DoDEA 504

Accommodation Plans

Kaisersalutern DistrictRamstein & Kaiserslautern Schools

School Counselors, Nurses & Psychologists

DoDDS-EuropeApril 3, 2013

DoDEA AI 2500.14 Nondiscrimination and 504 Accommodation on the Basis of Disability in DoDEA

“A student with a disability, or who has a record of a disability, or is regarded as having a disability,

shall not be excluded from participating in, or be denied the benefits of, any DoDEA education program or activity;

or be subjected to discrimination based solely on a disability.”

DoDEA AI 2500.14: Policy Nondiscrimination

“DoDEA schools will provide a free appropriate public education (FAPE):

-to students with disabilities

-by implementing reasonable 504 Accommodations

-upon establishing a student has a disability requiring such 504 Accommodation.”

p.2, 4.b

DoDEA AI 2500.14: Policy Accommodation

Establish Accommodation Teams & Team Leaders at beginning of school year

Make adequate resources available

Review accommodation plans annually

Inform teachers of students 504 plans

Receive and resolve parent concerns

Post notices of nondiscrimination

p.5-6

School Responsibilities Principals

Process referrals & evaluate records

Determine eligibility

Prescribe 504 accommodation plans

Leader: Coordinate all aspects of accommodation team process Document decision in writing and provide copy to parent Ensure minutes of meetings are recorded Secure all notices & consents to parents, sponsors, guardians

p.6-7

School Responsibilities Accommodation Teams

Implement accommodations

Participate in accommodation teams

Assist administration in resolution of complaints

School Responsibilities Educators

Identifying Students with Disabilities Initial Identification

When: Any time

By Whom: Parent, teacher, student, counselor, nurse school or medical personnel, community agency

Identify What: Student’s substantially limited performance in one or more major life activities believed to be caused by physical/mental impairment; or

Student records or documents that student has a record of, or regarded as, having a

physical/mental impairment

Referrals for AccommodationsWhen should a student be referred?

Enrolls with a 504 Accommodation Plan;

Has a major health concern, especially if documented on an Individual Health Plan (IHP), that is suspected of substantially limiting major life activity;

Requires physical accommodations to access the school;

Continues to display academic and/or behavior problems after receiving SST services; or

Has been referred to the CSC but the student is ineligible or will not be evaluated

Referrals for AccommodationsRefer for 504 plan or IEP?

504 Enrolls with a 504 Plan Major health concern Requires physical

accommodations for access Academic/Behavior problems

after receiving SST services Determined ineligible for

special education or decision not to evaluate

IEP Enrolls with an active IEP Enrolls with an expired IEP Enrolls with a partially

completed evaluation for special education

Shows poor academic performance and failed response to intervention

Referrals for AccommodationsEvaluation information

The 504 Accommodation Team will evaluate the student’s needs and may consider:

-Records -Observations -Teacher Reports

-Informal/Formal Assessments

*The Accommodation Team may request additional assessments and should develop an assessment plan, obtain parent consent, and provide at no cost to the parent*

Eligibility DeterminationQuestions

1. Does the student have a physical or mental impairment?- “physiological disorder or condition, cosmetic disfigurement, anatomical loss affecting body system, mental or physical disorder”

Mental or physical impairments are notlimited to specific diseases or categories ofmedical conditions.

2. Does the impairment substantially limit a major life activity? - “barrier to student performing major life activity (seeing, hearing,

eating, thinking, concentrating, etc.) compared to other students

NB: If both, “YES,” student is eligible for accommodations

Disability must be the reason why the student cannot equally access from the school’s program and services.

Think: “Level Playing Field”

Access vs. Educational BenefitWheelchair exampleo ADHD example

AND

Simply having a disability or condition does not automatically qualify a student for a DoDEA Accommodation Plan.

The condition or disability must be a barrier to the student performing one or more major life activities as compared to an average student in the general population.

This may be evaluated by considering the manner, conditions, and duration in which a student performs a major life activity in comparison to how non-disabled students perform the same activity.

What does “substantially limit” mean?

Major life activities are basic activities that the average person in the general population can perform with little or no difficulty.

Major life activities include, but are not limited,

caring for oneself, walking, seeing, hearing, speaking, breathing, performing manual tasks, and learning.

What is a major life activity?

