Sevier County School System

Section 504 Manual

 

 

It is important for all administrators to understand that Section 504 is a function of regular education.  The fact that a child has a disability is separate from the need for special education.  Therefore, it is not appropriate for special education teachers to serve as Section 504 coordinators or case managers.  According to the current law, that should be a responsibility of regular education personnel.  Guidance counselors, assistant principals, classroom teachers, or others in a professional capacity may be selected.  The knowledge they need may be gained by studying this or other Section 504 manuals, or by having a special education teacher serve as a consultant on the 504 committee. 

 

Introduction

 

§504 of the Rehabilitation Act of 1973 is a federal civil rights law protecting the rights of individuals with disabilities. The term "handicap" was replaced with "disability" by the Rehabilitation Act Amendments of 1992. §504 prohibits discrimination against persons with a disability in any program receiving federal financial assistance, including discrimination against students and staff members by school districts.

 

§504 requires that, "No otherwise qualified individual with disabilities in the United States shall, solely by reason of disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance including employment practices, program accessibility, preschool, elementary and secondary education, post-secondary education, and health, welfare, and social services. The provisions of §504 with the most significant impact on school districts relate to employment practices, program accessibility, and preschool, elementary, and secondary education. The preschool, elementary, and secondary education requirements impact on the school district's responsibilities to the public to provide a free and appropriate public education (FAPE) for all students with disabilities.

 

§504 defines an individual with a disability as anyone who:

 

1.Has a mental or physical impairment which substantially limits one or more major life activities such as caring for one's self, performing manual tasks, walking1 seeing, hearing, speaking, breathing, learning, and working;

 

2.Has a record of such an impairment; or

 

3.Is regarded as having such an impairment.

 

The definition prongs "2" and "3" rarely apply to elementary and secondary students and usually are not the basis for triggering FAPE according to an Office of Civil Rights Memorandum (August 3, 1992).  §504 applies to all persons with disabilities regardless of age, for preschool, elementary, secondary, and adult educational programs and requires school districts to provide commensurate opportunity and accommodation in educational programs, nonacademic services, transportation, and facilities.

 

 

 

 

 

Index of 504 Manual

 

Americans with Disabilities Act of 1990 (ADA)

Individuals with Disabilities Education Act (IDEA)

§504 & IDEA

Identification of Eligible Students: "Child Find" Requirements

§504 Committee

Referral and Evaluation

Programming and Services

Re-Evaluation/Review

Confidentiality/Student Records

Procedural Safeguards/Due Process

Discipline

Student Population

IDEA/§504 Flow Chart

§504 Position Responsibilities

 

 

Americans with Disabilities Act of 1990

 

The Americans with Disabilities Act (ADA) extends full civil rights and equal opportunities to individuals with disabilities in both the public and private sector, and prohibits discrimination on the basis of physical or mental disability in employment, services, communication, and accommodations for employees, students and the public served by the school district. The educational requirements of the ADA essentially are those required by §504 and, therefore, are not addressed separately.

 

 

 

Individuals with Disabilities Education Act (IDEA)

 

The Individuals with Disabilities Education Act (P.L. 105-17, formerly P.L. 94-142

[IDEA-Amended 1997]) addresses educational requirements for students, ages 3 - 21, who (1) meet one of the specified categories of disabilities defined in the act and (2) who are in need of special education and related services. Students who receive special education and related services under IDEA must have an Individualized Education Program (IEP) which designates program placement and services in the least restrictive environment. Under the IDEA, the school district ensures child find, confidentiality, and due process to students and parents.

 

Students with disabilities who are identified under IDEA and in need of special education also qualify as §504 students with disabilities, The requirements of IDEA, including the IEP, meet §504 requirements for these students. IDEA students are eligible for all §504 protections, including commensurate educational opportunity as related to non-disabled peers, program accessibility and comparability of facilities.

 

 

§504 & IDEA

 

Students may be disabled under §504 even though they do not require services pursuant to the Individuals with Disabilities Act.  Students who are disabled under IDEA, also are considered to be disabled under §504. However, students determined to be disabled under §504 may not be eligible under IDEA. §504 provides a much broader definition of disability than IDEA, in that individuals may be considered disabled if they have a physical or mental impairment which significantly restricts them from performing a major life activity such as learning.

 

Students who are disabled under §504 require an appropriate response from regular education and may require accommodations in regular education and related service even though special education services are not required. §504 requires commensurate opportunity for students with disabilities relative to meeting needs of the non-disabled. Students identified as disabled and eligible for services under §504 must have a §504 Accommodation Plan. §504 is not an aspect of special education. Rather, it is a responsibility of the regular education system.

