I was asked the other day to explain what the job responsibilities are for a school district's Section 504 Coordinator. The person was trying to better understand what Assistant Superintendent Dan Baker's responsibilities were in the Fox C-6 School District for the last 6 years as the Section 504 Coordinator. I gave them a very brief description of what a Section 504 Coordinator does. This person was also trying to understand how the Fox C-6 school board allowed the Bakers to keep their jobs after being implicated in the recent Internet scandal in the Fox C-6 School District.
Perhaps some of the Fox C-6 school board members will read the job description posted below so they can get a better understanding of what Mr. Baker's job responsibilities were for the Fox C-6 School District.
Dan Bakers Unique Position Not Covered by News Media
Someone also asked my why the news media hadn't picked up on the fact that Mr. Baker's job position in the district put him in a very unique position. It would certainly be an issue if anyone in the Fox C-6 School District were to make defamatory comments in online forums that were directed at persons who had filed Section 504 complaints with the school district. To make the posts anonymously and have them traced back to your home would seem even more deceptive. Since Mr. Baker was the Section 504 Coordinator for the Fox C-6 School District for the past 6 years, having defamatory comments traced back to his home that were made against a person who had filed Section 504 complaints against the district seems as if that would have been a problem.
So, it's a really good question as to why the news media hasn't looked into and reported on that issue yet.
A SECTION 504/ADA COORDINATOR JOB DESCRIPTION
Background
Under Section 504 of the Rehabilitation Act of 1973, each school district that receives federal financial assistance must designate at least one employee to coordinate the district’s compliance with its responsibilities under Section 504. If a district has 50 or more employees, it must also designate at least one employee to coordinate the district’s compliance with Title II of the Americans with Disabilities Act (ADA). Most school districts designate one employee to serve both of these roles. This employee is often known as the Section 504/ADA Coordinator.
The district’s Section 504/ADA Coordinator may also serve as the district’s Civil Rights Compliance Coordinator.
While school districts may determine additional job requirements, the Section 504/ADA
Coordinator is, at a minimum, responsible for:
- Coordinating and monitoring the district’s compliance with Section 504 and Title II of the ADA, as well as state civil rights requirements regarding discrimination and harassment based on disability;
- Overseeing prevention efforts to avoid Section 504 and ADA violations from occurring;
- Implementing the district’s discrimination complaint procedures with respect to allegations of Section 504/ADA violations, discrimination based on disability, and disability harassment; and
- Investigating complaints alleging violations of Section 504/ADA, discrimination based on disability, and disability harassment.
Choosing a Section 504/ADA Coordinator
The Section 504/ADA Coordinator should be sufficiently knowledgeable about the requirements under state and federal disability discrimination laws, regulations, and guidance (including Section 504 and Title II of the ADA) to advise the district about its policies, procedures, and practices and to investigate complaints alleging violations of Section 504/ADA, discrimination based on disability, and disability harassment.
The school district should ensure that the Section 504/ADA Coordinator receives appropriate and on going training. The district should clearly communicate the responsibilities and expectations of the position with the Section 504/ADA Coordinator, and should provide them with the time and resources needed to effectively perform these duties.Section 504/ADA Coordinator
Sample Section 504/ADA Coordinator Job Description
Note: If the Section 504/ADA Coordinator also serves as the district’s Civil Rights Compliance Coordinator and/or Title IX Officer, please see the sample job descriptions for these roles for additional responsibilities.
In coordination with the Civil Rights Compliance Coordinator, the Section 504/ADA Coordinator is responsible for monitoring and implementing the district’s compliance with state and federal laws prohibiting disability discrimination, including Section 504 and Title II of the ADA.
The major responsibilities are (1) to prevent discrimination against students, employees, and others on the basis of disability; and (2) to ensure compliance with all procedures and procedural safeguards required under Section 504/ADA. Particularly when indicated below, the Section 504/ADA Coordinator should coordinate closely with the district’s Civil Rights Compliance Coordinator.
The Section 504/ADA Coordinator’s duties include the following:
Knowledge of Section 504/ADA Requirements
- Develop a working knowledge of current laws, regulations, and guidelines related to disability discrimination in public schools, including Section 504, Title II of the ADA as well as rules and guidelines of the U.S. Department of Education’s Office for Civil Rights (OCR)
- Become familiar with resources and information available from OCR and request technical assistance when needed
- Attend trainings on Section 504/ADA and share information with district administrators and staff
- Serve as the district’s liaison to OCR for issues regarding Section 504/ADA and disability discrimination generally
- Update Section 504/ADA Coordinator contact information with OCR as needed
District Policies and Procedures
- Facilitate the implementation of the district’s policies and procedures related to Section 504/ADA, and ensure that they are applied consistently across the district and at each school building
- Coordinate revisions to district policies and procedures related to Section 504/ADA, as necessary, to ensure that they are up-to-date and consistent with current requirements under these laws
Nondiscrimination Notices
In coordination with the district’s Civil Rights Compliance Coordinator:
- Regularly review district and building publications to ensure that they include a consistent nondiscrimination statement with all of the necessary protected classes and the name (or title), Section 504/ADA Coordinator phone number, and address of the district’s Section 504 Coordinator, Title IX Officer, and Civil Rights Compliance Coordinator
- Ensure that the district uses effective methods to annually inform all students, parents, and employees about the district’s discrimination complaint procedure, such as in staff and student handbooks
- Ensure that copies of the complaint procedure and any related forms are available in each school building to provide to students, parents, staff, and others who allege discrimination or discriminatory harassment
Section 504 Procedures and Procedural Safeguards
Develop a systematic process for monitoring both district and building level compliance with Section 504 requirements, including but not limited to:
- Child find responsibilities
- Parental consent before all initial evaluations and initial placements
- Written notice to parents, including notice of procedural safeguards, before any actions are taken regarding identification, evaluation, or placement under Section 504
- Team-based decision-making regarding evaluation and placement of students under Section 504
- Dissemination of Section 504 plans to appropriate staff
- Periodic re-evaluations of all students who are eligible under Section 504, at least every three years
- Manifestation determination requirements for disciplinary changes in placement under Section 504
- Participate on Section 504 teams as needed
- Coordinate training for building-level Section 504 designees, and ensure that they are informed about their job responsibilities (listed below)
- Collect and maintain all Section 504 data, such as Section 504 plans, evaluation reports and related records, lists of eligible students, discipline records, etc.