Each DoDEA school is responsible A school may elect to use an existing educational team, (other

than the CSC)Parents/guardians will participate on these teams to the

greatest extent possible. The local team reviews the nature of the student’s impairment

to determine how it affects his or her access to educational programs and activities.

If the team determines that the student’s impairment substantially limits a major life activity, he or she will be identified as a qualified student with a disability.

Who is responsible for implementing the DoDEA Accommodation Plan?

The local team will then proceed to develop an individualized DoDEA Accommodation Plan outlining necessary accommodations to ensure the student has educational opportunities and benefits equal to those provided to non-disabled students.

In DoD schools, the GENERAL EDUCATION STAFF is responsible for reviewing 504 eligibility for students and for developing and implementing DoDEA Accommodation Plans.

SST & 504 not necessary prerequisite for CSC referralWhen in doubt in the presence of a suspected disability,

use the CSC processDescribes the 504 meeting as an eligibility meetingSpecifically refers to eligibility questions“unduly burdensome” determined by DoDEA OGCRefers to new Disciplinary Reg and Manifestation

Determination meetings, outcome is different for 504s and IEPs

In 2012, 504 Form was revised

Changes in the 2009 DoDEA AI 2500.14

Accommodations include adaptations and modifications that a student may need to participate in DoDEA programs and activities.

Most reasonable accommodations will occur in the student’s general classroom and involve minor adjustments that enable the student to obtain equal access to learning opportunities.

Reasonable accommodations may include, but are not limited to, a change is the student’s seating arrangement, visual aides, large print educational materials, use of video recordings, and extended time to complete specific tasks.

What are some examples of reasonable accommodations?

Status Report 504 Accommodation PlansDoDDS-Europe as of 5 Nov 2012 n= 319

Grade Distribution

Hearing 12 4% Vision 7 2% Asthma 4 1% Seizure Disorder 11 3% Severe Allergy 5 2% Diabetes 10 3% Heart Condition 0 0% Digestive Disorder 2 1% Cerebral Palsy 0 0% ADD/ADHD 201 63% Dyslexia 17 5% Communication 2 1% Anxiety 25 8% Depression 8 3% Oppositional Defiant Disorder 2 1% Other 81 25%

People may select more than one checkbox, so percentages may add up to more than 100%.

Status Report 504 Accommodation PlansDoDDS-Europe as of 5 Nov 2012 n= 319

By Impairment

Status Report 504 Accommodation PlansDoDDS-Europe as of 5 Nov 2012 n= 319

AccommodationsPreferential seating

167Extended time for testing up to 150%

158Testing in small groups/distraction-free

112Check for understanding/attention 91Verbal and visual cues 90Daily agenda/planner/assignment sheet check 90Shortened assignments 80Task broken down into shorter steps/assignments

64Extended time for task completion 135Use of assistive technology

42change of response mode 8Accommodate for specific allergies 5

People may select more than one checkbox, so percentages may add up

Yes, but only if the accommodation is documented in the student’s DoDEA Accommodation Plan or has been used routinely in the student’s educational program

And is allowed by the test manual

Are reasonable accommodations available during DoDEA system-wide assessments such as the TeraNova exam?

Does not directly apply to all students on 504 Accommodation Plans

A special medical need is determined by threshold criteria for each condition

It is the responsibility of the sponsor/parent to know the thresholds

For 504 plans, the Coding form only requires checking the box and attaching the 504 plan

504 Plans and EFMP Coding

Extended time often helps students regardless of their disability status.

It can change the proper interpretation of students’ test scores.

Decisions about it are not made consistently.Other interventions may help to decrease students’

reliance on it.

Extended Time AccommodationIssues

Q: When working on a 504 plan for a student, do all core teachers have to be present at the meeting?

Q: Can a 504 plan be developed for a student that is suspected of having an impairment or is possibly impaired, but has not been evaluated?

Q: How recent must an evaluation be?Q: May personnel resources be allocated on a 504 plan?Q: Can a 504 Plan be used as a basis for graduation

requirement waivers?

Frequently Asked Questions

504 plans are designed to ensure ACCESS by leveling the playing field

Students with good grades might still experience barriers to access, and could be eligible

Like the SST, 504 Team is General Ed (not Special Ed),identified at beginning of the year, with leader(s) selected.

Alert nurses to 504 protections for students on Individual Health Plans

In regard to Discipline and Attendance Policies, students with disabilities may have 504 protection even without a 504 Plan.

Top 5 Points to Take Away