IEP vs. 504 - What's the Difference?

Parents often wonder about the difference between an IEP (Individualized Education Program) and a 504 Plan. While both provide support for students with disabilities, they are not the same. An IEP offers more protections, services, and parental rights than a 504 Plan. Below we’ll explain the key differences — and share a side-by-side chart so you can quickly compare IEPs and 504 Plans.

Key Differences Between IEP and 504 Plans

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: Developed by a smaller team, often a guidance counselor, teacher, or administrator. No specific team membership is required.

4. Parental Rights & Safeguards

  • IEP: Parents have stronger rights. Schools must make reasonable efforts to ensure parental participation, provide written plans, and give notice before changing placement. Parents also have access to formal dispute resolution (mediation, due process hearings, and “stay-put” protections).

  • 504 Plan: Parents have fewer protections. 504 Plans do not have to be written, schools are not required to give notice before changes, and dispute resolution is generally handled through the Office for Civil Rights (OCR).

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: Children can be removed for behavior not related to their disability, but the school must still provide a Free Appropriate Public Education (FAPE).

  • 504 Plan: Students can be permanently expelled for behavior not related to their disability. (Massachusetts law provides additional protection against permanent expulsion.)

Here’s a simple side-by-side comparison of IEP vs. 504 Plans to help you see the differences at a glance:

IEP vs. 504 Plan Comparison Chart

Category IEP (Individualized Education Program) 504 Plan
Law IDEA (Individuals with Disabilities Education Act) Section 504 of the Rehabilitation Act
Eligibility Disability impacts ability to make progress in school and requires specialized instruction Disability substantially limits a major life activity (e.g., learning, concentrating)
Services Special education + related services (speech, OT, counseling, specialized reading, etc.) Accommodations for access (extended time, seating, behavior supports, modified work)
Plan Requirements Must be in writing; includes measurable goals Written plan not required
Team Parents, special ed teacher, gen ed teacher, administrator Smaller team, often teacher + counselor; no set requirements
Parental Rights Strong safeguards: notice, meetings, “stay-put,” due process hearings Fewer protections; disputes handled through OCR
Accountability Schools must monitor progress and share updates regularly No progress reporting requirements beyond what all students receive
Discipline Protections Must still provide FAPE if student is removed Student may be permanently expelled (MA law provides added protections)
Funding Additional federal funding for special education services No additional funding; accommodations from general budget

How Can I Move My Child From a 504 Plan to an IEP?

Schools must provide an IEP if a child’s disability requires special education and related services. If your school refuses:

  1. Request a special education evaluation in writing.

  2. Collect documentation (evaluations, teacher reports, medical records) that show your child’s needs.

  3. Consider consulting a special education attorney if the school continues to deny eligibility.

Final Thoughts

The key difference between an IEP vs. 504 Plan is this:

  • An IEP provides individualized instruction, services, and strong parental rights.

  • A 504 Plan provides accommodations for access, but fewer protections.

If your child is struggling with a 504 Plan and not making progress, it may be time to seek an IEP and contact a special education attorney.

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Independent Evaluations in Massachusetts: What Parents Need to Know