Section 504 Plans in Utah
How does Section 504 work in Utah?
Section 504 of the Rehabilitation Act of 1973 is a federal civil rights statute that in Utah, as in all states, protects students with disabilities who may not qualify for special education under IDEA but who need accommodations to access education on an equal basis. 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. Utah's special education rules (Utah Admin. Code R277-750) govern IDEA-based services; Section 504 plans are a separate track enforced by the U.S. Department of Education's Office for Civil Rights (OCR). Utah LEAs must have a designated 504 coordinator and an established grievance procedure under 34 CFR 104.7. Unlike IEPs, 504 plans do not require a Utah disability category or need for specialized instruction; they focus on accommodations and services that provide equal access. Key differences: IEPs require a qualifying disability category, adverse effect on educational performance, and need for special education; 504 plans cover any qualifying impairment with a substantial limitation on a major life activity; IEPs mandate annual review and triennial reevaluation while 504 plans have no federally mandated review schedule. Students who are exited from IDEA services upon graduation or aging out should be evaluated for potential 504 eligibility if they have a continuing disability.
What Utah Requires
Section 504 applies to any student with a physical or mental impairment substantially limiting one or more major life activities — a broader standard than Utah's IDEA eligibility criteria (29 U.S.C. § 794; 34 CFR 104.3).
Utah LEAs must designate a Section 504 coordinator and maintain a grievance procedure for disability-based complaints under 34 CFR 104.7.
504 plans provide accommodations and services but do not require specialized instruction, unlike IEPs under Utah Admin. Code R277-750.
504 plans have no federally mandated annual review or triennial reevaluation schedule, though periodic review is best practice.
Students who are ineligible for IDEA or who exit IDEA but continue to have a disability should be considered for Section 504 protection.
Section 504 OCR complaints may be filed with the U.S. DOE OCR within 180 days of the alleged discrimination (34 CFR 104.61; 34 CFR Part 100).
Key Timelines
There is no federal or Utah-specific deadline for completing a 504 evaluation, but it must be completed within a reasonable time.
504 plans have no mandatory annual review under federal law, though annual review is best practice.
OCR complaints must be filed within 180 days of the alleged discriminatory act (34 CFR 104.61).