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Stockton Unified School District

Section 504 Overview for Substitute Teachers

District 504 Coordinator – Jennifer Robles

Student Support Services Department

(209) 933-7130 ext. 2617 or jrobles@stocktonusd.net

School Site 504 Team Contacts

504 Team Leader – Administrator

504 Team Members– School Counselors and School Nurse

Updated 7/30/25

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Meet and Greet

Turn to your neighbor.�

Wish each other good morning.�

Introduce yourselves.�

Ask your neighbor what they want to learn about 504 today.

Stockton Unified School District

504 is a Civil Rights Law. It has 2 primary functions – to provide equal access and to protect from discrimination. The 504 Plan is the instrument used to provide FAPE – Free and Appropriate Public Education. It also provides procedural safeguards for families and one of our new documents is a “Notice of Parent/Guardian Rights and Procedural Safeguards.”

Note: The recent audit found that we were greatly under-serving our students with disabilities. Past practice was to provide SST’s (Student Success Team) or IHP’s (Individual Health Plan) to meet the student’s needs. The attorneys have advised that this is NOT sufficient because SST’s and IHP’s do not offer protection from discrimination and they do not offer the procedural safeguards for families (specifically, the right to appeal and manifest determination protections).

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What is Section 504?

Section 504 is a civil rights law that provides qualified students with a disability equal access to programs and activities operated by public entities that receive federal financial assistance.
It provides eligible students with the right to a FAPE (Free Appropriate Public Education).
It also provides protection from discrimination on the basis of a student’s disability.

Stockton Unified School District

504 is a Civil Rights Law. It has 2 primary functions – to provide equal access and to protect from discrimination. The 504 Plan is the instrument used to provide FAPE – Free and Appropriate Public Education. It also provides procedural safeguards for families and one of our new documents is a “Notice of Parent/Guardian Rights and Procedural Safeguards.”

Note: The recent audit found that we were greatly under-serving our students with disabilities. Past practice was to provide SST’s (Student Success Team) or IHP’s (Individual Health Plan) to meet the student’s needs. The attorneys have advised that this is NOT sufficient because SST’s and IHP’s do not offer protection from discrimination and they do not offer the procedural safeguards for families (specifically, the right to appeal and manifest determination protections).

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Bullying and Discrimination

Stockton Unified School District

7	9	11	Non-Traditional
31%	24%	18%	13%

Results from 2024-25 California Healthy Kids Survey. This is the percentage of students who have reported being harassed on campus in the past 12 months. The report also has percentage of students harassed for race/ethnicity, gender, religion, perceived sexual orientation, perceived immigrant, and perceived disability.

CHKS Data on Harassment

Our training today is focusing on using the handbook and forms to determine eligibility and provide FAPE. But let’s pause for one moment to make a quick note about the protections from discrimination.

Students with disabilities are often the victims of bullying and harassment. Our California Healthy Kids Survey shows that a high number of students report being harassed in the past 12 months.

Your efforts to address bullying and harassment are so important. Research has shown that the most effective strategies are building caring connections and positive, inclusive school climate. Making sure staff is trained in how to effectively intervene and respond to bullying is also important.

We have Unity Day coming up October 30 and November is Bullying Prevention Month. Please support these initiatives as this will help in the prevention of bullying and harassment and support the safety of all students and especially our students with disabilities.

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Who qualifies for Section 504?

How do we determine if a student qualifies as disabled under Section 504?

Question 1: Does the student have a physical or mental impairment?
Question 2: Does the impairment substantially limit a major life activity?

1. Has a physical or mental impairment that substantially limits one or more major life activities;

A student who qualifies under this category is entitled to FAPE.

2. Has a record of such impairment; or

Not entitled to FAPE, but districts may not discriminate against such students on the basis of the impairment.

3. Is regarded as having such impairment

Not entitled to FAPE, but districts may not discriminate against such students on the basis of the impairment.

Stockton Unified School District

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Important Note:

This slide is from our March and April 2019 Trainings by attorney Jennifer Fain of Atkinson, Andelson, Loya, Ruud, and Romo

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Important Note:

This slide is from our March and April 2019 Trainings by attorney Jennifer Fain of Atkinson, Andelson, Loya, Ruud, and Romo

Determining Eligibility is the area with the greatest impact from recent changes.

The law was updated in 2008 with the intention of broadening the number of individuals who would qualify as having a disability. Therefore, we should expect the number of students with 504 plans to increase.

Court rulings and the updated law are requiring more defined evaluation for eligibility and requiring documentation of parent/guardian consent for evaluation.

Our new handbook outlines procedures for evaluating for eligibility.

