Section 504: Knowledgeable Committees and 504 Plans

Information on the knowledgeable committee and 504 Plan development, review, and revision.

Knowledgeable Committee Membership

If the student qualifies as a student with a disability under Section 504, a committee of knowledgeable people shall develop a 504 Plan within 30 calendar days following the initial qualification. Typically, the knowledgeable committee is made up of staff members who work directly with, or supervise, the student in the educational setting. The 504 Plan is a statement of the required accommodations, modifications, and/or services that FCPS will provide to a student.

The knowledgeable committee must include the following people:

  • Principal or designee
  • Teacher(s) who are, or will be, working with the student

(Whenever possible, the committee should include those persons who will be responsible for implementing the proposed accommodations, modifications, and/or services.)
Other committee members such as the school psychologist, public health nurse, school social worker, school counselor, and/or related service provider may be included as appropriate to the needs of the student.

Parents and/or guardians must be invited to the Section 504 meeting.  In addition, schools should, whenever possible, work with the student to solicit his or her feedback regarding 504 Plan supports, and invite the student to participate in the meeting as appropriate.

504 Plan Development

Use the Notice of Section 504 Meeting (SS/SE-281) to invite the parent(s) and/or guardian to the meeting.  A copy of the Section 504 of the Rehabilitation Act of 1973 Procedural Safeguards (“504 Procedural Safeguards”) (SS/SE-92) must be sent with the notice, along with a copy of the 504 Plan Meeting Agenda (SS/SE-339).  The meeting notice, procedural safeguards, and agenda should be sent to the parents no less than 3 days in advance of the meeting, to allow the parents adequate time to review and prepare for the meeting.

During the 504 Plan meeting, the knowledgeable committee reviews the specific needs of the student in the educational setting and completes a 504 Plan form (SS/SE-86), using the 504 Plan Meeting Agenda to help ensure that the committee is addressing all of the student’s pertinent disability-related needs.  The 504 Plan includes accommodations, modifications, and/or services, including medication administration, necessary to provide the student an equal opportunity to access programs and activities and to demonstrate achievement.  The accommodations, modifications, and/or services shall do the following:

  • Reflect the unique needs of the student.
  • Relate directly to the area of impairment.
  • Address only what is necessary to ensure that the student has the opportunity to access programs and activities provided by the school system.
  • Be specific enough in description to clearly indicate when and where the accommodations, modifications, and/or services will be provided during the school day and during school- related and/or sponsored activities.

The focus is on what is necessary for the student as a result of the limitation of his or her impairment on one or more major life activity.

The knowledgeable committee shall determine whether the student who qualifies as a student  with a disability under Section 504 requires classroom testing accommodations and whether those accommodations or modifications should be provided for any state and/or district-wide assessments. These decisions shall be recorded on the appropriate 504 Plan Accommodations
form (SS/SE-86A, 86B, or 86D). 

If the knowledgeable committee considers the read aloud (for the English:  Reading Standards of Learning [SOL] assessment) or calculator accommodations, the committee must use the Read Aloud or Audio Accommodation Criteria Form (SS/SE-274) and/or the 504 Plan Calculator Criteria Form (SS/SE-272) to determine whether the student meets the criteria to utilize the specific accommodation on the SOL tests.

In addition, discussions by a knowledgeable committee regarding the option to pursue credit accommodations can begin at any point after the student’s 8th grade year.  Committees shall use the Credit Accommodation Eligibility Form (SS/SE-353) to document their decision-making.

Federal law requires an annual English Language Proficiency (ELP) assessment to be administered to all students identified as English Learners (ELs) in grades K-12 ELP levels 1-5 and 9. ELs whose parent(s) and/or guardians have refused English for Speakers of Other Languages (ESOL) services are still required by federal law to participate in the annual assessment. The WIDA ACCESS for ELLs (English-language learners) and certain alternate tests are approved by the Virginia Department of Education (VDOE) to meet this requirement.  For those ELs who also have a documented disability, IEP/504 Plan committees must work collaboratively with ESOL staff, utilizing the WIDA ACCESS for ELLs Accommodations Selections form (RF 7).

