Hey there!
As OT practitioners, we understand IEPs.
I mean, we have to. You can't get through a school-based OT job interview without knowing at least the basics of an IEP.
But 504s are different.
I don’t think I knew what a 504 plan was until my second year in the schools, and it was probably an additional year or two before I was actually included on a 504 team.
While IEPs follow a pretty standardized structure outlined by federal law, the landscape of 504 plans is notably varied. Across the country, districts seem to interpret what constitutes 504 plan interventions very differently, resulting in a wide range of approaches and practices.
In this article, we’ll address the similarities and differences between these plans. I’ll also share insights and strategies from my experiences providing OT services under both an IEP and a 504 plan.
Overview of 504 Plans and IEPs
504 plans and IEPs both serve as guiding documents that delineate the unique needs and accommodations for students with disabilities. And while both aim to ensure equitable access to education, they operate under distinct legal frameworks.
A 504 plan, governed by Section 504 of the Rehabilitation Act of 1973, caters to students whose disabilities “substantially limits one or more major life activities” but do not necessitate specialized instruction.
On the other hand, an IEP is mandated by the Individuals with Disabilities Education Act (IDEA) and must be tailored for students with specific disabilities who require specialized educational services.
OT Significance: OT practitioners can support students under both a 504 plan and an IEP.
Are you currently providing support to students under 504 plans?
Yes, frequently
Yes, occasionally
Rarely
No, not at all
Eligibility Criteria
Understanding the eligibility criteria for these plans is muddy, even on the best of days.
For a student to qualify for a 504 plan, their disability must significantly impede major life activities such as learning, walking, or concentrating. This definition lacks the specificity outlined by IDEA, leaving the idea of who can benefit from a 504 plan ambiguous, at best.
In contrast, eligibility for an IEP (not just OT services on an IEP) is well documented in IDEA and requires that a student must be identified as meeting one (or more) of 13 different disability criteria.
In addition to meeting the disability criteria, the student must also be identified as needing specialized instruction to access and benefit from their educational curriculum.
Eligibility for school-based OT services is not explicitly outlined by IDEA or Section 504.
Scope of Services
The scope of services offered under 504 plans and IEPs are often very different. Whereas IEPs usually include accommodations, modifications, specialized instructional supports, and related services, 504 plans will frequently only include accommodations for a student.
While uncommon, it is not unheard of for districts to provide services (in addition to accommodations) to students on a 504 plan.
As an OT practitioner, you may be asked to limit your 504 plan recommendations to accommodations and reserve services for students who qualify for an IEP. This is one of the many situations in which you might learn a lot about your personal ethical boundaries
OT Assessment Process
In the assessment realm, OT practitioners play a role in evaluating students' functional abilities and determining the most appropriate interventions.
To understand the OT assessment process as it relates to IEPs and Section 504, you need to consider several factors, including:
IDEA
Section 504 provisions
your State OT Practice Act
Regarding IDEA and 504 Plans, the statutes have similar requirements for what an evaluation must look like. Information must “draw from a variety of sources” and “all significant factors related to the student's learning process must be considered.” Likewise, sources may include “aptitude and achievement tests, teacher recommendations, physical condition, social and cultural background, and adaptive behavior” (“Protecting Students with Disabilities,” 2023)
I obviously cannot discuss every state practice act, but by looking at the OTPF-4 we’ll get a good sense of what is required of an OT evaluation.
The OTPF-4 notes that prior to providing OT services, OT practitioners need to have a solid evaluation to guide the intervention process. It also outlines the three primary aspects of an OT evaluation. Those are:
The development of an occupational profile
An analysis of occupational performance, and
A synthesis of the evaluation data
So, to answer the question of how 504 plan OT assessments differ from IEP OT assessments, my answer is that they don’t - or at least the process should be the same.
Sure, the outcomes of a 504 plan assessment may be different from those of an IEP assessment, but that doesn’t mean that you need less data to come to your conclusions.
There will likely be some occasions when you are asked to evaluate a very specific area of need for a 504 plan. In that case, your evaluation may be more targeted than others, but the process and how you arrive at your recommendations will remain the same.
Want to learn more about OT Evaluations?
Sign up for the A-Z School-Based OT Course to help you better understand how to complete an OT evaluation. You'll get access to my evaluation document template to improve your evaluation write-ups!
Intervention Process
Traditionally, interventions for students with a 504 plan revolve around providing accommodations such as preferential seating, extended time on tests, assistive technology to facilitate equal access to educational opportunities, etc. In addition to the accommodation(s) put in place, consultations with team members may be required to ensure they are implemented with fidelity.
In contrast, an IEP frequently includes weekly, monthly, and/or less frequent consultative services in addition to accommodations.
However, as I noted above, 504 plans can include consultative or direct services. Likewise, OT practitioners can suggest accommodations to an IEP team without implementing any service—although I recommend at least a consultative service when first implementing accommodations.
I hope you are starting to see how entangled and gray 504 plans and IEPs genuinely are. It is because of this that I see more and more districts bypassing 504 plans and going straight to an IEP.
Documentation
I’ll keep this section short and sweet.
When it comes to documentation, the answer is to ALWAYS DOCUMENT!!!
Whether the student has an IEP, 504, is on MTSS, or any other program with an acronym that only educators know, document everything - Evals, notes, progress, sessions… everything!
Conclusion
As I hope you have gleaned from this article, IEPs and 504 plans intersect in complex ways. 504 plans are not “accommodation only” plans. And IEPs do not always have to include OT services.
When it comes to the OT assessment and intervention pieces, I have come to acknowledge that there are more similarities than there are differences.
What really seems to separate them out are the pieces that OT practitioners have less say in - such as how the student qualifies for one or the other and details in the paperwork.
No matter what kind of plan you are supporting, I know OT practitioners are always going to be on the side of supporting the student. And so long as you do that, you’ll just about always do the right thing.
What are your experiences like with 504 plans and how do they compare to IEPs? Please share this article on LinkedIn and share your thoughts. I would love to hear what you think.
Thanks for having a read,
👋 Jayson
Resources
Occupational Therapy Practice Framework: Domain and Process—Fourth Edition. Am J Occup Ther August 2020, Vol. 74(Supplement_2), 7412410010p1–7412410010p87. doi: https://doi.org/10.5014/ajot.2020.74S2001
Protecting Students With Disabilities. (2023). Ed.gov. http://www.ed.gov/about/offices/list/ocr/504faq.html
Sec. 300.8 Child with a disability - Individuals with Disabilities Education Act. (2018, May 25). Individuals with Disabilities Education Act. https://sites.ed.gov/idea/regs/b/a/300.8
