Section 504: Identification, Evaluation, and Reevaluation Procedures

FCPS has a responsibility to identify and evaluate those students who are believed to qualify as disabled under Section 504.

FCPS has a responsibility to identify and evaluate those students who are believed to qualify as disabled under Section 504.  FCPS also has a responsibility to provide notice to a student’s parent(s) or guardian prior to evaluation, identification, reevaluation, and/or placement.


When there is reason to suspect that a general education student has a disability and is in need of accommodations, modifications, and/or services in order to access the programs and activities offered by FCPS, a referral shall be made to the local screening committee (LSC) for review.

Referrals can be made either orally or in writing; both types of referrals are documented on a Multipurpose Referral form (SS/SE-5). If parents make an oral referral, they should be asked if they want to complete the Multipurpose Referral form or the principal or designee shall complete it on their behalf.

If parents make a referral to a teacher, they should be directed to the principal or designee selected to receive referrals. Whether provided orally or in writing, the date the referral is received must be noted on the Multipurpose Referral form.  Page two of the the Multipurpose Referral form (SS/SE-5A) must be completed by the student’s classroom teacher, or other appropriate school staff member if the student has more than one teacher.

Local Screening Committee (LSC)

The LSC must convene within ten business days following the receipt of a referral. The date the referral was received and the date on which the LSC convened are recorded on the Student Audit Trail (SS/SE-8).

For all referrals, the LSC must consist of the following members, at a minimum:

  • Principal or designee
  • School psychologist
  • Special education teacher
  • General education teacher
  • Referral source, except if inclusion of the referral source would breach the confidentiality of the student

The parents must be invited to the LSC meeting orally and in writing by way of a Notice of Local Screening Meeting (SS/SE-83).  This notice letter should be accompanied by the following documents:  Virginia Special Education Procedural Safeguards Requirements (SS/SE-4), Section 504 of the Rehabilitation Act of 1973 Procedural Safeguards (SS/SE-92), and the Parent Information form (SS/SE-127).  Schools are advised to contact the parents by telephone or in person to explain the local screening process prior to the provision of these documents.  The parents must be notified of the meeting early enough to ensure they have an opportunity to participate; however, the meeting must be held within ten business days of the referral date.  If parents cannot attend the meeting, school staff members should consider alternative ways for the parents to participate (e.g., conference call).

During the LSC meeting, the committee shall review information from a variety of sources. The information reviewed should pertain to the student’s functioning in the school environment and should include, as available, the referral; educational records such as aptitude and achievement tests, report cards, and/or teacher recommendations; oral or written observations; evaluations of adaptive behavior; social and cultural background; medical, psychological, and/or other specialty reports; and parent information.  Following this review, the LSC may do the following:

  • Determine that an evaluation for special education services under the Individuals with Disabilities Education Act (IDEA) is not warranted at this time.
  • Refer the student to another resource such as child study team (CST), teacher assistance team (TAT), multi-tiered systems of support (MTSS) team, professional learning community-response team (PLC-RT), etc.
  • Determine that there is a need for an evaluation for special education services under IDEA.
  • Determine that there is a need for an evaluation for qualification under Section 504.
  • Determine whether the student qualifies as disabled under Section 504.

Making Initial Qualification Decisions

If, upon review of the Multipurpose Referral form and available information, the LSC determines that there is insufficient evidence to suspect that a disability warrants an evaluation for special education under IDEA, but suspects a disability under Section 504, the LSC will complete a Notice Not to Evaluate (SS/SE-13) to indicate the decision not to evaluate for special education eligibility.  The Local Screening Committee Report (SS/SE-14) will reflect “Do not conduct evaluation” and “Pursue the following action” with a notation that the LSC will pursue a Section 504 evaluation.

In some cases, the LSC may determine that while a special education evaluation is warranted, there may be sufficient existing information to consider whether the student would qualify with a disability under Section 504.  In these cases, the Local Screening Committee Report will reflect that the committee chose to “Conduct Evaluation” [for special education], and the committee will determine recommended assessments for special education.  The LSC will then indicate on the Local Screening Committee Report that it will move forward to consider initial Section 504 qualification.

If the LSC chooses to reconvene at a later date to hold the 504 initial qualification determination meeting, a Notice of Section 504 Meeting (SS/SE-281) will be completed and sent to the parent and/or guardian (and student, if appropriate) along with a copy of the Section 504 of the Rehabilitation Act of 1973 Procedural Safeguards (SS/SE-92).

The LSC shall complete a Section 504 Qualification form (SS/SE-85) for students suspected of having a disability under Section 504.  The Section 504 Qualification form has two pages:  page one includes data review and evaluation, and page two includes the qualification criteria (504 eligibility).

Page one of the Section 504 Qualification form must document the following:

  • Demographic information
  • Names and titles of knowledgeable committee members
  • Presenting problem
  • Data review (sources of evaluation and current information considered)
  • Evaluation (considering the need for additional data in order to determine 504 qualification)
  • If additional data is needed, the knowledgeable committee will recommend required assessments. 
  • Parental consent (required for all initial 504 evaluations as well as any formal assessments)

    In order to move forward to consideration of an initial 504 qualification, written parent consent must be provided for the evaluation (whether or not formal assessments are required).  If the parent refuses to give consent to a 504 evaluation, the committee will not move forward to page two of the form and will not make a decision regarding Section 504 qualification.

