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An IEP and a 504 plan both help students with disabilities in New York City public schools. They are not the same thing. They come from different laws, they cover different students, and they give different kinds of help. This guide explains each one in plain words, so you can tell which your child has and what that means if services were missed.
IEP Hours is a free, independent information site. We are not the NYC Department of Education (DOE) and we are not a law firm. Nothing here is legal advice, and no one can promise a result. There is no cost to you, now or later.
The short answer
An IEP is a special education plan. It can change how your child is taught and can add services such as speech therapy or counseling. A 504 plan is an accommodations plan. It changes the conditions around learning so your child can take part like other students, such as extra time, a seat near the door, or a nurse visit at lunch.
Think of it this way. An IEP can change what the school delivers to your child. A 504 plan mostly changes how the school removes barriers for your child. Some children need the first. Many children only need the second.
The laws behind each plan
An IEP comes from the Individuals with Disabilities Education Act, a federal special education law, along with New York State rules. In NYC, the DOE's special education office and the Committees on Special Education handle IEPs. You can read the DOE's own steps on its IEP process page.
A 504 plan comes from Section 504 of the Rehabilitation Act of 1973. That is a civil rights law. The DOE says it requires public schools to offer accommodations for eligible students with disabilities, so they can take part in DOE programs and activities on an equal basis with peers who do not have disabilities. In NYC the rules for 504 are set out in Chancellor's Regulation A-710.
Because the two plans come from different laws, the steps, the paperwork and the people in charge are different too.
Who qualifies for an IEP
To get an IEP, a child must be evaluated and found to have a disability that affects learning in school, and must need special education because of it. The evaluation looks at how your child learns, behaves and functions. Our guide what an IEP is walks through the parts of the plan, and how to get an IEP in NYC covers the request, the evaluation and the meeting.
The DOE states that after you give consent, it has 60 calendar days to evaluate your child. That is one of the few timelines worth knowing by heart.
Who qualifies for a 504 plan
The DOE gives a two-part test. A student qualifies for 504 accommodations if they have a physical or mental impairment, and that impairment substantially limits at least one major life activity.
A few points from the DOE's 504 page surprise many parents:
- The limited activity does not have to be learning. A child who does well in class can still qualify.
- Short-term impairments, like a broken leg, may qualify.
- Episodic conditions, like asthma, may qualify.
- Examples include physical disabilities, health conditions, mental disorders and learning disabilities.
So a 504 plan often fits students with diabetes, allergies, ADHD, anxiety or a mobility need who do not need specially designed teaching.
What an IEP can provide
An IEP is a written plan with goals and a list of services. It can include:
- A class setting, such as a general education class with extra support or a smaller special class.
- Special education teacher support, given a set number of times a week.
- Related services, such as speech, occupational therapy, physical therapy or counseling. Our page on related services explains each one.
- Testing accommodations and other supports.
- Goals the school measures and reports on.
The key detail is that an IEP usually says how often, how long and in what group size each service happens. That detail is what makes it possible to count missed sessions later. For a closer read of each section, see understanding the IEP.
What a 504 plan can provide
A 504 plan lists accommodations. Common examples are extra time on tests, breaks, preferred seating, use of an elevator, access to water or snacks, a place to take medicine, or a plan for a health need during the day. The DOE also points families to a separate Diabetes 504 Plan template for students with diabetes.
A 504 plan does not usually set special education teaching goals. It is about access and fairness, not a change to the teaching itself.
Side by side
- Law: IEP, special education law (IDEA). 504 plan, Section 504 of the Rehabilitation Act.
- Who: IEP, a child with a qualifying disability who needs special education. 504, a child whose impairment substantially limits a major life activity.
- What: IEP, services, goals, settings and accommodations. 504, accommodations.
- Who decides: IEP, the IEP team, which includes you. 504, a school 504 Team, which also includes you.
- Who to ask: IEP, the school or the Committee on Special Education. 504, the school 504 Coordinator or principal.
How to ask for a 504 plan in NYC
The DOE's process starts with forms submitted to the school. After that, the DOE says each student's case is reviewed one by one, and the 504 Coordinator will contact you to set a meeting. You are part of the school 504 Team. The team looks at your request and information about your child, decides if your child is eligible, and if so, which accommodations fit.
The meeting includes people who know your child's abilities and the kinds of accommodations that might help. If you want an interpreter at the 504 meeting, tell the school's 504 Coordinator. If you have questions about 504 policy, the DOE lists 504Questions@schools.nyc.gov.
Keep copies of the forms you hand in and any doctor's notes you attach. Write down the date you submitted them.
How to ask for an IEP evaluation
Put your request in writing to the school or the Committee on Special Education, and keep a copy. Once you sign consent, the evaluation timeline starts. The team then meets to decide if your child is eligible and, if so, to write the IEP. Our IEP meeting preparation guide lists what to bring.
How to tell which plan your child has
Many parents are not sure. Here are simple ways to check:
- Look at the title. An IEP says Individualized Education Program at the top. A 504 plan usually names Section 504 or accommodations.
- Look for services with numbers. If the document lists services like "speech, 2 times a week, 30 minutes," that is almost always an IEP.
- Look for annual goals. Measurable goals are a sign of an IEP.
- Ask in writing. You can ask the school for a copy of your child's current plan. Our page on requesting school records has a simple way to do it.
If words on the page are unclear, our glossary defines common terms.
Why this matters for missed services
Compensatory services are make-up services for a child who did not get what the school was supposed to provide. In practice, these claims usually come from an IEP, because an IEP lists services with a set frequency and length. If a speech session was on the IEP and did not happen, the gap can be counted.
A 504 plan is different. It lists accommodations, which are harder to count in hours. That does not mean a 504 plan never matters. It means we cannot say there is a general right to make-up hours for a 504 plan. The answer depends on the facts, and a lawyer or advocate is the right person to judge it.
If your child has an IEP and missed services, start with what compensatory services are and who may qualify. Then use our guide to documenting missed services so you have dates and details ready.
Common mix-ups
"A 504 plan is a lighter IEP." Not really. It comes from a different law and has a different purpose.
"My child gets good grades, so no 504." The DOE says the limited activity does not have to be learning. Grades alone do not decide it.
"Accommodations on an IEP need a 504 too." Usually not. An IEP can carry accommodations on its own.
"The school will tell me if my child needs more." Sometimes. You can also ask for an evaluation yourself at any time.
Questions to ask the school
- Which plan does my child have right now, and can I get a copy?
- Who is the 504 Coordinator, or who runs IEPs at this school?
- Does the plan list services with a set number of sessions?
- Who provides each service, and how will I know when a session is missed?
- If my child needs more than accommodations, how do I ask for an evaluation?
Write the answers down with the date and the name of the person who gave them.
Your next step
Find your child's current plan and check which one it is. If it is an IEP and services were missed, write down what was missed and when. Our parent checklist helps you keep it in order, and our guide to your rights as a parent explains what you can ask for along the way.
Want to talk it through? Ask for a free callback. We are not the DOE and not a law firm, but we can explain your options and, if it fits, point you to someone who can help. There is no cost to you, now or later.
Official source: NYC DOE: 504 accommodations.
Last reviewed: October 2026
