​Section 504 of the Rehabilitation Act of 1973 is a federal civil rights law designed to prevent discrimination against individuals with disabilities. Often referred to as the “Civil Rights Law for the Disabled,” it states:
“No otherwise qualified individual with a disability in the United States shall, solely by reason of their disability, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.” 
​In practical terms, Section 504 ensures that students with disabilities have equal access to education. Schools must provide accommodations and services necessary to meet the individual needs of students with disabilities as adequately as they meet the needs of students without disabilities.

Understanding Eligibility for Section 504

Unlike IDEA (Individuals with Disabilities Education Act), which requires a student to meet specific eligibility criteria for special education, Section 504 has a broader definition of disability.
A student is considered to have a disability under Section 504 if they:
  • Have a physical or mental impairment that substantially limits one or more major life activities;
  • Have a record of such an impairment; or
  • Are regarded as having such an impairment.
Major life activities include (but are not limited to): learning, reading, seeing, walking, concentrating, communicating, and performing manual tasks. 

Key Questions for Eligibility Determination

To determine if a student qualifies for a Section 504 Plan, the school team typically answers:
  • Does the student have a physical or mental impairment?
  • Does the impairment substantially limit one or more major life activities?
  • What accommodations or supports are necessary to provide equal access to learning?
A formal evaluation must be conducted before determining eligibility or providing services under Section 504. While this evaluation may draw on existing data from IDEA assessments, it must follow Section 504-specific requirements, such as using multiple sources of information and considering the impact of mitigating measures (e.g., glasses or medication).

​What Does “Substantially Limits” Mean?

Although Section 504 does not define “substantial limitation” precisely, the Americans with Disabilities Act (ADA) guidance interprets it to mean that the student is:
Unable to perform a major life activity that an average student of the same age can perform, or significantly restricted in the condition, manner, or duration of performing that activity.
This interpretation emphasizes the importance of comparing the student to peers of the same age and not minimizing the impact of the disability, even if the student performs well academically with extra effort.

​Accommodations Under Section 504

Accommodations are individualized and designed to level the playing field, not give an unfair advantage. The goal is to ensure students with disabilities have the same access to learning opportunities as their nondisabled peers. Examples of common accommodations include:
  • Extended time on tests or assignments
  • Preferential seating (e.g., near the board or away from distractions)
  • Large print or audio materials
  • Use of low vision devices
  • Peer note-taking or use of assistive technology
  • Access to an extra set of textbooks for home
  • Modified physical education or mobility supports
  • Use of screen readers, speech-to-text software, or Braille materials
The 504 Plan should clearly outline the accommodations and identify the responsible personnel for their implementation.

​Final Thought

Section 504 Plans can be powerful tools for students with visual impairments and other disabilities who may not qualify for an IEP under IDEA but still need support to participate in the general education environment fully. These plans should be reviewed annually and updated as needed to reflect the student's evolving needs.

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