1. Purpose & Eligibility
IEP: For students whose disability impacts their ability to make progress in school and who need specialized instruction. Governed by the Individuals with Disabilities Education Act (IDEA).
504 Plan: For students with a disability that substantially limits a major life activity, such as learning, walking, or concentrating. Governed by Section 504 of the Rehabilitation Act. Focuses on access and accommodations, not instruction.
2. Services Provided
IEP: Provides special education and related services such as speech therapy, occupational therapy, counseling, or specialized reading instruction.
504 Plan: Provides classroom accommodations, such as extended time on tests, preferential seating, behavior supports, or modified assignments.
3. Team & Development
IEP: Must be created by a team that includes parents, at least one general education teacher, one special education teacher, and a school administrator.
504 Plan: Does not require specific team roles. However, placement decisions must be made by a group knowledgeable about the student, the evaluation data, and available placement options. In Massachusetts, a guidance counselor often helps coordinate the 504 process and participates on the team.
4. Parental Rights & Safeguards
IEP: Parents have more detailed procedural protections, including prior written notice and “stay-put” protections that generally preserve the student’s placement during covered disputes, subject to exceptions. In Massachusetts, parents can pursue BSEA mediation and due process hearings, or file complaints with DESE’s Problem Resolution System (PRS).
504 Plan: Procedural protections are less detailed than IDEA’s. Federal regulations do not expressly require a written plan, but schools must provide notice, records access, and impartial-hearing rights. In Massachusetts, parents may pursue BSEA mediation or hearings on Section 504 FAPE disputes, PRS complaints, and OCR discrimination complaints. Monetary damages may be granted in a court action.
5. Accountability
IEP: Schools must track progress toward IEP goals and share updates with parents at least as often as general education students receive report cards.
504 Plan: No progress monitoring requirements beyond what all students receive.
6. Discipline Protections
IEP: Students receive detailed discipline protections under the IDEA, including manifestation determinations, continued educational services in certain circumstances, and consideration of supports such as an FBA or BIP.
504 Plan: Students also have disability-related discipline protections, but the framework is less detailed than under the IDEA and generally focuses on whether the discipline constitutes disability discrimination or a significant change in placement.
