Section 504 Plans in Michigan
How does Section 504 work in Michigan?
In Michigan, Section 504 of the Rehabilitation Act of 1973 provides protections for students with disabilities who may not qualify for special education under IDEA and MARSE but still need accommodations to access the general education curriculum. Section 504 uses a broader disability definition than IDEA — a student qualifies if they have a physical or mental impairment that substantially limits one or more major life activities. Students who do not meet eligibility under Michigan's 13 MARSE disability categories, or who qualify but whose needs are fully addressed through general education with accommodations, may receive 504 plans. Michigan does not have a separate state-law equivalent of Section 504 — Michigan relies directly on the federal statute and OCR guidance. Section 504 is enforced by the U.S. Department of Education Office for Civil Rights (OCR). Michigan school districts designate a Section 504 coordinator, typically a building administrator or special education director. Unlike IEPs, 504 plans have no federally mandated content requirements, review timelines, or specific evaluation procedures — districts follow their own local policies consistent with OCR guidance. Michigan OCR interpretations have clarified that: (1) students with ADD/ADHD frequently qualify under Section 504 if IDEA eligibility is not established; (2) students who were previously IDEA-eligible may transition to 504 plans after graduation criteria are nearly met; (3) 504 plans must be reviewed periodically and parents must be notified of significant changes.
What Michigan Requires
Section 504 applies to students with a physical or mental impairment that substantially limits one or more major life activities — a broader definition than IDEA's 13 disability categories (29 U.S.C. §794; 34 CFR Part 104).
Students who do not meet IDEA/MARSE eligibility may still qualify for a 504 plan if they have a qualifying impairment that substantially limits a major life activity — districts must refer denied IDEA students to the 504 coordinator.
Section 504 is enforced by the U.S. Department of Education OCR — Michigan parents may file OCR complaints instead of or in addition to state IDEA complaints.
Michigan districts must designate a Section 504 coordinator and maintain local Section 504 policies and grievance procedures consistent with federal requirements (34 CFR 104.7).
Students with ADD/ADHD who do not meet OHI criteria under MARSE (R 340.1709a) may still qualify under Section 504 if ADHD substantially limits learning or another major life activity — this is a common scenario in Michigan.
504 plans do not carry the same procedural safeguards as IEPs — there are no mandated timelines, no required content elements, and no state-level complaint process specific to Section 504.
Key Timelines
Section 504 plans should be reviewed periodically — annually is the standard local practice — though there is no specific federal or Michigan state timeline requirement.
Referral to the Section 504 coordinator should occur promptly when a student is found ineligible for IDEA services but may have a qualifying disability under Section 504.
OCR complaints must be filed within 180 days of the alleged discrimination (34 CFR 100.7(b)).