There is a form for “Request for Section 504 Evaluation and Consent” for parents/guardians to sign to document their informed consent for 504 evaluation.

There are also 2 forms to assist teams with conducting and documenting the evaluation process – the “Rubric for establishing level of impact of disability on school activities” and the “Section 504 Eligibility Summary” form.

The law also states that an extensive analysis is not required. We will be going over what is required and best practices in this training.

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Who is on the 504 Team?

Administrator- 504 Site Manager
School Counselor-504 Service Coordinator*
School Nurse – 504 Service Coordinator**
Teacher
Parent
Student

Stockton Unified School District

*Mental Health Impairments-usually the counselor will coordinate

**Physical Health Impairments-usually the school nurse will coordinate

Other staff as relevant to impairment or supports

School Psychologist
Mental Health Clinician

The most frequent question we get asked is “Whose job is it to do 504?”

The answer is that 504 is a team function of the school. Here is the phrasing from the law – “A group of persons, including persons who are knowledgeable about the child, the meaning of the evaluation data, and the placement options.”

This list here shows the team members who need to be involved and some others that may be involved when it relates to them.

You will notice that Administrators are recommended to be the School 504 Site Manager. ☺ Administrators - As the district 504 coordinator, I feel your pain and anxiety. But let’s pause for a moment (take a deep breath) and unpack why the involvement and leadership of our administrators is so important for 504.

-Leader of team, able to empower, make decisions about resources

-Have authority to direct staff and provide correction when needed

-Have the ultimate responsibility for compliance

-In cases of behavior and discipline –administrators need to have knowledge of which students have 504 and what their disabilities and supports are for consideration in responding to behavior with interventions and discipline. Students with 504 plans are required to have Manifestation Determination review prior to change in placement and referral for expulsion (after 8 days of suspension parallel to procedure for students with IEP’s).

-Helps the most vulnerable students and when we care for the most vulnerable, it shows everyone that they are valued and supported and that we will keep them safe.

“Showing kindness towards those who are different and embracing our imperfections as proof of our humanness is the remedy for fear.” – Emma Zurcher-Long of Emma’s Hope Book

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How does Section 504 relate to Special Ed?

Stockton Unified School District

_{IDEA and 504}

_{504 ONLY}

_{General Ed}

Note:

This slide shows how the laws apply. The center circle is for students with IEP’s, the next circle is for students with 504 plans and IEPs, and the third circle is for all students.

This slide is from our March and April 2019 Trainings by attorney Jennifer Fain of Atkinson, Andelson, Loya, Ruud, and Romo

This diagram shows 3 concentric circles. The diagram encompasses all students.
The outer ring of the circle represents students who do not have disabilities and are served only by general education.
The center circle represents students with IEPs who are served by both IDEA and 504. These students are regarded as having a disability. They have an IEP to outline the special education services they receive. They are also protected from discrimination and have the rights of due process as outlined by Section 504. They do not receive a 504 plan. The IEP is considered to provide these protections and FAPE and “trumps” a 504.
The students who are in the ring designated as “504 ONLY” have a disability (or are regarded as having a disability) and receive support from a 504 plan.

Section 504 of the Rehabilitation Act protects students with disabilities from discrimination and entitles them to regular or special education and related aids and services.
They are able to access special education aids and services but are not qualified as a special education student.
This raises the question of what funding will cover the cost of the aids and services for 504, which is one of the primary functions of our district 504 Leadership Team.
If your school thinks a student with a 504 is in need of a related aid or specialized service, you need to submit that request to the District 504 Coordinator for review by the District 504 Leadership Team.

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Section 504 as part of MTSS/SAP/CARE

CARE and SAP can generate referrals for possible 504
MTSS can provide supports for students that can provide data for the evaluation
CARE can monitor roster of 504 students for progress and red flags such as attendance or discipline
MTSS can provide supports that can be used as accommodations on the 504 Service Plan

Stockton Unified School District

504 fits in with our prevention and intervention structures of Multi-Tiered System of Supports, Student Assistance Program, and CARE team (which is one of the Tier 2 interventions of SAP/MTSS)
504 is also a team process, which parallels the team process of MTSS and CARE
The bullets here outline 4 ways section 504 fits in with and is supported by MTSS and SAP

Generate referrals
Provide data for evaluation
Monitor 504 process and monitor 504 students for progress and risk factors

Can monitor 504 process, such as new referrals, timelines, which students due for review or re-evaluation
Can monitor 504 students for progress and for risk factors such as attendance and behavior and alert protections such as manifest determination
Recommended best practice is to review updated roster of students with 504 plans at each CARE meeting to double check for red flags and timelines

MTSS supports can be used as accommodations on the 504 Service Plan (academic supports, testing supports, behavior supports, etc.)

