Clackamas Middle College 504 Guidance
1. Concern
A parent or school personnel brings a concern to the school intervention team.
Clackamas Middle College (CMC) must find students who may qualify for services under Section 504. This is accomplished by informing school personnel of the characteristics of disabilities, their effects, and the procedures for making referrals.
CMC has a process for identifying students in need for interventions. This team meets bimonthly during its Student Academic Planning (SAP) meetings. This intervention team consists of teachers, counselors, administrators, and other school personnel. A student’s parent or a staff member may bring a concern to the school’s team during these meetings, including concerns about students with possible disabilities.
As with Special Education referrals, in situations involving learning, behavioral, or emotional concerns, the school team will begin the evaluation process if there is a known or suspected disability along with the implementation of tiered interventions through the SAP process before proceeding with 504 consideration if a parent is specifically requesting 504 consideration, these processes may be implemented simultaneously. Physical or mental impairment doesn't require specially designed instruction.
The SAP team meets to act on the concern.
The SAP team meets to review the concern, along with any accompanying evaluations, reports or other written materials.
If the SAP team determines there is a significant possibility that the student would qualify as disabled under the Individuals with Disabilities Education Act (IDEA) or Section 504, the team will make a referral to the special education or 504 team, as appropriate, for consideration of a formal evaluation, and forward all relevant documentation.
504 vs. Special Education Referral
In cases where the student may qualify under one of the IDEA disability categories, the student should go through the special education “child find” process. If the concerns are solely related to medical or health issues (with no or negligible impact on behavior or learning), the referral may go directly to the 504 team.
All 504 decision-making must be by a knowledgeable team.
The 504 team must include:
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- Someone who is knowledgeable about the student;
- Someone who is knowledgeable about the evaluation data; and
- Someone who is knowledgeable about the accommodations/placement options.
The 504 team includes the school counselor as the building 504 coordinator, the student’s teacher and the parent. The team may also include a principal or vice principal, a school nurse or other school personnel. The team composition will vary according to the concern/needs of the student.
The 504 team includes the school counselor as the building 504 coordinator, the student’s teacher and the parent. The team may also include a principal or vice principal, a school nurse or other school personnel. The team composition will vary according to the concern/needs of the student.
The 504 coordinator for the building determines the appropriate individuals to comprise the team in a specific situation. When it appears the student will need supports that will require an allocation of district resources, the District 504 Coordinator must be consulted before the meeting and may need to attend the meeting. The 504 team reviews current information and evaluates as needed.
The 504 team considers the student’s need for a 504 evaluation and what new assessment is needed, if any. An evaluation should be conducted if there is information indicating that the student has a mental or physical impairment that is affecting a major life activity. Here are some examples of mental or physical impairments: learning, concentrating, thinking, speaking, breathing, sleeping, other bodily functions, such as walking, hearing, seeing. These physical impairments are non-exhaustive, and shouldn't be limited to the ones listed above.
The evaluation process begins with parent consent along with a review of existing information. If there is an indication that the student has a mental or physical impairment that may substantially limit a major life activity, then Section 504 eligibility should be considered. The Section 504 team begins by reviewing the evaluation results along with the student’s files, current teacher report of classroom performance, and information from the parents.
If, after reviewing this information, the 504 team concludes that further evaluation is needed, the team will obtain written parental consent on the Prior Notice/Parent Consent to Evaluate form. Once the parent gives written consent, the 504 team completes the evaluation.
f the parent does not attend the 504 meeting, the Notice/Consent may be sent home. If it is not returned, concerted efforts should be made to obtain it. No initial individual evaluation may occur without written consent.
A medical statement is not necessary or a pre-condition to move forward with a 504 evaluation. However, if the team suspects that the student has a mental or physical impairment, the team may ask the parent to provide a Medical or Health Assessment Statement. If the team suspects a physical or mental impairment and the parent does not have access to a physician or health care provider, the district has a responsibility to assist the parent to obtain this information, if needed, to determine whether the student is eligible under Section 504. Please contact the District 504 Coordinator in this circumstance. There are benefits of having a medical assessment, but it is not necessary.
