Section 504 coordinators carry a lot. Evaluations, plan meetings, accommodations in every classroom, health plans, family communication and federal data requests all land on the same small team. Good reporting turns that workload into something we can see, plan and evidence.
In this guide we cover what Section 504 compliance means for K-12 districts, where the regulations stand in 2026, and the eight reports that help every eligible student get the support they are entitled to.
What is Section 504 compliance?
Section 504 compliance means a school district meets its duties under Section 504 of the Rehabilitation Act of 1973: identifying and evaluating students with disabilities, providing a free appropriate public education (FAPE) through accommodations and services, following procedural safeguards, and keeping records that show it has done so. For public schools, these duties are set out in the U.S. Department of Education's regulations at 34 CFR Part 104 and enforced by its Office for Civil Rights (OCR).
Section 504 is a civil rights law. It applies to every program that receives federal funding, and it protects students whose physical or mental impairment substantially limits a major life activity, such as learning, reading, concentrating or breathing. Many students who do not qualify for an IEP under IDEA are eligible for a 504 plan. Our guide to Section 504 vs IDEA explains how the two laws overlap, and our article on IEP and 504 plan differences compares the plans side by side.
Section 504 regulations: a quick overview
The core of the Department of Education's Section 504 regulations has barely changed since 1977. For school districts, the duties that matter most for day-to-day compliance are:
- Designate a Section 504 coordinator. Districts with 15 or more employees must name at least one person to coordinate compliance and adopt grievance procedures (34 CFR 104.7).
- Find and notify. Districts must identify and locate every qualified student with a disability in their area and let students and families know about their rights (34 CFR 104.32).
- Provide FAPE. Regular or special education and related aids and services must meet each student's individual needs as adequately as the needs of students without disabilities are met (34 CFR 104.33).
- Evaluate before placement and reevaluate periodically. Students must be evaluated before initial placement and before any significant change in placement, and reevaluated periodically (34 CFR 104.35).
- Follow procedural safeguards. Families must receive notice, access to records, an impartial hearing and a review procedure (34 CFR 104.36).
Section 504 does not set exact deadlines for evaluations or plan reviews. OCR has long pointed districts toward IDEA timelines as a reasonable benchmark, and many states and districts adopt them in local policy. When in doubt, following IDEA timelines gives us a consistent, defensible standard.
Where Section 504 stands in 2026
Several years of headlines about "new 504 rules" have left many teams unsure what applies. Here is the current position for K-12 districts.
- Section 504 requirements haven't changed. In May 2022, the Department of Education announced plans to update its Section 504 rules, but never published the proposed changes. The existing rules remain in place. In July 2026, the Department removed outdated guidance on vocational education and related references. It confirmed that schools still have the same responsibilities under Section 504 (Federal Register, July 23, 2026).
- Federal guidance and enforcement are shifting. OCR's staffing, priorities and guidance have changed during 2025 and 2026. The underlying law has not. Families can still file complaints with OCR, request due process hearings and bring claims in court, so strong local records matter as much as ever.
The practical takeaway: the duties in Part 104 are the same ones districts have always had. What protects students and districts alike is consistent practice and clear documentation.
Why Section 504 reporting matters
Reports are how a district shows its work. When a family asks whether accommodations are happening, when a state monitor visits, or when OCR opens an investigation, the question is always the same: can we show what we committed to and what we delivered?
Regular reporting helps 504 teams to:
- Spot overdue evaluations and plan reviews before they become compliance findings.
- Confirm that every accommodation and service in a plan is reaching the student.
- Answer family questions quickly and with confidence.
- Prepare accurate Civil Rights Data Collection (CRDC) submissions.
- Give leaders a clear view of caseloads, trends and equity across buildings.
It also frees coordinators, counselors and teachers from chasing paperwork, so more of their time goes to students. That is what neuroinclusive practice looks like at a system level: processes that make sure every learner, including neurodivergent students and students with health needs, receives the support written into their plan.
8 must-have Section 504 reports
These are the reports we see districts rely on most. Each one answers a specific compliance question.
1. 504 student roster report
What it shows: a single view of every active, pending and recently exited 504 student.
Typical fields: legal name, student ID, date of birth, grade, building, case manager, enrollment status, eligibility status, disability category, plan start date and next review date.
Who uses it: district compliance officers, 504 coordinators, school counselors and building administrators.
Why it matters: child find under Section 504 means every eligible student must be accounted for. A roster report shows caseloads by building, flags students who have changed schools, and confirms that no student has slipped through the gaps between enrollment and eligibility.
