504 plan in Colorado: a parent's complete guide

Last updated 2026-07-10

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

A 504 plan is a written document a school creates so a student with a disability gets the same access to education as everyone else. It lists specific accommodations, things the school must do differently, and it assigns responsibility for each one. It does not provide special education services. It is not an IEP.

The name comes from Section 504 of the Rehabilitation Act of 1973, a federal civil rights law. ^[1] Every school district in Colorado that receives federal money, which is all of them, must comply. Colorado has no separate state 504 statute stacked on top. Your rights come straight from the federal law and the regulations in 34 CFR Part 104. ^[2]

For a struggling reader or a child with dyslexia, a 504 plan might include extended time on tests, audiobooks in place of print, preferential seating, directions read aloud, or the right to use text-to-speech software. None of those things change what the child is expected to learn. They remove the barrier the disability creates.

If your child needs more than accommodations, meaning specialized instruction, a different curriculum, or related services like speech therapy, an IEP under IDEA is the right tool instead. See our breakdown of IEP vs 504 if you're not sure which one fits.

Colorado districts must designate a 504 coordinator, usually in the special education or student services office. That person is your first contact.

Who qualifies for a 504 plan in Colorado?

Eligibility is broader than most parents expect. Under Section 504, a student qualifies if they have a physical or mental impairment that substantially limits one or more major life activities. ^[1] Reading, writing, concentrating, thinking, and learning are all named as major life activities in the ADA Amendments Act of 2008, which widened the definition schools use. ^[3]

Dyslexia qualifies. ADHD qualifies. Anxiety that wrecks test-taking qualifies. A student does not need a medical diagnosis to start the process, though a diagnosis often speeds things up. The school has to look at the functional impact of the condition, more than the label on it.

Here's a rule that catches parents off guard. The ADA Amendments Act says schools must assess the impairment in its unmitigated state. If your child takes medication for ADHD that helps them function, the school must consider what ADHD does to them without the medication when deciding eligibility. ^[3]

Students found ineligible for an IEP, either because they don't fit the specific disability categories under IDEA or because their disability doesn't hurt educational performance enough to require special education, often do qualify for a 504. The thresholds are different. A child can have a real, documented disability that doesn't rise to the IDEA level but still substantially limits a major life activity.

There is no IQ cutoff, no grade-point threshold, and no requirement that the child is failing. A student who works hard and passes, but only because they've built exhausting workarounds (common in kids with dyslexia), can still qualify.

How do you request a 504 evaluation in Colorado?

Put it in writing. Email is fine. A letter works too. Send it to the school principal and the 504 coordinator. State clearly that you are requesting an evaluation for a 504 plan under Section 504 of the Rehabilitation Act. Keep a dated copy.

Teachers, counselors, administrators, or parents can all start the referral. ^[2] But parent requests in writing leave the cleanest paper trail if a dispute ever comes up.

Once you request an evaluation, the school must get your written consent before it evaluates. After you consent, the school must finish the evaluation within a reasonable time. Colorado does not write a specific number of days into law for 504 evaluations the way it does for IEP timelines. The Office for Civil Rights (OCR) has treated 30 to 60 days as reasonable. If a school drags past that without a clear reason, raise it with the 504 coordinator and, if you have to, file a complaint.

The evaluation is free to you. The school can use existing data: teacher observations, grades, standardized test scores, and any prior evaluations you hand over. You can submit outside evaluations, such as a private psychoeducational report, and the school must consider them. It is not required to accept every conclusion in them.

After the evaluation, the school holds a meeting to review the data and decide if the student qualifies. You have the right to attend. If the school says no and you disagree, jump to the section below on your rights when a school refuses.

What accommodations can a Colorado 504 plan include for reading struggles?

Accommodations in a 504 plan have to tie back to the specific limits the disability creates. There's no master list you shop from. For reading disabilities, these are common, well-supported, and regularly granted by Colorado schools.

