504 Accommodations: Student & Family Guide

Section 504 of the Rehabilitation Act of 1973 requires public schools to offer accommodations for eligible
students with disabilities. These accommodations help students with special health needs to participate
in New York City Department of Education (DOE) programs and activities on an equal basis with their
peers who do not have disabilities. This guide explains who qualifies for accommodations, how to apply,
and how accommodation plans are developed.
DOE program or activity means those sponsored by the DOE, including PA/PTA-sponsored after-school
programs or extracurricular activities in a DOE building.
Learn more about Section 504 on the DOE 504 Accommodations webpage or by reaching out to your
school’s 504 Coordinator.

Which students qualify for 504 accommodations?

Students qualify if:
1. They have a physical or mental impairment; and
2. The impairment substantially limits at least one major life activity.

1. Physical or Mental Impairments

Some examples of physical or mental impairments are physical disabilities, health conditions,
mental disorders, and learning disabilities.
What about short term or episodic impairments?
• Short term impairments (like a broken leg) may qualify a student for 504 accommodations.
Such accommodations vary depending on how long the impairment lasts and how limiting it is.
• Episodic impairments (like asthma) may qualify a student for 504 accommodations. Students
are qualified if the impairment substantially limits a major life activity when it is active.

2. Examples of Major Life Activities

• Caring for oneself • Eating • Focusing
• Walking • Sleeping • Thinking
• Seeing • Standing • Communicating
• Hearing • Lifting • Learning
• Speaking • Bending • Working
• Breathing • Reading • Doing tasks with one’s hand
• Major bodily
functions

The substantially limited major life activity need not be “learning” for a student to be eligible for
504 accommodations.
Does your child have an impairment that substantially limits them in any of the life activities listed
above? If so, your child may qualify for accommodations under Section 504. Once the correct
forms are submitted to the school, each student’s case is reviewed individually.

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 Which accommodations are available for eligible students under Section 504, and how do I
request them?
Your child may be eligible for accommodations. All forms can be found on the DOE Health Services or 504
Accommodations webpages. You may also ask your school’s 504 Coordinator for the forms.
To request a 504 accommodation and 504 Plan, submit these 504 request forms to your school’s 504
Coordinator:
• Request for Health Services/Section 504 Accommodations Parent Form with
HIPAA Authorization (completed by the student’s parent); and
• Medical Accommodations Request Form (completed by the student’s health care provider).
Educational and other accommodations are for students who need building, classroom, or testing
accommodations. For example, students with trouble hearing may need to be seated close to the
teacher or blackboard, or a student may need breaks or extra time to take tests.
Examples of other accommodations include assistive devices, special furniture, building adaptations, and
elevator use. Parents should contact the DOE Office of Student Enrollment or the Director of Placement
for District 75 with questions about building accessibility.
Paraprofessionals are assigned to students who require support with tasks due to their disability in
order to access DOE programs and activities. For example: a student with diabetes who is not able to
monitor their blood glucose levels on their own or a student who may need assistance with toileting due
to a physical or physiological disability.
Transportation Accommodations, such as for limited travel time or paraprofessional support (to provide
one-to-one supervision on the school bus), are reviewed by the 504 Team (for students with a long-term
medical condition that impacts their ability to take public transportation) or the DOE Office of Pupil
Transportation (for students with a temporary medical condition or short- or long-term limited
mobility). Ask your 504 Coordinator for more information.
Health services are for students who need to take medicine (like insulin to treat diabetes or
asthma inhaler) or receive a special nursing treatment at school. To request health services, the
parent must submit the following forms completed by the student’s health care provider to the
school nurse/medical professional in the student’s school building:
• Medication Administration Form (MAF) (for medication administration); and/or
• Medically Prescribed Treatment Form (non-medication).
If a 504 Plan is also required, the parent must submit the 504 request forms to the 504
Coordinator.
What happens after I request accommodations?
After the parent returns completed 504 request forms to the 504 Coordinator, and medication/medical
treatment forms for health services to the school nurse/medical professional in the school building: the
504 Coordinator will contact you within 5 school days of your initial request to schedule a meeting that
will occur, depending on the services requested, no later than 15 or 30 school days from receipt of the
completed 504 request forms. You will be part of the school-based 504 Team that meets to discuss your
request and other relevant information about your child and decides if your child is eligible for
accommodations and if so, which accommodations are appropriate.

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 Diabetes: Interim Care Meeting
As soon as possible, and no later than 5 school days (unless additional time is necessary to
accommodate a parent’s schedule) after DOE’s receipt of the Diabetes MAF, the school will convene
a meeting with a school administrator, the 504 Coordinator, parent, school nurse, and if possible
Office of School Health member (e.g., Borough Nursing Director, Nursing Supervisor, Diabetes Team
Member, health care provider), to discuss the student’s needs between when the Diabetes MAF is
complete and ready to implement and when a final 504 Plan is signed and implemented, such as
staff training on hypo- and hyperglycemia, blood glucose monitoring, insulin administration, and
accommodations such as access to food and water during the school day.

