504 plan in Arkansas: what parents need to know

Last updated 2026-07-10

What is a 504 plan and how does it work in Arkansas schools?

A 504 plan is a legally binding document that a public school must provide to any student who has a physical or mental impairment that substantially limits one or more major life activities. Reading, concentrating, thinking, and communicating all count as major life activities under the law. The plan lists specific accommodations the school agrees to put in place so the student can access the same educational programs as their non-disabled peers.

The authority comes from Section 504 of the Rehabilitation Act of 1973, a federal civil rights law ^[1]. Every public school district in Arkansas has to follow it as a condition of taking federal money. The U.S. Department of Education's Office for Civil Rights (OCR) enforces Section 504 and investigates complaints when schools fall short ^[2].

An IEP requires that the student need specially designed instruction. A 504 plan does not. It only requires a documented disability that creates a barrier in the school environment. That distinction matters. A child with dyslexia who can make progress with the right accommodations may qualify for a 504 plan but not an IEP, or may need both. For a side-by-side breakdown of which document does what, see IEP vs 504.

Arkansas does not publish a single statewide 504 procedure manual the way it publishes IDEA special education rules. Each district writes its own 504 policies, and those policies must comply with federal Section 504 regulations at 34 CFR Part 104 ^[3]. Your experience can shift district to district. Your federal rights do not.

Who qualifies for a 504 plan in Arkansas?

Three things must all be true. The student has a physical or mental impairment. That impairment substantially limits a major life activity. The impairment is not temporary and minor (though "temporary" is narrower than many parents assume, see below).

The 2008 ADA Amendments Act broadened what "substantially limits" means, and schools must apply that broader standard ^[4]. Before 2008, some districts rejected students with dyslexia or ADHD because those students looked like they were functioning fine with coping strategies. That reasoning is now off the table. The law says you compare the student to most people in the general population, not to a high-achieving peer group, and you ignore the effects of mitigating measures like medication or self-taught coping skills when deciding if the impairment is substantial.

Diagnoses that commonly support 504 eligibility in Arkansas schools include dyslexia, ADHD, anxiety disorders, depression, autism spectrum disorder (when the student does not need specially designed instruction), Type 1 diabetes, epilepsy, asthma, and food allergies. That list is not the whole list. There is no master roster of qualifying conditions because the law is functional, not diagnostic: what matters is whether the condition limits a major life activity, not what it is called.

Temporary conditions can qualify if they are severe enough. A student recovering from a traumatic brain injury or a serious illness might get a short-term 504 plan. A student with a broken wrist probably does not qualify unless writing is a major life activity that is substantially limited for a meaningful period.

Here is the part parents miss most: a student does not need to be failing. A child with dyslexia who is pulling Bs by working three times as hard as their classmates still has a disability that substantially limits reading. Effort spent compensating does not erase the disability.

How do you request a 504 evaluation in Arkansas?

Put the request in writing. Email the school principal or the district's 504 coordinator (every district that takes federal funds has to name one ^[2]). Keep it short: "I am requesting an evaluation to determine whether my child, [name, grade, school], qualifies for a 504 plan under Section 504 of the Rehabilitation Act. Please confirm receipt and let me know the next steps."

You do not need a private diagnosis first. The school must run its own evaluation using existing data, teacher observations, grades, test results, and any outside records you choose to share. Requesting an evaluation is free. The school cannot charge you for it.

Arkansas does not set a specific number of days for the school to finish a 504 evaluation, unlike the IDEA's 60-school-day rule for special education eligibility. Federal OCR guidance says the timeline must be "reasonable" ^[2]. In practice, most districts aim for 30 to 60 calendar days. If yours is dragging past that, a polite written follow-up citing OCR guidance is fair game.

If the school denies your request for an evaluation, they must give you written notice of the denial and the reason. You can challenge that denial through the district's grievance procedure or by filing an OCR complaint. More on that in the rights section below.

One note on records. If your child already has a private diagnosis from a psychologist, neuropsychologist, or developmental pediatrician, share it. Schools do not have to treat it as conclusive, but a solid evaluation report speeds things up and cuts the odds of a blanket denial.

What does the 504 evaluation process look like in Arkansas?

