Section 504 Plans in Hawaii
How does Section 504 work in Hawaii?
Section 504 of the Rehabilitation Act of 1973 applies in Hawaii as in all states as a federal civil rights law providing protections for students with disabilities who may not qualify for IDEA special education services. A student qualifies for a 504 plan if they have a physical or mental impairment that substantially limits one or more major life activities — a broader standard than IDEA eligibility. Because HIDOE is simultaneously the SEA and sole LEA in Hawaii, 504 plan administration is centralized through HIDOE, which provides statewide 504 policies and procedures through the Office of Student Support Services. Unlike IEPs, 504 plans do not require classification under an IDEA disability category and focus on accommodations rather than specialized instruction. HIDOE uses 504 plan coordinators at the school and complex area levels. Students who do not qualify for IDEA special education should be considered for 504 eligibility. Section 504 complaints may be filed with HIDOE under its 504 grievance process or directly with the U.S. Department of Education Office for Civil Rights (OCR), which oversees Hawaii compliance.
What Hawaii Requires
Section 504 covers students with a physical or mental impairment substantially limiting one or more major life activities — a broader standard than Hawaii's IDEA eligibility requirements (29 U.S.C. § 794; 34 CFR 104.3).
504 plans provide accommodations and modifications but do not require specialized instruction, unlike IDEA IEPs (34 CFR 104.33).
HIDOE, as the sole LEA and SEA in Hawaii, is responsible for implementing Section 504 across all public schools and must maintain a 504 grievance procedure (34 CFR 104.7).
504 plans have no mandatory annual review requirement under federal law, though periodic review is best practice; HIDOE guidance recommends annual review.
Students who do not meet IDEA eligibility criteria should be evaluated for Section 504 eligibility if they have a disability that substantially limits a major life activity.
Section 504 complaints may be filed with HIDOE's 504 grievance coordinator or with the OCR regional office (San Francisco) covering Hawaii (34 CFR 104.7).
Key Timelines
There is no federal deadline for completing a 504 evaluation; it must be completed within a reasonable time.
504 plans have no mandatory annual review requirement under federal law; HIDOE guidance recommends annual review as best practice.
IEPs require annual review (HAR § 8-56-32) and triennial reevaluation (HAR § 8-56-20); 504 plans have no equivalent mandated timelines.