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IEP vs. 504 plan

A comparison of Individualized Education Programs and Section 504 plans for families, educators, and spoken-language interpreters.

IEP vs. 504 plan

Individualized Education Programs (IEPs) and Section 504 plans are two common ways schools support students with disabilities. They may overlap, but they are created under different laws and serve different purposes. This comparison is designed to help families, educators, and spoken-language interpreters understand the terminology used in meetings and school communications.

What is it?

  • IEP: A formal written plan that describes the special education services and supports a school will provide to meet the unique needs of a student with a disability. An IEP includes specially designed instruction.
  • 504 plan: A plan describing accommodations, related aids, and services that remove disability-related barriers and give an eligible student an equal opportunity to participate in education. A 504 plan generally focuses on access rather than specially designed instruction. Federal Section 504 rules do not require one nationwide plan template, so the format may vary by school or district.

Which law covers it?

  • IEP: The Individuals with Disabilities Education Act (IDEA), a federal special education law.
  • 504 plan: Section 504 of the Rehabilitation Act of 1973, a federal civil rights law that prohibits disability discrimination in programs and activities receiving federal financial assistance. The Americans with Disabilities Act (ADA) may also apply to schools and other educational settings.

What is included in the plan?

  • IEP: An IEP must include information such as:
    • The student’s present levels of academic achievement and functional performance
    • Measurable annual academic and functional goals
    • How progress toward goals will be measured and reported
    • Special education and related services
    • Supplementary aids and services
    • Program modifications and supports for school personnel
    • Accommodations and modifications, when needed
    • Assistive technology devices or services, when needed
    • The student’s participation in general education, extracurricular, and nonacademic activities
    • The frequency, location, duration, and provider of services when required
  • 504 plan: A 504 plan commonly identifies:
    • The student’s disability-related barriers or access needs
    • Accommodations and adjustments
    • Related aids and services, when needed
    • Assistive technology or other tools, when needed
    • Testing or assessment accommodations
    • Health or medical supports used during the school day, when applicable
    • The staff member or team responsible for implementation
    • How teachers and other school personnel will be informed of the plan

How does the plan track progress?

  • IEP: An IEP must describe the student’s present levels, measurable annual goals, how progress will be measured, and when progress reports will be provided. Progress may be reported with report cards or on another schedule identified in the IEP.
  • 504 plan: Section 504 does not require the same annual-goal and progress-report structure as IDEA. Schools may still monitor accommodations, participation, academic performance, health needs, and whether the plan remains appropriate. Local procedures determine how this monitoring is documented.

Who can qualify for a plan?

  • IEP: A student must meet IDEA eligibility requirements. Generally, the student must have a disability that fits one of the IDEA disability categories, the disability must adversely affect educational performance, and the student must need special education and related services.
  • 504 plan: A student must have a physical or mental impairment that substantially limits one or more major life activities, such as learning, reading, concentrating, thinking, communicating, walking, seeing, hearing, or breathing. A student who does not qualify for an IEP may still qualify for a 504 plan because Section 504 has a different eligibility standard.

Who creates the plan?

  • IEP: The IEP is developed by an IEP Team that generally includes:
    • The student’s parent or guardian
    • At least one general education teacher
    • At least one special education teacher or special education provider
    • A public agency representative who understands the general curriculum and has authority or access to resources
    • A person who can interpret the instructional implications of evaluation results
    • The student, when appropriate or required for transition planning
    • Other people with knowledge or special expertise about the student, when invited by the parent or school
  • 504 plan: Section 504 does not prescribe the same detailed team membership as IDEA. The team may include the parent or guardian, the student, general and special education teachers, a school administrator, the 504 coordinator, a school psychologist, a school nurse, medical professionals, or other people who understand the student, evaluation information, and available supports.

When is parental consent required?

  • IEP: Written parental consent is generally required before an initial evaluation and before the initial provision of special education and related services. Consent for an evaluation does not necessarily mean the parent agrees with every later service, goal, or placement decision.
  • 504 plan: Written parental consent is generally required for an initial Section 504 evaluation under federal guidance. Procedures for consent, plan development, placement, and implementation may vary by state, district, and school.

How often is the plan reviewed?

  • IEP: The IEP Team must review the IEP at least once each year and revise it when appropriate. A reevaluation must generally occur at least once every three years unless the parent and public agency agree that it is unnecessary, or unless applicable rules require a different action.
  • 504 plan: Review and reevaluation procedures vary by state, district, and school. Many schools review a 504 plan periodically, often annually, and reevaluate eligibility when required by local procedures, when needs change, or when a significant change in placement or services is being considered.

When are families notified about changes?

  • IEP: The school must provide prior written notice when it proposes or refuses to initiate or change the identification, evaluation, educational placement, or provision of FAPE to the student.
  • 504 plan: The school should provide notice under applicable Section 504 procedures when it proposes or makes a significant change to identification, evaluation, placement, or services. The form and timing of notice may vary locally.

How are disputes resolved?

  • IEP: Families and schools may try informal problem-solving first. Other options may include facilitated meetings, mediation, a state complaint, an IDEA due process complaint and hearing, an Office for Civil Rights complaint, or court review, depending on the issue and applicable procedures.
  • 504 plan: Families and schools may use informal resolution, a grievance process, an impartial hearing, a Section 504 complaint process, an Office for Civil Rights complaint, or other remedies available under local policy and law.

What is the difference between an IEP and a 504 plan?

  • IEP: Provides specially designed instruction and related services to meet a student’s unique educational needs under IDEA. It has detailed federal requirements for content, goals, progress monitoring, team participation, and procedural safeguards.
  • 504 plan: Primarily provides accommodations, related aids, and services so a student with a disability can access and participate in education without discrimination. It does not generally include specially designed instruction and has fewer federally prescribed content requirements.
  • Important distinction: A student who receives an IEP is also protected by Section 504’s disability nondiscrimination requirements. Schools generally do not create a separate 504 plan to duplicate the same FAPE already provided through an IEP.

Can a student receive accommodations without an IEP or 504 plan?

A school may provide informal classroom supports to any student when appropriate. Formal disability-related accommodations and services, however, may require an IEP, a 504 plan, another documented health or support plan, or a different process under local policy. Families should ask the school which process applies to the student’s needs.

What is the difference between services, supports, and accommodations?

  • Services: Professional or educational assistance provided to meet a student’s needs, such as speech-language therapy, occupational therapy, counseling, transportation, nursing, or specially designed instruction.
  • Supports: A broad term for assistance provided to a student or school personnel, including instruction, materials, technology, consultation, or staff training.
  • Accommodations: Changes to how, where, when, or with what materials a student learns or demonstrates knowledge. Accommodations generally change access or participation rather than the learning standard.
  • Modifications: Changes to what a student is expected to learn or demonstrate, such as a different academic standard or assignment expectation. Modifications are more closely associated with special education and IEPs.

How do IEPs and 504 plans apply after high school?

A K–12 IEP does not automatically continue as the same document after graduation or transition to college. Postsecondary institutions generally use their own disability-services processes under Section 504 and the ADA. Students may need to request accommodations and provide documentation through the institution’s established process.


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