An investigation into education plans at UAHS including IEPs and 504s.


Publicly educating students in the United States is complicated. Meeting the widely varying needs of students requires a lot of time, knowledge and effort. Each student learns differently, and each student has different capabilities. Some students may qualify for gifted services, while a majority of students are considered ‘on-level’ and do not qualify for any additional assistance. There is, however, also a third group of students that needs additional help to learn and qualifies for either additional services through an Individualized Education Plan (IEP) or additional accommodations through Section 504 Plans (504).

When a student is struggling, a parent can request that a school psychologist complete a Multi-factor Evaluation (MFE) to determine if there is a problem affecting the student’s ability to learn. An MFE includes a series of tests that are designed to identify academic issues and is usually conducted over several days in order to not overwhelm a student. Once a conclusion is reached, a student may qualify for an IEP or 504. Each plan has its own unique arrangement that is designed to fit a student’s needs and can involve daily services from an Interventional Specialist (IS) or classroom accommodations such as extra time on tests. So what is the difference between an IEP and 504?


Through legislation titled the Individuals with Disabilities Education Act (IDEA), the United States federal government says that a student with a disability who could qualify for an IEP is a school-age child who has been evaluated and determined to have a discrepancy between their intellectual capacity and academic achievement and identified as having one of 13 specific disabilities that adversely affects the child’s educational performance, therefore needing special education and related services.

The 13 disabilities that make students eligible for an IEP, in order from most common to least common, include Specific Learning Disabilities (Dyslexia, Dysgraphia or Dyscalculia), Speech or Language Impairments, Other Health Impairments (ADHD, Executive Functioning problems), Autism, Developmental Delay, Intellectual Disabilities, Emotional Disturbance, Multiple Disabilities, Hearing Impairment (including deafness), Orthopedic Impairment, Traumatic Brain Injury, Visual Impairment (including blindness) and Deaf-Blindness.

“It might be other health impairments that affect your learning, but you have a deficit and you’re working towards getting better at that deficit,” Upper Arlington High School Individual Needs Center teacher Kim Wilson said.

Approximately 19.3% of Upper Arlington PK-12 students or 14.6% of UAHS students have IEPs. If a student is identified with a disability after undergoing an MFE, an IEP is written by an IEP team that consists of parents, teachers, administrators and other service providers. The IEP then documents the student’s needs, the goals that address those needs and how the team plans to help the student meet those goals. Services, such as assigned Intervention Specialists and access to specialized learning areas like the Individual Needs Center (INC) at UAHS, encompass an IEP student’s learning process. 

“You have to do the correct assessments and you have to go through all of the steps in order to get an IEP,” Nicole Holder, an Individual Needs Center teacher at Upper Arlington High School, said. “And the reason for that is because an IEP shouldn’t be the answer. It really should be, ‘how can we support the student with as little support as possible, but also give that student as much access to the curriculum’?’”

Everyone in the Upper Arlington High School INC classrooms is on an IEP plan. Part of Holder and Wilson’s roles as teachers within this class is to create lesson plans that fit every student’s distinctive standards while learning in one collective space. 

“The big word that you’ll hear especially when thinking about IEPs is differentiation,” Holder said. “And so that’s when you take something like one big lesson plan and divvy it up to meet each student’s needs.” 

IEPs differ from 504s mainly because they consume a student’s learning experience completely. Advisors are placed for supervision over students, and large measures are taken to create the best learning environment for each student.

Sam Carine, a student at Upper Arlington High School, has an IEP that includes accommodations like extended time on tests, working alone for group projects if desired and no more than a 20% reduction in grade for late assignments.

“What I like about my IEP is that it helps me be organized, which is something I really struggle with,” Carine said.

WHAT IS A 504?