- Coordinate due process hearings when requested
Accessibility and Requests for Accommodations
- Continually monitor the reduction of architectural barriers for individuals with disabilities
- Receive and process requests for reasonable accommodations at school and district events Coordinate with the district’s human resources office to facilitate the provision of reasonable accommodations for district employees with disabilities
Training and Consultation
In coordination with the district’s Civil Rights Compliance Coordinator:
- Provide ongoing support and training to administrators and district- and building-level staff about requirements under Section 504/ADA, staff responsibilities, complaint procedures, and related district policies and procedures
- Disseminate information and coordinate training for students and/or parents about their rights under Section 504/ADA, and the district’s complaint procedures
- Advise the superintendent and school board regarding the status of the district’s compliance with Section 504/ADA
- Receive and respond to inquiries from students, parents, staff, administrators, and others regarding Section 504/ADA, disability discrimination, and harassment based on disability
- Serve as a resource for administrators, district- and building-level staff, and Section 504 teams about Section 504/ADA and disability discrimination
Complaints and Investigation
In coordination with the district’s Civil Rights Compliance Coordinator:
- Respond to students, parents, staff, administrators, and others who report suspicion of Section 504/ADA violations, disability discrimination, or harassment based on disability. The coordinator should investigate these concerns, institute corrective actions when appropriate, inform the individual about the district’s complaint procedures, and assist individuals in filing complaints when needed
- Implement the district’s discrimination complaint procedure with respect to allegations of Section 504/ADA violations, disability discrimination, and harassment based on disability; receive and process complaints; and oversee the step-by-step process to be sure that timelines are met
- Conduct and/or coordinate investigations of Section 504/ADA complaints in accordance with the district’s discrimination complaint procedures. This may involve interviewing complainants, respondents, and witnesses; reviewing documents and other relevant materials; and researching legal standards and requirements relevant to the complaint. If the Section 504/ADA Coordinator has identified a conflict of interest with respect to a particular complaint, the coordinator should recommend that the district hire a neutral outside investigator to investigate a particular complaint
- Upon completion of the investigation, provide the superintendent with a written report of the complaint and the results of the investigation in time for the superintendent to respond to the complainant within 30 days after the district initially received the complaint
- Organize and maintain records of all Section 504/ADA and disability discrimination complaints filed, including all formal and informal complaints. At least annually, review complaint files to ensure that the district’s complaint procedures and timelines are consistently being followed, and to identify any patterns and repeat offenders
Textbooks and Instructional Materials
In coordination with the district’s Civil Rights Compliance Coordinator:
- Participate in the development and implementation of the school district’s instructional materials policy and bias review criteria with respect to bias pertaining to disability in all textbooks and instructional materials
- Ensure that the district evaluates all textbooks and instructional materials for bias, update bias review criteria when needed, and participate on the instructional materials committee when appropriate
Reviewing Systemic Barriers
In coordination with the district’s Civil Rights Compliance Coordinator:
- Participate in the development and implementation of the school district’s process to routinely review disaggregated student discipline data and course and program enrollment data to identify and address potential disparities and systemic barriers based on disability
- Continually monitor school programs, activities, and services (including, but not limited to, Advanced Placement courses, Highly Capable Programs, Career and Technical Education courses, Alternative Learning Experiences, extra-curricular activities, etc.) to ensure that all students are given an equal opportunity to participate without discrimination based on disability
- Coordinate with the district’s human resources office to evaluate employment criteria, recruitment, compensation, job classification, benefits, and advertising to ensure that they are not discriminatory on the basis of disability
Sample Section 504 Building Designee Job Description
- Maintain building records and documentation for all students eligible under Section 504 and provide copies to the district Section 504 Coordinator
- Ensure the implementation of Section 504 procedures in the school building, including:
- Coordinating referrals
- Determining appropriate Section 504 team composition and participating on Section 504 teams as needed
- Facilitating Section 504 evaluations and development of Section 504 plans
- Providing notices and documenting parental consent
- Distributing Section 504 plans to appropriate staff
- Monitoring the implementation of Section 504 plans
- Scheduling annual reviews of each Section 504 plan
- Scheduling period re-evaluations of all students eligible under Section 504 at least every three years
- Assuring that Section 504 plans move with the student to the next grade level and to new schools
- Coordinating training of building staff on Section 504 requirements
- Conducting manifestation determinations when required for students eligible under Section 504
- Serve as a daily resource to the building administrators, teachers, and staff regarding Section 504
- Serve as a liaison between the school building and other district staff regarding Section 504 issues
- Maintain contact with the district Section 504 Coordinator and request assistance and training when needed
- Attend periodic district Section 504 trainings as needed to stay informed about current district requirements to comply with Section 504
