Indiana 504 Plan Accommodations: What Schools Must Provide and How to Request Them

A 504 plan is not a consolation prize for children who do not qualify for an IEP. For students whose disabilities substantially limit a major life activity but who do not need specialized instruction, a well-crafted 504 plan can be the difference between a student who struggles through each school day and one who can access their education on equal footing with peers. The problem is that Indiana schools vary enormously in how seriously they take 504 obligations — and parents who do not know what to ask for end up with plans that say little and enforce even less.

What Section 504 Requires in Indiana Schools

Section 504 of the Rehabilitation Act is a federal civil rights law that prohibits discrimination against individuals with disabilities in programs receiving federal funding — which includes every Indiana public school. A student qualifies for a 504 plan if they have a physical or mental impairment that substantially limits one or more major life activities, including learning, reading, concentrating, thinking, communicating, or caring for oneself.

Unlike the IDEA and Article 7, Section 504 does not have its own implementing state regulation in the way that IDEA has Article 7. Indiana schools must comply with the federal Section 504 regulations, and enforcement goes through the Office for Civil Rights (OCR) rather than the Indiana Department of Education's Article 7 complaint process.

This distinction matters: the enforcement mechanism for 504 violations is an OCR complaint or a civil lawsuit, not the I-CHAMP system Indiana parents use for IEP disputes.

Common Conditions That Qualify for a 504 Plan in Indiana

Students with the following conditions frequently qualify for 504 plans in Indiana schools when those conditions substantially limit a major life activity:

• ADHD (attention and executive function limitations)
• Anxiety disorders (learning, social interactions, testing)
• Dyslexia and other reading disabilities when IEP eligibility threshold is not met
• Depression and mood disorders affecting school attendance and concentration
• Physical health conditions (Type 1 diabetes, asthma, severe allergies, epilepsy)
• Traumatic brain injury with residual cognitive effects
• Sensory processing disorders

The key question is not just whether the diagnosis exists, but whether the condition substantially limits a major life activity in the school setting. A student with mild anxiety who functions well academically may not meet the threshold. A student with severe anxiety that is preventing them from completing tests, attending school consistently, or participating in class likely does.

What Strong 504 Accommodations Actually Look Like

The most common mistake in Indiana 504 plans is vague language that gives teachers discretion to provide accommodations inconsistently. Compare these:

Weak: "Student may receive extended time as needed." Strong: "Student receives 1.5x extended time on all timed assessments and in-class assignments requiring sustained written production."

Weak: "Teacher will check in with student during class." Strong: "Teacher conducts a brief check-in at the beginning and middle of each class period to verify student has materials, understands the task, and is on-track."

Weak: "Student may take breaks when necessary." Strong: "Student has a designated calm-down space in the classroom and may access it for up to 5 minutes without requesting permission when they experience sensory overload, at a maximum of twice per class period."

Accommodations must be written specifically enough that any substitute teacher could implement them without judgment or interpretation. If an accommodation requires the teacher to decide when it applies, it will be inconsistently provided.

Specific accommodation categories to consider by condition:

For ADHD:

• Extended time (1.5x or 2x) on all tests and assignments
• Preferential seating away from high-traffic areas and doors
• Chunked assignments with interim check-ins
• Access to fidget tools and movement breaks
• Oral testing as alternative to written for subjects where writing is not the skill being measured
• Homework reduction or modification for practice tasks

For anxiety:

• Extended time, particularly on assessments
• Testing in a separate, low-distraction environment
• Advanced notice of quizzes, tests, and schedule changes
• An identified safe person the student can go to when anxiety escalates
• Permission to step out of class briefly without negotiating each time
• Reduced public speaking requirements (alternatives to oral presentations)

For dyslexia:

• Extended time on all timed tasks
• Text-to-speech tools for reading-heavy assignments
• Audiobook access for class texts
• Spell-check and grammar tools for written work
• Oral testing for content knowledge assessments

For physical health conditions:

• Access to medical supplies (insulin, inhaler) at all times, including during fire drills
• Ability to eat or drink in class if medically required
• Attendance flexibility for medical appointments and health-related absences
• Modified physical education requirements based on physician recommendations
• An emergency health plan attached to the 504 document

How to Request a 504 Evaluation in Indiana

There is no formal 504 referral system in Indiana — schools do not have a uniform process for 504 evaluations the way they do for special education under Article 7. You typically initiate the process by submitting a written request to the school's principal or 504 coordinator, stating that you believe your child has a disability under Section 504 that is substantially limiting their ability to access education.

Attach supporting documentation with your request: a diagnosis from a medical provider or psychologist, recent academic records, and any written communication from teachers about struggles your child is having. The school will then convene a 504 team to review the documentation and determine eligibility.

Unlike IEP evaluations under Article 7, Section 504 does not have a federally mandated timeline for the school's response. Indiana schools should respond within a reasonable time — best practice is 30 to 60 school days — but there is no state-level enforcement mechanism for delays in the same way that I-CHAMP addresses Article 7 timeline violations.

When a 504 Is Not Enough

A 504 plan provides accommodations but not specialized instruction. If your child needs something the classroom teacher is not trained to deliver — explicit phonics instruction, Applied Behavior Analysis, specialized reading intervention, speech-language therapy — a 504 cannot mandate it. Those services require an IEP.

If the 504 plan has been in place for a year or two and your child's performance is not improving despite consistent accommodation implementation, it may be time to request a special education evaluation under Article 7. The evaluation request is separate from the 504 process and triggers Article 7's formal timeline requirements.

If you are navigating both a 504 plan and questions about IEP eligibility, the Indiana IEP & 504 Advocacy Playbook covers Indiana-specific strategies for both tracks, including how to advocate for meaningful 504 accommodations and when to escalate to the IEP process.

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