1 in 20 Washington Students Now Has a 504 Plan

Wed, 04 Mar 2026 12:00:00 GMT

On Bainbridge Island, 17% of public school students have a Section 504 disability accommodation plan. In Federal Way^↗, 30 miles to the southeast and serving a student body more than six times as large, the rate is 2.9%.

Both districts operate under the same federal law. Both serve students with ADHD, anxiety, diabetes, and other conditions that can substantially limit a major life activity. The enrollment data cannot measure disability prevalence directly, only identification rates. But a sixfold gap between neighboring districts points less to differences in how many students have disabilities than to differences in who gets evaluated and who gets the paperwork that converts a diagnosis into a classroom accommodation.

Statewide, Section 504 plans have quadrupled over 16 years, from 13,762 students (1.3% of enrollment) in 2009-10 to a peak of 60,833 (5.5%) in 2024-25. Combined with the 16.4% special education rate that year, more than one in five Washington students carried some form of documented disability accommodation. That combined rate was 14.5% in 2010.

Then, in 2025-26, 504 plans dropped by 6,440 students, the largest single-year decline on record.

The law changed before the culture did

The acceleration began before COVID, before the youth mental health crisis entered the national vocabulary, before pandemic-era telehealth made ADHD diagnoses easier to obtain. It started with a legal change.

The Americans with Disabilities Act Amendments Act of 2008, effective January 2009, broadened the definition of disability under both the ADA and Section 504. The new standard lowered the threshold: impairments no longer needed to "prevent or severely or significantly restrict" a major life activity to qualify. The law expanded the list of major life activities to include concentrating, reading, and thinking, and it barred schools from considering how well a student's medication or coping strategies managed their condition.

For students with ADHD, the effect was immediate. A student earning good grades could no longer be denied a 504 plan on that basis alone. Federal guidance later reinforced that "grades alone are an insufficient basis" for determining whether a student has a disability.

Washington's data shows the result. In 2009-10, 184 districts reported any 504 students. By 2024-25, 283 districts did. The statewide count grew every single year from 2010 through 2019, averaging 3,825 new 504 plans annually.

The pandemic interrupted, then turbocharged growth

COVID-19 briefly reversed the trend. Schools lost 1,062 Section 504 students in 2019-20 and another 1,477 in 2020-21, as remote learning made evaluations difficult and some families disengaged from formal accommodation processes entirely.

The rebound was swift and steep. From 2021-22 to 2022-23, the state added 8,363 Section 504 students in a single year, an 18.0% jump that dwarfed any pre-pandemic annual increase. The post-pandemic growth rate from 2021 to 2025 averaged 3,797 new plans per year, roughly matching the pre-pandemic pace, but compressed into a recovery surge that peaked in 2022-23 and 2023-24.

The timing coincides with a national surge in ADHD diagnoses. Between 2016 and 2022, approximately one million additional children received ADHD diagnoses nationwide, bringing the overall rate to 11.4% of children ages 3 to 17. Post-pandemic awareness campaigns, expanded telehealth access, and heightened attention to youth mental health all contributed to more families seeking evaluations.

But rising diagnoses alone do not explain the pattern in Washington's data. If they did, 504 rates would be climbing at roughly similar rates everywhere. They are not.

Where you live determines whether you get identified

The correlation between district wealth and 504 identification is stark. Among Washington districts with at least 2,000 students, the correlation between a district's economically disadvantaged rate and its Section 504 rate is -0.62: the more affluent the district, the higher the 504 rate.

Bainbridge Island^↗, where fewer than 15% of students are economically disadvantaged, identifies 17.0% of its enrollment on 504 plans. Northshore^↗, a large suburban district north of Kirkland, identifies 10.7%. Snoqualmie Valley^↗ and Shoreline^↗ both exceed 10%.

