Question · Section 504
What's the difference between Section 504 and IDEA for AI accommodation tools?
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
Section 504 is a civil rights law that bars disability discrimination by any recipient of federal funds and covers any student with a disability that substantially limits a major life activity. IDEA is a funding law that gives students in specific disability categories who need special education an IEP, detailed evaluation rules and due process rights. Students covered by IDEA are also protected by Section 504. An AI accommodation tool must fit whichever plan applies, a 504 plan or an IEP, and both depend on individualized decisions by people.
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 · Can a generative AI tool legally write Section 504 plans?