If the knowledgeable committee determines that there is currently no specific impairment-related limitation that requires accommodations, modifications, and/or services, this should be noted on the 504 Plan.  This decision shall be reviewed by the knowledgeable committee on an annual basis (or more frequently, as needed), and the determination shall be noted on a current 504 Plan document (SS/SE-86). (Please note that in SEA-STARS, the 504 process documents for 504 Plans are obtained by selecting the “504 Plan” process in the dropdown menu.)

A copy of the 504 Plan shall be provided to the parent and/or guardian following its completion.  Parental consent is not required prior to the implementation of a 504 Plan for a student. The principal is responsible for adherence to the overall procedures and implementation of a 504 Plan.  Each individual working with or supervising the student shall be provided access to the 504 Plan and will comply with the applicable components.  The 504 Plan remains in effect as specified until either a new 504 Plan is developed, at least annually, or the knowledgeable committee determines through reevaluation that the student no longer qualifies as a student with a disability under Section 504.

Plan Review and Revision

The principal or designee (generally, this is the 504 school-based coordinator [SBC]), is responsible for ensuring that 504 Plans are reviewed at least annually or more frequently as conditions warrant.  504 case managers are responsible for planning and facilitating these meetings.  The purpose of this review is to determine the appropriateness of the Plan and to make any needed modifications.  The participants in 504 Plan meetings should be those individuals relevant to the discussion of the student’s accommodations, modifications, and/or services.  At minimum, the committee must consist of at least one of the student’s teachers and a principal or designee.  Use the Notice of Section 504 Meeting (SS/SE-281) to invite the parent and/or guardian to the meeting.  A separate SS/SE-281 may be used to invite the student, as well.  A copy of the Section 504 of the Rehabilitation Act of 1973 Procedural Safeguards (“504 Procedural Safeguards”) must be sent with the notice, along with a copy of the 504 Plan Meeting Agenda (SS/SE-339).   

Discipline Procedures

The knowledgeable committee shall convene for a Section 504 Causality Hearing to assess whether the behavior requiring disciplinary action was caused by or directly related to a qualified student’s disability when the following is true:

  • A decision is made to remove a Section 504-qualified student from school for more than ten consecutive school days in a school year.
  • The Section 504-qualified student is subjected to a series of removals during a school year that will accumulate to more than ten school days.

Parent(s) and/or guardians should be notified with sufficient time to allow them the opportunity to attend, participate, and provide input at the Section 504 causality hearing.  The school shall use the Parent Notice of Section 504 Causality Hearing (SS/SE-220A) to notify the parent(s) and/or guardian of the meeting.  A copy of the 504 Procedural Safeguards (SS/SE-92) shall be included with the meeting notification letter.  The knowledgeable committee shall complete a Section 504 Causality Hearing form (SS/SE-220) and forward it to the Superintendent’s hearing officer when there is a recommendation for expulsion or exclusion.  The following scenarios apply:

  • If a student is qualified under Section 504, and the committee determines that the student’s conduct was caused by or had a direct and substantial relationship to the child’s disability, and/or the student’s conduct was a direct result of the school division’s failure to implement the 504 Plan, then the determination is that the conduct is a manifestation of the student’s disability.  The student may not be disciplined in the same manner as a nondisabled student.  The committee shall determine whether the student’s educational program should be modified.
  • If a student is qualified under Section 504, and it is determined that the student’s conduct is not a manifestation of the student’s disability, the student may be disciplined in the same manner as a nondisabled student, including the cessation of services.
  • If a student qualified under Section 504 is receiving disciplinary action based on the illegal use and/or possession of illegal drugs or alcohol, and the individual is currently engaging in the illegal use of drugs or alcohol, a committee of knowledgeable persons is not required to convene, reevaluate the student, or determine whether there is a direct and substantial relationship between the behavior and the disability.


When a student transfers into an FCPS school and/or program with a 504 eligibility and/or Plan, the 504 school based coordinator (SBC) must complete a 504 transfer process for the student, as soon as practicable, but no later than five school days following enrollment and/or first day of attendance.  (In SEA-STARS, the 504 Transfer document is obtained from the 504 Process menu.)  The receiving school is required to implement the existing 504 Plan, as documented within the 504 transfer document, until the knowledgeable committee convenes to review the student’s needs and develops an FCPS 504 Plan within 30 calendar days of the student’s enrollment.