Section 504 plans for OT, PT, and SLP in schools

Section 504 of the Rehabilitation Act of 1973 is a civil rights law enforced in schools by the U.S. Department of Education’s Office for Civil Rights (OCR). Its regulations require a public elementary or secondary school program that receives federal funds to provide a free appropriate public education to each qualified student with a disability, through regular or special education and related aids and services. A Section 504 plan is not the same as an IDEA IEP. OCR’s parent and educator guide lists speech or occupational therapy among examples of related aids and services. That example list does not name physical therapy.

Quoted from official pages checked November 10, 2026. Confirm current requirements, fees, and dates on those sites. This page is not legal advice and does not guarantee eligibility, certification, or licensure.

The U.S. Department of Education’s current Section 504 and FAPE FAQ (page last reviewed June 30, 2025) and its Section 504 page were read on November 10, 2026. The older www2.ed.gov address for the OCR FAQ returned a not-found page that day. The regulation was read on eCFR (34 CFR 104.33 and 34 CFR 104.35, up to date as of November 6, 2026). The regulation’s text still uses the older word “handicapped”, which appears below only inside quotations.

What Section 504 is

The FAQ states: “OCR, a component of the U.S. Department of Education, enforces Section 504 of the Rehabilitation Act of 1973, as amended, (Section 504) a civil rights statute which prohibits discrimination against individuals with disabilities.” ASHA’s IEPs, IFSPs, and Section 504 Plans page states that Section 504 “is a federal law designed to protect the rights of individuals with disabilities in programs and activities that receive federal financial assistance from the U.S. Department of Education (ED).”

A free appropriate public education

34 CFR 104.33 states that a recipient that operates a public elementary or secondary education program or activity “shall provide a free appropriate public education to each qualified handicapped person who is in the recipient's jurisdiction, regardless of the nature or severity of the person's handicap.” It defines an appropriate education as “the provision of regular or special education and related aids and services that” meet individual educational needs as adequately as the needs of nondisabled students are met and follow the regulation’s procedures.

The FAQ puts it this way: “Section 504 requires that school districts provide a free appropriate public education (FAPE) to qualified students in their jurisdictions who have a physical or mental impairment that substantially limits one or more major life activities.” It states that this determination “must be made on the basis of an individual inquiry.”

Evaluation and placement

34 CFR 104.35 requires an evaluation “of any person who, because of handicap, needs or is believed to need special education or related services before taking any action with respect to the initial placement of the person in regular or special education and any subsequent significant change in placement.” The placement decision must be made “by a group of persons, including persons knowledgeable about the child, the meaning of the evaluation data, and the placement options”.

The FAQ states: “OCR has interpreted Section 504 to require districts to obtain parental permission for initial evaluations.” On re-evaluation: “The Section 504 regulations require that re-evaluations be conducted periodically.” And, of direct interest to therapists: “OCR would also consider transferring a student from one type of program to another or terminating or significantly reducing a related service a significant change in placement.”

Section 504 plan vs IEP

The FAQ asks whether a student eligible under both laws needs both plans. It answers: “No. If a student is eligible under IDEA, he or she must have an IEP. Under the Section 504 regulations, one way to meet Section 504 requirements for a free appropriate public education is to implement an IEP.” The regulation says the same in its own words: “Implementation of an Individualized Education Program developed in accordance with the Education of the Handicapped Act is one means of meeting the standard”. A student with a disability who does not need special education may still qualify: the FAQ says “The student may be eligible for services under Section 504.”

ASHA’s page states: “A 504 plan is not special education.” It continues: “It is designed to outline accommodations that a student needs to access the educational curriculum.” It also states: “While there is no specific template for a 504 plan, it should include” “specific accommodations, supports, and services for the student”, “name(s) of service providers”, and “name of the person responsible for ensuring the 504 plan is followed”. The IDEA rules for IEPs and IFSPs are on IEPs and IFSPs.

Where OT, PT, and SLP fit

OCR’s Parent and Educator Resource Guide to Section 504 in Public Elementary and Secondary Schools (December 2016, linked from ASHA’s page) states: “Students who are identified as having a disability and needing special education and/or related aids and services are entitled to special education and a broad range of supplemental and related aids and services, as needed, such as tutors, note-takers, or one-on-one aides; assistive technology, psychological and counseling services; or speech or occupational therapy.”

The FAQ’s glossary defines related services as “A term used in the elementary and secondary school context to refer to developmental, corrective, and other supportive services, including psychological, counseling and medical diagnostic services and transportation.” Neither passage names physical therapy. This page does not say whether a school must provide any particular therapy under a 504 plan. Under IDEA, physical therapy is named among related services; see working in schools.

Rules may change

ASHA’s page states: “The U.S. Department of Education recently announced its intent to strengthen and protect rights for students with disabilities by amending regulations implementing Section 504.” The regulation quoted above is the eCFR text in force that day.

What this page does not do

It gives no caseload numbers, minutes, eligibility criteria, or state rules. The FAQ notes that “OCR generally will not evaluate the content of a Section 504 plan or of an individualized education program (IEP)”. Disagreements go through the district’s procedures. It is not legal, billing, or compliance advice. Confirm current rules with the agency that publishes them, your employer, and your state board.