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Identifying students with 504 plans

How do I know if this student has a 504 Plan?�

Synergy Alert

Stockton Unified School District

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504 plans on Document Tab in Synergy

Student Atom has a Documents Tab�

Synergy Alert

Stockton Unified School District

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Protecting Confidentiality

Stockton Unified School District

Privacy rights
Protect computer information
Do not discuss in front of class or other students

Guideline – how would you want your information or your child’s information discussed

Our training today is focusing on using the handbook and forms to determine eligibility and provide FAPE. But let’s pause for one moment to make a quick note about the protections from discrimination.

Students with disabilities are often the victims of bullying and harassment. Our California Healthy Kids Survey shows that a high number of students report being harassed in the past 12 months.

Your efforts to address bullying and harassment are so important. Research has shown that the most effective strategies are building caring connections and positive, inclusive school climate. Making sure staff is trained in how to effectively intervene and respond to bullying is also important.

We have Unity Day coming up October 30 and November is Bullying Prevention Month. Please support these initiatives as this will help in the prevention of bullying and harassment and support the safety of all students and especially our students with disabilities.

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Section 504 Service Plan – pages 1-2 (of 4)

This form is used for the initial 504 as well as updates that involve changes and also for exiting from the 504 plan.
Part 3 is used to show which purpose the form is serving.
Page 2 is the accommodation and services outline.

Stockton Unified School District

This form is used for documenting 504 status. Section 3 is where the current status is documented. The student my be eligible, technically eligible but not in need of a plan, not eligible, no longer eligible (exiting).

Page 2 is the accommodation and services outline. It is no longer a checkbox or menu format. Many of our schools have copied in the existing accommodations from students with 504 plans on the previous forms.

The idea is that the accommodation or service needs to address the identified area of need. The person responsible and the timeline are recorded similar to the way we do so for an SST.

The purpose of the 504 Service Plan is provide equal access by supporting the student in the area impacted by their disability or impairment. We want to do just enough so that the student has access and support to reach their potential. If we provide more than what is needed for access, then we are oversupporting the student and limiting their potential development. It is a balance that may need some adjustment. The goal is empowering support.

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Section 504 Service Plan – pages 3-4

Page 3 has the parent /ed rights holder consents and the team signatures
Page 4 is for notes to document the discussion and for documenting evaluation findings from each of the team members
Filing:

Signed original in the cum. folder
Copy in site working folder
Copy to District 504 Coordinator
Upload copy into Documents Tab on Student Atom in Synergy
Copy for parent/caregiver

Stockton Unified School District

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EXAMPLE - Section 504 Service Plan

Top of pages can be prepopulated.
Complete the rest of the form together as a team.
Page 2 is the service plan. Other info and supports can be documented on Page 4.

Stockton Unified School District

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EXAMPLE – Section 504 Service Plan

Page 3 has an area for parent comments
Page 4 shows a list of evaluation summaries by team member and a list of supports that are in addition to the 504 plan

Stockton Unified School District

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Stockton Unified School District

Mitigating Measures

School districts can no longer consider the

“ameliorating effects of any mitigating

measures that a student is using”.

(ameliorate: to make or become better; improve)

■

Mitigating measures not defined but law

provides non-exhaustive list.

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Stockton Unified School District

For example: �

A person with diabetes who is taking insulin must be viewed in terms of how the diabetes would impact the person without the insulin.

�

A person with ADHD who is taking medication must be viewed in terms of how the ADHD would impact the person without the medication.�

A hearing impaired person must be viewed in terms of how the person hears without hearing aids.

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Medical diagnosis of an illness does NOT

automatically mean a student qualifies for

services under Section 504.

■ A student who has a physical or mental

impairment would not be considered eligible for

504 services if the impairment does not in any

way limit the student's ability to learn or other

major life activity, or only results in some minor

limitations.

■ The impairment must substantially limit one or

more major life activity.

May be “technically eligible but not require aplan

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Example – Student with Diabetes

Stockton Unified School District

Identify impairment	Necessary Accommodation	Individual responsible to implement	Start/End Date
low and high blood glucose, can not manipulate the medication to give injection, needs supervision when providing care, frequent has high blood sugar.	Allow student to carry equipment	Principal, teacher, nurse	6/1/2019-5/30/2020
	Private area for treatment	Principal, teacher, nurse
	Snack in classroom	Teacher
	Emergency action plan training	Nurse
	DMMP update as needed	Nurse

Example of a Diabetic 504 Accommodations

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Example – Student with Asthma

Other possible accommodations:

Allow student to carry self-care equipment any time to all locations

If requested provide private area for blood glucose monitoring

Unrestricted bathroom privileges and access to water

Snack available in classroom, non carb classroom snack for parties

Provide in-service training and care coordination

List of trained staff available on site and on field trips to help with diabetic care/emergencies

Allow participation in sports and PE as allowed in DMMP

School site staff to receive copy of Emergency Action Plan.

