Including Students in the 504 Eligibility Process

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When we think about 504 Plans, the process often centers around documentation, diagnosis, and teacher input — all of which are important. But one voice that is sometimes overlooked in the process? The student’s.

Student feedback is a critical (and underutilized) part of determining both eligibility for a 504 Plan under Section 504 of the Rehabilitation Act and identifying the necessary accommodations to support that student’s access to learning.  

Remember - The accommodations should be necessary and are not designed to optimize performance or enhance academic performance.  Accommodations are designed to give students a seat at the table and provide them with equal access to their education.  

Here’s how incorporating student feedback into the process can make your 504 eligibility determinations a more accurate representation of the student's disability through hearing from the expert source - the student.  Including students throughout the 504 process can also make 504 Plans more specific, targeted, and more meaningful...so let's dive in!


1. Student Feedback as Part of the 504 Eligibility Process

To qualify for a 504 Plan, a student must have a mental or physical impairment that substantially limits one or more major life activities. This includes areas like learning, concentrating, thinking, communicating, and more.

While medical or psychological documentation can help confirm an impairment, student voice can provide context that makes a big difference when determining whether that impairment is substantially limiting.

Ask questions like:

📍  What difficulties are you experiencing?

📍 Are there specific times or causes for things becoming harder or more difficult?

📍 What do you think you need in order to be able to learn?

When a student describes barriers they’re facing — things like sensory overload, anxiety spikes during testing, or difficulty focusing for long periods — those insights can paint a clearer picture of how the impairment is affecting access to learning. It helps shift the conversation from “Does the student have a diagnosis?” to “Is this student’s ability to access learning significantly limited — and how?”

2. Using Student Voice to Guide Appropriate Accommodations

Let’s be real — even the most well-intentioned 504 Plan can fall flat if the accommodations aren’t aligned with the student’s actual needs. That’s why it’s so powerful to include students in the conversation about what helps them, what doesn’t, and what they wish teachers knew.

By asking students things like:

  • What strategies have worked for you in the past?

  • What makes learning easier or less stressful?

  • Is there anything a teacher could do to help you feel more comfortable in class?

…you’re not just ticking a box. You’re co-creating a plan that’s personalized, practical, and more likely to be effective.  Plus, it empowers students to develop self-awareness and advocacy skills — two major goals of any support plan.

A Tool to Make It Easy: The 504 Student Survey (Elementary School Level)

This 504 Student Survey can include the student collaboratively throughout the 504 referral process.  For elementary students this may be easier said than done because developmentally they may not be ready, or able to fully:

  • Practice self-awareness and reflection
  • Understand the limitations of their disability or restrictions they are experiencing
  • Identify their needs
  • Use the language an adult would use to communicate

This resource is a simple student-friendly conversation guide to help:

  • Identify what struggles the student experiences

  • Narrow in on specific accommodations and strategies to support the student

  • Learn about the students overall learning style and preferences

  • Match specific challenges and restrictions to pre-written example 504 accommodations

It’s perfect to use:

  • Before a 504 eligibility determination meeting

  • As part of a re-evaluation

  • When revising or updating accommodations

  • As a part of an I&RS / MTSS referral

  • To gather important feedback to collaborate with teachers & parents

  • Or anytime you want to better understand your student’s experience

👉 [Check out the 504 Student Survey here on Super Cool Counseling's Teachers Pay Teachers]


Don't miss out!  - The 504 Plan Ultimate Growing Bundle 

Want to save time and money while getting all the 504 tools you need? Check out my 504 Plan Growing Bundle! It includes all my current 504 resources at a discounted price — plus, when you grab it now, you’ll get access to all future resources I add to the bundle for FREE. It’s a one-time purchase that keeps growing with you. 💡 [504 Growing Bundle on TPT]



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© Super Cool Counseling by Michelle Beech, 2025



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