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Frameworks

Framework

ADA / Section 504

Disability rights and reasonable accommodation across education and employment, two overlapping statutes institutions routinely conflate.

What the law is

Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act protect people with disabilities from discrimination and require covered institutions to provide reasonable accommodation. Section 504 applies to recipients of federal funds; the ADA applies more broadly, including to most employers and public entities.

The two overlap heavily, which is exactly why institutions conflate them, and exactly why the conflation causes problems. In PK–12, Section 504 drives much of the accommodation and grievance analysis for students; in employment, the ADA governs. Assuming compliance with one satisfies the other is a common and costly error.

The core duties are an interactive, documented accommodation process, a grievance procedure that is actually followed, and a record showing how each determination was reached. Where those break down, complaints and OCR referrals follow.

What it requires

01

The right framework

Knowing which statute governs which decision, and not assuming compliance with one satisfies the other.

02

Interactive accommodation process

A documented, good-faith process for evaluating and providing reasonable accommodation.

03

Grievance handling

A grievance procedure that exists on paper and is actually followed in practice.

04

Documentation

A record showing how each determination was reached.

How Fractional Coordinator helps

Fractional & interim coordination

Senior ADA / Section 504 coordination during a gap, a surge, or as a standing partner, owning the role, not just advising on it.

Fractional leadership

Neutral investigations

Defensible ADA / Section 504 investigations, from intake to a written report built to survive review.

Investigations

Certification & training

ADA / Section 504 certification, workshops, and refreshers through the Learning Institute.

Certified training

Why institutions bring us in

Interactive process discipline

Individualized, documented, and timely. Most ADA exposure is a process failure before it is a substantive one.

Digital accessibility deadlines

The Title II web accessibility rule is now in force for large public entities. We help you meet it as an access obligation, not an IT project.

Both statutes, one practice

ADA, Section 504, and state analogs applied coherently, so students and employees get consistent answers.

Accommodation through grievance

From the first request to the final appeal, one standard of documentation and care across the full arc.

Working through a 504 or ADA matter?

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