 

For all students with disabilities identified under IDEA or §504, the school district must provide a free, appropriate public education to the students. It is the intent of the Sevier County School System to provide a free and. appropriate public education to each student with a disability within its jurisdiction, regardless of the nature or severity of the disability. The due process rights of students with disabilities and their parents will be enforced under §504 and IDEA.

 

Free and Appropriate Public Education (FAPE)

 

1.Appropriate. The §504 services are designed to meet the individual needs of the eligible student as adequately as the needs of the non-disabled students, and are based upon adherence to the regulatory procedures relating to educational setting, evaluation, and placement, and procedural safeguards.

 

2.Free. An eligible student's program, under §504, is provided without cost to the parent of the eligible student, regardless of where the services are provided or by whom. The only costs of educational services that may be assessed the eligible student are those borne by non-disabled students and their parents (such as tickets to athletic events, purchases of yearbooks, gym clothes, etc.).

 

When the Sevier County School System has made available a FAPE as required by §504, and the eligible student or his/her parents or guardians choose to place the student in a private school, the Sevier County School System is not required to pay for the eligible student's education in a private school.

 

 

Identification of Eligible Students: "Child Find" Requirements

 

As part of the on-going identification and referral process, the Sevier County School System will make reasonable efforts to identify and locate every qualified disabled student residing within the System who is not receiving a public education. The System will inform the parents or guardians of these potentially eligible students (who may be attending private or home schools) of the System’s duties under §504. As part of the Child Find effort, the System shall annually publish the Child Find Notice in local newspapers, student handbooks, and/or place the Notice in locations likely to be seen by parents of eligible students (such as supermarkets, pediatrician's offices, etc.). Additionally, every teacher should have information regarding how to initiate a §504 referral and how to identify students who should be referred.

 

 

Referral for §504 Services

 

A referral for consideration of §504 eligibility should be initiated by school personnel to the school support team (S-Team) if there is a reason to believe that the student has a "physical or mental impairment that substantially limits one or more major life activities." A parent may make a referral for determination of §504 eligibility. Referrals must be accompanied by documentation of attempts to re-mediate difficulties in the regular education setting.

 

The following are examples of instances when a referral should be considered for §504 eligibility:

 

Hospitalization - a student returns from treatment in a medical, rehabilitation or psychiatric facility, except for short-term medical problems.

Existing Medical or Emotional or Behavioral or Physical Problems - when a student has been identified by other professionals, such as a physician, psychologist, or licensed counselor, when the student is on medication at school or requires specialized medical procedures or equipment at school. Among the myriad of medical, emotional, behavioral or physical conditions which may qualify are attention deficit disorders, allergies, asthma, diabetes, emotional adjustment disorders, behavior disorders, orthopedic problems, hearing and vision impairments, certain communicable diseases such as HIV/AIDS or tuberculosis, and temporary medical conditions due to illness or accident.

 

Problems Observed in the School Setting - when a student is demonstrating a pattern of not benefiting from the educational program because of medical, emotional, behavioral, or physical problems.

 

Former IDEA Students - when a student has a disability but is dismissed from needing

special education services. The student may be eligible for §504 services, but students

dismissed from special education are not automatically §504-eligible.

 

Not Eligible Under IDEA

 

When a student is evaluated under IDEA procedures and is found to have an identified disability that does not have an educational impact, the student does not qualify for special education. If students have a disability that is not in need of special education, the student may qualify as §504-eligible.

 

Drug/Alcohol Addiction - when a student is diagnosed as an addict but is not currently using drugs or alcohol (e.g., has been in a drug rehabilitation program and is no longer using drugs.  A person who is currently using illegal drugs or alcohol does not qualify under §504 eligibility for services or disciplinary due process protections.

 

Attention Deficit Disorder - when a student is diagnosed as ADD/ADHD by a professional, such as a physician. Some students with ADD/ADHD may qualify for special education services under IDEA as ADHD, Learning Disabled, Emotionally Disturbed, or some other category.  Some students may qualify as ADD/ADHD under §504, but not all children are eligible either under §504 or IDEA.

 

Criteria to Qualify for a §504 Accommodation Plan

 

The student's ability to learn or behave in an appropriate manner MUST BE SUBSTANTIALLY LIMITED. All students with identified disabilities will not qualify for an accommodation plan under §504. They must, however, be given consideration that such a plan may be necessary to meet individual educational needs as adequately as the needs of non-disabled students are being met.  Educational need is defined as a serious academic deficit, a serious behavior problem resulting from the suspected disability and not from other causes, or any other physical or mental impairment which seriously affects the student's opportunity to benefit from educational services.

