504 plans can create some uncertainty for school based therapists. What is my role? How is a student eligible? What is my service delivery model? Can I provide a service to the student? or not?
504 is not the default for a student who is not eligible for IDEA services. It involves a separate discussion with a team of professionals that know the student well and evaluation to see if a student qualifies for 504 support. 504 is legally supported by the Office of Civil Rights; if a student is eligible for the plan, services from an OT or PT cannot be denied by administration if it is needed for access and participation.
Under 504, disability is broadly defined. 504 eligibility comes through the evaluation process and the student meeting the definition of having a disability: a physical or mental impairment which impacts a major life function, such as walking, reading, seeing etc.
The Pacer Center has an excellent flow sheet to assist a team with making decisions regarding the need for a 504 plan as opposed to IDEA supports. https://www.pacer.org/parent/504/
Services to the 504 student are generally accommodations. That being said, it may be educationally relevant and necessary to support the student directly in order for them to participate and meet classroom expectations. The school based practitioner should provide the services the student needs.
The 504 Plan document should include what the accommodations are, who is responsible for providing them and the method of implementation. Goals and objectives are generally not part of the 504 document; however, you should document your services and outcomes as part of your licensure documentation as required by your state practice act. Examples of accommodations that a OT or PT might provide is an extra set of books for a student with JRA or headphones for a student with autism during fire drills if the noise causes them to have negative behavioral responses making them unsafe during an evacuation. The 504 Plan should be revisited every year; the team should reconvene to ensure student success with the current accommodations and or update accommodations.
IDEA requires us to communicate progress as part of the IEP process; 504 does not. However, it is incumbent on us as professionals to communicate to our parents and caregivers that (1) we have provided the supports listed on the 504 plan and (2) what the outcome of those supports/services have been "leveling the playing field" for their student- safe access and participation in school related activities and routines.
Sequoia has created a 504 annual report form just for this purpose. As part of your practice this year, consider using a report that documents your 504 student's success during school year 23-24.