Section 504 Plans in Missouri
How does Section 504 work in Missouri?
Section 504 of the Rehabilitation Act of 1973 is a federal civil rights law enforced by the U.S. Department of Education's Office for Civil Rights (OCR) that provides protections for students with disabilities who may not qualify for IDEA special education services. In Missouri, students who do not meet IDEA eligibility criteria may still be entitled to accommodations and services under Section 504 if they have a physical or mental impairment that substantially limits a major life activity including learning. The Missouri Department of Elementary and Secondary Education (DESE) provides guidance on Section 504 implementation, and each school district is responsible for implementing Section 504 consistent with federal requirements. Section 504 does not require formal testing — the 504 team considers multiple sources of information including grades, teacher reports, parent feedback, state test scores, behavior records, attendance, and health information. If a student qualifies, the 504 team develops a written accommodation plan. Reevaluation of 504 plans is required periodically and before any significant change in placement. Section 504 complaints about Missouri public schools are filed with OCR, not with DESE's IDEA complaint process. Students exiting IDEA special education may still qualify for a 504 plan.
What Missouri Requires
Students who do not qualify for IDEA special education services may still be entitled to a 504 Plan if they have a physical or mental impairment that substantially limits a major life activity (29 U.S.C. §794; 34 CFR Part 104).
Section 504 prohibits discrimination on the basis of disability in programs receiving federal financial assistance, including all Missouri public schools (29 U.S.C. §794).
Section 504 complaints about Missouri public schools are filed with the U.S. Department of Education's Office for Civil Rights, not with Missouri DESE (34 CFR 104.61).
Section 504 evaluation does not require formal testing; the 504 team considers multiple sources including grades, teacher reports, parent feedback, test scores, behavior, attendance, and health data (34 CFR 104.35).
A written 504 accommodation plan must be provided to parents and maintained by the district when a student qualifies (34 CFR Part 104).
A student who is exited from IDEA special education may still require and be entitled to a Section 504 plan based on a continuing disability (29 U.S.C. §794).
Key Timelines
Section 504 complaints must be filed with OCR within 180 calendar days of the alleged discriminatory act (34 CFR 100.7(b)).
Section 504 plans must be reviewed periodically and before any significant change in placement (34 CFR 104.35(d)).