If the 504 team does not suspect a disability after a careful team review of all existing information about the student, the 504 coordinator gives the parents Notice of Section 504 Eligibility form of that decision, along with a copy of the Section 504 Notice of Parent/Student Rights in Identification, Evaluation, and Placement.
The 504 team determines disability and need for a 504 plan.
The 504 case manager arranges a meeting time with the parent to share the evaluation data and determine eligibility/non-eligibility. The 504 case manager sends a written meeting notice to the parent as a reminder of the meeting time and location.
The Section 504 team meets to review the evaluation results and to complete the Section 504 Eligibility Form. This may be done at the first meeting if no additional assessment is needed to determine eligibility and need for a 504 plan. Based on the information from the evaluation and any information from the parents, the 504 team decides:
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- whether the student has a disability under Section 504, and
- whether, as a result of that disability, the student needs a 504 Student Accommodation Plan.
The 504 team develops a Section 504 Accommodation Plan.
If the student needs a 504 Accommodation plan, the team develops the plan for the student on the Section 504 Accommodation Plan form. The district’s expectation is that 504 plans will be written at the meeting and finalized within 10 days days of the meeting. Communication to staff will be made in our SAP meetings within the 10 day period, and to families on an individual basis via phone/written correspondence within the 10 day period.
Steps to 504 Accommodation Plan:
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- Gather appropriate 504 team. See 504 Meeting Planner: Who to Invite.
- Review student’s educational history, prior evaluations and present status.
- Review any new evaluations.
- Review what prompted 504 consideration at the present time.
- Determine whether student has a mental or physical impairment under Section 504.
- If yes, determine whether impairment substantially limits a major life activity. Here are some examples of major life activities including but not limited to: hearing, seeing, breathing, learning, walking, speaking, thinking, concentrating, reading, bodily functions (neurological, respiratory, endocrine, bowel/bladder, etc.) These major life activities are non-exhaustive, and shouldn't be limited to the ones listed above. A substantial limitation means that the student is restricted as to the condition, manner or duration in performing the major life activity as compared to an average student. Do not consider medication or assistive devices when determining whether there is a substantial limitation.
- If yes, determine whether student needs accommodations, services or supports to access the benefits of public education at a level similar to the average student. (May consider medication or assistive devices when determining whether accommodations, services or supports are needed.) If yes, develop a 504 Accommodation Plan.
Give parents a copy of the 504 documents.
The school’s 504 coordinator gives the parents a copy of the written evaluation and the Section 504 Eligibility Determination Report, Section 504 Accommodation Plan, and the Section 504 Parent/Student Rights.
3. Cumulative File
All 504 documents for a student must be placed in the student’s cum file. The 504 case manager may retain copies of the documents for everyday access.
4. Synergy Reporting
Once a student is found eligible for 504, the 504 case manager will finalize the process in Synergy. This will create a 504 flag, informing the student's teachers of the 504 plan.
5. Implementation
The 504 case manager is responsible for informing the student’s teachers about the accommodations on the student’s 504 plan. Any new teachers must be notified when there is a schedule change. In addition, 504 plans should be maintained in each teacher’s sub file so substitute teachers are informed of needed accommodations. Other staff may need to be informed of the 504 plan depending on the provisions in the plan. The 504 case manager should periodically check in with the student and the student’s teachers to ensure the plan is effectively being implemented. Any concerns about implementation should be brought to the attention of the building 504 coordinator, building administrator or district 504 coordinator, as appropriate.
6. Periodic Re-Evaluation
- Three Year Evaluation: At least once every three years the 504 team must reconsider whether the student is still disabled under Section 504. At this meeting, the 504 team will consider:
• the need for additional evaluation information;
• the student’s continued eligibility under Section 504; and
• the content of the Section 504 Plan. - Annual Review of 504 Plan: Each student's Section 504 Plan must be reviewed at least annually. At this meeting, the 504 team reviews the current 504 plan and revises as needed.
- Section 504 requires a school district to conduct a re-evaluation prior to a significant change of placement.
- Office for Civil Rights considers an exclusion from the educational program of more than 10 school days a significant change of placement.