Review the Parent Resource: Diabetes Care for Students in DOE Public Schools and Diabetes
webpage (https://www.schools.nyc.gov/school-life/health-and-wellness/staying-healthy/diabetes)
for more information.

Who goes to the 504 accommodations meeting (“504 Team meeting”)?

The 504 Team meeting is attended by you and people who know your child’s abilities. They understand
the information that is being reviewed and know the types of accommodations that may meet your
child’s needs. The 504 Team meeting must also include at least one person in each category below who
can:
• Talk about your child’s abilities and skills. (For example, your child’s teacher or guidance
counselor may attend.)
• Interpret reports or evaluations. (For example, the school social worker or nurse may attend.)
• Share information about the accommodations that may meet your child’s needs. (For
example, the 504 Coordinator.)

Where health services are requested, the school nurse, or Office of School Health member (e.g., Borough
Nursing Director, Nursing Supervisor, Diabetes Team Member, health care provider) must be a member
of the 504 Team.

What information is reviewed at the meeting?

The 504 Team will review information from different sources, such as your child’s tests,
observations, work samples, report cards, and medical records. This will help the Team understand
your child’s abilities, achievement, behaviors, and health needs. Parents and school staff may bring
any information they believe best describes the child’s abilities and needs.

Diagnosis and Suggestions from Your Child’s Doctor

Your child’s doctor must complete the Medical Accommodations Request Form. The doctor may
suggest that the school provide certain accommodations. The 504 Team will decide if the suggested
accommodations are appropriate, and if so, how to provide them at school.

How is eligibility determined?

The 504 Team will consider if your child’s impairment substantially limits a major life activity. The
Team will make this decision based on information reviewed at the meeting, and will consider if your
child’s impairment has a significant impact on your child’s performance or participation in school.
See the Glossary at the end of this Guide for helpful definitions.
What is the difference between an Individualized Education Program and a 504 Plan?
An Individualized Education Program (IEP) is developed by an IEP team for a student who is eligible for
one of the 13 disability classifications (defined under the Individuals with Disabilities Education Act
and New York State law) and requires specialized instruction and/or related services to meet their
instructional goals. A Section 504 Accommodation Plan (“504 Plan”) is for a qualified student with a
disability who needs support to access DOE programs and activities. More information on IEPs and
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the special education process can be found at https://www.schools.nyc.gov/learning/special-
education/the-iep-process/the-iep.

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When a student has an IEP, 504 accommodations are often provided through the IEP. However, for
students with or being evaluated for an IEP who require health services to attend school safely, in
addition to the IEP, school 504 Teams, in collaboration with the student’s IEP team, may develop a
504 Plan consistent with Chancellor’s Regulation A-710. Students with a Diabetes MAF, and who
require diabetes-related accommodations, must have a separate Diabetes 504 Plan in addition to
their IEP.
Can my child receive related services with a 504 Plan?
Typically at the DOE, students who require related services receive them through an IEP, and not a 504
Plan. Eligibility for related services is determined on an individualized basis. Examples of related services
are physical therapy, speech therapy, and mandated counseling services. If your child appears to need
any of these services, generally the 504 Team will refer your child to the school-based IEP team or
district Committee on Special Education.

Does my child need a 504 Plan for health services?

Not all students who need health services at school need a 504 Plan. If your child’s health service does
not affect their ability to participate in school and other DOE programs and activities on an equal basis
with their peers who do not have disabilities, then they do not need a 504 Plan. Contact your school’s
504 Coordinator for guidance.
• Example 1: A student stubbed their toe and visits the nurse’s office for treatment
during the day. They do not need any other supports or accommodations.
• This student does not need a 504 Plan.
• Example 2: During the school day, a student with diabetes must have their blood glucose levels
monitored throughout the day, takes insulin at certain times, and needs bathroom breaks and
access to glucagon and snacks to manage their diabetes care.
• This student does need a 504 Plan.

How are accommodations developed?

The 504 Team decides which accommodations will best meet your child’s individual needs. The Team
considers the type of condition your child has, and how significant its impact on the student’s ability to
participate. They will choose accommodations that will give your child an equal opportunity to take part
in school.
Students are provided necessary accommodations in the least restrictive environment in order to
interact to the greatest extent possible with their peers who do not have disabilities. This means each
504 Team develops an individual student’s 504 Plan with the goal of limiting missed instruction time and
separation from classmates.
• For example: A student with diabetes who cannot yet independently manage their health condition
at school may be assigned a paraprofessional to monitor their blood glucose in the classroom, or
wherever the student is throughout the school day, such as the gymnasium or hallways.

Factors to consider in determining the least restrictive environment for each student’s accommodations
include, for example:
1) The student’s health and safety (e.g., the ability of trained staff to provide emergency
medication without moving the student)
2) The student’s needs and preferences
3) The parent’s preferences
4) Minimizing missed classroom or instruction time
5) Minimizing time spent away from peers who do not have disabilities
6) The student’s co-disabilities requiring accommodation

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Resources, such as the availability of the school nurse, are not a proper consideration for determining
each student’s least restrictive environment. For questions regarding the location where health services
will be provided, the 504 Coordinator, school nurse, and other members of the 504 Team conduct an
individualized assessment for each student.

