In Clark County School District, an Individualized Education Program, or IEP, is for a student who has a disability under the federal special education law and needs specially designed instruction because of it. A Section 504 Plan is for a student whose physical or mental impairment substantially limits a major life activity and who needs accommodations to reach the same instruction everyone else gets. CCSD's Section 504 Plans site and the district's November 2026 Special Education Procedures Manual, linked from ssd.ccsd.net, draw that line, and both were checked Wednesday, November 4, 2026.
What is the legal difference between a 504 plan and an IEP?
They come from two different federal laws. An IEP comes from the Individuals with Disabilities Education Act, known as IDEA, which Nevada carries out through Chapter 388 of the Nevada Administrative Code. A 504 Plan comes from Section 504 of the Rehabilitation Act of 1973, which CCSD's 504 site describes as "a federal civil rights statute prohibiting discrimination on the basis of disability in any program or activity receiving federal financial assistance."
IDEA is an education program law, so it comes with eligibility categories, required evaluations, written goals, and a state run dispute system. Section 504 is an access and nondiscrimination law, so it asks a broader question: is this student being shut out of learning because of a disability, and what would remove the barrier?
The 504 definition is wider. Under the federal regulation at 34 CFR 104.3(j), a person with a disability has a physical or mental impairment that substantially limits one or more major life activities, and the listed activities include learning. CCSD's 504 site adds that "Section 504 does not provide an operational definition of 'substantial limitation'" and that the question is decided case by case by the school's 504 team.
The IEP door is narrower. The CCSD manual describes two conditions a student must meet: the student has one of the disabilities defined in IDEA and Nevada rules, and because of it the student needs specially designed instruction. Both conditions have to be true. A student with a qualifying condition who is learning well with ordinary teaching plus a few supports may not qualify for an IEP, but may still qualify for a 504 Plan.
What does each plan actually give my child?
A 504 Plan, in CCSD's own words, details "specific changes and support, such as extended time on tests or access to audiobooks." Think preferential seating, breaks, a quiet testing room, copies of notes, a health plan for medication or blood sugar checks, or permission to carry water. The teaching stays the same; the path into it changes.
An IEP is a bigger document. The manual's IEP chapter walks through present levels of performance, measurable annual goals, how progress will be reported, the special education services themselves, related services such as speech or occupational therapy, and supplementary aids and services. Specially designed instruction means a change in what or how your child is taught, delivered by special education staff.
Some supports can sit in either plan, and the manual says so in specific places:
Adapted physical education. The manual answers whether a student with a Section 504 Plan can receive Adapted PE: if the student meets the general guidelines, contact the Adapted PE Department at 702 799 0104.
Supplementary Home Services for students with chronic illness who miss school often. The manual calls it "an IEP or Section 504 Plan team decision," and says any team member, including a parent, can ask for a meeting to consider it.
Transportation. CCSD's 2026 to 2027 Back to School legal notices say a disability related transportation need "will be documented in the student's Individualized Education Plan (IEP) or Section 504 Plan."
A shortened school day. The same notices say all students are entitled to a full school day "unless an IEP or Section 504 Plan explicitly documents the need for a shortened school day." If anyone asks you to pick your child up early every day, that sentence is your answer.
One more overlap matters. A student who has an IEP is already protected by Section 504. The 504 regulation at 34 CFR 104.33(b)(2) says carrying out an IEP developed under the Education of the Handicapped Act, the older name for IDEA, is one means of meeting the 504 standard. A child does not need both documents.
Does an ADHD diagnosis get my child a 504 plan?
Not by itself. CCSD's 504 site answers this exact question: a medical diagnosis of ADHD "is one source of data to consider," but "the diagnosis alone does not necessarily ensure a student would be eligible for a Section 504 Plan."
It cuts the other way too. The manual's ADHD section says a formal ADHD diagnosis "is not required for a school team to recognize" an ADHD profile that may call for a Section 504 Plan or "specially designed instruction and support services through an IEP." Its ADHD Protocol does not require a diagnosis or medication, and a diagnosed child does not "automatically qualify for, or need a Section 504 Plan or special education services." The manual says that call belongs to "a properly constituted school team (i.e., MDT or Section 504 Plan team)."
So bring the doctor's letter, but bring the school evidence with it: missed assignments, teacher emails, behavior notes, grades that swing with the class period. Those show the limitation the 504 team has to find.
How does each one start in CCSD?
For a 504 Plan, CCSD's site says "Every Clark County School District School has a Section 504 Plan liaison. Contact the 504 liaison at your child's school." The evaluation, the site says, does "not necessarily involve formal testing" and "would include a review of all available current data." Ask the front office who the liaison is, then put your request in an email so the date is on record.