Accommodation	What it addresses
Extended time (usually 1.5x or 2x)	Slow decoding speed
Text-to-speech / audiobooks	Decoding barriers
Directions read aloud	Comprehension under time pressure
Reduced visual clutter on worksheets	Processing load
Preferential seating	Distraction, attention
Spell-check allowed	Spelling disability
Oral responses instead of written	Writing disability tied to dyslexia
Frequent breaks	Fatigue from compensating
Testing in a low-distraction setting	Anxiety, focus
Access to class notes	Processing speed

Accommodations do not lower academic standards. A student on a 504 plan takes the same grade-level content as everyone else. If your child needs modified content or a different instructional approach, that's an IEP conversation.

Colorado uses CMAS (Colorado Measures of Academic Success) for state testing. Students with 504 plans get testing accommodations that match their school-day accommodations, as long as those accommodations are written into the plan and marked approved for state testing. The Colorado Department of Education publishes its accessibility and accommodations manual every year. Read it before the plan gets written. ^[4]

Ask for one thing explicitly: make the plan name who is responsible for each accommodation. A vague plan that says "extended time will be provided" without naming the subject, the test type, and who monitors it is hard to enforce.

What are a parent's legal rights under a Colorado 504 plan?

Section 504 gives you procedural safeguards. ^[2] The school must notify you before it takes any action that changes your child's identification, evaluation, or placement. You can review your child's educational records, request an independent educational evaluation if you disagree with the school's, and challenge the school's decisions.

Unlike IDEA, Section 504 does not force the school to pay for an independent evaluation you request. That cost difference matters. A private psychoeducational evaluation from a neuropsychologist in Colorado usually runs $2,000 to $4,500, though prices swing hard by provider and region. ^[5]

You have the right to an impartial hearing if you disagree with the school's call on identification, evaluation, or placement under a 504 plan. ^[2] You can bring an attorney or advocate. But unlike IDEA, Section 504 does not automatically award attorney's fees even if you win.

If informal resolution fails, file a complaint with the Office for Civil Rights at the U.S. Department of Education. OCR complaints are free, need no attorney, and OCR will investigate. You file online through OCR's complaint portal. ^[6] One caution: OCR complaints usually take six months to a year to resolve, and the remedy is usually compliance, not money.

Colorado also runs a State Complaints process through CDE, but that's for IDEA violations. 504 complaints go to OCR at the federal level, not to CDE. That distinction trips up a lot of parents.

For what to actually say in meetings and how to document your requests, the ReadFlare parent advocacy kit walks through 504 and IEP prep step by step.

How is a Colorado 504 plan different from an IEP?

This is the question parents ask most. Short answer: an IEP provides specialized instruction, a 504 provides accommodations only. The laws behind them differ, the eligibility bars differ, and the procedural protections differ some.

An IEP comes from the Individuals with Disabilities Education Act (IDEA), which requires schools to provide a Free Appropriate Public Education (FAPE) with specially designed instruction. ^[7] A 504 comes from the Rehabilitation Act, which requires equal access, not specialized instruction.

For a child with dyslexia who needs explicit, systematic phonics taught by a trained specialist, an IEP is almost certainly the right document. For a child who can access grade-level content but needs barriers cleared, a 504 is often enough. Plenty of kids have both at different points in their school years.

Key differences that matter in practice:

Feature	504 Plan	IEP
Governing law	Rehabilitation Act (Section 504)	IDEA
What it provides	Accommodations	Specialized instruction + services
Eligibility threshold	Substantially limits a major life activity	Disability adversely affects educational performance AND requires special ed
Federally required timeline	Not specified (OCR says "reasonable")	60 days from consent in most states (Colorado uses 60 days) [7]
Costs for independent eval	Paid by parent	School pays if certain conditions are met
Attorney's fees if you win	Not guaranteed	Recoverable under IDEA
Annual review required	Yes (best practice; not always mandated)	Yes, by law

See our full comparison at IEP vs 504 for a deeper walkthrough of when each applies.

How long does a 504 plan last in Colorado, and how is it reviewed?

A 504 plan does not expire on its own. It stays in effect until the school or family asks for a change, or until the student's circumstances shift enough to warrant a review. Best practice, and what most Colorado districts do, is an annual review meeting where the team checks whether the accommodations are still needed and whether they're actually working.

Periodic re-evaluations are required under Section 504 regulations, generally at least every three years. ^[2] People sometimes call this a "triennial," even though that word belongs more to IDEA. The point is to confirm the student still qualifies.