At the other end: Yakima^↗, where more than 75% of students are economically disadvantaged, identifies 3.4%. Highline^↗, just south of Seattle, identifies 1.3%. Federal Way, at 2.9%, serves a student body nearly the size of Bainbridge Island, Mercer Island, Snoqualmie Valley, and Shoreline combined.

This pattern is consistent with national research. A policy brief from the National Education Policy Center found that Section 504's "broad eligibility criteria, lack of funding, and substantial deference to the professional judgment of educators" have favored families with the resources to pursue private evaluations. White students are more than twice as likely as Black or Hispanic students to have a 504 plan nationally, despite comparable rates of underlying conditions like ADHD.

"Section 504's broad eligibility criteria, lack of funding, and substantial deference to the professional judgment of educators and external evaluators have favored powerful and privileged families." -- National Education Policy Center, 2024

The mechanism is straightforward. Section 504 is an unfunded federal mandate. Unlike special education under IDEA, which carries dedicated federal funding, 504 plans bring no additional dollars to districts. Schools must provide the accommodations (extended test time, preferential seating, modified assignments, breaks for medication) but receive nothing to pay for them. Districts with smaller caseloads have less institutional infrastructure for evaluations. Families in those districts may not know a 504 plan exists, may lack access to private psychologists who can document a qualifying condition, or may face language barriers in navigating the referral process.

The 2025-26 reversal

After 13 years of growth interrupted only by COVID, Section 504 plans fell by 6,440 students in 2025-26, dropping from 60,833 to 54,393. The statewide rate slid from 5.5% to 5.0%.

The decline was not uniform. Eight fewer districts reported any 504 students at all (275, down from 283). Some individual district drops suggest reporting changes rather than genuine declines: Cheney^↗ fell from 186 to one, and Grandview fell from 71 to two, patterns more consistent with a data submission issue than a mass revocation of accommodation plans.

But the drop also touched large districts with no obvious reporting anomaly. Seattle^↗ lost 458 Section 504 students. Lake Washington^↗ lost 310. Lake Stevens^↗ lost 292. Battle Ground lost 576. Whether these reflect tightened identification criteria, families leaving the public system, or a natural plateau after a decade of rapid expansion is not yet clear from the data alone.

What 1 in 5 means for schools

Even after the 2025-26 decline, the combined accommodation rate tells a structural story. In 2025-26, 54,393 students hold 504 plans (5.0%) and 169,080 receive special education services (15.4%). Together, that is 20.4% of Washington's enrollment, up from 14.5% in 2010.

This is not a temporary phenomenon. The special education rate has climbed steadily from 13.2% to 15.4% over 17 years, and Section 504 rates, even with the 2025-26 correction, remain nearly four times their 2010 level.

For districts, the fiscal implication is real. Special education carries per-pupil costs well above the base rate, funded partly through IDEA. Section 504 accommodations receive no categorical funding at all. Every extended-time test, every behavioral intervention plan, every physical accommodation comes out of the district's general fund. As 504 caseloads have grown fourfold, the unfunded cost of compliance has grown with them.

A federal law under federal challenge

The legal foundation for all of this is not as secure as it was a year ago. Seventeen states have filed suit in Texas v. Becerra challenging the constitutionality of Section 504 itself. While the lawsuit's proximate trigger was the Biden administration's 2024 rule update, the states' legal brief asks the court to "declare Section 504 unconstitutional" and "enjoin enforcement" of the law entirely. Washington is not among the plaintiff states.

If the challenge succeeds, 54,393 Washington students would lose the federal guarantee that schools must provide them with disability accommodations. Whether the state's own laws would fill that gap is an open question.

The more immediate question is local. The sixfold gap between Bainbridge Island's 17.0% identification rate and Federal Way's 2.9% is not a gap in disability prevalence. It is a gap in access to the system that documents disability and converts it into classroom support. Four times as many students hold 504 plans as in 2010. Whether the students who need them most are the ones getting them is a different question, and the data suggests they are not.

Detailed code that reproduces the analysis and figures in this article is available exclusively to EdTribune subscribers.

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