$0 Pennsylvania Dispute Letter Starter Kit

How to Get a 504 Plan in Pennsylvania: The Step-by-Step Process

Your child has a diagnosis — ADHD, anxiety, a learning disability, diabetes, asthma — and they're struggling in school. The school may suggest a 504 plan, or you may have to push for one yourself. Either way, knowing how the process works in Pennsylvania gives you the leverage to move it forward efficiently.

Pennsylvania's 504 process operates under Chapter 15 of the Pennsylvania Code (Title 22), which implements Section 504 of the Rehabilitation Act of 1973. Here's how it actually works.

Who Qualifies for a 504 Plan in Pennsylvania

Chapter 15 covers "Protected Handicapped Students" — students who have a physical or mental impairment that substantially limits one or more major life activities, but who do not require specially designed instruction. If a student needs specially designed instruction, they should be evaluated for an IEP under Chapter 14 instead.

Major life activities include learning, reading, concentrating, thinking, communicating, caring for oneself, and walking, among others. The threshold is "substantial limitation," not complete inability. A student with ADHD whose ability to concentrate is substantially limited compared to most students qualifies. A student with Type 1 diabetes who needs accommodation during testing or for blood sugar monitoring qualifies.

The 504 plan delivers accommodations and related aids, not individualized instructional goals. That distinction matters: if your child's primary need is accommodations (extended time, preferential seating, reduced homework load, access to a quiet testing environment), a 504 plan is the right vehicle. If they need a fundamentally different instructional approach — specially designed instruction — they need an IEP.

Step 1: Submit a Written Request

You can request a 504 evaluation verbally, but written requests create a paper trail and are far more effective. Address the letter to the principal or the district's 504 coordinator. State clearly:

  • Your child's name, grade, and school
  • The disability or medical condition you believe qualifies them
  • The specific ways the condition substantially limits a major life activity
  • A formal request for a 504 evaluation under Section 504 of the Rehabilitation Act and Chapter 15 of the Pennsylvania Code

Keep a copy. Note the date you sent it. If you send it by email, save the sent confirmation.

Pennsylvania's Chapter 15 does not set a specific timeline for responding to a 504 evaluation request the way Chapter 14 sets a 60-day timeline for IEP evaluations. However, unreasonable delays are themselves a potential Section 504 violation. If the school is stalling, follow up in writing and reference the date of your original request.

Step 2: The District's Evaluation

The district must evaluate the student to determine whether they have a qualifying disability and whether that disability substantially limits a major life activity in the educational context. This is typically less extensive than a full IEP evaluation — the district may review existing medical records, diagnostic reports, and teacher observations rather than conducting extensive new testing.

You can and should provide supporting documentation. If your child has a diagnosis from a psychologist, pediatrician, or specialist, provide a copy of the evaluation report or diagnostic letter. The more clearly the documentation connects the diagnosis to educational functioning, the harder it is for the district to deny eligibility.

The district may not require a specific type of evaluation or insist that your child be evaluated by a school psychologist. The law requires that they evaluate; it does not mandate a particular assessment format.

Free Download

Get the Pennsylvania Dispute Letter Starter Kit

Everything in this article as a printable checklist — plus action plans and reference guides you can start using today.

Step 3: The 504 Meeting

If the district determines your child qualifies, the team meets to develop the Chapter 15 Service Agreement (the 504 plan). This meeting should include you, a district representative with authority to approve services, and relevant school personnel who know your child's educational needs.

Come prepared with a written list of the specific accommodations your child needs and the educational data that supports each one. General accommodation lists are a starting point, but the most effective 504 plans are specific: "extended time of 1.5x on all timed tests and assignments" rather than "extended time."

Common accommodations in Pennsylvania 504 plans include:

  • Extended time for tests and assignments
  • Preferential seating (near the teacher, away from distractions)
  • Reduced homework quantity with the same rigor
  • Access to a quiet testing environment
  • Printed copies of notes or lecture outlines
  • Use of a calculator for non-math assessments
  • Check-in/check-out systems with a trusted adult
  • Modified restroom access or blood sugar monitoring for medical conditions

The resulting document is called a Chapter 15 Service Agreement, not an IEP. It does not have annual goals. It is reviewed periodically, usually annually.

What to Do If the School Refuses

If the district refuses to evaluate or denies eligibility after evaluation, they must provide you with written notice of the decision. Pennsylvania Chapter 15 entitles you to an impartial hearing to challenge this decision.

Unlike IEP disputes, 504 disputes do not go through ODR — the Office for Dispute Resolution handles IEP/IDEA matters. For 504 disputes, you can:

  • Request an impartial hearing directly with the district
  • File a complaint with the U.S. Department of Education's Office for Civil Rights (OCR)

The OCR enforces Section 504 nationally and investigates complaints against school districts. Filing an OCR complaint is free, does not require a lawyer, and has resulted in school districts being required to change their 504 practices.

The Chapter 14 vs. Chapter 15 Decision

One practical issue: schools sometimes steer parents toward a 504 plan when the child actually needs an IEP, or refuse to evaluate for special education because the child "gets by" academically. If your child has been given a 504 plan but you believe they need specially designed instruction, you can request a special education evaluation under Chapter 14 at any time. The existence of a 504 plan does not prevent a child from being evaluated for an IEP.

The Pennsylvania IEP & 504 Advocacy Playbook covers both Chapter 14 and Chapter 15 in detail, with templates for evaluation requests, accommodation requests, and challenge letters when the district refuses. Get the complete toolkit at /us/pennsylvania/advocacy/.

Get Your Free Pennsylvania Dispute Letter Starter Kit

Download the Pennsylvania Dispute Letter Starter Kit — a printable guide with checklists, scripts, and action plans you can start using today.

Learn More →