The school builds a team, often called a 504 committee or eligibility team, to review the data. This team usually includes at least one person who knows the student (a teacher or counselor), one person who can interpret evaluation data, and an administrator with authority to commit resources. Parents are members of the team.

The team looks at existing school data first: state assessment results, classroom grades, teacher reports, attendance, and any prior evaluations. If that data is not enough to make an eligibility call, the school may run additional testing, such as reading assessments, a behavioral rating scale, or academic achievement testing. The evaluation does not have to match a full psychoeducational battery. It just has to be enough.

Once the data is in, the team meets to decide two questions. Does the student have a physical or mental impairment? Does that impairment substantially limit a major life activity? Yes to both means the student is eligible. The team then writes the 504 plan.

Most districts ask parents to give written consent before an initial 504 evaluation, though federal Section 504 regulations do not spell out the same explicit consent requirement IDEA does. Check your district's local policy. Either way, you will be notified and involved.

If you disagree with the school's eligibility decision, you have a right to an impartial hearing. That process is described later in this article.

What accommodations can a 504 plan include in Arkansas?

Accommodations change how a student reaches the learning without changing what they are expected to learn. They are not the same as modifications, which lower the level of content. A 504 plan can include accommodations only. An IEP can include both.

Common 504 accommodations for students with reading disabilities, dyslexia, or ADHD in Arkansas schools include extended time on tests and assignments (usually time-and-a-half or double time), preferential seating, reduced-distraction testing environments, text-to-speech software, audiobooks through Learning Ally or Bookshare, a calculator, speech-to-text tools for writing, reduced homework volume (not reduced rigor), frequent check-ins from the teacher, and oral testing in place of written.

For students with dyslexia, parents often push for access to structured literacy instruction as part of the 504 plan. Arkansas passed Act 1062 in 2019 (the Dyslexia Act), which requires schools to screen all K-2 students for dyslexia risk and provide appropriate intervention ^[5]. If your child is flagged through that screening, the intervention can be written into a 504 plan even when the child does not meet IEP eligibility criteria.

Accommodations must be reasonably calculated to give the student equal access. Vague language like "teacher support as needed" is not an accommodation. A good 504 plan names the tool, the situation it applies to, and who is responsible. If your plan reads vague, ask the team to rewrite it with specifics before you sign.

Some kids need more than accommodations. If your child needs a structured literacy program or direct phonics instruction, an IEP may fit better, because it can require specially designed instruction rather than supports built around the instruction. See 504 plan explained for a fuller comparison.

How is a 504 plan different from an IEP in Arkansas?

This question comes up in almost every parent meeting, and it is worth getting right.

An IEP (Individualized Education Program) is created under IDEA, a separate federal law ^[6]. It is for students who need specially designed instruction, meaning the curriculum or teaching method itself has to be adapted to their unique needs. An IEP includes measurable annual goals, special education services, and formal progress monitoring. Arkansas follows IDEA procedures closely, including the 60-school-day evaluation timeline and strict procedural safeguards.

A 504 plan is created under the Rehabilitation Act. It is for students whose disability creates a barrier to access but who can make adequate progress with accommodations alone. There are no annual goals, no special education teacher required, and (this one surprises people) far fewer procedural safeguards written into the federal regulations.

Feature	504 Plan	IEP
Governing law	Section 504, Rehab Act 1973	IDEA 2004
Requires specially designed instruction	No	Yes
Annual goals required	No	Yes
Evaluation timeline in Arkansas	No state-set deadline ("reasonable")	60 school days [6]
Cost to parent	Free	Free
Dispute process	Impartial hearing + OCR complaint	Due process hearing + mediation
Applies to private schools receiving federal funds	Yes	Only public schools
Reviewed annually	Yes (best practice / required by OCR)	Yes (required by IDEA)

For a child struggling hard with reading, especially a child with dyslexia who needs explicit, systematic phonics instruction, an IEP often gives stronger protection because it mandates the instruction itself, more than supports around it. If your school offers a 504 plan but you think your child needs an IEP, you can request an IDEA evaluation separately. The two are not mutually exclusive. A student can have a 504 plan and later be found eligible for an IEP, or can have an IEP that also folds in 504-type accommodations.

