AOTA Comments on the Process to Update Section 504 Regulations

Abe Saffer 07/26/2022

When the U.S. Department of Education announced the beginning of the long process to update the regulations implementing Section 504 of the Rehabilitation Act of 1973, they requested broad feedback from the public. This feedback was to help ensure staff from the Office of Civil Rights (OCR) focused on the critical aspects of the regulations. The unusual nature of the request for information created a rare opportunity to shape education for students with disabilities.

AOTA launched a national survey of school-based OTs and OTAs on the 504 process. Your responses were overwhelming—nearly 400 practitioners took the time to provide thoughtful feedback. Here is a word cloud representing the feedback from practitioners regarding the current challenges faced while providing services in schools.

Multicolored Word Cloud created from survey responses. Biggest or most often repeated words throughout the responses to the survey include: Accommodations, students, services, direct, team, education, needs, staff, school, District, IEP, and Time.

This feedback, provided by practitioners, helped AOTA create a comment letter. AOTA submitted this comment letter to the Department of Education’s Office of Civil Rights. The full comment letter highlighted where the regulation update debate should start and can be found through this link.

The process to update the regulations will be a long one. Currently, department staff is reviewing the thousands of responses submitted through the comment process. Once they have reviewed the responses, they will release their proposal for the updated regulations. At which point AOTA will review and respond. AOTA will continue to advocate for the role of occupational therapy in schools throughout this process.

You can read the comment letter as submitted. If you have any questions, email Abe Saffer, AOTA Senior Legislative Representative, at ASKFAD@AOTA.org.