IEPs and 504 Plans

How are they similar? Different? And when should each be considered?

May 21, 2025

As we near the end of the school year, many parents, educators, healthcare providers, and advocates are talking about services and supports for next year. For some families, this may include deciding whether a child’s services and supports should be outlined in a legal document called an Individualized Education Program (IEP) or in a 504 Plan.

What are IEPs and 504 Plans?

Individualized Education Programs (IEPs) and 504 Plans are essentially different ways to explain the services and supports that a child with a disability will receive in school. That said, these two approaches fall under different laws—providing different legal rights and requiring schools to follow different rules.

IEPs and 504 Plans are two different ways to explain the services and supports that a child with a disability will receive in school. These approaches fall under different laws—providing different legal rights and requiring schools to follow different rules.

Some students will qualify for both an IEP or 504 Plan, while others will only qualify for one. In general, if a student qualifies for an IEP, they also likely qualify for a 504 Plan. That said, if a student qualifies for a 504 Plan, they do not necessarily qualify for an IEP.

How are IEPs and 504 Plans Similar? And Different?

Although IEPs and 504 Plans have some similarities, they also have a lot of differences that can impact a child’s educational experience and legal rights. Below are a few key differences that can be helpful to keep in mind when considering whether a child should receive an IEP or 504 Plan:

The Law

First, it is important to note that the rules relating to IEPs and the rules relating to 504 Plans fall under different laws. As a result, whether a child has an IEP or a 504 Plan can impact many things, including who develops the child’s educational plan, and the child’s (and parent’s) legal rights.

IEPs: The right to an IEP falls under the Individuals with Disabilities Education Act (I.D.E.A.) The I.D.E.A. is an education law that gives children with disabilities the right to a "free appropriate public education" and provides powerful steps and procedures to make sure the child receives the supports that they need.
Both IEPs & 504 Plans: Both IEPs and 504 Plans fall under (different) federal laws that apply to every state.
504 Plans: The right to a 504 Plan falls under the Rehabilitation Act. The Rehabilitation Act is a civil rights law that makes it illegal for any program that receives federal funds (such as a public school) to discriminate against someone because of their disability. This law applies to public schools but also applies to other areas of life such as employers.

Format

A major difference between IEPs and 504 Plans is how they describe a child’s needs, supports, and services. While IEPs are detailed plans that must be put in writing and include specific information, 504 Plans do not have to be written down or include the same detailed information.

IEPs: The I.D.E.A. requires that a child’s IEP include specific information about the child’s current performance, learning needs, goals, and services. Importantly, the I.D.E.A requires that the IEP is formalized in writing.
Both IEPs & 504 Plans: None.
504 Plans: The Rehabilitation Act allows a 504 Plan to be verbal or written. That said, many schools use forms to outline a child’s 504 Plan. 504 Plans are not legally required to include the same detailed information as an IEP.

Tip: If a school does not provide a written version of a 504 Plan, the child’s parent or guardian can send an email to the school that summarizes the services and supports that make up the child’s 504 Plan. Putting this plan in some form of writing helps to create a paper trail in case there is a disagreement in the future, and also helps to make sure that everyone is on the same page before the plan is put into action.

Referral and Identification

Both the I.D.E.A. and the Rehabilitation Act require that schools proactively identify, locate, and evaluate children with disabilities who may qualify for specialized supports or services, no matter if the child ultimately receives an IEP or a 504 Plan.

IEPs: The school is only required to identify, locate, and evaluate a child suspected of having a disability who is between 3 and 22 years old. This obligation ends when the child completes high school.
Both IEPs & 504 Plans: Schools must identify, locate, and evaluate children who may have a disability that requires additional supports and services in school. No matter if a child ultimately receives an IEP or 504 Plan, the parent/guardian can raise concerns about their child’s educational needs and ask the school to complete an evaluation.
504 Plans: Any program that receives federal funds (such as a school) must identify a student who may need a 504 Plan up until high school. Unlike the I.D.E.A., the Rehabilitation Act requires colleges and postsecondary programs to meet certain referral and identification requirements as well.

Eligibility

An important, and sometimes confusing, difference between IEPs and 504 Plans is eligibility. Some children with disabilities will qualify for both, while others will not. This is because the I.D.E.A. and the Rehabilitation Act have different requirements when it comes to who qualifies for services.