You can request a review anytime. If your child changes schools or moves up to middle school, high school, or college, the plan should revisit whether it still makes sense. Accommodations that worked in third grade may not be set up the same way in seventh.

One thing Colorado parents miss a lot: when a student graduates or turns 18, the 504 plan ends. Colleges and universities do not have to implement the school's 504 plan. The student has to self-identify to the disability services office and provide documentation. The accommodations may look similar, but the process starts over.

What happens if a Colorado school refuses to create a 504 plan?

Schools do say no sometimes, and sometimes they're wrong. If the school evaluates your child and finds they don't qualify, you have the right to review all the evaluation data it used. Ask for it in writing.

If you think the decision is wrong, your first step is usually a meeting to go through the data with the 504 coordinator and any evaluators. Bring your own documentation: outside evaluations, teacher reports, medical records. Make your case in writing, more than out loud.

If that doesn't fix it, you can request an impartial hearing through the district. ^[2] You can also file a complaint with OCR. ^[6] OCR takes these seriously and has found many Colorado districts in violation over the years. The threat of an OCR complaint sometimes moves a district faster than anything else.

A disability rights attorney or educational advocate can be worth the cost when the stakes are high and the district digs in. Colorado has several nonprofits that give free or low-cost help, including Disability Law Colorado, which handles school-based 504 and special education advocacy. ^[8]

If your child has a clear diagnosis, functional evidence of impact, and outside evaluation data, a refusal is hard for a school to defend. Document everything, stay calm in meetings, and follow up every verbal conversation with an email summary. That paper trail matters if you land at a hearing.

What does Colorado law say about dyslexia screening and 504 plans?

Colorado passed a dyslexia-focused law, CRS 22-20.5-101 et seq., part of the Early Literacy framework, that requires schools to screen for reading deficiencies including characteristics of dyslexia starting in kindergarten. ^[9] As of the 2024-25 school year, Colorado requires universal literacy screening three times a year in grades K-3 using approved instruments.

A positive screen does not automatically create a 504 plan. But a screen showing persistent reading difficulty, paired with functional evidence that the difficulty substantially limits learning, is strong evidence for a 504 eligibility meeting. Parents can and should ask: "My child failed the reading screener twice. What is the school's process for deciding whether a 504 evaluation is appropriate?"

The Colorado Department of Education keeps a list of approved screening tools and a dyslexia resource guide. ^[4] Schools also have to provide reading intervention under their Multi-Tiered System of Supports (MTSS) framework before or alongside any evaluation. Intervention and evaluation can run at the same time. The school cannot make you wait for intervention to fail before it evaluates for a 504.

To understand what phonics-based reading instruction looks like and why it matters for kids with dyslexia, our explainer on 504 plan school connects the accommodation side to the instruction side.

How do Colorado parents request records and monitor 504 plan implementation?

Your right to review educational records comes from FERPA, the Family Educational Rights and Privacy Act. ^[10] Colorado schools must give access within a reasonable time. If you want copies, they can charge a fee only if it doesn't effectively block access, usually a small per-page charge.

Here's the most practical way to monitor a plan. At the start of every semester, email each teacher listed on the plan and ask them to confirm they've received a copy and understand the accommodations. Get the reply in writing. If problems come up later, you have proof the teacher knew their obligations.

Schools are not required by federal law to send you written progress reports specifically on 504 accommodations, unlike IEPs, which carry specific reporting rules. So ask the school to build some monitoring into the plan itself. A quarterly check-in with the counselor works. So does a teacher note home.

If you find accommodations aren't being followed, put it in writing right away. A short email to the principal and 504 coordinator saying what wasn't done and when creates a record. Most failures are accidents, and a written reminder usually clears them up. Persistent failure to implement is a civil rights violation under Section 504.

What does the 504 plan process look like from start to finish in Colorado?

Here's the realistic sequence most Colorado families move through.

Step 1: Parent submits a written request for a 504 evaluation to the principal and 504 coordinator. Keep the email.

Step 2: School gives written notice and asks for your written consent to evaluate. Sign and return it fast.

