Palo Alto’s 504 Plan Puzzle

Palo Alto Unified School District’s 504 Plan demographics are substantially different than California’s or the rest of the US states with around 7% of our students having a 504 plan (see attachments) vs. the national average of 2.7%, California at 4% and the highest state average New Hampshire at 6.2% (tab 2 of “Enrollment-Overall”)

Thank you to PAUSD Staff

First, thank you to Amanda Bark and the PAUSD staff for providing this data. I only looked at this because the 504 numbers were broken out in the recent mid-school math report and they were surprisingly high.

What is a 504 Plan?

Students with 504 plans typically do NOT have IEPs and are NOT covered under IDEA.

504 plans are focused on education accessibility and addressing discrimination as opposed to supporting individualized learning needs.


There have been cases that I’ve heard in other school districts pushing students to get 504 plans instead of IEPs (and PAUSD has a low number of Students with Disabilities defined by IDEA both vs. California and nationally). State IDEA metrics do not flag schools for low IDEA metrics, so I do not know if PAUSD is notably low at the state level (there is no slick dashboard for IDEA data like there is for general education)

504 plans are not monitored with any of the attention that is given to IDEA, unfortunately, so, it is much harder to “see” what is going on.

I do not know the reason for this number – it is just a notable outlier.

I believe that the district can break this down by disability category and certainly look at the trends over time. Given other disproportionality issues, it might also be worth looking into ethnic, SED, and other demographic groups to see if there are other drivers.

All my best.


  • Note the “Enrollment Overall” spreadsheet was retrieved from the Office of Civil Rights reporting at the US Department of Education.