Section 504 Plans in Kentucky
How does Section 504 work in Kentucky?
Section 504 of the Rehabilitation Act of 1973 is a federal anti-discrimination law administered by the U.S. Department of Education's Office for Civil Rights. In Kentucky, 504 plans are not governed by the 707 KAR Chapter 1 regulations (which cover IDEA); instead, Section 504 operates as a civil rights statute. Kentucky mandates that each school district appoint a Section 504 Coordinator to assist parents in obtaining 504 plans. To qualify for a 504 plan in Kentucky, a student must have a physical or mental impairment that substantially limits one or more major life activities — a broader definition than IDEA eligibility. Major life activities include caring for oneself, performing manual tasks, eating, sleeping, walking, seeing, hearing, breathing, communicating, reading, thinking, concentrating, and learning. Students who are found ineligible for an IEP under IDEA may still qualify for a 504 plan. Section 504 plans provide accommodations and may include related services but do not involve the specialized curriculum modifications and individualized specially designed instruction required by IDEA. Key distinctions from an IEP: 504 plans do not require a formal team meeting structure, do not have the same procedural timelines, and do not mandate annual review in law (though best practice recommends it). Due process for 504 disputes is handled through OCR complaints or the district's own 504 grievance procedures, not through the IDEA ECAB structure. Students with IEPs are automatically protected by Section 504.
What Kentucky Requires
A student qualifies for a 504 plan if they have a physical or mental impairment substantially limiting one or more major life activities — a broader standard than IDEA eligibility.
Kentucky requires each district to appoint a Section 504 Coordinator to assist parents in the 504 process.
Students found ineligible for an IEP under IDEA must be evaluated for potential Section 504 eligibility before dismissal from consideration for supports.
Section 504 plans may include accommodations and related services but do not involve the individualized specially designed instruction or formal ARC process required by IDEA.
504 disputes are resolved through OCR complaints or the district's internal 504 grievance procedures — not through the IDEA due process/ECAB structure.
Students with IEPs are automatically protected by Section 504's anti-discrimination provisions.
Key Timelines
There is no mandated evaluation timeline for 504 in Kentucky law; districts must act within a reasonable timeframe.
Annual review of 504 plans is recommended best practice, though not required by federal law.
OCR complaints must be filed within 180 days of the alleged discriminatory act (34 CFR 100.7).