Question · Section 504
Can a generative AI tool legally write Section 504 plans?
Section 504 bars disability discrimination by recipients of federal funds, and ED's rules require free appropriate public education, fair evaluation, and academic adjustments for students with disabilities.
01 / The answer
The short answer
An AI tool can draft material, but it cannot make the decisions. Section 504 rules require that a K-12 student's evaluation and placement draw on varied information and be decided by a group of people who know the child, the evaluation data and the options, and the plan must meet that student's individual needs. A district that lets a tool write plans with no policy and no review by that group risks plans that are not individualized. Review and adapt every AI draft before it is adopted.
02 / The rule
What Section 504 requires
Section 504 bars disability discrimination by recipients of federal funds, and ED's rules require free appropriate public education, fair evaluation, and academic adjustments for students with disabilities. AI ed-tech is covered when a school uses it, so inaccessible tools, unreviewed AI-written 504 plans, and AI flags that penalize disability-related behavior can all violate the law.
- 01Do not exclude or disadvantage students on the basis of disability, directly or through contractual or licensing arrangements (34 CFR 104.4).
- 02Provide K-12 students with disabilities a free appropriate public education, with individualized 504 plans decided by knowledgeable people.
- 03Evaluate students with validated tests given by trained personnel, drawing on varied sources (34 CFR 104.35).
- 04Modify academic requirements and exam methods so evaluations measure achievement, not disability (34 CFR 104.44).
03 / Records
Records to keep
- 01Accessibility review and conformance report for each AI tool procured
- 02504 team records showing individualized review of AI-drafted plans
- 03Accommodation request and response logs
- 04Grievance procedure and complaint resolution records
Optional evidence · where Planisphere fits
Keep a record anyone can check
When your team meets a duty, Planisphere can seal the event it reports as a receipt.
A disclosure shown, a review signed, a model change approved: the event your system reports.
The event becomes a sealed receipt, dated and attributed to whoever is signed in.
Paste the receipt into Verify. No account or key.
A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.
SOURCES
Go back to the source
Legal Information Institute (Cornell)
Legal Information Institute (Cornell)
Legal Information Institute (Cornell)
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Related: Section 504: the full guide · What's the difference between Section 504 and IDEA for AI accommodation tools?