Section 504

Section 504 of the Rehabilitation Act of 1973 is a civil rights statute that prohibits discrimination against individuals with disabilities.

The law requires school districts with students with disabilities to be provided reasonable accommodations to allow access to educational programs and associated activities to the same extent as students without disabilities.

A student may be eligible to receive Section 504 Accommodations if he/she:

• • Has a physical or mental impairment, and

  • The impairment substantially limits one or more major life activities.

DoDEA schools provide a free appropriate public education (FAPE) to students with disabilities by implementing reasonable 504 Accommodations upon establishing that a student has a disability requiring such 504 Accommodations.

The 504 Instructional Systems Specialist (ISS) provides guidance for ensuring that processes and plans are compliant and students receive necessary accommodations.

The Pacific East has positively impacted Section 504 Compliance as evidence by:

• • 100% due date compliance at the end of the 2020-2021 school-year.

  • 100% of plans meet the minimum requirements.

  • Most 504 plans meet our best practice expectations now that the step-by-step guides are more user friendly and easily accessible.

DoDEA webpage for Section 504 Accommodations with frequently asked questions and answers along with important links. This website is updated regularly.

Administrative Instruction (AI) 2500.14 Nondiscrimination and 504 Accommodation on the Basis of Disability in DoDEA Conducted Education Programs and Activities which includes: Enclosure 2 Responsibilities, Enclosure 3 Procedures, Appendix 1 to Enclosure 3 DoDEA 504 Accommodation Plan, Appendix 2 to Enclosure 3 DoDEA Consent for Assessment, Enclosure 4, Rights of Parents/Sponsor/Guardian and Student, and Enclosure 5 Notice of Nondiscrimination.

Changes to a form created in 2018:

• January 2018 and August 2018 Best Practices Discussed original was developed based on Fall 2017 reviews and was updated after spring reviews. Newer documents were created after additional reviews were completed.

• January 2018 and August 2018 Step-by-Step of what to write in each section of the 504 plan in Aspen

These show the changes made to the 504 review forms in 2020:

• February 2020 Review Form Updated the 504 review form to include guidance related to changes from the old template to the new.

• Fall 2020 Review Form Updated the 504 review sheets again to provide even better guidance based on errors seen during reviews.

Due to COVID-19 Outbreak: April 2020, created Folder regarding DoDEA Virtual School and 504s was added to the google shared drive. This folder includes support staff, flow-charts for processes, Standard Operating Procedure changes, suggested accommodations for this setting, etc.

August 2021, Developed spreadsheet of well-worded accommodations as examples now that drop-downs are no longer available for classroom accommodations.

2017-2018 School-Year

DoDEA Headquarters:

• Email about the Schoology training for entering 504 Plan Accommodations into the PARCC system (15 FEB 2018)

• Cheat Sheets for developCreating a 504 Plan in Aspen (24 JAN 2018)

• Cheat Sheet for 504 Plans in Aspen (20 FEB 2018)

• Email telling us to look for the new book HQ purchased and sent to Section 504 ISSes “What to Do When… the Answer Book on Section 504, Fifth Edition” (12 APR 2018)

Pacific East District:

• A District ISS was hired to support School Psychologists and 504 Teams in addition to School Nursing and generally speaking, all the teams and tasks typically led by these individuals.

• 504 training and reviews began. However, this position was not included in the budgeting for the 2017 fiscal year, so no travel was possible to the distant locations. All support, instruction and monitoring was done online and by phone. Met with each 504 Team Coordinator individually to review their present knowledge, provided the guidance they seemed to need and worked with them on at least one 504 Plan walking through the steps in Aspen. The following concerns were noted (AUG-DEC 2017):

  • Meeting minutes were either not included at all or were often only included in the “summary” section of the plan itself. No separate minutes were taken.

  • There was no mention of parent rights being offered.

  • There was no parent invitation providing evidence that parents were invited to participate.