IEPs: Under the I.D.E.A., a child with a disability qualifies for special education services/supports through an IEP if they are a child age 3 through 21 who:
1. Has one or more disability classifications under the I.D.E.A., and
2. Because of their disability requires special education services.

Note: The thirteen disability classifications are (1) Autism, (2) Deaf-blindness, (3) Deafness, (4) Emotional Disturbance, (5) Hearing Impairment, (6) Intellectual Disability, (7) Multiple Disabilities, (8) Orthopedic Impairment, (9) Other Health Impairment (includes ADHD/ADD), (10) Specific Learning Disability, (11) Speech or Language Impairment, (12) Traumatic Brain Injury, and (13) Visual Impairment Including Blindness.

Both IEP & 504 Plans: Have requirements about who qualifies for services/supports.
504 Plans: Under the Rehabilitation Act, a student (in preschool, elementary school, high school, or college) qualifies for services/supports through a 504 Plan if they:
1. Have a physical and/or mental disability,
2. Their disability “substantially limits” one or more “major life activities,” and
3. Either has a record of the disability or is regarded as having the disability.

Note: Major life activity includes “caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working.”

Again, some students will qualify for an IEP as well as a 504 Plan. In general, however, fewer students will qualify for an IEP because the qualification criteria is more narrow. If a child qualifies for both, the parent may have to decide whether one meets their child’s needs more than the other.

Initial Evaluations

Before a child can have either an IEP or a 504 Plan, the school must thoroughly evaluate the child’s unique learning needs. Under the I.D.E.A., an initial evaluation must be completed within 60 days of parental consent (or within the state’s specific timeframe if different). The Rehabilitation Act does not require a specific timeline for evaluation.

IEPs: The I.D.E.A. outlines specific timelines for starting and completing an initial evaluation. Specifically, a public school district must evaluate a child within 60 days of when the parent gives consent to evaluate (or if the state provides a different timeframe, within the state’s timeframe).
Both IEPs & 504 Plans: No matter if a child ultimately receives an IEP or a 504 Plan, the school must thoroughly evaluate the child’s learning needs before developing that IEP or 504 Plan.
504 Plans: Unlike the I.D.E.A., under the Rehabilitation Act there is no specific requirement that an evaluation is completed within certain timeframe.

Reevaluations

No matter if the child has an IEP or a 504 Plan, the child must be reevaluated throughout their time in school. A child with an IEP must be reevaluated every three years (or earlier if requested by the parent or school district). A child with a 504 Plan only needs to be reevaluated “periodically” or when there is a major change in the child’s educational placement.

IEPs: A child with an IEP must be reevaluated every three years (this is called a triennial evaluation). That said, the parent or school district can request an evaluation sooner than three years.
Both IEPs & 504 Plans: Require reevaluations (though on different timelines).
504 Plans: A child with a 504 Plan must be reevaluated “periodically.”

Transition Planning

Transition planning is a critical part of supporting a child’s growth and development. While the I.D.E.A. speaks directly to transition planning relating to a child’s goals after high school, the Rehabilitation Act does not. This is partly because the Rehabilitation Act applies to postsecondary institutions (such as college) and protects students with disabilities from discrimination on the basis of their disability.

IEPs: The I.D.E.A. requires IEPs to include transition planning by the time a child turns 16 years old. Transition planning is an important part of the child’s IEP and must include goals and services relating to the child’s transition out of high school. These services will end once the child has graduated from high school.
Both IEPs & 504 Plans: None.
504 Plans: The Rehabilitation Act does not require 504 Plans to include transition planning, in part because the Rehabilitation Act applies to students after high school and gives students with disabilities in postsecondary programs the right to reasonable accommodations.

Cost of Services & Supports

A significant difference between IEPs and 504 Plans is the role of the cost of services and supports. Under the I.D.E.A., a school district must provide a child with the services necessary for that child to receive a FAPE—no matter the cost. Under the Rehabilitation Act, public schools must make sure that students with disabilities are not treated differently because of their disabilities unless the school can show that an accommodation would fundamentally alter the nature of the program or cause an undue financial burden.

IEPs: In general, a public school district must provide the child with any services/supports necessary to make sure the child receives a “free appropriate public education” no matter the cost.
Both IEPs & 504 Plans: None.
504 Plans: Schools must make sure that children with disabilities are not treated differently because of their disabilities and provide “reasonable accommodations” unless the school shows that the reasonable accommodation “fundamentally alters the nature of the program” or results in an “undue financial burden.” If the school can show that the accommodation either fundamentally alters the nature of the program or results in an undue financial burden then they may not need to provide the service/support.