On the other hand, if a student is experiencing challenges, but after undergoing an MFE is not determined to have a large discrepancy between their intellectual capacity and academic achievement, they may be identified as having other disabilities under Section 504 of the Rehabilitation Act. Section 504 of the Rehabilitation Act of 1973 is a federal law which prohibits discrimination against people with a handicap in any program receiving federal financial assistance. The act defines a person with a handicap as anyone who has a mental or physical impairment that substantially limits one or more major life activities including caring for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning and working.

Depending upon a student’s specific 504 struggle, such as ADHD or anxiety, they can request accommodations – not services – that might be able to help with academic performance. Some 504 directives can include extra time for tests, specific seating placement within classrooms or written directions for classwork. 504 accommodations can address a student’s academic, non-academic or extracurricular needs.

“My 504 just allows me to have extended time on assignments and tests,” said Ellison Kase, a junior at Upper Arlington High School with a 504 plan. “I go into a testing center just [to] find different alternatives instead of taking it in a classroom.”

Roughly 6.4% of UA students PK-12 or 11.6% of UAHS students are on a 504 plan, and yet both staff and students feel the majority of the student body still remains uneducated in many aspects. Because of this, students can feel unsure if they are in need of a 504 plan or even an IEP and don’t recognize when to reach out for this help.

“I don’t think the general student really understands, and I honestly don’t think the general teacher really understands truly what [a 504] is and why you would need one,” Wilson said. 

Kase shares this observation, noting the absence of conversation regarding 504s. 

“I feel like there’s still a lack of awareness of them,” she said. “They’re really flexible, so I feel like there are some instances where students don’t really know when and what they can use them for. And [there’s] just kind of a gray area.”

Another factor that shadows over 504s is the comparison of IEPs. IEPs provide a more dramatic shift in learning due to a larger range of students with more deficits that can require an entirely different schedule and curriculum. 504s include more subtle accommodations, like allowing students an extension on assignments or extra time given for a test.


While both IEPs and 504s benefit students, the management of these plans falls to different figures within the education system. Intervention Specialists are responsible for implementing and servicing IEPs, while each classroom teacher is responsible for meeting any accommodations for 504s and IEPs. This can become a daunting task for teachers if they have the UA district average of 19% IEPs and 6% 504s in each class.

“Ensuring that all accommodations are implemented for both IEP and 504 meetings is the teacher’s responsibility,” Jaclyn Angle, the director of student services at UAHS, said. “And depending on how many students a teacher has with accommodations, it can be challenging.” 

Classroom teachers, who could have gifted, on-level and IEP/504 kids, must not only tailor their teaching methods to a wide-range of capabilities, they also have to schedule around IEP Intervention Specialists and meet IEP and 504 accommodation requests. 

“I think that the paperwork is daunting and overwhelming. And so for a lot of teachers, it’s a lot because they maybe weren’t educated on the background of it and why it is and what it is,” Wilson said.

There is also an issue of transitioning through grade levels and how services and accommodations shift from elementary school to high school and through college. Senior Gwyn Jones, who has an IEP plan, has had first hand experience with the chaos of managing every student’s needs and maintaining an IEP through multiple schools and grade levels.

“In middle school, I felt like my IEP really helped me, but the IEP teachers at the high school have so many students that you don’t get as much help,” Jones said. 

But there are steps that can be taken to improve this situation. To take the burden off of teachers, Holder and Wilson propose switching focus to the education plans rather than the educators themselves.

“Really, the education system needs to change to support concepts like mental health or to support more 21st century skills,” Holder said.

A large part of having a specialized plan also comes down to the students themselves. The classroom teachers and Intervention Specialists can specialize their teachings and meet accommodations, but the students play a huge role in their own success, especially as they get older.

“My IS is super helpful and to be honest it comes down to me just not doing the work, so the IS can only do so much,” Sam Carine said. 


Managing the special education of students is hard for families, classroom teachers, intervention teachers and administrators. With 19% of UA school district kids on IEPs and 6% on 504s, the need for academic help in Upper Arlington is clearly large and appears to only be growing. The good news is that there are two meaningful options through which struggling students can find help.