Once my child is determined to be eligible, is my child always eligible for

accommodations?
The parent must submit the MAF and/or Medically Prescribed Treatment Form annually. New
504 request forms are also required to request new or modified health services or other
accommodations, but may not be needed to continue an existing accommodation.
504 Plans must be reviewed before the end of each school year or more often if necessary, and
amended at the time of the review, if necessary.
If your child’s impairment continues to substantially limit their participation in school, your child will
remain eligible for accommodations. The 504 Team will meet before the end of the school year, to the
extent possible, to create a new Plan for the upcoming school year.
If it is decided that your child’s impairment no longer substantially limits their ability in a major life
activity, your child is no longer eligible for accommodations (the 504 Plan is ended).

What types of communications will I receive?

Schools will communicate with you about DOE Section 504 policies. All schools post and share the
Notice of Non-Discrimination under Section 504 annually and upon request.
If the 504 Team decides that your child qualifies for 504 accommodations, you will receive:
• A Notice of Eligibility. If you do not agree with the eligibility determination, talk to your school’s
Health Director. Contact information will be provided by the school or can be found on the
Section 504 webpage. You may also request an Impartial Hearing to challenge the determination
of the Health Director and must submit the written request within 10 days of receiving the
determination.
• 504 Plan. If your child is determined eligible for accommodations, the 504 Coordinator completes
the 504 Plan with the 504 Team’s input and based upon the relevant documentation. No 504 Plan
may be implemented without written parental consent, which is typically provided at the 504
Team meeting where the Plan is completed or soon thereafter.
• An Annual Notice of Reauthorization (Parent Letter – 504 Accommodations Reauthorization).
This letter will tell you the steps that you must take to have your child’s 504 accommodations
renewed for the next school year.

See Chancellor’s Regulation A-710 and the Section 504 Accommodations webpage for more
information.

Do I have the right to language access services during the Section 504 process?
Upon request, parents whose preferred language is one of the nine most common languages other than
English spoken by NYC residents as identified by the DOE (“covered languages”) have the right to
interpretation at 504 meetings, and translation of 504 Plans and notices. You can request language access
services by speaking with your school’s 504 Coordinator. Parents, who prefer a language other than
English or one of the covered languages, may also request language access services.

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 If you have concerns regarding language access services, please follow the escalation process described
on the DOE’s website (at schools.nyc.gov/connect-with-us). If your concern is not resolved at the school
or district level, you may file a complaint. Details on how to file a complaint are explained on the DOE's
website (at https://www.schools.nyc.gov/school-life/school-environment/get-help/parent-complaints-
and-appeals).

Do you have additional questions?

• Reach out to your school’s 504 Coordinator or Health Director if you have any questions, or if you
are concerned about your child’s access to a DOE or non-DOE extracurricular program. The DOE
Section 504 Program Manager can also be reached at [email protected].
• Learn more about accommodations on the DOE's webpages mentioned above.

Glossary
The following is a summary of definitions relevant to accommodating qualified students with disabilities
pursuant to Section 504 and Chancellor’s Regulation A-710.
Qualified Student: (1) of an age at which students without disabilities are provided elementary and
secondary educational services; or of an age at which it is mandatory under State law to provide elementary
and secondary educational services to students with disabilities; or (2) a student to whom a State is
required to provide a free appropriate public education (FAPE) under the Individuals with Disabilities
Education Act (IDEA).
Individual with a Disability: (a) has a physical or mental impairment; (b) which substantially limits at least
one major life activity. “Disability” is defined broadly and determined for each student on a case-by-case
basis.
Physical or Mental Impairment: any physiological disorder or condition, cosmetic disfigurement, or
anatomical loss affecting one or more of the following body systems: neurological; musculoskeletal; special
sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genito-urinary;
hemic and lymphatic; skin; and endocrine; or any mental or psychological disorder.
Major Life Activities: for example:
• caring for oneself, doing tasks with one’s hand, walking, seeing, hearing, speaking, breathing,
learning, concentrating, thinking, and working; and
• major bodily functions (such as functions of the immune system, normal cell growth, and
digestive, bowel, bladder, neurological, brain, respiratory, circulatory, and endocrine
functions).
Substantially Limits: the degree of limitation is determined on an individualized basis, and is interpreted
without regard to the remedial effects of mitigating measures (like medications, prosthetic devices,
assistive devices), other than ordinary eyeglasses or contact lenses. An impairment need not prevent or
severely restrict a major life activity to be considered substantially limiting.
Program or activity: Any program or activity sponsored by the DOE, including after-school programs or
extracurricular activities in a DOE building that are sponsored by the Parent Association (PA)/Parent
Teacher Association (PTA) or DYCD COMPASS or SONYC.

OSH-4 504 Student & Family Guide rev. 5/2023