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Counting "Section 504" Students

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Kudos to Rachel A. Holler, the principal of Stewart Middle School in Norristown, Pa., and go-to special education law expert Perry A. Zirkel of Lehigh University in Bethlehem, Pa., for a recent research article that attempts to take a crack at quantifying just how many "section 504" kids are in public schools. Their work has been published in the March issue of the National Association for Secondary School Principals Bulletin.

But first, a quick primer on "Section 504:" Section 504, a part of the Rehabilitation Act of 1973, actually predates the Individuals with Disabilities Education Act by two years. It prohibits discrimination against people with disabilities by organizations that receive federal money, like schools. One major difference between the two laws is how "disability" is defined. IDEA has 13 disability categories, while Section 504 has a three-part definition that is broader than IDEA. So, though all students covered by IDEA are also covered by Section 504, there's also a smaller group of Section 504 kids who are not a part of IDEA.

Confused yet?

Another major difference is in funding: The federal government provides some money to school districts to educate children in special education, along with a specific legal framework for doing so. Accommodations for Section 504 students is a mandate, but does not come with specific federal funding.

Holler and Zirkel extrapolate their results from 549 surveys sent to public schools. Among the nuggets of information they uncovered:


  • 504-only students represent about 1.2 percent of the population covered by the survey.

  • Districts may be inflating even that small percentage, based on recent judicial opinions that have restricted the definition of a 504 impairment.

  • Attention deficit hyperactivity disorder was the most commonly listed impairment for Section 504 students. Diabetes came next.

  • There was no significant difference in the number of Section 504-only students in a wealthy school compared to a less affluent school.

  • High schools and middle schools had significantly more Section 504-only students than elementary schools.


Principals and others who are in charge of making Section 504 determinations should definitely check this out.

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