IEPs, 504 plans, and ADA accommodations: a guide from kindergarten to a first job

In K-12, accommodations come through an IEP under IDEA or a Section 504 plan, and the school must evaluate a child it suspects has a disability. In college and at work, the Americans with Disabilities Act and Section 504 apply instead: the student or employee must self-identify, provide documentation, and request specific accommodations. Nothing transfers automatically at 18.

Every week a family asks me some version of the same question: we have the diagnosis, now what is the school supposed to do? The honest answer is that it depends on which law applies, and the law changes three times between kindergarten and a first job. This guide walks the ladder in order. It is written for Texas, where I practice, with the federal rules that apply everywhere.

The three laws, in one paragraph

The Individuals with Disabilities Education Act (IDEA) covers public school students from age 3 through high school who meet one of its eligibility categories and need specially designed instruction; its plan is the IEP. Section 504 of the Rehabilitation Act of 1973 covers anyone with a physical or mental impairment that substantially limits a major life activity, in any program that receives federal money, which includes public schools and nearly every college; its K-12 plan is the 504 plan. The Americans with Disabilities Act (ADA) extends the same protection to colleges (Titles II and III) and to employers with 15 or more employees (Title I). IDEA puts the burden on the school to find and evaluate the child. Section 504 and the ADA, after high school, put the burden on the person to ask.

Kindergarten through grade 12: IEP or 504 plan

When the school must evaluate

Under IDEA's "child find" duty, a Texas public school that suspects a student has a disability affecting education must evaluate, and a parent can trigger that duty by asking in writing. Once you sign consent, the Full and Individual Evaluation (FIE) must generally be completed within 45 school days, and the ARD committee, Texas's name for the IEP team, meets within 30 calendar days of the report. If the school declines to evaluate, it must tell you why in writing and give you notice of your rights. Since House Bill 3928 took effect in 2023, dyslexia evaluations in Texas run through this same FIE process rather than a separate track, which is a meaningful change for reading referrals.

IEP versus 504: which one fits

The rule of thumb I give parents: an IEP changes what is taught, a 504 plan changes how the student gets to it. A child with dyslexia who needs structured literacy instruction needs an IEP. A child with ADHD who learns fine with extended time, a seat away from the door, and a copy of the notes usually needs a 504 plan. Anxiety, when it substantially limits concentration or attendance, is a 504 question. Autism can be either, depending on whether the need is instruction or access. A 504 plan is faster to obtain and lighter to maintain; an IEP carries goals, services, progress reporting, and stronger procedural protections.

What a private evaluation adds

A school evaluation answers whether the student qualifies for school services. A private neuropsychological evaluation answers why the child is struggling, what the profile of strengths and weaknesses looks like, whether something else is going on (anxiety, a language disorder, autism), and what to do at home and in treatment as well as in the classroom. It also belongs to you: you can take it to the pediatrician, a prescriber, a testing agency, and, years later, a college. The school must consider an outside report at the ARD meeting but is not required to adopt it. Our evaluation page describes what is included and what a virtual evaluation can and cannot cover.

STAAR and classroom testing

State testing accommodations flow from the IEP or 504 plan and from TEA's accommodation rules, which change by year; ask the campus testing coordinator early in the fall. Test anxiety on its own usually does not qualify; a documented disorder with functional impairment may. There is more on that in our STAAR test anxiety guide.

The SAT, ACT, and other exams

Testing agencies make their own decisions. College Board's Services for Students with Disabilities (SSD) and ACT's accommodations system each require an application, usually submitted through the school's SSD coordinator, and both generally approve requests that match accommodations a student already uses under a plan at school. College Board asks families to allow about seven weeks for a decision, so the request belongs in the fall of junior year, not the month before the test. For graduate and professional exams, the GRE (ETS), the LSAT (LSAC), and the MCAT (AAMC) each publish documentation requirements; they tend to want a more recent and more detailed report than a college does, and their lead times are long.

College: the handoff nobody explains

IDEA ends the day a student graduates from high school, and a 504 plan does not travel. In college, the Americans with Disabilities Act and Section 504 govern, and the mechanics reverse. The student, not the parent, must go to the disability services office, disclose, supply documentation, and request specific accommodations. The college decides what is reasonable, is not required to alter essential course requirements, and will not talk to a parent without a signed release. Students who wait until midterms to start this process typically lose the semester's benefit, because accommodations are not retroactive.

Documentation standards vary by school, so ask the office, but most now follow the guidance published by AHEAD, the Association on Higher Education and Disability: a report from a qualified professional that names the diagnosis, describes functional limitations in academic terms, and ties each requested accommodation to those limitations. Many offices have dropped rigid rules about how recent the evaluation must be, and a prior IEP or 504 plan is treated as useful evidence rather than a requirement. When we write an evaluation report for a high school junior or senior, we write the recommendations section for this reader.