  • There was no evidence that drafts were being developed with input from all participants and provided prior to annual review meetings.

  • Teachers were not providing accommodation logs or other helpful data.

  • Student history and evaluation sections did not actually include any helpful information for the person following the plan. Instead they included the diagnosis and physician’s name, mentioned that observations were made and that teacher recommendations were given, without saying what was learned by the observations and recommendations.

  • Often only “Learning” was chosen as the limited major life activity which is rare.

  • Too many students had active or old 504 plans in the system, but were also on IEPs.

  • There were many plans in the system that had not been reviewed in more than a year.

  • The 504 Plan template at this time had drop-down accommodations listed by “Content Area/Settings.” Sometimes what the team meant to be a testing accommodation was listed in the “Classroom Assignment” Setting, so was not actually showing as a testing accommodation.

  • 504 Accommodations were not always reasonable in their combination

  • 504 Chairs need to be given time to review the 504 documentation and instruction provided at the beginning of each year and complete beginning of year 504 compliance procedures .

  • 504 Chairs need to review instructions prior to developing plans.

  • Some 504 Chairs had so many responsibilities, tasks, and duties that making time for the 504 Chair responsibilities appeared impractical.

• Reviewed the Schoology training participation on the quarterly training days of 504 Chairs and sent an e-mail with the course code to those who had not yet registered. (28 DEC 2018)

• Developed a Pacific East parent invitation for 504 Team meetings as one was not available in Aspen nor in the other provided 504 documentation (28 NOV 2017)

• Emails with HQ ISS about a need for the “summary” section in the plan to be removed and only the separate “meetings” permitted due to so many people not entering meeting minutes (18-19 JAN 2018)

• Email to administrators and 504 reps about the 504 visits and personal trainings (26 JAN 2018):

  • Developed and shared Summary of 504 Best Practices discussed with 504 representatives (26 JAN 2018)

  • Developed and shared Visual step-by-step of what should be included in each section of the 504 in Aspen based on HQ instructions at the time (26 JAN 2018)

  • Email from one grateful 504 Chair regarding email, mentioning how not only the visits, but the e-mail and documentation developed have and will likely help her (29 JAN 2018)

  • Email from a grateful administrator about that e-mail and training materials (26 JAN 2018)

• Provided Common Sources of Evaluation Data (22 JAN 2018)

• Provided Administrative Instruction (AI) 2500.14 Nondiscrimination and 504 Accommodation on the Basis of Disability in DoDEA Conducted Education Programs and Activities which includes: Enclosure 2 Responsibilities, Enclosure 3 Procedures, Appendix 1 to Enclosure 3 DoDEA 504 Accommodation Plan, Appendix 2 to Enclosure 3 DoDEA Consent for Assessment, Enclosure 4, Rights of Parents/Sponsor/Guardian and Student, and Enclosure 5 Notice of Nondiscrimination.

• Example Record of Parent Contacts (5 APR 2018)

• Example of scheduling meetings (5 APR 2018)

• Example Accommodation Log (5 APR 2018)

• Email about Accommodation Log in Word (30 APR 2018)

• Email reminding where to store the 504 Plans, meeting minutes, and other data (7 JUN 2018)

2019-2020 School-Year

DoDEA Headquarters:

• The 504 template changed in Aspen, so the training and instructions were updated.

  • January 2019, a new 504 template was created in Aspen. So, in February 2019, these instructions were shared for re-entering accommodations now that system-wide assessment accommodations were separated from classroom accommodations. Additionally, too many people had not been adding meeting minutes because the old template had a section for meeting summary, so it was removed.

