How To Prepare For And Write Enforceable 504 Plans


How to write enforceable student 504s

Last Updated on October 29, 2021 by Michelle Ball

By Michelle Ball, Sacramento California Expulsion, Special Education, sports/CIF, College, Education and School Attorney/Lawyer for Students since 1995

A 504 Plan is a key document for disabled students who may not qualify for special education.  However, drafting these plans can be confusing and execution flawed due to lack of clarity.  As such, it is critical that parents know how to develop a proper 504 plan with their school.

What is a 504 Plan?

A 504 Plan is a critical document developed at a “504 meeting” between school staff and parent(s), which classroom teachers and school personnel will thereafter be required to implement.  

The purpose of a 504 Plan is to specify student accommodations to be implemented at school, which will assist the disabled student to access their education equal to peers.  

A well-written 504 plan can truly make the difference between success and failure in school.

How Does a Parent Know if a 504 Plan is Adequate?

What is important in a 504 plan?  How does a parent know the plan is “good” and will help the student?  

504 Plans and their appropriateness depend on many different factors, such as the student involved and his/her unique needs, the school where they are, the structure of the school day and other factors.

Often 504 plans are extremely inadequate, often consisting of only preferential seating, vague statements, and requirements for the parent or student to implement, not the school personnel.  As such, these types of 504 plans can be difficult to enforce and may be completely inadequate for the student.

504 Plan Guidelines

Some guidelines I use in developing 504s are as follows:

1)  Requested Accommodation List:

Prior to a 504 meeting, a list of accommodations the student needs to access the classroom/learning/school should be developed.  This list is valuable as a starting point and will help make the student 504 meeting more productive for all.

This list can be provided by parents/their attorney to the school in advance of a 504 meeting, to ensure that all requested items can be addressed.

2)  Specific Accommodations:

Accommodations should be as specific as possible, so they are enforceable and verifiable.  If an accommodation is not written clearly, it may be difficult to verify if the accommodation is being implemented and easy for that accommodation to be ignored.  

Phrases such as “as needed” by themselves can allow the teacher to determine when an accommodation is necessary, which may be never!  An accommodation never implemented is valueless.  

Instead, more specific terms should be used if possible, such as “student will be given a break when requested” or “teacher will check in with student once per class period.” The language will be fact and student dependent, but the clearer the language, the better for ALL.  

3)  Tailored To This Student:

Accommodations must be specifically tailored to the student and his/her needs.  What does the student actually need in the class, after class, on breaks?  For example, if the student cannot take notes there could be an accommodation that teacher notes and overheads will be provided electronically at the beginning of the month.  

Difficulty focusing in class?  There could be an accommodation for subtle redirection or check-ins by the teacher at specific intervals.  

Can the student not write down assignments or upcoming test dates?  There should be a home-school communication system set up with weekly email to provide the assignments, upcoming tests, etc.  

4)  Legibility:

Often schools try to squish a 504 and student accommodations into a pre-printed form. However, this may mean accommodations are shortened, placed in size 4 font, or otherwise hard to read.  

An attachment page or simply a more spacious 504 document may be developed so anyone picking up the student’s 504 plan can read it quickly and easily without squinting.  

If an accommodation is unreadable, or takes too long to decipher, a teacher may skip it, which will ensure it won’t be implemented for the student.

5)  Accommodations Not Limited:  

Speaking of a pre-printed form, parents should know that they are not limited only to accommodations on a district’s form. The 504 team may develop accommodations for the student which are individually tailored, and which include attachments to any preprinted form.

6)  Accountability:

Is there someone who is accountable for implementing each accommodation, such as the teacher, administrator or counselor?  The parent can volunteer to help (such as sending an email to teachers weekly for any missing assignments, upcoming due dates, etc.) but the parent is not the one responsible.

However, responsibility for execution should mainly fall on school personnel’s shoulders.

7)  OCR:  

Know what the Office for Civil Rights is and how to file a complaint with them in case the 504 is not implemented and/or the school refuses certain critical student accommodations.

8)  Experts:

Find someone outside the school system who can review the 504, help with developing student accommodations, and even accompany a parent to a 504 meeting

504 Plans are very important and powerful documents.  Don’t underestimate the value of a well-written, legally enforceable 504 plan, to a student’s future and school success.  

There is usually only one shot at a grade level and falling behind can be problematic.  As such, ensure the student’s 504 Plan is specific, executable, and has the accommodations they need to succeed!

[Originally written January 17, 2014]


Student 504 attorney Michelle attends 504 meetings with parents, helps develop 504 accommodations, and gets 504 plans enforced for students. As a 504 lawyer in Sacramento, Michelle Ball represents students statewide in Los Angeles, San Francisco, Fresno, Redding and many other locations.