504 Plans in Arizona: When Your Child Needs One Instead of (or Alongside) an IEP

A 504 plan in Arizona is a written plan of accommodations for a student whose disability substantially limits a major life activity but who does not require specially designed instruction. 504 plans are required under Section 504 of the federal Rehabilitation Act of 1973, a civil rights law that applies to any school receiving federal funding (which includes virtually every public school in Arizona). Unlike an IEP, a 504 plan does not change what your child is taught. It changes how the school removes barriers so your child can access the same curriculum as their peers. A child can have a 504 plan, an IEP, or in some cases both, depending on whether they need accommodations alone or accommodations plus specially designed instruction.

If you are trying to figure out whether your child needs an IEP or a 504, or how to request a 504 in an Arizona public school, this guide walks through who qualifies, how the process works, and what makes a 504 plan effective once it’s in place.

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What a 504 Plan Is, in Plain Terms

A 504 plan is a written agreement between your child’s school and you that documents the accommodations your child needs to access the general education curriculum on equal footing with classmates without disabilities. It is shorter than an IEP. It does not include specially designed instruction, special education services, or modified academic standards. It is built around the principle that your child’s disability is a barrier to access, and the school’s job is to remove or mitigate that barrier.

Common 504 accommodations include:

• Extended time on tests and assignments
• Preferential seating
• Permission to take breaks
• Access to a quiet testing environment
• Modified homework load
• Use of assistive technology
• Permission to use the bathroom or nurse’s office without restriction
• Allergy or medical accommodations
• Permission to keep medication or medical supplies at school
• Communication accommodations (text-to-speech, speech-to-text, ASL interpretation)
• Behavioral accommodations like scheduled check-ins

The list is not exhaustive. Accommodations are individualized to your child’s specific needs and the specific barriers their disability creates.

Who Qualifies for a 504 Plan in Arizona

The federal eligibility standard is broader than the IEP standard. To qualify for a 504 plan, your child must have:

1. A physical or mental impairment
2. That substantially limits one or more major life activities

“Major life activities” is interpreted broadly under federal law. It includes learning, reading, concentrating, thinking, communicating, walking, breathing, eating, sleeping, working, and the operation of major bodily functions like neurological, immune, and digestive functions.

In practice, this means many children qualify for 504 protections even when they don’t qualify for an IEP. Examples of conditions that often support a 504 plan in Arizona:

• ADHD (when it limits attention, learning, or behavior)
• Anxiety or depression (when symptoms affect concentration, attendance, or participation)
• Type 1 diabetes (medical management and glucose monitoring needs)
• Severe food allergies
• Asthma
• Chronic migraines
• Concussion recovery
• Tourette syndrome
• Dyslexia (when accommodations are sufficient and specially designed instruction is not needed)
• Autism (when masking allows the child to access curriculum but accommodations reduce sensory or social barriers)

The standard is functional, not categorical. A diagnosis alone doesn’t guarantee a 504. The question is whether the diagnosis substantially limits a major life activity in a way that affects your child’s access to school.

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504 vs. IEP: The Practical Difference

This distinction trips up a lot of parents. Here is the cleanest way to think about it:

An IEP is for children who need specially designed instruction. They cannot make adequate progress in the general curriculum even with accommodations. The IEP team designs custom instruction, goals, and services to meet their unique learning needs.

A 504 plan is for children who can access the general curriculum with accommodations. They can learn the same content as their peers, but barriers caused by their disability need to be removed for them to do so.

A child with severe dyslexia who needs structured literacy instruction usually needs an IEP. A child with milder dyslexia who can keep up with the general curriculum using audiobooks, extended time, and a text-to-speech tool may need only a 504. A child with anxiety severe enough to keep them out of school for weeks at a time may need an IEP under the emotional disturbance category. A child with anxiety that affects test performance but who attends regularly may need only a 504.

The decision is made case by case, based on data. The right plan is the one that actually meets your child’s needs. If the school proposes a 504 and you believe an IEP is warranted (or vice versa), you have the right to request the evaluation that would answer the question.

How to Request a 504 Plan in Arizona

The 504 process is faster and less formal than the IEP process, but it still has procedural requirements you should follow:

Step 1: Submit a written request to the school’s 504 coordinator. Every school district in Arizona must have a 504 coordinator. Ask the principal or front office who that is if you don’t know. Send your request in writing (email is fine), document your concerns, identify the diagnosis or condition, and request that a 504 evaluation be conducted.

Step 2: The school reviews existing data and determines if more is needed. Unlike the IEP process, 504 evaluations rarely require formal cognitive or achievement testing. The school typically reviews medical documentation, teacher observations, attendance records, and any outside evaluations you provide. If the school believes more data is needed, they may request additional assessments with your consent.

Step 3: A 504 team determines eligibility. The team usually includes the 504 coordinator, your child’s teacher(s), you, and any other staff with relevant knowledge. The team decides whether your child has a disability that substantially limits a major life activity and what accommodations are needed.

Step 4: A written 504 plan is created. If your child is eligible, the team drafts the 504 plan with the specific accommodations agreed upon. You should receive a copy and a clear plan for how the accommodations will be communicated to teachers and implemented.

Step 5: The plan is implemented and reviewed annually. 504 plans are reviewed at least once a year. They can be updated more often if circumstances change. You can request a 504 meeting at any time.

What to Do When a 504 Isn’t Working

The most common 504 problem in Arizona isn’t getting one. It’s making sure the accommodations are actually delivered. Teachers change. Classrooms change. New teachers may not know your child has a 504 or what accommodations apply.

If accommodations are not being delivered:

• Request the 504 plan in writing be re-shared with all current teachers
• Ask the 504 coordinator to confirm in writing that teachers have acknowledged the plan
• Document specific incidents where accommodations were missed
• Request a 504 meeting to discuss implementation if the pattern continues
• File a complaint with the U.S. Department of Education Office for Civil Rights if persistent non-compliance is not resolved through district escalation

Section 504 disputes are also covered by dispute resolution mechanisms, though they differ from IDEA dispute resolution. The Office for Civil Rights handles 504 complaints federally.

When to Push for an IEP Instead

If the school keeps offering a 504 when you believe your child needs an IEP, request a special education evaluation in writing. The school is required to consider the request and either evaluate or provide prior written notice explaining why they won’t. If they refuse, that refusal is grounds for a state complaint or due process.

The signs your child may need an IEP instead of (or in addition to) a 504:

• Your child needs to learn skills using a different method than the standard curriculum
• Goals need to be individualized and progress-monitored over time
• Related services like speech, occupational therapy, or specialized counseling are needed
• The child is not making meaningful progress in the general curriculum even with accommodations
• Specialized instruction in reading, math, writing, or behavior is needed