Step 3: School collects data. This can include a meeting, observations, testing, review of existing records, and consideration of any outside evaluations you provide. This phase usually takes two to four weeks.

Step 4: Eligibility meeting. You attend, review the data, and the team decides whether the child qualifies. If yes, you move to writing the plan. If no, you can challenge the decision (see above).

Step 5: The 504 plan is written. Accommodations are listed, responsibilities are assigned, and the plan is dated. You sign.

Step 6: The plan goes to every teacher who works with your child. The school has a legal duty to implement it right away.

Step 7: Annual review. At least once a year the team meets to check whether the plan is working and whether the child still qualifies.

From written request to signed plan, most Colorado families report four to eight weeks when the process runs smoothly. Contested eligibility decisions take longer. If you're heading into this, the 504 plan overview shows what a strong plan document looks like.

Frequently asked questions

Does Colorado have a separate state law for 504 plans, or does federal law apply?

Colorado does not have a separate state 504 statute. Your rights come entirely from Section 504 of the federal Rehabilitation Act of 1973 and its regulations at 34 CFR Part 104. Colorado's Department of Education publishes guidance documents, but the legal floor is set federally. That means you file complaints with the federal Office for Civil Rights, more than through the state.

How long does a Colorado school have to complete a 504 evaluation after I request one?

Colorado law does not set a specific number of days for 504 evaluations. The Office for Civil Rights has treated 30 to 60 days as reasonable. If your school takes longer without a clear explanation, put your concern in writing to the 504 coordinator and principal. Unreasonable delay can itself be the basis for an OCR complaint.

Can a child with dyslexia get a 504 plan in Colorado even without a formal diagnosis?

Yes. Section 504 eligibility rests on functional impact, not a diagnosis. The school must evaluate whether the student has an impairment that substantially limits a major life activity like reading or learning. A formal diagnosis from a psychologist or doctor can strengthen the case, but the school cannot refuse to evaluate or deny eligibility just because you don't have one.

Will a 504 plan follow my child to a new Colorado school district if we move?

The new district must review the existing plan and provide comparable services while it runs its own review. The new school is not automatically bound by the old plan, but it cannot simply ignore it. Contact the new school's 504 coordinator before or right at enrollment, bring a copy of the plan, and ask in writing how they'll handle the transition. Most districts honor existing plans while reviewing.

Does a Colorado 504 plan transfer to college?

No. College and university disability services offices operate under the ADA and Section 504, but they require the student to self-identify and provide current documentation. The high school 504 plan does not transfer automatically. Start gathering documentation (a recent psychoeducational evaluation, ideally within three to five years) before senior year. The student, not the parent, makes the request at the postsecondary level.

What is the difference between a 504 plan and an IEP in Colorado?

An IEP is created under IDEA and provides specialized instruction and related services. A 504 plan is created under the Rehabilitation Act and provides accommodations only. The eligibility bar for an IEP is higher and more specific. A 504 fits when a child needs barriers removed but can access grade-level content. For a full comparison, see the IEP vs 504 breakdown at ReadFlare.

Can a teacher refuse to follow a student's 504 plan in Colorado?

No. Once a 504 plan is signed and in effect, every teacher who works with that student must implement the accommodations. Refusing is a violation of Section 504, a federal civil rights law. If a teacher isn't following the plan, notify the principal and 504 coordinator in writing immediately. Persistent failure to implement can be reported to the Office for Civil Rights.

How often does a 504 plan need to be reviewed in Colorado?

Best practice, and what most Colorado districts do, is an annual review. Federal regulations also require a periodic re-evaluation, generally at least every three years, to confirm the student still qualifies. You can request a review anytime your child's needs change, if the plan isn't working, or if there's a major transition like moving to middle or high school.

What is the Colorado dyslexia screening law and how does it connect to 504 plans?

Colorado law (CRS 22-20.5-101 et seq.) requires universal reading screeners three times a year in grades K-3. A screening result showing persistent reading difficulty is strong evidence to bring to a 504 eligibility meeting. A failed screener doesn't automatically trigger a 504, but parents can formally request a 504 evaluation based on that data. Schools cannot make you wait for intervention to fail first.

How do I file a 504 complaint in Colorado if the school isn't complying?