For more on what an IEP actually is, what does IEP mean gives a plain-language walkthrough.

How often is a 504 plan reviewed in Arkansas, and can it be changed?

Federal OCR guidance says 504 plans should be reviewed periodically, and annual review is the standard ^[2]. Arkansas districts generally hold annual 504 meetings, though the law sets no penalty if a meeting slips a few weeks. Request a review any time there is a real change in your child's needs, a new diagnosis, a move to a new school or grade, or evidence that the current accommodations are not working.

You can request a review in writing at any time. You do not have to wait for the annual meeting. If your child's dyslexia screening shows ongoing difficulty despite the current accommodations, that is a solid reason for a mid-year review.

Changes to the plan go through the 504 team. The school cannot pull an accommodation on its own without a team meeting and your input. You are a member of that team. The school does not legally need your signature to finalize the plan under Section 504 (unlike an IEP), but many districts get parental consent anyway, and OCR strongly encourages real parental involvement ^[2].

Keep a copy of every version of the plan, dated. If accommodations stop happening (a substitute does not give extended time, say), that is a compliance issue you can raise with the 504 coordinator or, if it stays unresolved, with OCR.

What are your rights as a parent under Section 504 in Arkansas?

Your rights under Section 504 come straight from federal regulations at 34 CFR Part 104 ^[3] and OCR enforcement guidance. Here are the ones that matter most.

Right to notice. The school must notify you of any action about your child's identification, evaluation, or placement, and give you an explanation of your rights ^[3].

Right to examine records. You can review all educational records tied to the evaluation and placement, the same right you have under FERPA.

Right to an impartial hearing. If you disagree with any decision the school makes about identification, evaluation, or placement, you can request an impartial hearing before a person not employed by the district ^[3]. You have the right to take part, to be represented by counsel, and to get a decision in writing. This is separate from IDEA's due process system.

Right to file an OCR complaint. If you believe the school discriminated against your child or failed to follow Section 504, you can file a complaint with the U.S. Department of Education's Office for Civil Rights at no cost ^[2]. OCR complaints generally have to be filed within 180 days of the alleged violation. OCR can investigate and, if it finds a violation, require the school to fix it.

Right to a grievance procedure. Any district with 15 or more employees must have a grievance procedure for Section 504 complaints ^[3]. Ask for your district's procedure in writing.

Arkansas also has a federally funded Parent Training and Information Center that helps families understand their rights and prepare for school meetings at no charge ^[7]. Every state has one, and they exist specifically for parents in your position.

One practical warning. Section 504 does not give you the same "stay put" rights IDEA provides. During a dispute, the school can change the child's placement while the disagreement is worked out, unless a court orders otherwise. That is a real gap compared to IDEA, and it is one reason some advocates push hard for IEP eligibility when a disability significantly affects a child's education.

How does Arkansas's dyslexia law interact with 504 plans?

Arkansas Act 1062 of 2019, the Dyslexia and Related Disorders Act, requires all public schools to screen students in kindergarten through second grade for dyslexia risk using a state-approved screener ^[5]. Schools must also screen any student referred for reading difficulties at any grade level.

If a student is flagged as at risk, the school must provide structured literacy intervention. The law also requires districts to have at least one trained literacy specialist and to report screening data to the Arkansas Division of Elementary and Secondary Education (DESE) ^[5].

Here is the connection to 504: a positive dyslexia screening result is evidence. It does not automatically create a 504 plan, but it is exactly the kind of documentation the 504 team should weigh when deciding whether a student has an impairment that substantially limits reading. If your child screened positive and the school has not offered any formal plan, ask the 504 coordinator in writing whether the screening results have been reviewed for 504 eligibility.

The ReadFlare parent advocacy kit includes a checklist for exactly this situation: connecting a dyslexia screening result to a formal 504 or IEP request, with draft language you can adapt for your own district.

Students who need more than accommodations and require systematic, explicit phonics instruction may be better served under IDEA. Arkansas requires schools to use evidence-based literacy instruction aligned with the science of reading under its LEARNS Act (Act 237 of 2023) ^[8], which means structured literacy programs should now be in most Arkansas classrooms as a baseline. But a program in the classroom does not deliver the intensity and frequency a struggling reader with dyslexia needs. A 504 plan can specify the intervention type. An IEP can require it as a special education service.

