Section 504 Plans in Connecticut

How does Section 504 work in Connecticut?

Section 504 of the Rehabilitation Act of 1973 provides protections in Connecticut for students with disabilities who may not qualify for special education under IDEA but who have a physical or mental impairment that substantially limits one or more major life activities. Connecticut's public schools are required to provide FAPE under Section 504, which may mean regular or special education and related aids and services designed to meet individual needs as adequately as nondisabled students' needs are met (34 CFR 104.33). Connecticut does not have a separate state statute specifically governing Section 504 plans in schools beyond the federal framework — 504 plans are governed by 34 CFR Part 104 and enforced by the U.S. Department of Education's Office for Civil Rights (OCR). Key differences from IEPs: 504 plans do not require one of Connecticut's 13 IDEA disability categories; the standard for eligibility is substantially limiting a major life activity; 504 plans focus on access and accommodation rather than specially designed instruction; and 504 plans do not have the same procedural safeguards as IEPs under IDEA. Connecticut students who do not meet IDEA eligibility should be evaluated for potential 504 eligibility. 504 complaints may be filed with OCR or through the district's grievance process.

What Connecticut Requires

Section 504 applies to any student with a physical or mental impairment that substantially limits one or more major life activities — a broader standard than Connecticut's IDEA eligibility criteria (29 U.S.C. § 794; 34 CFR 104.3(j)).

Under Section 504, Connecticut schools must provide FAPE — regular or special education and related aids and services meeting individual needs as adequately as the needs of nondisabled students (34 CFR 104.33).

504 plans provide accommodations and modifications; they do not require specially designed instruction as IEPs do, and do not require one of Connecticut's 13 IDEA disability categories.

504 plans have no mandatory annual review or triennial reevaluation under federal law, though periodic review and reevaluation are best practice.

Students who do not meet Connecticut's IDEA eligibility criteria should be considered for Section 504 eligibility if they have a disability substantially limiting a major life activity.

Section 504 complaints in Connecticut may be filed with the U.S. Department of Education OCR or through the district's grievance procedure (34 CFR 104.36).

Key Timelines

No federal or Connecticut-specific deadline for completing a 504 evaluation; must be done within a reasonable time.

504 plans have no mandatory annual review requirement under federal law; annual review is recommended best practice.

IEPs require annual review (Conn. Agencies Regs. § 10-76d-12) and triennial reevaluation (Conn. Agencies Regs. § 10-76d-10); 504 plans have no equivalent mandated timeline.

Sources

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