Services, Support & Safety » Clackamas Middle College 504 Guidance

Clackamas Middle College 504 Guidance

Section 504 of the Rehabilitation Act of 1973 prohibits discrimination against students and/or employees with disabilities. This guide provides information on Section 504 and the obligations of the North Clackamas School District.
Clackamas Middle College prohibits discrimination and harassment on any basis protected by law, including but not limited to, an individual’s perceived or actual race, color, religion, sex, sexual orientation, national or ethnic origin, marital status, age, mental or physical disability, pregnancy, familial status, economic status, veterans’ status, or because of the perceived or actual race, color, religion, sex, sexual orientation, national or ethnic origin, marital status, age, mental or physical disability, pregnancy, familial status, economic status, veterans’ status of any other persons with whom the individual associates.


North Clackamas School District Student Services Department: 503-353-6133
Provided below is the Oregon Department of Educations comprehensive manual regarding Section 504. Please refer to the manual below for initial guidance and contact the CMC for further guidance.
504 Parent/Student Rights
Procedures for Serving Students with Disabilities under Section 504


1.  Concern

A parent or school personnel brings a concern to the school intervention team.

The district 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.


Each school in the district has an intervention team. Any teacher, counselor or other school personnel, or a student’s parent, may bring a concern to the school’s team, including concerns about students with possible disabilities.


As with Special Education referrals, in situations involving learning, behavioral, or emotional concerns, the school team will try tiered interventions through the MTSS / Student Study Team process before proceeding with 504 consideration. (If a parent is specifically requesting 504 consideration, these processes may be implemented simultaneously.)


The Intervention team meets to act on the concern.

The Intervention team meets to review the concern, along with any accompanying evaluations, reports or other written materials.


If the Intervention 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 Intervention 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.

2.  Evaluation, Eligibility, and 504 Plan

All 504 decision-making must be by a knowledgeable team.


The 504 team must include:

    • 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 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 (such as learning, concentrating, thinking, speaking, breathing, sleeping, other bodily functions, walking, hearing, seeing, etc.)


The evaluation process begins 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, 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 gets written parental consent on the Prior Notice/Parent Consent to Evaluate form. Once the parent gives written consent, the 504 team completes the evaluation.


If 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.


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.


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:

    1. whether the student has a disability under Section 504, and
    2. 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.


Steps to 504 Accommodation Plan:

    1. Gather appropriate 504 team. See 504 Meeting Planner: Who to Invite.
    2. Review student’s educational history, prior evaluations and present status.
    3. Review any new evaluations.
    4. Review what prompted 504 consideration at the present time.
    5. Determine whether student has a mental or physical impairment under Section 504.
    6. If yes, determine whether impairment substantially limits a major life activity. Major life activities include hearing, seeing, breathing, learning, walking, speaking, thinking, concentrating, reading, bodily functions (neurological, respiratory, endocrine, bowel/bladder, etc.) 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.
    7. 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

a. 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.


b. 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.

A new medical statement is not required unless there is reason to think that student’s medical condition has changed.


c. In addition, the 504 team must review the student’s 504 plan before any significant change in placement. A significant change in placement includes:

  • expulsion;
  • suspensions of more than 10 days in a row or more than 10 days in a school year if the removals are a “pattern”;
  • moving a student to an alternative education setting to address needs arising from the disability.

In each of these cases, the 504 case manager will inform the District 504 Coordinator who will facilitate a manifestation determination Meeting.


d. 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.


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.