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Section 504 Practical Suggestions for Compliance


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1. Appoint 504 Coordinator(s)
2. Responsibilities Regarding Student Issues
3. Referrals
4. Evaluations
5. Placement
6. Hearings
7. Grievance Procedures
8. Complaints

Appoint 504 Coordinator(s)

  • Coordinator(s) must cover student issues, employment issues, and facilities (Section 104.7(a))
  • One or more coordinators should be appointed to cover student issues. Local district conditions will determine who and how many to appoint. This position is a regular education function; however, local districts may choose to use special education personnel if appropriate "split funding" is used.

Responsibilities Regarding Student Issues

  • Develop and publish annual notice and conduct childfind activities (Section 104.8(a), Section 104.32)
    Place notice in student handbooks (Section 104.8(b)) 
  • Develop wording and procedures for giving specific notice to parents upon referral, evaluation, and placement (Section 104.36)
  • Develop local policies and procedures on referrals, evaluations, placement, parent access to records, and due process hearing, including what documentation is needed (Section 104.33-Section 104.36)
  • Coordinate referrals, evaluations, multidisciplinary committee, placements, and hearing (Section 104.35-Section 104.36)
  • Plan and provide inservice education for staff
  • Coordinate procedures with specific programs, e.g., special education, compensatory education, and dyslexia programs; if a handicapping condition is suspected, follow all procedures before placing a child in a program, such as a dyslexia program or a transitional kindergarten/first grade class.
  • Assure that appropriate programs and placements in the least restrictive environment are available for eligible students. (Section 104.33, Section 104.34)


  • Receive from parent/guardian of school official; should also be considered if, as a result of a referral to special education, the child is found ineligible
  • Provide notice to inform how to initiate a referral
    Provide notice to parents of due process rights and of identification, evaluation, and placement when a referral is made (Section 104.36)
  • Determine evaluation process and content (Section 104.35(a))


  • Determine what evaluation information is needed and who will do testing and provide other information
    Assure that testing is done in accordance with Section 104.35
  • Do periodic reevaluations as needed and before any significant change in placement (Section 104.35(d))


  • Determine makeup of multidisciplinary committee to evaluate and place student if found eligible (Section 104.35(c))
    Assure that the evaluation of the data and placement are done by persons knowledgeable about the student, the data, and placement options (Section 104.35(c)
  • Assure that decisions about placement are based upon the child's individual needs, and the least restrictive environment considerations (Section 104.33(b), Section 104.34(a & b))


  • Develop proceedings for timely due process hearings. Hearings may be conducted informally.
    Have trained, impartial persons who are not connected with the school district available to serve as hearing officers (Section 104.36)
  • Process request for hearings from parents/guardians regarding identification, evaluation, or placement
    Supervise hearing process to assure timely completion of hearings

Grievance Procedures

  • Develop procedures for timely processing complaints regarding 504 issues files with the district. (Section 104.7)
  • Informal procedures similar to employment grievances may be used, with district personnel as grievance officers; however, the grievance process may not be used to override decisions about an individual child's program made by the group of knowledgeable persons.


  • Notify parents/guardians that they may file complaints alleging a violation of Section 504 at U.S. Department of Education, Office for Civil Rights, Region VI, 1200 Main Tower Building, Suite 2260, Dallas, TX 75202

Division of IDEA Coordination

1701 North Congress Avenue | Austin, Texas 78701-1494

Telephone: 512.463.9414 | Fax: 463-9560


Updated Febuary 10, 2011

Page last modified on 2/11/2011 10:01:46 AM.