 

 

 

 

§504 Committee

 

The decision to qualify a student for §504 services is made by a multidisciplinary team of people, composed of at least three members. It should include persons knowledgeable about the student, the meaning of evaluation data, and educational interventions. The §504 Committee includes persons such as the student's teacher, school psychologist, guidance counselor, school nurse, and school administrator. The parent should be invited to participate with the committee in the §504 process for eligibility and services. The §504 Committee should be chaired by a person appointed by the school principal, and it is recommended that this person be the §504 Building Coordinator.

 

 

Referral and Evaluation

 

If school personnel have reason to believe that a student has a disability, as defined under §504, the student must be evaluated. A parent may initiate a referral for evaluation, but regardless of the referral source, the parent must provide written consent prior to the evaluation and the Sevier County School System needs to provide procedural safeguards at the time the child is identified as having a disability.  Guidelines for evaluating and determining a disability under §504 require a multidisciplinary team, the §504 Committee. The evaluation must accurately and thoroughly assess the nature and extent of the disability and focus on specific areas of educational deficit.

 

The specific evaluation procedures employed are determined by the type of disability suspected and the type of services that may be needed. In some cases, the evaluation may be handled solely by the school-based multidisciplinary team, which includes the student’s teacher, the school psychologist, and other persons knowledgeable of the student. The team, in cooperation with the parent, can appropriately assess existing evaluation data, review school records, obtain observation data, evaluate effectiveness of educational interventions over time, determine eligibility under §504, and recommend programming within regular education.

 

The evaluation procedures under §504 have been interpreted by the Office For Civil Rights as requiring prior written consent. The evaluation procedures under §504 are usually less formal and comprehensive than those under IDEA. An evaluation less comprehensive than a full IDEA evaluation may be adequate, but the extent of the evaluation must be made on a case-by-case basis.  In instances, however, when a more comprehensive evaluation is needed and/or the student demonstrates characteristics of a disability under IDEA, which would require special education, a referral for an IDEA evaluation is warranted. Regulations governing IDEA evaluations would then be operative.

 

 

 

 

Programming and Services

 

Once all evaluation data have been reviewed and the student's eligibility under §504 has been determined, the multidisciplinary team must determine what educational services are needed. Most children identified only under §504 can be educated in the regular setting with accommodations and/or related aids and services which ensure commensurate opportunity to meeting educational needs of non-disabled peers in the least restrictive environment.

 

Qualified students with disabilities must be given the opportunity to participate in nonacademic and extracurricular services and activities, such as recreational and athletic activities and school-sponsored clubs. Participation in non-academic activities may require accommodations.

 

The multidisciplinary team is made by a group of persons knowledgeable about the student. The group should review the nature of the disability, how it affects the student's education The decisions about §504 eligibility and services must be documented on the appropriate forms, maintained in the student's confidential record, and reviewed periodically.

 

 

 

Re-Evaluation/Review

 

§504 regulations require that re-evaluations be done periodically, but a specific time frame is not mandated. However, regulations do require that a re-evaluation with notice to parents occur prior to any significant change in placement, including long-term suspensions or expulsion. Following the same rationale employed for the IDEA, a re-evaluation of the student's disability status should be conducted every three years or more often if warranted.  The Sevier County School System requires that each student's §504 Accommodation Plan be reviewed at least annually to determine if the plan continues to be appropriate for the student.

 

 

 

Confidentiality/Student Records

 

Student Records: Parents or guardians have the right to examine all educational records of the student, including the records of the §504 Committee. The District will comply with all of the requirements of the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C.123g) and its implementing regulations found at 34 C.F.R. Part 99. §504 records will be maintained under the same policies and procedures for confidentiality under IDEA, ensuring that only those persons with the "right to know" have confidential information concerning the student's disability.

 

§504 Student File: Each school will maintain a confidential §504 documentation file for each student referred to the §504 Committee.  The confidential records of each student will be housed at the school. When a student transfers within the district, this file is transferred as part of his/her student record as a confidential file, using the same procedures as IDEA files.  When a student transfers out of district, the §504 file may be transferred with parent permission or notification under FERPA requirements.

 

§504 Census Roster: Each school will maintain a §504 census roster, and will forward this list of §504 students receiving services to the System Coordinator on an annual basis.

 

 

 

Procedural Safeguards/Due Process

 

Notice: Parents will be provided notice of the actions of the §504 Committee with respect to the identification and education placement of students referred to the §504 Committee. Notice to parents needs to include procedural safeguards/parent rights.