Follow Diabetic Management Plan for meals, carbs, insulin, hyper/hypo glycemic management.

Extra diabetic management supplies provided by parent to be a school

Stockton Unified School District

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5 Most common 504 Accommodations

1. Extra time on tests and assignments:

This is a common accommodation for students who need more time to process information or complete tasks due to disabilities like ADHD or learning disabilities.

2. Preferential seating:

This could involve seating the student near the teacher, away from distractions, or in a location that best suits their needs (e.g., near a window for natural light).

3. Frequent breaks:

For students who have difficulty sustaining focus or who need to move around, short breaks can be very helpful. These breaks allow for movement, stretching, or simply a chance to refocus.

4. Assistive technology:

This could include using a computer for writing, speech-to-text software, or other tools that help the student access and process information.

5. Modified assignments:

This might involve breaking down assignments into smaller chunks, providing alternative assignments, or allowing students to complete assignments in different formats (e.g., a video presentation instead of a written report).

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OCR Guidance – 504 & ADHD

In its Resource Guide, OCR stated, “a diagnosis of ADHD is evidence that a student may have a disability. OCR will presume, unless there is evidence to the contrary, that a student with a diagnosis of ADHD is substantially limited in one or more major life activities.”

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Disability or Neurodiversity?

Neurodiversity Article

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Disability or Neurodiversity?

Neurodiversity Article

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EXAMPLE - ADHD

Strategies for Working with ADHD Children

When working with young children with ADHD, keep the following points in mind:

1. Make directions clear and short. Repeat if necessary. (2 times, then rephrase or demonstrate)

2. Make each task specific…in other words; instead of giving several directions at once, split the directions into smaller steps.

3. Give reminders often, coaxing the child to finish. It is important to complete projects once started to help the child learn to sequence beginning to end.

4. Use interesting materials; hands-on activities, visual and auditory aids.

Stockton Unified School District

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EXAMPLE - ADHD

Strategies for Working with ADHD Children

When working with young children with ADHD, keep the following points in mind:

5. Point out the positives. Don’t forget to tell him/her when their behavior is good.

6. Help the child organize and keep their work area free of clutter. Defined spaces for everything helps.

7. Cut down noise and movement in the room. Take a look at who the child is seated next to.

8. Talk less and use short sentences (this actually is beneficial to ALL children).

9. Plan activities well. Think in advance what you will do when s/he gets fidgety, can’t sit still, and can’t follow the lesson. Have plan B in place BEFORE the problem occurs.

Stockton Unified School District

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EXAMPLE - ADHD

Strategies for Working with ADHD Children

When working with young children with ADHD, keep the following points in mind:

10. Reward correct responses. The child with ADHD is only too aware of his/her failures.

11. Be specific with praise. Instead of, “You did a good job," say, “I see you followed the instructions perfectly! You put all the words in the right place.”

12. Let a restless child move; stand at the desk. Don’t take away recess as punishment. Not ever!

13. Mix active and quiet periods. Give the ADHD child extra time to transition between them. Give warnings as you come to an end of an active period so the child has time to start readjusting their thinking.

Stockton Unified School District

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EXAMPLE - ADHD

Strategies for Working with ADHD Children

When working with young children with ADHD, keep the following points in mind:

14. Prepare a child for any change. KEEP a routine! These children aren’t well structured and a lot of their difficulties come from confusion, not knowing what’s coming next, and anxiety or over stimulation because of it.

15. Set aside a "thinking space" where the child can go when feeling out of control. This is not punishment. It is simply a place to calm.

16. Keep a notebook between home and school. I call this "both ends against the middle!"

17. Help the ADHD child develop his/her OWN strategies for when their behavior gets out of control, by asking, “what can you do when…”

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Stockton Unified School District

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EXAMPLE - ADHD

Strategies for Working with ADHD Children

When working with young children with ADHD, keep the following points in mind: �

18. Recognize that the child is going to have “difficult days.” Don’t take them personally. Help the child over those hurdles, or help him/her recognize them before they are coming.

19. Differentiate the child from the behavior. See the child first, then the disorder.

20. Involve parents in what you do. You can’t believe how much it helps to know you’re not alone dealing with this. Rapport with parents will help minimize difficulty in the child. �

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Stockton Unified School District

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Evaluation – please provide your feedback

Stockton Unified School District