Is a child required to have an SST before a 504 plan?

A Student Study Team (SST) is sometimes considered the first step to help a student get academic, behavioral, or social-emotional support at school. However, an SST is not a requirement before the school can implement a 504 plan. Section 504 of the Rehabilitation Act does not require that pre-referral interventions be attempted first. Here's what the regulations say:

• Under Section 504, a school must evaluate a student when there is reason to believe that the student has a disability that substantially limits a major life activity and may require accommodations or services.
• The U.S. Department of Education’s Office for Civil Rights (OCR) has made it clear that schools cannot delay or deny an evaluation by insisting that pre-referral interventions (such as RTI or MTSS) be completed first.
• While schools may use interventions as part of a comprehensive evaluation or data gathering process, they cannot require them as a prerequisite for initiating a Section 504 evaluation.

It's possible for the school to write and implement 504 plan first, then hold the SST and use the data from the SST to rework the 504 if needed.

For more information about 504 plans, see our article What’s the Difference Between a 504 Plan and an IEP?