally, Stevenson said, conditions that qualify for an IEP under IDEA requires a comprehensive educational evaluation conducted by the school district, often accompanied with medical or psychological documentation for clinical conditions like Autism Spectrum Disorder or ADHD.
On the other hand, learning disabilities such as dyslexia are often evaluated and identified within the school system by a school psychologist or similar position, he said.
A note from a pediatrician confirming a child’s disability, like asthma, could be enough to establish the need for a 504, Burke added.
Can a student have both an IEP and a 504?
Technically, yes. But, in practice, it would be redundant, Stevenson said. An IEP would generally include all of the key components a 504 plan would cover.
There are some cases in which a school district may use both for one student, Burke said. For example, if a student has a condition that affects both their physical and academic progress, a district could use an IEP to cover their academic needs, and a 504 plan to outline their physical accommodations, she said.
Why might a family pursue a 504 plan instead of an IEP?
Sometimes, a family might opt for their child to have a 504 plan instead of an IEP, even when they are eligible for an IEP, because of stigma, both Stevenson and Burke said.
Having a 504 means the student is not formally part of the special education system, Stevenson said, and the student would be less likely to be pulled out of class for services, meaning fewer of their peers may be aware of their disability.
There is also research that shows students in special education programs are more likely to drop out of high school, be unemployed, or be incarcerated at some point, which can make families hesitant to officially enroll their kids in special education services, he said.
“There are all of these outcomes that are not caused by special education, but are associated with special education, and that’s no small thing for a lot of people,” Stevenson said.
What happens to students’ special education plans when they transition to college or the workforce?
Schools and districts must provide students with an IEP services through the age of 22, or they exit the education system, whichever comes first, Burke said. There is no age limit for 504s, meaning schools must provide the services outlined in the 504 until the child transitions from the K-12 system. If the child then goes to college or is employed by any company or institution that receives federal dollars, they may still be eligible for the same services, Burke said.
