Section 504 Plans in Arizona
How does Section 504 work in Arizona?
Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) applies in Arizona alongside IDEA, providing a broader eligibility standard for students with disabilities who do not qualify for IDEA special education services. A student has a disability under Section 504 if they have a physical or mental impairment that substantially limits one or more major life activities, have a record of such impairment, or are regarded as having such an impairment — no adverse educational impact or need for specially designed instruction is required. All Arizona public schools and charter schools must comply with Section 504 as recipients of federal financial assistance. A 504 Plan documents the accommodations, aids, and services needed to give the student equal access to education. Students found ineligible for IDEA may still qualify for a 504 Plan. Charter schools in Arizona must comply with Section 504 in the same manner as traditional school districts (A.R.S. § 15-183(E)(7); 29 U.S.C. § 794). Arizona does not have a state Section 504 law separate from the federal statute; enforcement is through the U.S. Department of Education Office for Civil Rights (OCR). The ADE does not administer Section 504 complaint investigations — those are filed directly with the OCR.
What Arizona Requires
Section 504 applies to any Arizona public school or charter school receiving federal financial assistance; qualifying disabilities are broader than IDEA and do not require adverse educational impact or need for specially designed instruction (29 U.S.C. § 794; per federal baseline applied in AZ).
A 504 Plan must specify the accommodations, aids, and services needed to provide equal educational access; it is not an IEP and does not provide specially designed instruction.
Charter schools must comply with Section 504 in the same manner as school districts (A.R.S. § 15-183(E)(7); 29 U.S.C. § 794).
Section 504 complaints alleging disability discrimination are filed with the U.S. Department of Education Office for Civil Rights (OCR), not with ADE-ESS.
Students determined ineligible for IDEA may still qualify for a 504 Plan if their disability substantially limits a major life activity.
Key Timelines
There is no federal statutory evaluation timeline for Section 504 equivalent to IDEA's 60-day rule; evaluations should be completed within a reasonable time.
504 Plans should be reviewed at least annually and updated whenever the student's needs change.
OCR complaints alleging Section 504 violations must generally be filed within 180 days of the alleged discriminatory act (34 CFR 100.7(b); per federal baseline).