LESSON 2 REQUIRED READING

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 →
READ FOR THESE IDEAS
  • 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
LOOK CLOSER

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.

01

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.

Why it matters: Eligibility analysis should focus on functioning, not simply report cards or test scores.
02

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.

Why it matters: A student can experience meaningful disability-related limitations even when basic academic skills appear intact.
03

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.

Why it matters: Success achieved through unusually intensive support should not be mistaken for absence of disability-related limitation.
04

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.

Why it matters: Neither diagnosis alone nor the absence of obvious academic failure should substitute for individualized analysis.
ACTIVITY 1 Sort the Evidence

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.

The student requires twice as long as peers to complete homework.
The student currently earns a B+ average.
A parent spends 90 minutes each evening organizing assignments with the student.
The student frequently loses track of multi-step directions without repeated prompting.
State assessment scores are above the proficiency cut score.
Teachers routinely provide reminders and checklists even though they are not formally documented.

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.

ACTIVITY 2 What Is Missing From the Team's Reasoning?

A student with a diagnosed attention disorder earns mostly A's. During the eligibility meeting, a team member says:

“The student is clearly doing well academically, so there is no evidence of a substantial limitation.”

Which question should the team ask before accepting that conclusion?

A. Does the student have any failing grades?
B. How much time, effort, prompting, or outside support is required for the student to achieve those grades?
C. Has the student ever received special education services?
D. Does the student's diagnosis appear on the school's most common list of Section 504 conditions?
Reveal the Best Answer
B. The team's analysis should include how the student functions, not merely the final academic outcome. High achievement may coexist with substantial difficulty when the student requires unusually high levels of effort, support, or compensation.
ACTIVITY 3 Same Diagnosis, Different Decision

Two students have the same diagnosed condition.

STUDENT A

Completes classwork independently, follows multi-step directions, manages assignments without assistance, and demonstrates no meaningful limitation in school functioning.

STUDENT B

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?
A diagnosis does not automatically determine Section 504 eligibility. The team must examine the effect of the condition on the individual student's functioning. Students with the same diagnosis can have very different educational needs and very different eligibility analyses.
ACTIVITY 4 · AI CASE ANALYSIS

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.

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LESSON TAKEAWAY

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.

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