    If formal assessments are recommended and parental consent is provided, the meeting will adjourn and members will reconvene within 65 business days of the referral to allow time for the completion of assessments.  Please note that all assessments must be completed within 65 business days of the LSC referral date.

    In the event that there is sufficient data to utilize for an evaluation, and the parent has given consent for an initial 504 evaluation, the knowledgeable committee may immediately move forward to 504 qualification consideration.

Page two of the Section 504 Qualification form must document the following:

  • Identification of the physical and/or mental impairment(s)
    • “Physical or mental impairment” means any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems:  neurological; musculoskeletal; special sense organs; cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and endocrine, or any mental or psychological disorder such as intellectual disability, organic brain syndrome, emotional or mental illness, and specific learning disability
  • The major life activity (or activities) limited by the impairment(s)
    • “Major life activity” includes, but is not limited to, caring for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, working, eating, sleeping, standing, lifting, bending, reading, concentrating, thinking, and communicating.
    • A major life activity also includes the operation of a major bodily function, including, but not limited to, functions of the immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions.
    • An impairment that substantially limits one major life activity need not limit other major life activities in order to be considered a disability.
  • Description of the limitation of the student’s impairment on the identified major life activity (or activities)
    • An impairment that is episodic or in remission is a disability if it substantially limits a major life activity when active.
    • Individuals being considered for qualification under Section 504 should not be disqualified solely because they manage their own adaptive strategies or receive accommodations (including informal or undocumented ones) that have reduced or eliminated the effects of a physical or mental impairment.
    • The determination of limitation to one or more major life activity must be made without regard for any ameliorative effects of mitigating measures that include, but are not limited to, a student health care plan (HCP), medication, medical supplies, equipment, low-vision devices1 , prosthetics, hearing aids and cochlear implants or other implantable hearing devices, mobility devices, oxygen therapy equipment and supplies, assistive technology, accommodations, auxiliary aids or services; or learned behavioral or adaptive neurological modifications.
  • The LSC’s determination of Section 504 qualification
  • A list of the LSC members participating in the determination
    The parent(s) and/or guardian (and student, if appropriate) should also be included in this list if they are present at the meeting.  All participants should provide their signature next to their printed name and role or title.  It should be explained that parent consent for qualification is not required and the signatures only indicate participation. In the event that the meeting was held virtually (online), participation signatures will not be required.

    [Please also note that the Office for Civil Rights (OCR) has stated that school divisions are not required to obtain extensive documentation to identify that students with the following impairments are qualified under Section 504 and the ADA:  diabetes, epilepsy, bipolar disorder, and autism (Dear Colleague Letter, 58 IDELR 79 (OCR 2012).]

A copy of the Section 504 Qualification form (SS/SE-85), along with the Local Screening Committee Report (SS/SE-14) and the Section 504 of the Rehabilitation Act of 1973 Procedural Safeguards (SS/SE-92), shall be provided to the parent.  (Please also note that in the online platform [“SEA-STARS”], the 504 process documents for a first-time 504 qualification are obtained by selecting the “504 Initial Qualification” process in the dropdown menu.)

1 Note – Low-vision devices do not include ordinary eyeglasses or contact lenses. The ameliorative effects of ordinary eyeglasses or contact lenses may be considered in determining whether the impairment substantially limits a major life activity. Ordinary eyeglasses are those that are intended to fully correct visual acuity or eliminate refractive error, and low-vision devices are those that magnify, enhance, or otherwise augment a visual image.


The knowledgeable committee shall conduct a reevaluation of each student’s qualification as a student with a disability under Section 504:

  • Every three years
  • More frequently, as necessary

The date of the student’s initial or most-recent reevaluation of Section 504 qualification is documented on the 504 Plan.  The reevaluation date is then calculated by adding three years to the initial or most-recent reevaluation review date.  Prior to the reevaluation review date, information should be collected from teachers and other school staff members who work with the student for review at the reevaluation meeting.  The Teacher Narrative form (SS/SE-22) should be used to assist in data collection, along with a review of additional, relevant information

The knowledgeable committee shall convene a reevaluation meeting with the purpose of reviewing evaluation information and determining if the student continues to qualify as a student with a disability under Section 504.  The Section 504 Qualification form (SS/SE-85) is used to guide the committee’s review and determination.  (Note:  In the SEA-STARS system, documentation specific to the reevaluation process is utilized.  The 504 reevaluation documents may be accessed via the 504 tab, “Make Decision” button.)  If existing data is sufficient to use for purposes of considering continued Section 504 eligibility, no parental consent is required for the reevaluation.  However, if additional individual assessments are needed in order to determine if the student continues to qualify, written parent consent for formal assessments is required.  Upon completion of assessments, the knowledgeable committee will reconvene and consider continued qualification under Section 504 (no more than 65 days following the referral).