Work: ADA Title I

The ADA covers employers with 15 or more employees. An employee with a disability may request a reasonable accommodation, and the employer must engage in what the law calls an interactive process to find one, unless it would impose undue hardship. The employer can ask for documentation of the disability and the need for the accommodation, but the employee does not have to disclose a diagnosis to coworkers or managers outside that process. For a young adult with ADHD, the accommodations that come up most are written instructions, a quieter workspace, flexible scheduling around a medication routine, and structured check-ins. The psychologist's letter should describe limitations and recommend specific adjustments without unnecessary clinical detail; we write those letters for our evaluation clients on request.

What a report needs to say, at every level

Across all of these, the same four things make a report usable: a named diagnosis with the criteria it met; the tests and rating scales used, with scores; a plain description of how the condition limits the person in the setting that matters, school, testing, or work; and recommendations that are specific, each one tied to a finding. A report that says "extended time" without saying why is the report that gets sent back.

Common questions

What is the difference between an IEP and a 504 plan?

An IEP is a legally binding plan under the Individuals with Disabilities Education Act for a student who meets one of its eligibility categories and needs specially designed instruction; it includes goals, services, and progress reporting, and in Texas it is written by the ARD committee. A 504 plan comes from Section 504 of the Rehabilitation Act and covers any student with a physical or mental impairment that substantially limits a major life activity; it provides accommodations such as extended time or a reduced-distraction setting without changing what is taught. Roughly, an IEP changes instruction; a 504 plan changes access.

How do I get my child evaluated by the school in Texas?

Put the request in writing to the campus principal or special education director. Texas law requires the school to respond, and once you give written consent for an evaluation, the Full and Individual Evaluation must generally be completed within 45 school days, with an ARD meeting held within 30 calendar days of the evaluation report. Since House Bill 3928 took effect in 2023, dyslexia evaluations in Texas also run through this IDEA process.

Do I need a private evaluation if the school will do one?

Not always. A school evaluation determines eligibility for school services; a private neuropsychological evaluation answers a broader question about why a child is struggling and what to do about it, and it belongs to you. Families choose a private evaluation when the school has declined to evaluate, when the school's evaluation did not explain the picture, when there are co-occurring questions such as anxiety or autism, or when they want a report they can carry to a pediatrician, a college, or a testing agency. Schools must consider an outside evaluation but are not required to adopt its conclusions.

Does my child's IEP or 504 plan carry over to college?

No. IDEA ends at high school graduation, and a 504 plan does not transfer. In college, accommodations come under the ADA and Section 504 and the student must register with the disability services office, supply documentation, and request accommodations; the college decides what is reasonable and does not have to change essential course requirements. Parents are not part of that process unless the student signs a release.

What documentation does a college disability office want?

Practices vary by school, so ask the office directly, but most follow the guidance of AHEAD, the Association on Higher Education and Disability: a report from a qualified professional that states the diagnosis, describes how it limits the student in academic terms, and connects each requested accommodation to that limitation. A current evaluation is helpful; many offices no longer impose a strict recency cutoff, and a prior IEP or 504 plan is useful supporting evidence. Our evaluation reports are written with this audience in mind.

How do I get extended time on the SAT or ACT?

Through the testing agencies, not the school alone. College Board's Services for Students with Disabilities and ACT's accommodations system each require an application, usually submitted through the school's coordinator, and both generally approve requests that match accommodations a student already uses under an IEP or 504 plan. Allow about seven weeks for College Board's decision, and apply well before registration deadlines. Graduate and professional exams (the GRE through ETS, the LSAT through LSAC, the MCAT through AAMC) have their own documentation requirements and longer lead times.

How do workplace accommodations work under the ADA?

Title I of the Americans with Disabilities Act covers employers with 15 or more employees. An employee requests a reasonable accommodation, the employer engages in an interactive process, and the employer may ask for documentation of the disability and the need. The employee does not have to disclose a diagnosis to coworkers, only to the people handling the request. A psychologist's letter that describes functional limitations and recommends specific adjustments, without unnecessary clinical detail, is usually what is needed.

Can test anxiety or ADHD alone qualify for accommodations?

ADHD can, when an evaluation documents that it substantially limits learning, concentration, or another major life activity; that is a 504 or ADA question, and the documentation matters. Test anxiety on its own usually does not qualify, because being nervous about a test is not a disability. A diagnosed anxiety disorder with documented functional impairment may.

Sources cited on this page

• Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seq. Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794. Americans with Disabilities Act of 1990, 42 U.S.C. § 12101 et seq.
• Texas Education Agency. Special education: Evaluation timelines and the ARD process; The Dyslexia Handbook; House Bill 3928 (88th Legislature, 2023). tea.texas.gov
• Association on Higher Education and Disability. Supporting accommodation requests: Guidance on documentation practices. ahead.org
• College Board, Services for Students with Disabilities; ACT, Accommodations and supports; U.S. Equal Employment Opportunity Commission, Enforcement guidance on reasonable accommodation and undue hardship under the ADA.

This page is general information, not legal advice. Timelines and documentation rules change; confirm current requirements with your district, college, testing agency, or employer.