If you have been in the field of special education for any amount of time, you have heard the terms 504 Plans and IEPs. IEPs are covered under IDEA, special education law, and are created to aid the child in learning. 504 Plans are covered under civil rights law and do not address learning goals or include specialized learning.
Many states have the two legal documents completely separate and if the child has a 504 Plan, he typically does not have an IEP and vice versa. However, in some states and districts, students can have both.
Having Both an IEP and a 504 Plan
As mentioned, IEPs and 504 plans have very unique goals when it comes to what they address and how they address it.
There are special cases where a school might use both, like if a child with an IEP has a temporary injury or a medical condition that doesn’t affect academics.
With that being said, some districts roll any health issues into the IEP making a 504 Plan moot.
Other districts create a separate Health Plan for health-related issues and still retain the IEP.
And yet other schools use the 504 Plan as their Health Plan and, thus, have students with both an IEP and a 504 Plan.
So, to make a blanket statement that students cannot have both documents in effect at the same time is simply untrue. While it may be unusual in many areas of the country, it does happen in others.
It boils down to what your state and district prefer and how they want the different services accounted for and implemented.
Reasons Why You May Have a 504 Plan in Addition to an IEP
For those districts and states that separate any other additional student needs into a 504 Plan, here are some reasons why there may be both documents:
- health issues (i.e. – trach tubes, feeding tubes, etc.)
- allergies (i.e. – anything that would cause anaphylaxis and require epinephrine)
- ADHD/ADD
- anything requiring the administration of medication by the school nurse
Although the list above is not all-inclusive, it does cover many of the reasons why districts opt to keep students on both 504 Plans and IEPs.
While, technically, the health concerns can be added to the IEP document, some districts feel safer keeping them in a separate document that addresses them specifically.
In most cases, the presence of both the IEP and the 504 Plan is determined by the child’s need for services outside of the realm of learning supports.
Scenarios for Having an IEP and a 504 Plan
There are several medical conditions that could warrant a student with an IEP also having a 504 Plan. These conditions often affect the student in ways that go beyond their educational needs addressed by the IEP. Here are some examples:
- Diabetes
- An IEP might address learning delays caused by frequent absences or fatigue from diabetes-related complications.
- A 504 Plan could provide accommodations like permission to eat snacks, monitor blood sugar, administer insulin, or access the bathroom as needed.
- Epilepsy
- An IEP might focus on learning gaps or cognitive issues caused by seizure-related brain activity.
- A 504 Plan could ensure safety measures, such as a seizure action plan, permission to rest after a seizure, or staff training for administering medication.
- Asthma
- An IEP could address issues like frequent absences due to severe asthma attacks or related illnesses.
- A 504 Plan might provide accommodations like access to an inhaler, air quality considerations, or modified physical activity during high-pollen seasons.
- Allergies (Life-Threatening)
- An IEP could address delays caused by missed school due to severe allergic reactions or hospitalizations.
- A 504 Plan might outline safety precautions like allergen-free zones, access to EpiPens, or staff training in managing anaphylaxis.
- Sickle Cell Anemia
- An IEP could focus on addressing cognitive or learning difficulties related to fatigue or pain episodes.
- A 504 Plan might provide accommodations like rest breaks, modified schedules, or hydration access.
- Cancer
- An IEP might cover specialized instruction for educational gaps caused by extended absences due to treatment or fatigue.
- A 504 Plan could include accommodations for medical needs like frequent rest breaks, flexible deadlines, or access to a nurse.
- Chronic Migraines
- An IEP might address academic challenges due to frequent absences or difficulty concentrating during migraine episodes.
- A 504 Plan could provide accommodations like allowing the student to wear sunglasses, access a quiet room, or have excused absences without penalty.
- Autoimmune Disorders (e.g., Lupus)
- An IEP could address the impact of missed school or fatigue on academic performance.
- A 504 Plan might include accommodations like temperature-controlled classrooms, extended time on assignments, or a reduced schedule.
- Traumatic Brain Injury (TBI)
- An IEP would provide services like speech therapy or occupational therapy to address the injury’s cognitive or physical impact on learning.
- A 504 Plan could address accommodations like shortened school days, physical activity modifications, or access to assistive technology.
- Tourette Syndrome
- An IEP could focus on addressing learning challenges or speech therapy needs related to the condition.
- A 504 Plan might provide accommodations like allowing for vocal tics in class without penalty, extended testing time, or a private space for breaks.
For a student with health concerns, it’s always important to keep a health log.
Get access to our Health Log Template by joining The Intentional IEP here.
Is One Way Correct and the Other Incorrect?
Teachers can become very adamant about the “right way” to do things – especially when it comes to IEPs and 504 Plans.
Those who have never experienced a child having both documents may see the existence of both as wrong or poorly executed.
For those who have always had students with separate documents for their health concerns, whether it be a specific Health Plan or a 504 Plan that’s used to address medical needs, the idea of combining the documents seems to be incorrect.
There is no right or wrong. There can be both documents in place at the same time and both will have weight and relevance.
At the end of the day, what matters is that the students are having their needs addressed in a way that makes sense and can be implemented. If that means having both an IEP and a 504 Plan per the school district’s policies, then that is the way it should be done.