Your guide to understanding 504 plans

IFPIES - IEPI-FPIES has developed the following guide as an overview of information to help establish a Section 504 Plan for a student with FPIES. For complete information and instructions specific to your district, please contact your local school district or access the U.S. Department of Education website at www.2.ED.gov.


Section 504 is a federal law designed to protect the rights of individuals with disabilities in programs and activities that receive federal financial assistance from the U.S. Department of Education (ED).

Section 504 provides: “No otherwise qualified individual with a disability in the United States…shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance…”

To be protected under Section 504, a student must be determined to:

  1. Have a mental or physical impairment which substantially limits one or more major life activities which include: Caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, working, eating, sleeping, standing, lifting, bending, reading, concentrating, thinking and communicating. Other major life activities include major bodily functions, such as functions of the immune system, normal cell growth, and digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine and reproductive functions.

Physical impairment includes any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological; musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and endocrine.

Mental impairment includes any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities.

2. Have a record of such impairment

3. Be regarded as having such impairment

A Section 504 Plan specifies the educational, related aids and supplemental support services that are needed to ensure that the individual educational needs of a disabled student are met as adequately as the needs of non-disabled students.

There are many challenges faced when caring for a child with Food Protein-Induced Enterocolitis Syndrome (FPIES), including dietary restrictions, illness and treatment. These challenges can be overwhelming for a parent and child when it comes to school. Not every child with FPIES requires special services and accommodations. However, if needed, a request can be made to the school to develop a Section 504 Plan to provide specific accommodations for that child while attending school and engaging in school activities. This plan should have many sections to address the important food-related issues so that the child can have the best possible chance of staying safe.

The criteria by which a child with severe food allergy (i.e., FPIES) can be eligible for protection under Section 504 is that the physiological condition or disorder of food allergy affects the respiratory, digestive, cardiovascular and skin body systems. The U.S. Office for Civil Rights, U.S. Department of Education formally recognizes allergy as a “hidden disability,” or not readily apparent to others.

NOTE: Solely having a physical or mental impairment does not constitute a disability. The impairment must substantially limit one or more of the student’s major life activities in order to be considered disabled under Section 504. Each request requires that a student evaluation and eligibility determination is made on a case-by-case basis.

A request can be initiated by parents or legal guardians, teachers or other licensed school employees.

HELPFUL TIP: Often times, your school and its 504 team will have a 504 template in place. It is important to request that your child’s physician provide a Medical Action Plan, Food Allergy Management Plan, and any recommendations and accommodations prior to your initial meeting. This will allow for a smoother process and help support open communication among 504 team members and your family. You may also consider signing a release for your physician to become a more integrated part of this team and to be contacted with any educational questions/emergencies.

  1. Each school district may have different steps, so it is important to first contact the school the child is attending to initiate the 504 request and obtain the necessary paperwork.
  2. For elementary and secondary school levels, determining whether a child is a qualified disabled student must begin with an evaluation process.
  3. School districts must establish standards and procedures for initial evaluations and periodic re-evaluations.
  4. An evaluation team, generally consisting of teachers and specialists (possibly including special education personnel, parents and the child), will meet and evaluate all the information and determine if the child qualifies for protection under Section 504.
  5. You may be asked to provide specific medical information and physician recommendations to help aid in the determination.

Once the child is determined to be eligible, a 504 accommodation plan will be created. The final modifications and accommodations will be individualized, according to the specific state regulations.

It is helpful to familiarize yourself with your school staff and members of the Regular Education 504 Team. Each officer has a different role, and identifying the roles of the team helps to address any questions or concerns you may have.

504 Coordinator: The 504 Coordinator will be the first person you should contact to request and initiate the 504 procedure. It is important that the Coordinator be contacted well in advance of the school year to allow for sufficient time to develop a solid and cohesive plan. Often times, the Coordinator at your school may also be the Special Education Coordinator. The Coordinator is responsible for initiating the first steps within the 504 planning process.

504 Compliance Officer: Oftentimes, the school principal, the 504 Compliance Officer is responsible for addressing any obstacles or breaches in compliance of the designated 504 accommodations. This individual must possess direct contact and legal authority to access the classroom and school staff on a daily basis. It is his/her job to address the compliance of the 504 plan and ensure its implementation.

School Nurse: The School Nurse is responsible for training staff, implementing emergency action plans, determining the need for emergent intervention, and promoting awareness and education of all medical aspects of care. The School Nurse writes the 504 Plan and ensures that all medical documentation and action plans are in place.

Important Note: Special Education is not responsible for carrying out 504 accommodations. 504 accommodations are the responsibility of the Regular Education Team. Individualized Education Plans (IEPs) are carried out by Special Education and are not often implemented for medical conditions.

<Parent’s Name>

<Home Address>

<City, State, ZIP>

<Phone Number>

<Email Address>


Attention: <Principal’s Name>

<School Name>

<School Address>

<City, State, ZIP>

RE: Request for <child’s name> 504 Plan for <School Year>

Dear <Principal>,

The purpose of this letter is to request a 504 Plan for our child <Insert Name, Date of Birth> for the <Insert Year>academic school year. Our child is diagnosed with Food Protein-Induced Enterocolitis Syndrome (FPIES), a rare food allergy of the gastrointestinal tract. <child’s name> will be a <grade level> student in <teacher’s name>classroom.

FPIES is food allergic disorder that falls under the Section 504/ADA Accommodation Plan. Symptoms of FPIES include delayed onset vomiting, diarrhea, lethargy, and in severe cases, hypovolemic shock. It is not a typical food allergy and does not cause symptoms of hives or anaphylaxis. NOTE: If your child does have an IgE-mediated food allergy, you will need to tailor the letter to state so here.

Attached is our physician’s Food Allergy Management Plan that outlines our child’s current list of food allergies and emergency action plan. Given the nature of this type of food allergy and its management, it is imperative that a 504 Plan be implemented for the best interest and safety of our child during academic hours and extracurricular activities.

This letter also serves as our consent for <physician’s name> to consult with the school nurse and administrators regarding our child’s action plan prior to our initial meeting and in the event of an emergency. Attached are our physician’s orders and requested 504 special accommodations. At the request of our physician, the school nurse should also write up an Individual Health Plan (IHP).

At our first meeting, we wish to request the presence and input of all school staff members who will have direct supervision and interaction with our child, not limited to nursing staff and the Child Study team responsible for implementing the 504 Plan. We also request the opportunity to provide education about FPIES to staff members who would like to learn more and who will be an integral part of our 504 team.

We are excited for the upcoming school year and request that a 504 Team Meeting be scheduled prior to the start of the school year. We look forward to building a long-term partnership with school staff and collaborating as a cohesive team to ensure <child’s name> safety.

We look forward to your response and to finding a mutually agreeable time to meet.



<Parent’s Name>

cc:  <Director of Student Services and Special Education>
      <504 On-site Coordinator>

     <School Nurse>


**Note to Parent: Be sure to attach the Food Allergy Management Plan from your child’s physician. This plan includes an emergency action plan and the physician’s recommended accommodations, including a list of safe and allergic foods.

FPIES Letter for School and Daycare

Download to share with your school or daycare to help explain FPIES and the special considerations it may present in a school setting

Caregiver Action Plan

This piece was developed to help educate teachers, daycare providers, and other caregivers learn more about caring for a child with FPIES

Other Key Resources