2. Evaluation and eligibility timeline report
What it shows: every open referral and evaluation, with key dates from referral and consent through to the eligibility decision.
Typical fields: referral date, consent date, evaluation start and completion dates, eligibility meeting date, decision, days elapsed and assigned staff.
Who uses it: 504 coordinators, evaluation teams and building administrators.
Why it matters: unreasonable delays in evaluation are among the most common issues in Section 504 complaints. Because the law sets no fixed timeline, a district needs evidence that it follows its own policy consistently. This report makes delays visible while there is still time to act.
3. 504 meeting and plan review report
What it shows: a record of every 504 meeting, including eligibility determinations, plan development, annual reviews and re-evaluations.
Typical fields: meeting type, scheduled and actual dates, next review date, location, attendees and roles, attendance method, signatures or digital confirmation, key discussion points and outcomes.
Who uses it: 504 team members, 504 administrators and compliance auditors.
Why it matters: this is your evidence during audits, OCR complaints or due process hearings. Filtering by meeting type or date range answers questions such as "how many initial evaluations did we complete last year?" or "which annual reviews are overdue?". It should include historical meetings for students who have moved, exited or become inactive, because complaints can reach back into past school years.
4. 504 accommodations report
What it shows: every approved accommodation for each student, with implementation details.
Typical fields: student name and ID, grade, building, case manager, accommodation description and category, implementation instructions, associated classes or teachers, and review dates.
Who uses it: general and special education teachers, 504 coordinators and families.
Why it matters: a 504 plan only works if the accommodations happen in every class, every day. This report gives each teacher a clear list for their students and gives coordinators evidence for compliance reviews. Many districts pair it with an implementation checklist or log. Section 504 does not require these checks, but they are widely regarded as best practice. For a refresher on the distinction teams need to get right, see our guide to accommodations vs modifications.
5. 504 services report
What it shows: the related services each student is meant to receive under their plan, and whether those services are being delivered.
Typical fields: student name and ID, grade, building, case manager, service type (such as counseling, occupational therapy or physical therapy), frequency, duration, minutes per session, start and end dates, responsible staff, location, delivery status, implementation notes and parent notification status.
Who uses it: 504 coordinators, service providers, administrators and families.
Why it matters: missed services are a direct FAPE concern. Listing each service on its own line makes gaps easy to spot, for example a counseling service with no sessions logged this month, so the team can arrange make-up time before it becomes a complaint.
6. Health plan services report
What it shows: an overview of health-related services and accommodations across student health plans and 504 plans.
Typical fields: student demographics, assigned nurse or health aide, health conditions, severity, allergies, prescribed medications, nursing services, service frequency, and responsible and backup staff.
Who uses it: school nurses, health services directors, 504 coordinators and families.
Why it matters: many students are eligible under Section 504 because of health conditions such as diabetes, epilepsy, severe allergies or asthma. This report confirms that medical accommodations are in place, that trained backup staff are named, and that the district is ready for audits and emergencies alike.
7. Discipline and change of placement report
What it shows: disciplinary removals for students with 504 plans, totaled per student across the school year.
Typical fields: student, incident date, removal type (in-school suspension, out-of-school suspension, expulsion, alternative placement), days removed, cumulative days, whether a pattern of removals exists, and the date and outcome of any reevaluation or manifestation determination.
Who uses it: 504 coordinators, building administrators and district discipline leads.
Why it matters: under 34 CFR 104.35, a significant change in placement requires a reevaluation first. OCR has long treated an exclusion of more than 10 consecutive school days, or a series of shorter removals that forms a pattern, as a significant change in placement. That triggers a review of whether the behavior is caused by the student's disability, often called a manifestation determination. A running total of removal days per student is the simplest way to catch this threshold before it is crossed.
8. Demographic and CRDC report
What it shows: counts of students served under Section 504 only, broken down the way the federal Civil Rights Data Collection requires.
Typical fields: enrollment by race, sex and English learner status; suspensions, expulsions and alternative school transfers; restraint and seclusion; law enforcement referrals and school-related arrests; students harassed or bullied on the basis of disability; threat assessment referrals; and AP and IB enrollment.
Who uses it: district data and assessment leads, 504 coordinators and senior leaders.
Why it matters: The Civil Rights Data Collection (CRDC) is mandatory for public school districts and usually takes place every two years. For 2025–26, schools must report data on students supported under Section 504 alone, including enrollment, discipline, restraint and seclusion, harassment and bullying, and participation in Advanced Placement (AP) and International Baccalaureate (IB) programs.