What happens at an Arkansas 504 meeting and how should parents prepare?

The meeting is a team conversation to review evaluation data, decide eligibility, and write the plan. It usually runs 30 to 60 minutes. The tone swings wildly by district. Some schools run these meetings collaboratively and welcome parent input. Others treat them as a formality to get through fast. Knowing what to expect helps you get more out of it.

Before the meeting, request all data the team will use: recent state test scores, classroom assessments, teacher notes, and any prior evaluations. You are entitled to review these. Write down the two or three accommodations you think matter most, and bring written evidence: samples of your child's work, a letter from a private provider, notes from tutoring sessions. Come with questions.

At the meeting, ask the team to explain how they are applying the "substantially limits" standard. Ask what evidence they reviewed. If they say your child does not qualify, ask them to explain in writing which criteria were not met.

If you agree with the plan and sign, accommodations should start right away. Most districts cannot legally delay a 504 plan once the team has agreed to it.

If you disagree, do not feel pushed to sign the same day. Take the draft home, review it, talk to an advocate or attorney, and respond in writing within a few days. You can also consent to some parts and object to others in writing.

For parents getting ready for a first 504 meeting, IEP meeting walks through preparation strategies that apply to both 504 and IEP meetings.

A move many advocates recommend: bring a trusted friend or take your own notes. Schools cannot bar you from bringing a support person. A second set of ears changes the dynamic and helps you remember what got said.

What if the Arkansas school denies a 504 plan or stops implementing it?

Denials happen, and they are not always legitimate. Here is what to do.

Get the denial in writing. The school must provide written notice explaining why the student was found ineligible or why an accommodation was removed. If they will not put it in writing, send a follow-up email documenting what was said out loud and ask them to correct any inaccuracies.

Request an impartial hearing through the district. Ask for the district's 504 hearing procedure and submit a written request within any deadline the district sets. At the hearing, you can present evidence, have counsel, and cross-examine witnesses.

File an OCR complaint. You can file while the district hearing is still pending. OCR complaints are filed online through the Department of Education's Office for Civil Rights ^[2]. They are free, and OCR has real enforcement power, including the ability to withhold federal funds, though in practice OCR usually seeks a voluntary resolution agreement first. Nationwide, OCR resolved roughly 11,000 disability discrimination cases in fiscal year 2022 ^[2]. This is an active enforcement mechanism, not a dead letter.

Consider an advocate or attorney. The Council of Parent Attorneys and Advocates (COPAA) keeps a directory of special education advocates and attorneys ^[9]. Arkansas also has Disability Rights Arkansas, which provides free legal help to Arkansans with disabilities in certain situations ^[10].

Non-implementation is a different problem from denial. If the 504 plan exists but teachers ignore extended time or the reading software never gets set up, document the failures in writing, report to the 504 coordinator, and escalate to the principal. If that stalls, an OCR complaint for failure to implement is appropriate. Section 504 says the "program or activity receiving Federal financial assistance" must not discriminate ^[3]. A plan that lives on paper but not in the classroom fails that test.

If you are working through an ongoing dispute and need tools for writing formal letters or tracking accommodations across teachers, the ReadFlare parent advocacy kit has templates built for that exact workflow.

Can a 504 plan cover standardized testing and state assessments in Arkansas?

Yes. Accommodations listed in a student's 504 plan can apply to Arkansas state assessments, including the ACT Aspire (used in grades 3 through 10) and end-of-course exams, as long as the accommodations are also used in routine classroom instruction and are written into the plan before the test window opens.

Arkansas DESE sets specific rules for state assessment accommodations, and those rules must line up with what is in the student's 504 plan ^[11]. Common approved accommodations include extended time, a separate testing room, text-to-speech for certain subjects, and scribing. Some accommodations you can use daily in class are not approved for state testing, so check the DESE accommodations manual before your child's testing window.

For the ACT (the college-entrance exam, not ACT Aspire), College Board and ACT each run their own accommodation request process. Having a 504 plan on file at school makes the application stronger, but it is a separate request to the testing company, not an automatic transfer. Start early, before junior year, since approval can take several months and the documentation requirements are detailed.