Resolving Disagreements

Both the I.D.E.A. and the Rehabilitation provide ways for a parent or guardian to challenge their child’s school if they disagree with a certain decision, action, or inaction. The exact process will vary quite a bit from state to state.

IEPs: Because IEPs fall under the I.D.E.A., any challenge relating to the IEP usually follows specific steps and procedures used to resolve disagreements. The I.D.E.A. gives parents/guardians a variety of tools to challenge a school district’s decision, action, or inaction. These options include mediation, submitting a complaint to the state, or submitting a due process complaint which essentially asks that a judge-like person called a “hearing officer” make a formal decision about how to resolve the matter.
Both IEPs & 504 Plans: Provide some procedures for challenging school/district action or inaction relating to child with a disability’s educational needs.
504 Plans: Because 504 Plans fall under the Rehabilitation Act, challenges relating to the 504 Plan will likely follow the Rehabilitation Act’s procedures for resolving disagreements. These procedures are more vague that those outlined in the I.D.E.A. In some states, parents/guardians can raise an issue relating to a child’s 504 Plan using the same procedures as those used for IEPs, but this is not the case everywhere.

This is important to keep in mind if the parent is concerned about the possibility of challenging the school down the road.

Key Takeaways

There is so much to consider when deciding whether a child should receive an IEP or a 504 Plan. In general, the rules and obligations relating to IEPs are much more detailed and specific.

Note: Some teachers report that IEPs can be easier to follow and put in place (than 504 Plans) because they must be written and include a lot of specific information relating to a child’s functioning, required services, supports, goals, and teaching methods.

On the other hand, some students do not qualify for an IEP but do qualify for a 504 Plan. For parents considering both, it can be helpful to think about their goals for their child’s education and weigh the pros and cons of an IEP compared to a 504 Plan in terms reaching those goals.

Below are a few key takeaways to keep in mind when considering each:

IEPs and 504 Plans have some similarities, but they also have a lot of differences that can impact a child’s educational experience and legal rights.
Law: IEPs and 504 Plans fall under different laws which impacts many things, including the child’s (and parent’s) legal rights. The right to an IEP falls under the Individuals with Disabilities Education Act (I.D.E.A.), while the right to a 504 Plan falls under the Rehabilitation Act.
Format: IEPs are detailed plans that must be put in writing and include specific information, while 504 Plans do not have to be written down or include the same detailed information.
Referral: Both the I.D.E.A. and the Rehabilitation Act require that schools proactively identify, locate, and evaluate children with disabilities who may qualify for supports or services, no matter if the child ultimately receives an IEP or a 504 Plan.
Eligibility: The I.D.E.A. and the Rehabilitation Act have different requirements when it comes to who qualifies for services. Some students will meet the requirements for both IEPs and 504 Plans, and some students will only qualify for one or the other.
Initial Evaluations: The school must thoroughly evaluate the child’s unique learning needs no matter if the child receives an IEP or a 504 Plan. That said, the evaluation timing differs between IEPs and 504 Plans.
Reevaluations: No matter if the child has an IEP or a 504 Plan, the child must be reevaluated throughout their time in school. A child with an IEP must be reevaluated every three years (or earlier if requested by the parent or school district). A child with a 504 Plan must be reevaluated “periodically.”
Transition Planning: While the I.D.E.A. speaks directly to transition planning relating to a child’s goals after high school, the Rehabilitation Act does not. The I.D.E.A. requires IEPs to include transition planning by the time a child turns 16 years old.
Cost of Services & Supports: Under the I.D.E.A., a school district must provide a child with the services necessary for that child to receive a free appropriate public education—no matter the cost. Under the Rehabilitation Act, public schools must make sure that students with disabilities are not treated differently because of their disabilities unless the school can show that an accommodation would fundamentally alter the nature of the program or cause an undue financial burden.
Resolving Disagreements: Both the I.D.E.A. and the Rehabilitation provide ways for a parent or guardian to challenge their child’s school if they disagree with a certain decision, action, or inaction. In some states allow parents to raise concerns about a 504 Plan using the I.D.E.A.’s procedures, but others do not.

As always, thank you all so much for everything you do on behalf of children with disabilities every day. I hope everyone has a wonderful week and I look forward to connecting soon.

All the very best,

Ashley