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School Accommodations: IEPs & 504s

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This page was developed in collaboration with educators to guide physicians in communicating with teachers and school personnel to ensure that patients receive appropriate education and school-related services.
Six-year-old boy with Down syndrome with fellow pupils in a school setting
The details you provide for school personnel will help determine 1) your patient's eligibility for Special Education, and 2) the exact nature of the child's special needs in the school setting. Your information will also be used in developing his/her Individualized Education Program (IEP), which may include special dietary, personal care, and medical requirements during school hours. The three steps detailed on this page will enable you to facilitate communications between you and the school. You will also find information about common issues and questions primary care providers confront as they work with schools, educators, families, and kids.
Some of the information provided here may vary by state or school district. Check with your state education agency or your local school district for specific information regarding federal regulations and state rules. For information about your state, see "Resources" below or see State Education Contacts and Information.

1. Initiate communication with the school.

School personnel must have parental permission to communicate with providers about patients. The family or the medical provider will need to provide consent from the parent/guardian to authorize transfer of records, verbal and/or email communications, etc., as appropriate. The Family Educational Rights and Privacy Act (FERPA) (USDOE) stipulates different (often more restrictive) guidelines to schools for communicating about students than the Health Insurance Portability and Accountability Act (HIPAA), with which physicians are more familiar. See: HIPAA and FERPA and HIPAA Frequently Asked Questions.
Sample forms to enhance communication between medical provider and schools include the Medical Home - School Information Release Form (PDF Document 49 KB) for students or a Baby Watch Referral Form (PDF Document 156 KB) for an infant or preschool child.
When permission has been obtained, you will need to determine the appropriate contact person at your patient's school. Your patient or their parent will likely have a contact name but, if not, check with your local school district to identify the person to talk with about your patient with special needs. The student’s classroom teacher, school counselor, school nurse, or principal should be able to direct you to the contact person.
Your state school nurse association or board of nursing can help you find a school nurse for your student's school. Your state education agency can help you find a special education director for your student's school. For links to these organizations, see "Resources" below.

2. Request an evaluation.

You can initiate a request for an evaluation for your patient by encouraging the parents to contact the school.
Either a parent or the Local Education Agency (LEA) may initiate a request for an initial evaluation to determine if a student is a student with a disability under Part B of IDEA. [IDEA Regulations: NIMAS access to instructional materials (PDF Document 45 KB)]
If the parental request is considered appropriate, the details you provide will be instrumental in determining how education specialists can best help your patient. If the school does not consider the parental request to be appropriate, the parent may follow the due process as outlined in the state rules. The parent may ask the doctor to provide documentation, as specific as possible, describing the educational and medical need for an evaluation.
If your patient is found eligible, the school may provide a variety of special services, based on the individual needs of the child, which may include:
  • specially designed instruction;
  • dietary accommodations;
  • personal care;
  • medical procedures;
  • transportation to/from school;
  • psychological services;
  • physical and/or occupational therapy services or consultation; and
  • speech, vision and/or hearing therapy services or consultation.

3. Request special services.

If appropriate, you can document recommendations for special services for your patient for the school’s consideration. The sample Medical Home to School Summary Form (PDF Document 40 KB) form provides a list of the most common types of special education services offered.

Evaluation

After receiving the referral from the parent or the (LEA), usually the local school district or school, and the parents’ written Consent for Evaluation (provided by the school), the school team will look at existing data and determine what further evaluation is necessary. Even if the child does not qualify for special education, he/she may be eligible for other services under Section 504 of the Rehabilitation Act of 1973, which applies to all children with disabilities. Section 504 requires schools to make programs and activities accessible and usable for children with disabilities. This may include providing for physical access and special accommodations like modified assignments to help children benefit from their education. If a disability substantially limits one or more of a child's major life activities then Section 504 may apply. (See Eligibility for Section 504 below.)

Eligibility for Special Education Services (IDEA)

A team comprised of school specialists, teachers, the student, and his/her parents, reviews the data from the evaluation and decides if the child qualifies in one of the categories under the Individuals with Disabilities Education Act (Individuals with Disabilities Education Act (IDEA)). Physicians or other professionals may participate in such reviews in person, by phone, or through written communications. In order to receive Special Education, the child must (1) meet the definition of one of the disabilities listed below, (2) adversely affects the student's learning ability, and (3) require specialized instructon to benefit from his/her education. It is possible for a child to have a disability and still not be eligible for services under IDEA if they are able to benefit from education without specialized instruction. The requirements for each category are determined by federal regulations and state rules.
The Federal categories include:
  • Autism,
  • Intellectual Disability,
  • Emotional Disturbance,
  • Hearing Impairments/Deafness,
  • Orthopedic Impairments,
  • Other Health Impairments,
  • Specific Learning Disabilities,
  • Speech/Language Impairment,
  • Traumatic Brain Injury,
  • Visual Impairment (Including Blindness).
Classification depends upon the particular characteristics associated with the condition and how the condition manifests itself in the student. State definitions may vary slightly. For more information about definitions, please see your state education rules and see "Resources" below. Some states may use a different term other than “intellectual disability”. For the Federal definition of a child with a disability, see: Definition for a child with disabilities

