7 Ways to Resolve a 504 Plan Dispute

You have your 504 plan, and everything is ready to go. But wait, you’re hearing from your child that the school is refusing to follow through with the plan. Or the teacher isn’t providing your child with the agreed-upon accommodations. Or maybe you and the school don’t see eye to eye on what should be in the plan or on how it’s being carried out. Or what if the school denies your child a 504 plan because “they’re getting good grades”? What can you do if you find yourself in these, or similar, situations?

For more information, we spoke to Non-Attorney Education Advocates Hadassah Lynn Foster and Sandy Shove, as well Special Education Attorney Matt Cohen of Matt Cohen and Associates.

Many times, a good conversation can clear things up. But sometimes, those disagreements turn into bigger conflicts. The good news is that federal law gives you several paths forward. Most issues get fixed at the teacher/school/district level. If not, we have some formal options you can also take.

Important note about 504 plans: Section 504 of the Rehabilitation Act is a federal law, but how it’s applied can look different from state to state. For example, California has specific rules and procedures that may not exist elsewhere. Because of this, any reference to a particular state’s process — such as how complaints are filed or how hearings are handled—may not apply where you live. It’s important to check your own state’s guidance or talk with a local advocate to understand what applies to you.

Cohen details these steps in this video. We also highlight them in a list after the video.

If things aren’t getting resolved at your child’s school, you can contact the district’s 504 coordinator for an informal review. This is still an informal step. You’re basically saying, “Hey, this isn’t getting fixed at the school level — can you step in?” It’s often faster and less formal, but it depends on how proactive your district is. It also keeps things collaborative, without triggering a formal investigation.

Just a heads-up — different districts may use different titles for this role, so double-check who’s in charge of 504 plans in your area. As Cohen says, “You might talk to the principal, you might talk to the director of special education, or if you're in a school district where you can identify the 504 coordinator, talk to them. You may even decide to go up to the superintendent or the overall district director of student services or special education, as the directors of special education are also responsible for kids with 504 plans.” Keep in mind that every school district may handle things a little differently, so it’s important to check your district’s specific procedures or ask directly if you’re unsure.

You may also have the option of filing a grievance or complaint with the school district, however note that this step is usually taken for complaints against unlawful discrimination, harassment, intimidation, or bullying. This step is a formal internal complaint process the district is legally required to have under Section 504. You put your complaint in writing with the provided form and the district must investigate and issue a written outcome within a set timeline. Note that some grievances are handled under the Uniform Complaint Procedures (UCP), like in California. In other states, it may just be called a “504 grievance procedure.”

Look for the form on the district’s website or ask the district 504 coordinator. In the written grievance, you can state what right under Section 504 you believe was violated, making sure to add facts/timeline and what you’d like changed or updated (e.g., accommodations, training, compensatory services, etc). Participate in any interviews/meetings and request the district’s written outcome.

For example, LAUSD states that if you can’t resolve the issue informally at the local school site, you can file a complaint with their Office of Student Civil Rights under the Uniform Complaint Procedures (UCP). You can find more, and a list of what this can be used for, here. Note that not all complaints fall under the scope of the UCP.

If you decide to file a formal legal complaint, know that this step may vary from state to state. Section 504 doesn’t have a federally mandated impartial hearing process like IDEA does, so states and districts create their own procedures. Most states require complaints or hearing requests to go through the school district (like California), while a few allow parents to file directly with the state education agency or another neutral body. As Cohen explains, unlike special education IEPs, which are overseen by the state, Section 504 is usually managed right at your child’s school district. Since 504 applies to any district that receives federal funding, the district is responsible for making sure your child gets the accommodations they need.

Foster explains that in general, parents can start by filing a complaint directly with the school district — often with the superintendent. From there, the district typically brings in its attorney and begins reviewing what may have gone wrong

In California, for example, Foster explains that parents must file directly with the school district. The district then hires someone to oversee the process, which runs much like an IDEA hearing. First, there’s usually an informal meeting where everyone can talk through the concerns and try to resolve them before things escalate. If issues remain, the next step is mediation, with a mediator hired by the district. And if the case doesn’t settle there, the district must hire a different person to serve as the hearing officer for the actual hearing. Note that some, but not all states, offer alternative forms of dispute resolution, such as mediation.

The impartial hearing is more formal, like a mini-trial run by the district or local education agency (LEA). Think of it as “we tried informal, we tried the grievance process, now we need a legal ruling.” If you're not already in the process, send a letter to the school district, 504 coordinator, superintendent, and/or the overall district director of student services or special education, formally asking for an impartial hearing. Make sure you know the rules that apply to your state. You can hire a special education advocate or lawyer for support and assistance.

At that point, the school district is required to set up a hearing run by a neutral person (not someone directly involved with your child’s plan). Both you and the school are allowed to bring an attorney or advocate to this hearing. Cohen tells us that you have a “right to have a hearing with all of the things that a hearing entails in terms of due process, including the right to give testimony, submit documentation, have an attorney present, cross-examine witnesses, and so on. And then the impartial hearing officer has the power to make a decision about who’s right or wrong, depending on how that comes out.”

It’s important to know that this process looks very different from the due process system under IDEA for IEPs. With IEPs, hearings are managed by your state education agency (for example, in California, through the Office of Administrative Hearings). With 504 plans, however, the hearing process is controlled locally by your school district, also called the local education authority (LEA).

Ignoring Section 504 usually amounts to discrimination. If you believe that your child has been discriminated against due to their disability, you can also file a civil rights complaint with the U.S. Department of Education’s Office for Civil Rights. The OCR handles complaints about disability discrimination, including issues with 504 plans. “The Office for Civil Rights has a responsibility for investigating violations of 504 and for investigating when parents file complaints under 504. Historically, they have also had the power to decide if the school district is right or wrong,” Cohen says. If you file a complaint, the OCR may investigate whether the school is following Section 504. That investigation can result in corrective steps or even changes to your child’s 504 plan.

Note that at the time you file, you can request mediation from the OCR. OCR may suggest early complaint resolution (ECR) as a way to handle a Section 504 complaint. This is a voluntary process where both the parent and the school meet right away to talk through possible solutions. If both sides agree to try it, OCR helps by explaining the legal standards and potential remedies, and guides the conversation toward an agreement. Keep in mind, though: if an agreement is reached, OCR does not monitor whether the school follows through.

Note the timeline: you must file an OCR complaint generally within 180 days of the last discriminatory act. The OCR also doesn’t handle cases that are being addressed within a school’s formal grievance procedure, so once the other complaint process is completed, you have 60 days to file your complaint with OCR. You can also request a waiver of the 180-day limit with reasons.

Something to note as of September 2025: our experts tell us that we’re at a time that is questionable with regard to the Department of Education and the Office for Civil Rights. Cohen tells us, “The priorities, in terms of the Office for Civil Rights, are changing with the current administration, and a lot of the staff at the Office for Civil Rights has been let go. So it’s at best unclear at the moment whether the complaints to the Office for Civil Rights for disability violations will be as likely to be as effective — or even get dealt with at all — as they had been in the past.”