What Disabilities Qualify for a 504 Plan? A Parent’s Guide to Eligibility.

If you’re trying to determine whether your child qualifies for a 504 plan, you’re not alone. Parents often hear about this important tool but don’t always get a clear explanation of how eligibility is determined, or what disabilities qualify for a 504 plan.

A 504 plan is designed to ensure students with disabilities can access their education on an equal playing field. But what exactly qualifies a child for a 504 plan? Let’s break it down step by step.

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What Is a 504 Plan?

A 504 plan is a formal document developed under Section 504 of the Rehabilitation Act of 1973. This civil rights law ensures that individuals with disabilities are not discriminated against in any program or activity receiving federal funding, including public schools.

A 504 plan provides accommodations to help students with disabilities fully participate in the general education curriculum alongside their peers. Unlike an IEP, a 504 plan does not include specialized instruction but instead focuses on accommodations that remove barriers caused by the disability.

What Disabilities Qualify for a 504 Plan?

The eligibility criteria for a 504 plan are broad and based on whether a student has a disability that substantially limits one or more major life activities.

Section 504 doesn’t include an exhaustive list of qualifying disabilities, but it does provide examples. Some specific disabilities listed in Section 504 include:

• Blindness or visual impairments
• Deafness or hearing impairments
• Cerebral palsy
• Epilepsy
• Muscular dystrophy
• Multiple sclerosis
• Chronic asthma
• Diabetes
• Heart disease
• Cancer
• Orthopedic impairments
• Mental illnesses, such as anxiety and depression
• ADHD and other attention disorders

This list isn’t exhaustive, and many other conditions can qualify, including temporary disabilities like recovering from surgery or a broken limb that affects mobility. The focus is always on how the condition affects the student’s ability to learn and participate in school activities.

Is a Medical Diagnosis Required for a 504 Plan?

One of the most common questions parents ask is whether a medical diagnosis is required to qualify for a 504 plan. The short answer is no, a medical diagnosis is not legally required by Section 504 of the Rehabilitation Act—but it can help. Schools must determine that the child has a disability that substantially limits a major life activity, and documentation is necessary to make this determination.

This documentation can come from a variety of sources, such as:

• Medical records or a doctor’s note
• Evaluations conducted by a school psychologist or outside professional
• Observations from teachers and school staff

While a diagnosis can provide clarity and support the case for a 504 plan, it is not the sole determining factor. The school must assess how the condition affects the child’s ability to function in the school environment.

Keep in mind, though, that having a diagnosis does not automatically guarantee a 504 plan; the disability must meet the substantially limits standard. It is very common for a school to evaluate a student for an IEP, find them ineligible for the IEP, but find them eligible for a 504 plan. Essentially this means that the data from their own evaluations told them that the child has a disability, but that it only “substantially limits” the child’s activities, and does not have “adverse impact.”

It’s ok, take a deep breath. I’ve explained both of those terms below.

Adversely Impacts vs. Substantially Limits

A critical part of understanding eligibility is the difference between adversely impacts and substantially limits. These terms define the thresholds for qualifying under IDEA (for an IEP) versus Section 504.

Under IDEA, a child qualifies for an IEP if their disability adversely impacts their educational performance and they require specialized instruction to access the curriculum. Adversely impacts means the disability significantly affects academic or functional performance, often in ways that are measurable through standardized testing or other assessments. This is a stricter standard compared to Section 504.

For a 504 plan, the standard is whether the disability substantially limits a major life activity. Substantially limits is intentionally broad and can include conditions that may not directly impact academic performance but still create significant challenges. For example, a child with ADHD may perform well academically but struggle with concentrating or sitting still for extended periods. This distinction allows for more inclusive eligibility under Section 504.

What Accommodations Are Provided Under a 504 Plan?

A 504 plan outlines accommodations that address the student’s unique needs. These might include:

• Extended time on tests and assignments
• Preferential seating to reduce distractions
• Use of assistive technology, such as text-to-speech software
• Access to a school nurse for medical needs
• Permission to take breaks or move around during class
• Adjustments to the physical environment, like wheelchair ramps or elevators
• Support for social-emotional challenges, such as access to counseling

Accommodations are individualized and designed to remove barriers so the student can fully participate in their education.

What Disabilities Don’t Qualify for a 504 Plan?

While Section 504’s criteria are broad, not every condition qualifies for a 504 plan. A child’s disability must substantially limit their ability to function in school. For example, mild conditions that do not create significant challenges in the school setting, such as slight vision impairments corrected with glasses, are unlikely to qualify. The key is whether the disability creates a barrier to accessing education.

How Is Eligibility Determined?

Eligibility for a 504 plan is determined by a team at the school, often including teachers, administrators, counselors, and parents. The process typically involves:

1. Reviewing documentation of the disability, such as medical records or evaluations.
2. Identifying how the disability impacts the student’s major life activities.
3. Determining whether the disability substantially limits the student’s ability to access the curriculum or participate in school activities.

The decision-making process is highly individualized, and parents have the right to advocate for their child throughout.

‘Substantially Limits”

The broad eligibility criteria for a 504 plan make it a valuable resource for students with disabilities, offering them the support they need to thrive in school. Understanding terms like substantially limits and how they differ from IDEA’s adversely impacts standard can help you navigate the process more effectively.

While a medical diagnosis can strengthen your case, it’s not required to develop a 504 plan. Ultimately, the focus is on whether the disability creates barriers to learning and participation—and if it does, the school is obligated to provide accommodations. If you’re unsure whether your child qualifies for a 504 plan or want more guidance on how to start the process, reach out to your school or consult a knowledgeable advocate. Your child deserves the support they need to succeed.