SAT accommodations through College Board also require a separate application. The College Board reports approving extended time for roughly 6% of SAT test-takers in recent years, and prior documentation of the accommodation in a 504 plan or IEP is the strongest evidence you can submit.

Frequently asked questions

How long does it take to get a 504 plan in Arkansas?

Arkansas has no state-mandated deadline for 504 evaluations, unlike the 60-school-day IDEA rule for IEPs. Federal OCR guidance requires a "reasonable" timeline. Most districts finish the evaluation and hold the eligibility meeting within 30 to 60 calendar days of a written request. If your district is well past that window with no explanation, send a written follow-up to the 504 coordinator and copy the principal.

Does my child need a dyslexia diagnosis to get a 504 plan in Arkansas?

No. A formal diagnosis helps but is not required. The school must run its own evaluation using available data, including Arkansas's mandatory K-2 dyslexia screening results, teacher observations, and academic records. If the data shows the student has an impairment that substantially limits a major life activity like reading, the student qualifies, whether or not a private clinician has issued a formal diagnosis.

Can a 504 plan be refused if my child is passing their classes?

No, passing grades do not disqualify a student. Federal law compares the student's functioning to most people in the general population, not to a grade-level standard. A student with dyslexia who earns Bs by spending three times longer on homework than peers can still have a disability that substantially limits reading. The ADA Amendments Act of 2008 says mitigating measures like extra effort or coping strategies cannot be used to find that no limitation exists.

What is the difference between a 504 plan and an IEP for an Arkansas student with dyslexia?

A 504 plan provides accommodations: tools and supports that reduce barriers. An IEP provides specially designed instruction, meaning the teaching method itself is adapted. A student with dyslexia who needs explicit structured literacy instruction (more than extra time) usually needs an IEP, not only a 504 plan. You can request an IDEA evaluation for an IEP separately from any 504 process, and a student can move from one to the other.

Who is the 504 coordinator at my Arkansas school, and how do I find them?

Every district that receives federal funds must name a Section 504 coordinator. Contact the main office of your child's school or the district's central office and ask specifically for the "Section 504 coordinator." Some small districts assign this role to a counselor, assistant principal, or special education director. Once you have the name, send all formal requests in writing to that person and keep copies.

Does a 504 plan transfer when my child moves to a new Arkansas school or district?

A new Arkansas district should honor an existing 504 plan while it conducts its own review. Send a copy of the plan to the new school's 504 coordinator before or at enrollment. The new school can convene a team to review eligibility under its own procedures, but it cannot simply ignore an existing plan during that review period. Follow up in writing within the first two weeks to confirm accommodations are in place.

Can parents request a 504 plan directly, or does it have to go through the teacher?

Parents can request a 504 evaluation directly, in writing, to the school principal or district 504 coordinator. You do not need the teacher's permission or a referral. Teachers, counselors, and administrators can also start referrals, but you hold an independent right to request an evaluation under Section 504. Put your request in writing and keep a dated copy.

Are private schools in Arkansas required to provide 504 plans?

Private schools that receive federal financial assistance must comply with Section 504. Truly private schools with no federal funding are not covered by Section 504, though they may have obligations under Title III of the ADA. Most small independent private schools in Arkansas do not receive federal funds and so are not required to provide 504 plans, though many adopt similar accommodation policies on their own.

What can I do if an Arkansas teacher is not following my child's 504 plan?

Document each failure in writing: the date, the accommodation that was missed, and what happened instead. Report to the 504 coordinator by email and request a written response. If it continues, escalate to the principal, then the district superintendent. Persistent non-implementation despite written notice is a basis for an OCR complaint filed with the Department of Education's Office for Civil Rights. Non-implementation is a civil rights violation, more than an administrative slip.

Does Arkansas have a state complaint process specifically for 504 plans?

Arkansas does not run a separate state complaint process for Section 504 the way it runs an IDEA complaint process through DESE. Your formal options are: (1) the district's own grievance procedure, (2) an impartial hearing requested through the district, and (3) an OCR complaint filed directly with the U.S. Department of Education. Disability Rights Arkansas can provide free legal advice to eligible families weighing these options.