Eligibility for Section 504

Those who do not qualify for special education services may qualify for a 504 Accommodation Plan since the eligibility criteria differ. Section 504 protects students with disabilities from discrimination and provides equal access in the educational setting. A 504 Accommodation Plan helps students receive additional supports to assist their participation in educational experiences.
Anyone who meets the eligibility criteria of having a mental or physical impairment which substantially limits one or more major life activities (e.g., caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working) may qualify for a Section 504 Accommodation Plan.

Preschool Children

IDEA eligibility has the same requirements for school-aged students and students ages 3-5. LEAs have a process to find and identify children with disabilities. If there is a concern about a child’s development in the areas of language, social/emotional, motor, cognitive or adaptive skills contact the school district of the child’s residence. The LEA will be able to provide information on how to seek a special education evaluation.

Individualized Education Program (IEP)

Once a student is determined eligible for Special Education, several things happen. First, parents and educators work together to develop an Individualized Education Program (IEP) for the student. The information you have supplied for the referral will also be considered in the development of this plan, including special dietary, personal care and medical requirements. Physicians or other professionals may participate in IEP meetings in person, by phone, or through written communications. Once established, the student's IEP is implemented by his/her school personnel.

Developing the Health Plan

The IEP may include health- or disability-related plans or a separate Individualized Health Plan (IHP) may be developed. [Janz: 1993]
  • If a health issue is identified during an evaluation, the school nurse or the case manager (usually the resource teacher) will request a release of information from the parent to obtain health information from the Medical Home or healthcare providers.
  • The school nurse uses professional judgment to determine if a student requires an individual healthcare plan (IHP) and initiates the IHP to meet student's health needs and the impact on the educational process.
  • The school nurse meets with the parent to take a health history and develop the health plan. The school nurse:
    • Assesses the student to determine the needs and barriers related to student safety and well being;
    • Collaborates with parents and healthcare providers;
    • Coordinates care during school hours;
    • Educates faculty and staff regarding student needs;
    • Promotes communication among family, school, healthcare providers; and
    • Supports the student.
  • The IHP is sent to the parent and healthcare providers.
  • The parent and healthcare provider signs off on the health plan.
  • Ideally, the nurse will attend the IEP meeting to offer health information input.

Dietary Accommodations at School

USDA regulations (7 CFR Part 15b) require substitutions or modifications in school meals for children whose disabilities restrict their diets. Another way you can help your patient is to provide a signed statement clearly defining:
  • the child's disability;
  • an explanation of why the disability restricts the child's diet;
  • the major life activity/activities affected by the disability;
  • the food(s) to be omitted from the child's diet, and food or choice of foods that must be substituted.
Food allergies that may result in severe, life-threatening (anaphylactic) reactions also meet the definition for "disability", and must also be accommodated, with your written statement.
For more information and a sample form see:
Accommodating Children with Special Dietary Needs in the School Nutrition Programs (PDF Document 849 KB)

Medication at School

If your patient will need medication during school hours, you can help by providing as much detail as possible to the school. Although policy on this varies by state, this information will be discussed and, if possible, incorporated into your patient's IEP or Health Plan. For sample forms see: Medication Administration Form (Utah) (Word Document 40 KB) and Asthma Medication Authorization & Self-Administration Form (UDHHS/USOE) (PDF Document 340 KB).

Resources

Information & Support

For Professionals

Individuals with Disabilities Education Act (IDEA)
Official U.S. Department of Education website of the Individuals With Disabilities Education Act including Part B (ages 3-21) and Part C (ages birth-2).

Section 504, Parent Guide, Utah State Board of Education (PDF Document 6 KB)
A Parent Guide to Section 504 prepared by the Utah State Board of Education.

Baby Watch Referral Form (PDF Document 156 KB)
Information referral and release form to exchange information between the Medical Home and early intervention programs in Utah.

Medical Home to School Summary Form (PDF Document 40 KB)
Sample form for communication between health care providers and schools about health concerns that impact a student's education.

Utah State Board of Education Special Education Services
This policy provides detailed, technical information about Utah's Special Education services.

Utah State Board of Education Special Education
A listing of Utah schools, with filters for district and special education.

Utah School Nurse Association
Provides lists of school nurses by district, conference information, newsletters, and links to related sites for teachers and school nurses.

IDEA Regulations 34 CFR Parts 300 (Cornell)
Regulations regarding the Assistance to States for the Education of Children With Disabilities.

