ADA / 504
Section 504 vs. ADA: what PK–12 teams get wrong
The two overlap, but they are not interchangeable. Where districts most often slip.
Section 504 and the ADA protect overlapping groups against overlapping harms, which is exactly why teams conflate them, and exactly why the conflation causes trouble. The obligations, thresholds, and processes are not the same.
Different statutes, different triggers
Section 504 is tied to federal funding and drives much of the accommodation and FAPE analysis in PK–12; the ADA reaches more broadly and carries its own standards. Treating a 504 obligation as satisfied because “we’re ADA-compliant” (or the reverse) is a common and consequential mistake.
Compliance with one is not compliance with the other.
Where districts slip
A grievance process that exists on paper but isn’t followed, accommodation decisions made without the required process, and documentation that can’t show how a determination was reached. These are the findings that turn a defensible situation into an OCR problem.
The bottom line
Think of them as two lenses on the same student, not one interchangeable label. The districts that keep the distinction clear are the ones that don’t get surprised.