File a complaint with the U.S. Department of Education's Office for Civil Rights. You can do it online through the OCR complaint portal. It's free and needs no attorney. OCR will investigate and can require the district to change its practices. Complaints usually take six months to a year to resolve. Keep all written records, emails, and meeting notes before filing.

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

Generally no. A student getting special education under an IEP is already protected by IDEA, which has broader protections. The IEP can include accommodations similar to what a 504 plan would hold. There are narrow situations where a student might have both, but in most cases the IEP replaces the 504. Ask your district's special education coordinator if you're unsure which applies.

Does Colorado require schools to pay for independent educational evaluations under a 504 plan?

No. Unlike IDEA, Section 504 does not require the school to fund an independent evaluation if you disagree with theirs. You can get one privately and submit it for the school to consider, but the cost is yours. A private psychoeducational evaluation in Colorado usually runs $2,000 to $4,500 depending on the provider. The school must consider your private evaluation but is not required to accept every conclusion.

What accommodations can a Colorado 504 plan include for CMAS state testing?

Colorado's accessibility and accommodations manual for CMAS testing lists which accommodations are approved for state tests. Common approved ones include extended time, text-to-speech, and separate testing settings. The accommodation must appear in the student's 504 plan and be used regularly during classroom instruction and testing to qualify for CMAS. Review the CDE accommodations manual before writing or updating the plan.

How do I find a 504 coordinator in my Colorado school district?

Every district that receives federal funding must designate a Section 504 coordinator. Call the district's main office or check the district website under Special Education or Student Services. The school principal can also point you there. If a district claims it doesn't have a 504 coordinator, that itself is a potential compliance issue worth raising with OCR.

Sources

1. U.S. Department of Education, Office for Civil Rights (main page): Section 504 of the Rehabilitation Act of 1973 prohibits discrimination based on disability in programs receiving federal financial assistance, including public schools.
2. Electronic Code of Federal Regulations, 34 CFR Part 104, Nondiscrimination on the Basis of Handicap in Federally Assisted Programs: 34 CFR Part 104 requires schools to provide procedural safeguards, including notice, the right to review records, and an impartial hearing for disputes over 504 identification, evaluation, or placement.
3. ADA.gov, Introduction to the ADA and the ADA Amendments Act of 2008: The ADA Amendments Act of 2008 expanded the definition of major life activities to include reading, writing, concentrating, thinking, and learning, and requires impairments to be assessed in their unmitigated state.
4. Colorado Department of Education, Special Education (Exceptional Student Services Unit): CDE maintains a dyslexia resource guide and publishes an annual accessibility and accommodations manual for CMAS state testing.
5. Child Mind Institute: Private psychoeducational evaluations from neuropsychologists typically range from approximately $2,000 to $4,500 or more depending on the provider and region.
6. U.S. Department of Education, Office for Civil Rights, How to File a Discrimination Complaint: Parents can file a Section 504 complaint with OCR online at no cost and without an attorney; OCR will investigate and can require districts to change practices.
7. U.S. Department of Education, Individuals with Disabilities Education Act (IDEA): IDEA requires schools to complete an IEP evaluation within 60 days of receiving parental consent (or within the state's established timeline), and to provide a Free Appropriate Public Education including specially designed instruction.
8. Disability Law Colorado (protection and advocacy organization): Colorado nonprofit providing free and low-cost disability rights legal assistance including school-based 504 and special education advocacy.
9. Colorado General Assembly, Colorado Revised Statutes (CRS 22-20.5-101 et seq., Early Literacy): Colorado law requires universal reading screeners three times per year in grades K-3 using approved instruments to identify reading deficiencies including characteristics of dyslexia, effective 2024-25 school year.
10. U.S. Department of Education, Family Educational Rights and Privacy Act (FERPA), Student Privacy Policy Office: FERPA gives parents the right to inspect and review their child's educational records; schools must provide access within a reasonable time and cannot charge fees that effectively prevent access.
11. U.S. Department of Education, Office for Civil Rights, Protecting Students with Disabilities (Section 504 FAQ): OCR guidance clarifies that Section 504 requires equal access to education for students with disabilities and that periodic reevaluations, generally at least every three years, are required.