Who Is Protected Under Section 504
Continue the U.S. Department of Education Office for Civil Rights guidance and focus on how Section 504 identifies students who may be entitled to protection and services.
Supporting Students with Disabilities and Avoiding the Discriminatory Use of Student Discipline under Section 504 of the Rehabilitation Act of 1973
Open Required Reading →- How Section 504 defines disability
- Why eligibility is not determined by grades alone
- How major life activities may be affected
- Why individualized evaluation matters
- How supports can mask the extent of a student's difficulty
Eligibility Is More Nuanced Than It Looks
Section 504 eligibility decisions can be difficult because students may appear successful on the surface while still experiencing substantial disability-related limitations. The team must examine how the student actually functions, not simply whether the student is passing classes.
Strong grades do not automatically rule out Section 504 eligibility.
A student may perform at or above grade level and still experience a substantial limitation in a major life activity. Academic outcomes alone may not reveal how much effort, support, time, or compensation is required for the student to achieve those outcomes.
Major life activities extend beyond reading and mathematics.
Section 504 analysis may involve activities such as concentrating, thinking, communicating, learning, or other important areas of functioning. A student's difficulty does not have to appear as a traditional academic deficit.
Existing supports can make a disability look less significant than it is.
A student may appear successful because teachers, parents, tutors, or the student have already created informal ways to compensate for the disability. The team should consider what functioning looks like with and without those layers of support.
Eligibility is an individualized determination.
A diagnosis may be relevant, but the team still needs to examine how that condition affects the individual student. Two students with the same diagnosis may function very differently in school.
A Section 504 team is reviewing a student who earns mostly A and B grades but has significant attention, organization, and task-completion concerns.
Sort each piece of information into the category where it is most useful for the eligibility analysis.
Functional Limitation
Evidence about how the student actually performs a major life activity.
Existing Supports
Help that may be masking or reducing the apparent impact of the disability.
Outcome Data
Grades or scores that are relevant but should not be considered in isolation.
A student with a diagnosed attention disorder earns mostly A's. During the eligibility meeting, a team member says:
Which question should the team ask before accepting that conclusion?
Reveal the Best Answer
Two students have the same diagnosed condition.
Completes classwork independently, follows multi-step directions, manages assignments without assistance, and demonstrates no meaningful limitation in school functioning.
Requires repeated prompting, extensive organization support, extended work time, and daily adult assistance to complete the same types of academic tasks.
What Does This Comparison Demonstrate?
Determine Whether Section 504 Protection May Apply
Analyze a more complex eligibility scenario. Your response should move beyond diagnosis and grades and focus on the student's actual functional limitations, existing supports, and the information the team needs before reaching a decision.
Beyond Academic Achievement: Evaluating Functional Limitations
A strong Section 504 analysis considers the major life activities affected, the degree of limitation, the support required for the student to function successfully, and the student's individual circumstances.