Keeping this information together with Section 504 records can make reporting easier, reduce manual counting, and help prevent errors. It also helps school leaders spot differences in how students are treated and supported across schools and student groups, so they can take action earlier.
Turning reports into a routine
Reports help most when they are part of a regular rhythm rather than something we pull together the week before an audit.
- Weekly: check the evaluation timeline report and upcoming meetings, so referrals keep moving and families get timely notice.
- Monthly: review the services, accommodations and health plan reports with building teams, and follow up on any gaps in delivery.
- Each grading period: check the discipline report for students approaching 10 cumulative days of removal.
- Each semester: run the roster and meeting reports to confirm plan review dates, caseload balance and records for students who have moved or exited.
- Annually: reconcile CRDC counts and review the year's data with your Section 504 coordinator and leadership team.
Three principles hold the routine together:
- Document thoroughly. Record how the disability affects a major life activity, and specify each accommodation or service with its frequency, location and method of delivery.
- Follow through. Share the plan or a plan summary with families, relevant staff and, where appropriate, the student. Then check that it is happening.
- Review your policies. Bring teachers, counselors and administrators together each year to review district 504 procedures, and make sure everyone knows who the 504 coordinator is.
Families are essential partners in all of this. Our guide on tools to strengthen parent engagement with 504 plans covers practical ways to keep them informed, and our FAPE checklist helps teams confirm each plan meets the standard.
Section 504 forms and templates
Consistent forms make consistent reports possible. Our free example Section 504 plan template pack includes three core documents that any district can adapt to local policy: a Section 504 plan, a Notice of Meeting and a Prior Written Notice.
Whatever forms you use, keep field names and options the same across every school. When every building records accommodations, services and meeting types in the same way, district-wide reports become accurate and easy to run.
How Everway supports Section 504 compliance
Embrace504 brings Section 504 forms, plans, student information and timelines into one web-based system. Compliance checks, due-date alerts and email reminders help teams stay ahead of reviews and reevaluations, while a dashboard highlights overdue annual reviews. Authorized staff can track accommodations, administrators can run reports, and families can view and sign documents through a Parent Portal.
For districts already using EmbraceIEP, Embrace504 runs on the same platform, so special education and Section 504 records sit side by side. Explore our wider special education solutions to see how it fits together, or talk to our team to see Embrace504 reporting in action.
Frequently asked questions about Section 504
What is Section 504 compliance in schools?
Section 504 compliance means a school district meets its duties under Section 504 of the Rehabilitation Act and the Department of Education's regulations at 34 CFR Part 104. That includes identifying and evaluating students with disabilities, providing FAPE through accommodations and services, following procedural safeguards, designating a 504 coordinator and keeping records that show each student's plan is being carried out.
What reports should a Section 504 coordinator run?
Most coordinators rely on eight core reports: a student roster, an evaluation and eligibility timeline report, a meeting and plan review report, an accommodations report, a services report, a health plan services report, a discipline and change of placement report, and a CRDC report. Together they show who is eligible, what each plan promises, whether it is delivered and what federal data must be submitted.
Are there new Section 504 regulations for schools in 2026?
No. The Department of Education announced plans to update its Section 504 regulations in 2022 but never proposed new rules, so 34 CFR Part 104 still applies. In July 2026 it removed an outdated vocational education appendix without changing districts' obligations. The 2024 HHS Section 504 rule applies to HHS funding recipients and is separate from ED's school regulations.
How often should a 504 plan be reviewed?
Section 504 requires periodic reevaluation and a reevaluation before any significant change in placement, but it does not set a fixed review cycle. Many districts review 504 plans at least once a year and reevaluate every three years, in line with IDEA timelines. Check your state guidance and district policy, and review sooner if a student's needs change.
Does Section 504 require a manifestation determination?
Section 504 requires a reevaluation before a significant change in placement, and OCR treats a removal of more than 10 consecutive school days, or a pattern of shorter removals, as one. Part of that reevaluation is deciding whether the behavior is caused by the student's disability. Tracking cumulative removal days for every 504 student helps teams meet this requirement on time.
Do Section 504 students count in the Civil Rights Data Collection?
Yes. The CRDC asks districts to report students with disabilities served under Section 504 only, separately from students served under IDEA. The 2025-26 collection includes Section 504 data on enrollment, discipline, restraint and seclusion, disability-based harassment, law enforcement referrals and advanced coursework, so accurate 504 records make CRDC reporting far easier.