For an IEP, you ask for a special education evaluation, verbally or in writing. The manual says the request goes to the principal and school psychologist "immediately," and that the district "has ten calendar days to respond, in writing," either with its decision or by scheduling a multidisciplinary team meeting. Once you sign consent, Nevada's NAC 388.337 gives the district 45 school days to finish the evaluation. CCSD Insider's guide to requesting an IEP evaluation has the step by step and a sample letter.
You do not have to choose before you ask. The manual's intervention checklists tell school teams, again and again, to "Consider a Section 504 Plan or special education evaluation needs." If you suspect your child needs more than accommodations, ask for the special education evaluation in writing and say you also want 504 eligibility considered.
How do I tell which one fits?
Skip the labels for a minute and look at what is going wrong.
If your child understands the material but the barrier is getting to it, a 504 Plan is often the fit. A student with diabetes who needs snacks and testing breaks. A student with anxiety who needs a plan for testing days. A student with ADHD who learns fine with movement breaks and chunked assignments. The manual even notes that voice disorders "could be appropriately served on a Section 504 Plan."
If your child is falling further behind even with accommodations, an IEP is the likelier fit. A third grader who still cannot decode, a middle schooler whose behavior keeps him out of class, a child who needs direct speech therapy. Accommodations do not teach reading. Specially designed instruction is meant to.
Watch for one trap. Extended time helps a child who knows the answer and needs longer to show it. It does not help a child who cannot read the question. If the 504 accommodations keep growing and the grades keep falling, that pattern is evidence for an IEP evaluation, and you can ask for one at any time.
Which plan gives me more ways to push back?
With an IEP, you get the full Nevada special education safeguards: prior written notice, consent rules, independent evaluations, and four free dispute options run by the Nevada Department of Education's Office of Comprehensive Student Services: IEP facilitation, mediation, a state complaint, and a due process complaint. CCSD Insider's guide to disagreeing with an IEP covers each one.
With a 504 Plan, the state route is closed. The NDE state complaint page says "NDE does not have jurisdiction to investigate violations pertaining to Section 504 accommodations." For a 504 problem in CCSD, the 2026 to 2027 Back to School legal notices point families to the school principal, the school's Special Education Region Director, or the Executive Director of the Office of Compliance and Monitoring at 702 799 1020 or 0135-ocm@nv.ccsd.net. Outside the district, the federal Office for Civil Rights takes disability discrimination complaints; federal rules give you 180 days from the date of the alleged discrimination to file, under 34 CFR 100.7(b), which 34 CFR 104.61 applies to Section 504. OCR's filing guide explains how to file. The 504 regulation at 34 CFR 104.36 also requires notice, a chance to review records, and an impartial hearing.
Review schedules differ too. An IEP must be reviewed at least once a year under 34 CFR 300.324(b), and reevaluated at least once every three years unless parent and district agree it is not needed, under 34 CFR 300.303. The 504 regulation at 34 CFR 104.35(d) calls for "periodic reevaluation." Ask your liaison when the plan will next be reviewed and write the date down.
What if the school offers a 504 when I asked for an IEP?
You can accept the 504 supports and still hold the school to your evaluation request. The manual says school team intervention practices "may not be used to defer or delay processing of a referral for an evaluation when the team suspects a disability under the IDEA." If the school decides not to evaluate, it has to tell you in writing on a Parental Prior Notice of District Refusal, form CCF 567 or 567.1. That written refusal is what lets you request mediation, file a state complaint, or file for due process under NAC 388.325. CCSD Insider's guide on what to do when CCSD says no to an evaluation walks through those steps, and our plain English guide to special education rights in CCSD explains the rights booklet.
Applying to a magnet school? Either plan travels with your child. The Magnet Qualification Requirements page says students with disabilities receive accommodations "where possible" during the application process, based on what is in Infinite Campus.
Who do I contact?
Your school's Section 504 liaison, through the front office, for a 504 evaluation or meeting.
Your school principal and school psychologist, for a special education evaluation request.
CCSD Office of Compliance and Monitoring, Student Services Division: 4170 McLeod Drive, Las Vegas, NV 89121, 702 799 1020, 0135-ocm@nv.ccsd.net.
CCSD Child Find, for children ages 3 to 21 not yet in a CCSD school: 702 799 7463, childfind@nv.ccsd.net.
CCSD Adapted PE Department: 702 799 0104.
Nevada Department of Education dispute resolution, IDEA matters only: 775 687 9171, disputeresolution@doe.nv.gov.
U.S. Department of Education Office for Civil Rights, Seattle office, as listed in CCSD's legal notices: 915 Second Ave., Room 3310, Seattle, Washington, OCR.Seattle@ed.gov.
Nevada PEP, the state's parent training center: 702 388 8899 or 1 800 216 5188, PEPInfo@NVPEP.org.
CCSD Insider is an independent parent resource and is not affiliated with the Clark County School District.