• Updated Section 504 Accommodation Plan Monitoring Form (18 JUN 2020)

• Section 504 Meeting Minutes between HQ and District ISSes- commitment requirement for DVS, how to write accommodations, who will case manage 504 DVS student plans, process, told not to send 504 plans yet as there is no assigned point of contact and teachers do have access to 504 alerts in Aspen for current students- so process were described for making sure new students with incoming 504 plans are not overlooked. Discussed flow charts, Pac East ISS shared instructions for virtual meetings and collecting signatures. (26 AUG 2020):

  • 504 Referrals

  • Incoming non-DoDEA 504s

  • Current 504s that need changes for virtual school

  • When DVS wants to make a referral to 504

  • Will not be completing assessments when in HPCON- C

Pacific East District:

• Completed in person visits to 504 Team Coordinators and checked to see that the paperwork in the files reflected what was in Aspen (AUG-NOV 2019)

• Completed 504 reviews at least once quarterly for active 504 plans that had not yet been reviewed. Was not able to review all 504 plans using this method (all year) Discovered:

  • The errors of the past two years were mostly resolved.

  • A few were still occasionally typing over top of old plans. When there were old meeting minutes attached to a new plan, this was evident. After explaining what to do, most re-typed the old plan back into Aspen.

  • A few still mentioned diagnoses or special education in their plans.

  • A few still didn’t include at least three pieces of data/evidence in the evaluation section of the plan.

  • Many were not putting the expected information in the different boxes on the plan, which didn’t make it “non-compliant” also didn’t include expected information.

  • Some meeting minutes really said nothing. They often did not include full names of participants, did not include the discussion of WHY accommodations were being added or discarded, and often repeated information from the plan itself, which can cause problems if they contradict the plan.

• Updated Monitoring Form Updated the 504 monitoring review form to include guidance related to changes from the old template to the new template and to include reminders regarding the weaknesses noted during the reviews and visits (FEB 2020).

• COVID-19 resulted in remote learning from March to the end of the school-year. Guidance for virtual meetings and memos for the record were provided so that any plans due during this shut-down period would continue to be followed until a new meeting could be held.

  • Added a shared Google drive 504 folder for DVS or Remote Learning This folder includes support staff, flow-charts for processes, Standard Operating Procedure changes, suggested accommodations for this setting, etc.

    • Using the examples created by the region for special education MRFs and PWNs, examples were created and shared for Section 504 Meetings when they could not be held (24 APR 2020):

      • 504 Eligible with Accommodation Plan Pending

      • 504 Eligible with Accommodation Plan Pending- Parents decline accommodations

      • Completed 504 Assessment, but eligibility meeting has not yet occurred

      • Postponed 504 Annual Review Meeting

    • Section 504 Training for holding meetings during remote learning (27 APR 2020)

  • Step-by-step instructions for Managing Field Sets in Aspen to see Standar Name (used often for virtual school documents), contact information and much more (28 APR 2020)

  • Guidance for sending encrypted e-mails (29 APR 2020)

  • Shared this information about Military and Family Life Counselors no longer providing in person support. (APR 2020)

  • COVID-19 Stress Management and Resiliency Workbook- Easy to follow Workbook for Exercises and Activities to Manage Stress and Resiliency During Uncertain Times, Created by LT Megan Camacho-Balkenbush Occupational Therapist, MS, OTR/L Educational and Developmental Intervention Services (EDIS) Division Officer NAF Atsugi, Japan MSC, USN (uploaded 5 MAY 2020)

  • Pacific East Special Education Informational Sessions - Town Hall with Ms. Kiyuna (3 JUN 2020)

  • Shared this “USFJ COVID-19 Restriction of Movement, Quarantine, and Isolation (RQI) Planning” (1 JUL 2020)- Cannot share the link, because the document is “For Official Use Only”

• Shared a List of Common Sources of Evaluation Data for Section 504 Eligibility because too many 504 Coordinators were confused about how they could show three sources of data (18 JUN 2020)

• Step-by-step guidance for adding digital signatures to 504 plans and minutes printed as PDFs. (June 2020)

• Section 504 of the Rehabilitation Act and DoDEA training slides for Pacific East District (26 JUN 2020)