Section 504 Plans in Indiana
How does Section 504 work in Indiana?
Section 504 of the Rehabilitation Act of 1973 is a federal civil rights law that protects students with disabilities who may not qualify for special education under IDEA but still need accommodations to access education equally. Indiana does not have state-specific Section 504 regulations beyond the federal requirements; each school corporation must designate a Section 504 Coordinator to prevent discrimination and ensure compliance (34 CFR 104.7). 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 Indiana's IDEA eligibility under 511 IAC 7-41. Unlike Indiana IEPs developed by the Case Conference Committee (CCC), 504 plans may be developed by any knowledgeable group of persons and do not require a formal multidisciplinary evaluation or specific team composition. Indiana practice requires a parent request in writing, after which the school should respond within 10 days establishing an evaluation timeline (no state mandate, but accepted practice). Key distinctions: IEPs require one of Indiana's 13 disability categories and need for special education; 504 plans cover any qualifying impairment and provide accommodations without requiring specialized instruction. Due process for 504 disputes proceeds through the U.S. Department of Education Office for Civil Rights (OCR), not through Indiana's IDEA due process system at OALP.
What Indiana Requires
Section 504 applies to students with a physical or mental impairment substantially limiting one or more major life activities — a broader standard than Indiana's 13 IDEA categories (29 U.S.C. § 794; 34 CFR 104.3).
Each school corporation must designate a Section 504 Coordinator responsible for nondiscrimination and compliance with Section 504 and ADA (34 CFR 104.7).
504 plans provide accommodations without requiring specialized instruction, unlike Indiana IEPs developed under 511 IAC 7 (34 CFR 104.33).
504 plans do not have mandatory annual review or triennial reevaluation requirements under federal law, though periodic review is best practice.
Due process for Section 504 disputes proceeds through the Office for Civil Rights (OCR), not Indiana's IDEA due process system at OALP.
Students who do not qualify under one of Indiana's 13 IDEA categories should be evaluated for 504 eligibility if they have a qualifying disability affecting a major life activity.
Key Timelines
Indiana practice: parent should request 504 consideration in writing; school should respond within 10 days establishing an evaluation timeline (no state-mandated timeline).
There is no state-mandated timeline for completing a 504 evaluation in Indiana; evaluations must be completed within a reasonable time.
504 plans have no mandatory annual review or triennial reevaluation under federal law.