504 & EB

Supporting 504 and Emergent Bilingual students alongside IEPs

Allie Wilson, Founder, IEP Assure · September 30, 2026 · 3 min read

Quick answer

Students with 504 plans and Emergent Bilingual students have accommodations that teachers must provide, just like students with IEPs. When those plans live in different places, teachers miss things and leaders lose sight of them. Tracking every plan's accommodations in one place makes support visible, especially for students served by more than one program.

Three plans, one teacher

A general education teacher might have students with IEPs, students with 504 plans and Emergent Bilingual students in the same class period. Each group has supports documented somewhere different. The teacher is expected to know and provide all of them.

Section 504

Section 504 of the Rehabilitation Act requires districts to provide a free appropriate public education to qualified students with disabilities, including regular or special education and related aids and services designed to meet their needs as adequately as the needs of students without disabilities are met (34 CFR 104.33). Accommodations in a 504 plan are not optional, and they deserve the same visibility as IEP accommodations.

Emergent Bilingual students with disabilities

Some students are both Emergent Bilingual and eligible for special education. The U.S. Department of Education's English Learner Tool Kit notes that these students are entitled to both language assistance and disability-related services. That means two sets of supports, two teams and a real risk that each assumes the other has it covered.

Where support breaks down

A 504 plan is updated, but the new accommodations never reach the teachers who provide them.
Language supports for an Emergent Bilingual student are listed in a separate system that special education staff never see.
A dually served student's IEP team and language team meet on different schedules and set conflicting priorities.
A substitute or new teacher has no quick way to see every support a student is entitled to.

In each case, the plan exists. What is missing is a shared, current view for the adults who carry it out.

What tracking together looks like

1Every accommodation from every plan appears in one list for each teacher.

2Teachers record when an accommodation was provided, and how the student responded.

3Dually served students are flagged so both teams see the full picture.

4Leaders can see accommodation use by campus, program and teacher.

Questions for your team

1Where do 504 accommodations live today, and who updates them after a meeting?

2Can a general education teacher see IEP, 504 and language supports for a student in one place?

3How do the special education and language teams share information about dually served students?

4When a family asks what supports were provided, how long does it take to answer?

The answers usually point to one practical change: put every plan's supports in front of the teacher in the same list, and make recording them part of the daily routine.

Why it matters

When accommodation use is recorded rather than assumed, teams can tell which supports are working. That makes 504 reviews, language proficiency conversations and IEP meetings more grounded, and it gives families a clearer answer when they ask what their child received.

Sources

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