How does Arkansas's LEARNS Act affect what 504 plans can require?

The LEARNS Act (Act 237 of 2023) requires Arkansas public schools to use evidence-based, structured literacy instruction aligned with the science of reading. This raises the floor for all students, but it does not replace individualized 504 accommodations. A student with dyslexia still needs a 504 plan to document specific accommodations like extended time, text-to-speech, or a separate testing environment, even as classroom instruction improves statewide.

Can a student have both a 504 plan and an IEP at the same time in Arkansas?

Generally no, not at the same time. Once a student has an IEP under IDEA, the IEP governs all special education and related services, and many protections that would go in a 504 plan get folded into the IEP. Some districts do keep a 504 plan alongside an IEP for specific situations (like a student with both a learning disability and a physical health condition), but this is uncommon and not legally required.

Is there a cost to parents for a 504 evaluation or plan in Arkansas?

No. The evaluation, the eligibility meeting, the written plan, and all required reviews are free to parents. The district pays. If a district tells you to pay for a private evaluation as a precondition for consideration, that is not a legitimate requirement, though you may choose to get a private evaluation at your own expense and submit it as supporting data.

How do I prepare for a 504 meeting in Arkansas to get the best outcome?

Gather documentation before the meeting: your child's reading assessment scores, samples of schoolwork that show the difficulty, and any private evaluation reports. Write down the two or three accommodations you want most and bring written evidence for each. Ask the team to explain the "substantially limits" analysis. If the draft plan uses vague language, ask for specific rewording before you leave. Bring a trusted support person to take notes.

Sources

1. U.S. Department of Justice, Section 504 of the Rehabilitation Act of 1973 overview: Section 504 of the Rehabilitation Act of 1973 prohibits discrimination against individuals with disabilities in programs receiving federal financial assistance.
2. U.S. Department of Education, Office for Civil Rights, Section 504 and ADA information: OCR enforces Section 504, requires schools to notify parents of rights, and accepts complaints that must be filed within 180 days of a violation; OCR resolved approximately 11,000 disability discrimination cases in fiscal year 2022.
3. Code of Federal Regulations, 34 CFR Part 104, Nondiscrimination on the Basis of Handicap in Programs Receiving Federal Financial Assistance: 34 CFR Part 104 sets out the procedural requirements for Section 504, including notice rights, record review, impartial hearing, and the grievance procedure requirement for districts with 15 or more employees.
4. U.S. Equal Employment Opportunity Commission, ADA Amendments Act of 2008 overview: The ADA Amendments Act of 2008 broadened the definition of 'substantially limits' and prohibited use of mitigating measures when determining whether an impairment substantially limits a major life activity.
5. Arkansas Department of Education, Dyslexia and Related Disorders Act (Act 1062 of 2019): Arkansas Act 1062 of 2019 requires universal dyslexia screening in kindergarten through second grade using a state-approved screener and mandates structured literacy intervention for identified students.
6. U.S. Department of Education, Individuals with Disabilities Education Act (IDEA) overview: IDEA requires a 60-school-day timeline for initial special education evaluations and mandates IEPs with annual goals, specially designed instruction, and formal procedural safeguards.
7. Center for Parent Information and Resources, directory of state Parent Training and Information Centers: Each state has a federally funded Parent Training and Information Center that provides free training and information to families of children with disabilities so they can participate effectively in their children's education.
8. Arkansas Department of Education, LEARNS Act (Act 237 of 2023): Arkansas Act 237 of 2023 (the LEARNS Act) requires public schools to use evidence-based structured literacy instruction aligned with the science of reading.
9. Council of Parent Attorneys and Advocates (COPAA), attorney and advocate directory: COPAA maintains a national directory of special education attorneys and advocates who assist families in 504 and IDEA disputes.
10. Disability Rights Arkansas, legal advocacy services for Arkansans with disabilities: Disability Rights Arkansas provides free legal assistance to eligible Arkansans with disabilities in education, employment, and other matters.
11. Arkansas Department of Education, Division of Elementary and Secondary Education assessment information: DESE sets rules for which 504 and IEP accommodations are approved for use on Arkansas state assessments including ACT Aspire and end-of-course exams.