Let's Talk About: IEPs vs. 504 plans

You may have heard, “IEPs are better than 504s,” “504 is a light IEP,” or “504s are a waste of time and paper.” The truth is that an IEP and a 504 plan are extremely different educational support documents and serve very different purposes. 

The most important difference is that an IEP is Special Education, and 504 is General Education. If you’ve read my other blogs, you know, broken down to the core, Special Education is specially designed instruction. Does the student need the grade-level curriculum to be instructed differently to understand the concepts? If yes, an IEP is needed. If not, then a 504 would be more appropriate. 

Let’s talk about how an IEP and 504 are the same. Both require a documented disability that is directly impacting education. (Note the disability must be impacting the student’s education. A student may have a disability that does not impact their education. This student would not be eligible for an IEP or 504.) Both require an evaluation by the school system. An IEP and a 504 will be individualized to the student’s needs and provided at no cost to the family.  Lastly, both provide accommodations (changes to the learning environment to enable students to learn alongside their peers.) That’s it. That is where the similarities end. Require a disability impacting education, evaluation by the school, individualized to the student, no cost to the family, and provide accommodations. 

The differences are significant. 

An IEP is supported by the federal special education law to uphold the student’s rights per IDEA.  A 504 plan is supported by the federal civil rights law, which stops discrimination against people with disabilities (Section 504 of the Rehabilitation Act). 

An IEP is Special Education with specialized instruction under the guidance of a special education teacher. A 504 is General Education and is mostly used for students who may have medical needs or a disability requiring support but not specialized instruction. 

Although both cover students from Pre-Kindergarten to 12th grade, a 504 can extend to college if needed. An IEP stops when the student is no longer served by the school system (up to the day before their 22 birthday for students on an alternative diploma path). 

The evaluation for an IEP is comprehensive and in-depth. The evaluation for a 504 is targeted to the area of the disability impacting education. 

For an IEP, a student must be found eligible under 1 or more of the 13 categories (Autism, Deafness, Deaf-Blindness, Emotional Disturbance, Hearing Impairment, Intellectual Disability, Multiple Disabilities, Orthopedic Impairment, Other Health Impairment, Specific Learning Disability, Speech-Language Impairment, Traumatic Brain Injury, Visual Impairment). There is no “eligibility” for a 504. Any student with a disability that interferes with the ability to learn in General Education can have a 504 Plan. 

An IEP meeting has mandated team members, and the parents/caregivers of the child are mandated members.  A school can hold a 504 meeting and implement the 504 Plan without the input of parents/caregivers. 

The law dictates specific information that must be included in the IEP document (i.e., present performance levels, strengths and weaknesses, goals, services, etc.). There are no standard requirements for a 504 Plan. 

An IEP has written goals and objectives for the student and requires progress monitoring through data collection. There are no goals, objectives, or progress monitoring with a 504 Plan. 

An IEP can include related services (OT, PT, nursing, etc.) if necessary for the student. A 504 Plan may have input from an OT, PT, nurse, or another related service provider if needed, but they are not provided as a service to the student. 

Modifications (changes to the curriculum) are only provided through an IEP.  Accommodations (changes to access to the curriculum or environment) are provided in IEPs and 504s. 

IEPs are reviewed annually at a minimum, with a re-evaluation every 3 years. Once a 504 is written, it is only reviewed as needed. 

The final major difference… an IEP is legally binding. It is a legal document. There are procedural safeguards for parents/caregivers if they disagree with the IEP or believe the IEP is not being implemented as written. With a 504, there are limited options for resolving disagreements. Filing a complaint with the Office of Civil Rights is the primary way. 

IEPs are not necessarily better than 504s. A 504 is not a “light IEP.” And 504s are not a waste of time and paper.  Misuse of a 504 or IEP is a waste of time and paper. A 504 is not the first step to get to an IEP. These two things are apples and oranges. Yes, they are both fruits, grow on trees, and have seeds.

However, if you need vitamin C, cutting an apple and eating it is a waste of time and fruit. If you need a rind, an orange is your only option of the two. IEPs and 504s are both educational support documents, but they do not provide the same support, services, or instruction. 

If you need help determining whether an IEP or 504 is appropriate, please contact an experienced Special Education Advocate.