- Office for Civil Rights considers transferring a student from one type of program to another
- Office for Civil Rights considers terminating or significantly reducing a related service a significant change in placement.-OCR 1/10/2020
- A reevaluation under Section 504 does not require consent but does require notice. However, Oregon law requires parent consent before conducting an intelligence test or a test of personality, including behavior checklists.
The Annual Review of the 504 Plan may be revised to be support each student.
A new medical statement is not required unless there is reason to think that student’s medical condition has changed.
In matters of disciplinary action that results in school exclusion, the 504 case manager will inform the District 504 Coordinator who will facilitate a manifestation determination meeting. The manifestation determination meeting must be held prior to the 10th day of school exclusion.
7. Functional behavior assessments
- Effective July 1, 2018, under Oregon HB 3318 (2017), staff must complete a functional behavior assessment for any student on a 504 plan (or IEP) who engages in behavior that puts the student, other students or staff at imminent risk of serious bodily injury as a result of the student’s behavior.
- This functional behavioral assessment and a behavior support plan must be completed within 45 school days of parent consent.
- For students eligible for 504 services who already have a behavior support plan, the plan must be reviewed and, if necessary, revised within the 45 day timeline.
NCSD Section 504 Roles and Responsibilities
Role of Building 504 Coordinator/Case Manager – coordinates 504 services in the school or program and coordinates 504 process for individual students
- Provides accurate data to Student Services, updates Synergy, and periodically checks Synergy 504 report for accuracy.
- Participates in district-wide training on Section 504 implementation.
- Acts as contact person in school when questions arise about 504 issues.
- Ensures that staff are using current Section 504 forms and following current procedures.
- Coordinates transition of students with 504s transferring into and out of the school.
- Schedules meetings & sends notices, including periodic reviews as indicated on plan.
- Gathers necessary information for meetings.
- Writes up 504 documents.
- Provides copies of documents to parents, saves in Synergy and puts in student’s cumulative file as applicable.
- Provides information to all teachers that need to know about 504 plan contents, including when the student’s schedule or classes change.
- Verifies implementation of 504 plan and is available to problem-solve when issues or concerns arise.
- Schedules periodic review at least annually or sooner if needed, and before any significant change in placement.
- Primary contact for student and family concerns.
- Completes three year review of eligibility.
Role of NCSD District 504 Coordinator – coordinates 504 implementation in the district
- Ensures that 504 forms and procedures comply with 504 requirements.
- Ensures training for building 504 coordinators, case managers, and others annually and as needed.
- Provides technical assistance and problem-solving on an as needed basis.
- Acts as liaison with Student Services and Technology & Information to ensure 504 student data is accurate.
- Addresses systemic issues related to Section 504 compliance.
- Provides accurate, accessible information about 504 to District community.
- Participates in decision-making when district resources are under consideration.
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- An exclusion from the educational program of more than 10 school days a significant change of placement.
- Transferring a student from one type of program to another
- Terminating or significantly reducing a related service a significant change in placement.-OCR 1/10/2020
- Current students with 504 Services
- Rights upon entry presented to each student receiving 504 Services
- Notification to staff one week prior to the beginning of each term and twice a month during SAP meetings
- Notification to families via email/letter regarding services and parent/student rights prior to annual review and/or re-evaluation.
- Transferring students with 504 Services
- Rights upon entry presented to each student transferring to CMC
- Re-Evaluation of 504 Services within 10 days of enrolling at CMC.
- Notification to staff within 10 days of enrolling at CMC, and twice a month during SAP meetings
- Notification to families via email/letter regarding 504 Services based on re-evaluation meeting within 10 days of enrollment at CMC.
- New 504 student referrals
- Rights upon entry presented for each student referral
- Once a 504 Service referral and consent is received, notification to conduct a 504 Support Team Meeting will be sent to staff and families via email/letter regarding 504 eligibility.
- At the 504 Support Team Meeting, the 504 Evaluation Report will be created and reviewed to finalize 504 Accommodation Plan.
- 504 Accommodation Plan will be created within 10 days of referral at CMC.
- The 504 Accommodation Plan will be communicated to staff in monthly meetings and to families via email/letter when completed.
