Talk to Us 
Have a Question?
Get answers  

Understanding Section 504


Questions like these have mystified educators across the country for decades:

  • How is a Section 504 plan different from an IEP?
  • Do they have different goals, different criteria?
  • How do you decide which is appropriate in a given situation?
  • Are your 504 eligibility determinations and plans compliant? How can you be sure?

In this 7-part video series, education law attorney John Comegno of the Comegno Law Group demystifies 504 by walking you through the seven core concepts of successful 504 implementation and compliance that can limit your potential liability.

Learn how to address individual need, plug that need into a compliant process and make sure 504-eligible students are making progress.


Episode 1: Introduction to Core Concepts of Section 504

Do you know your history when it comes to Section 504?

In this episode, we dive into the Rehabilitation Act and the Americans with Disabilities Act (ADA) to discuss how and why they came about, what was intended in passing them, and what was not intended, from a legal perspective.

We review how the Americans with Disabilities Act tracks Section 504 — and show how several important cases and events have influenced this legislation over time.

Questions answered in this episode:

  1. What’s the goal of a 504 plan?
  2. Is compliance with 504 the same as compliance with the ADA?
  3. How do you decide if you should use a 504 plan or an IEP to address a student’s disability?



Episode 2: Understanding the Section 504 Eligibility Criteria

To make informed Section 504-eligibility decisions, based on specific criteria, you need to gather high-quality 504 eligibility data.

In this video, find out which data you’ll need to make compliant 504 decisions. Learn what constitutes a physical impairment and a mental impairment — and what is meant by the term “major life activity” when determining student or staff eligibility.

Learn how important cases have shaped these criteria and definitions over time.

Questions answered in this episode:

  1. How do you follow a compliant process when determining 504 eligibility?
  2. What is meant by the term “major life activity” when determining 504 eligibility?
  3. How do learning disabilities like dyslexia factor into 504 eligibility decisions?



Episode 3: Unraveling the Key Concept of “Otherwise Qualified” and Its Implications

When it comes to compliance with Section 504 and the ADA, the term “otherwise qualified” has been historically challenging for education organizations to define and defend. What does it mean exactly?

In this video, update your knowledge of otherwise qualified and see why it’s such a hot topic in the landscape of litigation for education organizations.

Questions answered in this episode:

  1. What does “otherwise qualified” mean? Is it a pre-cursor to considering 504 eligibility?
  2. How can you know if a student is “otherwise qualified” to learn in the classroom?
  3. Does Section 504 require you to ignore some types of misconduct? What about bullying?



Episode 4: Are We Just Talking About Medical Diagnosis? Using Data in Section 504 Decision-Making

Watch Episode 4 – Thursday, May 2!

Episode 5: When Are 504 Plans for Students Exiting Special Education Appropriate?

Watch Episode 5 – Thursday, May 9!

Episode 6: What About Behaviors? Do Our 504 Students Receive “Extra” Due Process?

Watch Episode 6 – Thursday, May 16!

Episode 7: Best Practices in Drafting Section 504 Plans: The Need for Consistency

Watch Episode 7 – Thursday, May 23!

In the mood for more Section 504 or IEP decision-making best practices? Subscribe to the Frontline Blog.


Danielle Simbajon

Danielle is part of the global, award-winning content team at Frontline Education. She has developed content to empower the education community for over 10 years.