Student Placement and Section 504, US Dept. of Education
From the U.S. Department of Education, this website discusses placement of students in elementary and secondary schools in relation to Section 504 and ADA.

Nurse Practice Act Toolkit (NCSBN)
The NCSBN Nurse Practice Act Toolkit, with access to each state's Nurse Practice Act and related information; National Council of State Boards of Nursing.

Find Your Nurse Practice Act
Links to Nurse Practice Acts of states and territories; National Council of State Boards of Nursing.

IDEA Regulations: NIMAS access to instructional materials (PDF Document 45 KB)
A new and exciting addition to IDEA intended to greatly improve access to instructional materials for blind or other persons with print disabilities—textbooks and workbooks, for example. (National Instructional Materials Accessibility Standard NIMAS)

Accommodating Children with Special Dietary Needs in the School Nutrition Programs (PDF Document 849 KB)
Gives a useful guide for nutrition accommodations, including information about modifying school meals for students with disabilities and other dietary requirements such as food allergies. The site includes a sample Eating and Feeding Evaluation form to be completed by the child's parent and physician and a sample Information Card for use by school food service staff in preparing meals for the child. From the U.S. Department of Agriculture Food and Nutrition Service.

Utah School Nurse Medication Guidelines
Provided here are recommendations developed by teams of school nurses in collaboration with community and state resources that correspond to Utah Laws governing School Health Services.

Medication Administration Form (Utah) (Word Document 40 KB)
Sample form to be completed by the parent and medical provider to administer medications to students; gives a good example of a school medication form. From the Utah Schools for the Deaf and Blind.

Asthma Medication Authorization & Self-Administration Form (UDHHS/USOE) (PDF Document 340 KB)
Fillable PDF form that uses standard green, red, and yellow coding to guide treatment alternatives; complies with Utah Code 53A-11-602. Prepared in collaboration with the Utah Department of Health (Formerly UDOH) and Utah State Office of Education, 2016.

School Bus Transportation of CSHCN (AAP)
Policy on transporting CYSHCN on school buses with information about restraining wheelchairs and other equipment, accompanying aides, rescue medications, IEP considerations, emergency plans, and other background information.

For Parents and Patients

A parent's guide to Section 504 in public schools
An article addressing basic questions pertaining to the implementation of Section 504 in public school systems; GreatSchools.org.

Medical Home - School Information Release Form (PDF Document 49 KB)
Sample form for a child's parent/guardian to authorize two-way communication between the health care provider and school team.

Utah Parent Center
A nonprofit organization that provides training, information, referral, and assistance to parents of children and youth with all disabilities including physical, mental, hearing, vision, learning, behavioral, and emotional. Staff consists primarily of parents of children and youth with disabilities.

Office for Civil Rights answers questions about Section 504
Answers to frequently asked questions about Section 504 and education of children with disabilities, from the U.S. Office for Civil Rights.

Center for Parent Information and Resources (DOE)
Parent Centers in every state provide training to parents of children with disabilities and provide information about special education, transition to adulthood, health care, support groups, local conferences, and other federal, state, and local services. See the "Find Your Parent Center Link" to find the parent center in your state; Department of Education, Office of Special Education.

National Center on Secondary Education and Transition
This easy-to-use website provides information about transition during high school and to opportunities after high school including jobs, vocational education, and college. Provides links to contacts in each state for State Transition Contact, Regional Resource Center Contact, State Director of Special Education, Part B Contact, and State Director or Vocational Rehabilitation.

State Education Contacts and Information
This page has contact information for state school resources, including the department of education, the higher education agency, special education agency and adult education agency in any state, commonwealth, or territory; U.S. Department of Education.

IDEA-related Acronyms, Abbreviations, and Terms
From the U.S. Department of Education, alphabetically listed acronyms related to IDEA.

Authors & Reviewers

Initial publication: June 2008; last update/revision: January 2021
Current Authors and Reviewers:
Author: Jennifer Goldman, MD, MRP, FAAP
Authoring history
2012: update: Medical Home TeamA
2008: update: Janet GibbsA; Christine TimothyA; Barbara Ward, RN BSA
2008: first version: Jamie Ferdinand, RN, NCSNCA
AAuthor; CAContributing Author; SASenior Author; RReviewer

Page Bibliography

Janz J, Harrison J, Caldwell T.
Children with Special Health Needs in School: Developing an Individualized Educational Program (IEP) and an Individualized Health Care Plan (IHCP).
Annual Convention of the Council for Exceptional Children, 71st, 1993; San Antonio, TX. / http://eric.ed.gov/ERICWebPortal/custom/portlets/recordDetails/detailm...
Information about the IHCP and how it helps when there is a lack of necessary health information in school documents; includes information about the role of the school nurse in the IEP and IHCP, case examples, and example forms.