Virginia 504 Plan Transition: Moving from High School to College or Work

The Legal Framework Shifts Completely

Students with 504 plans in Virginia high schools receive accommodations under Section 504 of the Rehabilitation Act. The school is responsible for identifying the student's needs, developing the plan, and implementing the accommodations. The student doesn't have to ask — the system comes to them.

After high school, that school-based framework changes. At a Virginia college or university, Section 504 and the ADA govern accommodations; in the workforce, the ADA applies. In both settings, the individual generally must self-identify and request accommodations.

This is the single biggest adjustment families underestimate during transition. The school has been doing the heavy lifting for years. After graduation, your student is the one who has to initiate everything.

504 vs. IEP: Why the Transition Difference Matters

Students with IEPs have a formal transition planning process built into their program starting at age 14 in Virginia. The IEP team is required to address postsecondary goals, coordinate with agencies like DARS, and document the transition plan annually.

Students with 504 plans get none of that. There's no mandated transition planning, no required postsecondary goal-setting, and no agency coordination written into the plan. The 504 plan simply provides accommodations for the student's current educational program.

This means families of 504-plan students need to do their own transition planning. The school isn't going to hand you a roadmap.

What Changes at the College Level

At Virginia community colleges and four-year universities, the student must:

Self-identify to the disability services office. No one is going to reach out to them. The student walks into the office, fills out an application, and provides documentation.

Provide their own documentation. This is where many families get caught. A high school 504 plan alone may not be sufficient. Each college sets its own documentation requirements:

• Some accept a current 504 plan if it includes the underlying clinical evaluation
• Others require a full psychoeducational evaluation from a licensed psychologist, conducted on adult norms
• Medical conditions typically need documentation from the treating specialist, not just a school nurse's note

Request accommodations each semester. College accommodations aren't automatic. The student registers with disability services, receives accommodation letters, and personally delivers those letters to each professor at the start of the term.

Understand what colleges won't do. Colleges provide equal access, not modified curriculum. They won't reduce course content, change grading standards, or provide personal care attendants. "Reasonable accommodations" at the college level means things like extended test time, note-taking services, priority seating, or alternative format materials.

Preparing During High School

If your student is currently on a 504 plan and plans to attend college, start these steps during junior year:

• Check documentation requirements at target colleges' disability services offices. If they require a current clinical evaluation and your student's 504 was based on testing done in elementary school, you'll need updated testing — and that takes time to schedule and complete
• Practice self-advocacy skills. Can your student explain their disability, describe what accommodations they need, and request those accommodations from an adult in authority? If not, that's a skill to develop before move-in day
• Request a copy of all records from the school before graduation. Once the student leaves, accessing school records becomes much harder
• Explore whether an IEP evaluation makes sense. If your student's disability significantly impacts their educational performance, they may qualify for an IEP — which would give them access to Virginia's formal transition planning process, including DARS Pre-ETS and vocational rehabilitation services

Transition to Employment

504 plan students entering the workforce instead of college face a different accommodation landscape. In the workplace, the ADA requires employers with 15 or more employees to provide reasonable accommodations — but only if the employee discloses their disability and requests accommodations.

Key differences from school:

• There's no 504 plan in the workplace. The employee and employer negotiate accommodations through an interactive process
• The employee decides whether to disclose. Unlike school, where the 504 plan is part of the student's record, workplace disclosure is voluntary
• DARS vocational rehabilitation services are available to 504-plan students too, not just IEP students. If your student has a documented disability and needs employment support, a VR referral is worth exploring before or after graduation

Building a Transition Plan Without One Being Required

The Virginia IEP Transition to Adulthood Guide covers the transition planning framework that 504-plan families can adapt for their own use — the same postsecondary goal-setting, documentation preparation, and agency connections that IEP students receive through their mandated transition process. The guide helps you build the bridge that Virginia's 504 system doesn't build for you.

See more Virginia guides →