 

Evaluation: Before taking any action with respect to the initial placement of a disabled student in a special education program or provision of related services, and before any subsequent significant change in placement, including certain disciplinary removals, the System will conduct an appropriate evaluation. Under §504, the nature and extent of the professional evaluation is left to the judgment of the §504 Committee and/or the persons performing specific portions of the evaluation. Tests and other evaluation materials must be tailored to assess the specific areas of educational need and not merely be those which are designed to provide a single score. Tests must be selected and administered to ensure the student's aptitude or achievement level or whatever other factor the test purports to measure, rather than reflecting a student's impaired sensory, manual, or speaking skills except where those skills are the factors that the test purports to measure. Tests and other evaluation materials must be validated for the specific purpose for which they are used, and must be administered by trained personnel in conformance with the instruction provided by their publishers. Evaluation information also may come from sources other than formal, validated testing, Evaluation procedures used will be non-discriminatory.

 

Other Safeguards: If the parents of a student disagree with any actions of the §504 Committee regarding the identification, evaluation, and educational placement of a student, the parents have a right to an impartial hearing in which they may participate and be represented by counsel.

 

 

Discipline

 

Disciplinary procedures which apply to students with disabilities under IDEA also apply to students with disabilities under §504 with the following exceptions:  students with disabilities under §504 who have been expelled do not have to be provided with educational services following expulsion, and there is no "stay put" requirement under §504.

 

If a student is being considered for suspension beyond 10 days cumulative or expulsion, including suspension or expulsion from a school bus, a multidisciplinary team must determine if the behavioral infraction is related to the disability, a process known as "manifestation determination."  If the team determines that the behavior is caused by the disability, then the educational placement or service should be modified or alternative placement or services provided.  This process is identical to the one in effect for IDEA disabled students.

 

The District may discipline a student with a disability under §504 who is currently using illegal drugs or alcohol for the use or possession of illegal drugs and alcohol to the same extent as action taken against non-disabled students. In such cases, §504 due process procedures, namely evaluation and manifestation determination, are not required for current users.  If the student is an otherwise disabled student under IDEA, who is possession of and/or using illegal drugs and alcohol, evaluation and manifestation determination and all due process procedures must take place. Special procedures also apply in the discipline of students with disabilities for possession of firearms.

 

 

 

Student Population

 

 

 

IDEA/§504 Students                                                                504 Students Only

 

Students are qualified under one or more of

thirteen (13) IDEA disabling conditions

Specially designed individual education

programs are planned for each student by IEP

Teams.

 

 

                                                              Due to substantial mental or physical impairments

                                                           that limit one or more of the student's major tile

      activities, special accommodations to the student’s

                                                          program are required. A §504 Accommodation 

                                                        Plan is designed for each student according to

         individual need.

 

Examples of potential §504 disabling conditions

                                                  not typically covered under IDEA are:

 

 

Communicable diseases, such as HIV/

                                                   AIDS, tuberculosis

                                                                               Medical conditions, such as asthma,

                                                   diabetes, allergies

                                                                                  Temporary medical conditions due to

                                                   accident or illness

                                                               Attention Deficit Disorder

                                               Other conditions

 

 

 

§504 Position Responsibilities

 

I. System §504 Coordinator

 

1.Develop a district-wide §504 compliance plan.

 

2.Disseminate to each school building the compliance plan, with commensurate 504 procedures.

 

3.Train school building §504 coordinators in §504 compliance/procedures.

 

4.Develop, implement and disseminate a detailing of procedural safeguards.

 

5.Work in partnership with the district's special education director.

 

6.Communicate district-wide procedures to staff and parents.

 

7.Continually seek new information relative to §504 compliance and update all data.

 

8.Serve as the district liaison with the Office for Civil Rights.

 

9.Allocate public resources with respect to the funding of §504 - non-special education

services

 

II. Site-Based §504 Coordinator

 

1.Receives initial referral and post-referral information.

 

2.Responsible for gathering any additional and necessary evaluation data.

 

3.Responsible for notifying all §504 committee members of meetings.

 

4.Obtains written permission for initial assessment.

 

5.Responsible for sending notices to parents and scheduling Section 504 meetings.

 

6.Assists in developing §504 modifications for eligible students.

 

7.Ensures that annual review meetings are conducted.

 

8.Conducts initial meeting and fills out required forms, conducts subsequent meetings as is necessary.

 

III. Site-based §504 Monitor

 

Must be an administrator

 

1.Attends all §504 meetings.

 

2.Ensures that parents are provided with a copy of §504 Parental Rights.

 

3.Ensures the implementation of the §504 Plan by monitoring the plan and by keeping a written record of such monitoring.

 

Note: §504 monitor and coordinator may be the same person.

 

 

Updated: October 16, 2000

 

 

This document is provided as one tool for teachers and administrators to use when identifying, assessing, and providing for disabled students under Section 504.