Section 504: A Principal’s Checklist

Ensure your school is meeting the needs and standards required for students with disabilities.

By Perry A. Zirkel
January 2017, Volume 40, Issue 5

Many school principals are not well versed in the “other” federal disability law, Section 504—along with its sister statute, the Americans with Disabilities Act (ADA). Yet, the primary impact of and responsibility for Section 504 is in general education. The most common errors include, as a prime example, providing a 504 plan as a parent appeaser or consolation prize without a careful individualized evaluation according to current standards. The results include under-identification of low-income and minority children and over-exposure to not only federal court litigation, but also Office for Civil Rights (OCR) investigations.

Consider the following questions as a sample checklist for self-assessment in relation to your school:

  • Do you have a knowledgeable and effective 504 coordinator for your school? And has the coordinator provided current information to your staff about court decisions and OCR policies concerning major recent issues, such as bullying, service animals, and retaliation?
  • Do you have a grievance procedure at the district or school level for disability issues of students, employees, and others?
  • Do you have an eligibility procedure and form that meets current standards, including the ADAAA regulations issued in August 2016? And have you effectively included the school nurse with regard to students with concussions and students on health plans?
  • Do you have corresponding defensible procedures and forms for:
    • Procedural safeguards notice?
    • 504 plan?
    • Impartial hearing under Section 504?
    • Disciplinary changes in placement?

Perry A. Zirkel is university professor emeritus of education and law at Lehigh University.

To help close the gap in legal literacy and prudent practices in relation to Section 504, Lehigh University is offering a two-day institute for 504 coordinators on June 22–23, 2017. The program includes:

  • A systematic comparison between the IDEA and Section 504/ADA
    by Perry A. Zirkel, University Professor Emeritus of Education and Law at Lehigh University
  • A practical review of recent court decisions specific to P-12 students under Section 504 and the ADA
    by Mark Weber, Vince DuPaul Professor of Law at DuPaul University School of Law
  • A nuts-and-bolts session on effective forms and procedures that comply with the current requirements for identifying and serving 504-only students
    by Lisa Hardcastle, Section 504 Coordinator at Clear Creek (TX) Independent School District

This two-day institute is in coordination with the week-long Lehigh University Special Education Law Symposium, which is available optionally for the days preceding June 22–23. Information about, and registration for, the Symposium and the 504 Institute are available at

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