Section 504 Guidance & Regulations

The Laws

The Rehabilitation Act of 1973 includes the single paragraph (§794a) that we now refer to as Section 504. You'll find the language of Section 504 on p. 142.

 

The Americans with Disabilities Act (ADA) is a sister-statute that shares the eligibility language and nondiscrimination approach of Section 504.  The ADA provides some additional detail, understanding, and a large body of caselaw.

In 2008, the ADA was amended by the Americans with Disabilities Act Amendments Act or ADAAA.  Changes were made consistent with Congress' desire to  create easier eligibility analysis, protect more individuals with disability and to focus litigation on accommodation as opposed to eligibility. Two pieces of the ADAAA are provided below.

 

The Regulations:  The U.S. Department of Education's Section 504 regulations, although very old and very short, should be the foundation of your compliance knowledge. The regulations are supplemented with guidance documents from the Office for Civil rights (OCR). Links to important OCR guidance documents are provided below.

The Regulations

The U.S. Department of Education's Section 504 regulations, although very old and very short, should be the foundation of your compliance knowledge. The regulations are supplemented with guidance documents from the Office for Civil rights (OCR). Links to important OCR guidance documents are provided below.

Guidance from the U.S. Department of Education

The following are links to key Section 504 Guidance documents from the U.S. Department of Education's Office for Civil Rights (OCR) that can assist your understanding.

OCR, Civil Rights Protections Against Retaliation, December 2024

 

OCR, Supporting Students with Disabilities and Avoiding the Discriminatory Use of Student Discipline under Section 504 of the Rehabilitation Act of 1973, July 2022. 

 

OCR, Protecting Students with Disabilities: Frequently Asked Questions About Section 504 and the Education of Students with Disabilities, Revised January 10,  2020

 

OCR Dear Colleague Letter: Seclusion and Restraint of Students with Disabilities, December 28, 2016.

 

OCR Frequently Asked Questions about the Rights of Students with Disabilities in Public Charter Schools under Section 504 of the Rehabilitation Act of 1973, December 28, 2016.  

 

OCR Parent & Educator Resource Guide to Section 504 in Public Elementary and Secondary Schools, December 28, 2016.

 

Students with ADHD and Section 504: A Resource Guide, OCR July 2016. 

 

DOJ & OCR, Frequently Asked Questions on Effective Communication for Students with Hearing, Vision, or Speech Disabilities in Public Elementary and Secondary Schools, November 2014.

 

OCR Guidance on Bullying of Students with Disabilities, October 21, 2014.

 

OCR Guidance on Athletics & Extracurricular Activities and Disability, January 25, 2013.

 

OCR, Questions and Answers on the ADA Amendments Act of 2008 for Students with Disabilities Attending Public Elementary and Secondary Schools, January 19, 2012

 

OCR Guidance on Report Cards and Transcripts for Students with Disabilities Attending Public Elementary and Secondary Schools, October 2008.

 

OCR, Dear Colleague Letter on students with disabilities accessing accelerated programs (i.e., Gifted/Talented, Advanced Placement and International Baccalaureate), March 2007.

 

OCR, Dear Colleague Letter on post-secondary transition of students with disabilities, March 2007.

OCR Fact Sheets on Various Impairments

Beginning in 2024, OCR began the release of what appears to be a series of Fact Sheets focused on various physical or mental impairments. 

Anxiety disorders

Asthma

Bipolar-disorder

Depression

Diabetes

Eating disorders

Food allergy

Gastro reflux

Inflammatory bowel disease

Migraines

Narcolepsy

Measles & COVID-Related Guidance from the U.S. Department of Education