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Section 504 Implementation Concern Process

When concerns about the implementation of a Section 504 Plan arise, parents and guardians are encouraged to direct their concerns to the persons most closely involved. However, when an informal process fails to provide resolution, a parent may file a formal complaint and seek review at a higher administrative level. Concerns may be submitted by parents, guardians, custodial parents, or students. For the purposes of this process explanation, all complainants will be referred to as “parent”.

Section 504 Parental Rights →


Download a printable checklist to help guide you through this process

Start the Process

Step 1: School Staff Collaboration

  1. The first step is to address the concern or issue with the school staff member who is most directly involved with the implementation concern to reach clarity and/or an agreed-upon resolution.
  2. If the initial attempt to resolve the issue is not satisfactory, the parent can choose to move on to Step 2, completing the Section 504 Implementation Concern Form.

Step 2: Section 504 Administrative Building Coordinator (504 ABC) Review

First page of the 504 Concern Form PDF
Download Section 504 Implementation Concern Form (PDF) →

Parents who are not satisfied with with the staff collaboration in Level 1 may address the concern through the Level 2 process:

  1. Complete Part A of the Section 504 Implementation Concern Form, outlining specific concerns, and submit to the 504 ABC at your student’s school. The 504 ABC will confirm that the parent has attempted to resolve the issue or concern with the classroom teacher or other school-based staff member.
  2. The 504 ABC will provide initial contact to the parent within two (2) school days to review the concerns submitted on Part A of the Form.
  3. The 504 ABC will investigate your concern, complete Part B of the Form and contact you within ten (10) school days to share their findings and possible resolutions(s).
    • If a concern cannot be resolved within 10 school days, the 504 ABC may extend the time up to 10 additional school days, and will notify the parent in writing.
  4. If you are dissatisfied with the finding and/or resolution from the 504 ABC, proceed to Step 3.

Step 3: Principal Review

  1. If the concern is not resolved to the parent’s satisfaction,contact the school Principal and submit a copy of the completed Section 504 Implementation Concern Form that the parent received from the 504 ABC at the end of Step 2.
  2. The Principal will review all documentation related to the parent’s concern and communicate as needed with any individuals involved.
  3. Within ten (10) school days the Principal will contact the parent to review their findings and any possible resolutions.
    • If the parent is not satisfied with the findings and/or resolution of the Principal, the parent may proceed to Step 4.

Step 4: Central Office Review

  1. If the concern is not resolved through the Principal Review in Step 3, the parent may contact the Section 504 Coordinator or their designee and provide a copy of the completed Section 504 Implementation Concern Form.
    • The Coordinator/designee will obtain all applicable documentation from the Principal. Parents may also submit applicable documentation.
  2. The Coordinator will provide a written response within ten (10) school days to communicate findings and possible resolution(s).

Frequently Asked Questions

Expand the questions below toggling the arrow or question header.

What is an implementation concern?

A Section 504 implementation concern is when a parent alleges there is an issue with the delivery of accommodations/services written on their student’s 504 Plan. This may include concerns about how an accommodation is being provided or perhaps a belief that an accommodation is not being provided.

What is the benefit of documenting your concern via the Section 504 Implementation Concern Form?

Once you document your concern via the Section 504 Implementation Concern Form, you are essentially filing a formal complaint. The formal complaint documents and initiates a defined process for resolving the concern.

Do I have to complete the Section 504 Implementation Concern Form when I have a concern about 504 implementation?

No. You may collaborate with the school team to solve the concern starting with the staff member who is most directly involved in the implementation concern as outlined in Step 1 of the Section 504 Implementation Concern Process.

What is the expected timeframe for hearing a response from an implementation concern that was reported?

The start of an investigation regarding a Section 504 implementation concern begins with a signed form with Part A completed. The timeline for an implementation concern begins on the date when the form is received by the Section 504 Administrative Building Coordinator (504 ABC) to which it has been directed. The process has the following time requirements:

  • The 504 ABC has two (2) school days to connect with the parent to review the concerns outlined on the form.
  • After that discussion, the 504 ABC completes Part B of the form and responds to the parent within 10 school days of the discussion. However, if the 504 ABC determines they will not be able to resolve the concern in the initial 10 school days following the discussion, they will inform the parent that an additional 10 school days will be required.
  • If the process is escalated to the school’s Principal in Step 3, the Principal has two (2) days to make contact with the parent to review their concerns and then has ten (10) additional school days to review and respond.
  • If the response by the Principal is not satisfactory, the complainant can contact the Section 504 Coordinator who will review the concern and respond in writing within 10 school days.

What should I do if I requested my concern to be reviewed by the Section 504 Coordinator and am still not satisfied? Should I escalate the concern to the Superintendent?

If you have exhausted all steps of the Section 504 Implementation Concern Process and are still unsatisfied with the responses from the HCPSS school-based staff and Section 504 Coordinator, please review your parental rights under Section 504 for additional avenues. Section 504 Parental Rights can be found at www.hcpss.org/academics/section-504/due-process-right