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. USBE provides Section 504 guidance and resources through the Student Services division, and publishes a comprehensive guide titled 'Equal Rights for All Students: A Guide to Section 504' (updated August 2024). Utah LEAs must designate a Section 504 coordinator and maintain a grievance procedure under 34 CFR 104.7; USBE maintains a directory of all Utah Section 504 coordinators on its website. Under Utah Admin. Code R277-404-4, a student's Section 504 accommodation plan team determines the student's participation and accommodations for statewide assessments consistent with the Utah Participation and Accommodations Policy. 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. Section 504 OCR complaints may be filed with the U.S. DOE Office for Civil Rights.
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; USBE maintains a directory of all Utah 504 coordinators (34 CFR 104.7; USBE Section 504 guidance).
504 plans provide accommodations and services but do not require specialized instruction, unlike IEPs under Utah Admin. Code R277-750 (34 CFR 104.33).
A student's 504 accommodation plan team determines assessment accommodations consistent with the Utah Accessibility, Accommodations, and Participation Policy (Utah Admin. Code R277-404-4).
504 plans have no federally mandated annual review or triennial reevaluation schedule, though periodic review (at least annually) is USBE-recommended 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 Office for Civil Rights within 180 days of the alleged discrimination (34 CFR 104.61; 34 CFR Part 100).
USBE publishes 'Equal Rights for All Students: A Guide to Section 504' as the primary guidance document for LEAs (USBE Student Services — Section 504).
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 USBE recommends at least annual review as best practice.
OCR complaints must be filed within 180 days of the alleged discriminatory act (34 CFR 104.61).
Assessment accommodations under 504 plans must be determined before statewide testing windows (Utah Admin. Code R277-404-4).