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Posted on Sep 24, 2012 in Advocacy |

Does My Deaf or Hard of Hearing Child Need an IEP or a 504 Plan?

By Teresa Sundberg, Teacher Consultant for the Hearing Impaired / Parent of a Hearing Impaired Child / Hard of Hearing Adult

In the previous article, “How Does the IEP under IDEA 2004 Compare to a Section 504 Plan?” two types of educational plans for students with disabilities were addressed to show what schools may provide. But how does each of these plans differ in meeting the needs of children who are Deaf or Hard of Hearing (D/HOH)?

The majority of students who have hearing loss are being educated in the general education classroom in their neighborhood schools and some begin their education in center-based D/HOH Programs and transition to their home schools. Many of these students already receive special education services and have IEP plans that provide support and related services. However, there is a growing trend for school districts to create 504 plans for D/HOH students that provide general classroom and instructional accommodations. Let’s take a closer look at how IDEA 2004 and Section 504 Plans differ in the ways that they help support students who are Deaf or Hard of Hearing in the classroom. As parents of students with a disability, we need to decide which plan will be the best for our child.

If a school district only wants to consider a 504 plan for your child with hearing loss instead of special education services under IDEA, find out what accommodations the school will provide for your child. Will assistive listening devices be provided, and if so, who will monitor the equipment and what qualification will this person have? Who will be responsible for implementing the plan and instructing the classroom teachers on how to provide appropriate accommodations? How often will your child be re-evaluated to determine if the plan is successful, who will do the re-evaluation and what criteria will be used? Another thing to consider is the fact that Michigan Special Education Law is provided from birth to age 26, but 504 plans do not begin until a child reaches Kindergarten.

Eligibility for special education as D/HOH is determined by two pieces of medical documentation, a hearing evaluation by a licensed audiologist and a medical clearance from an ear nose and throat doctor (ENT) certifying a child as Deaf or Hard of Hearing and needing support. These two specific criteria will qualify a child for special education services under IDEA. In addition to medical information, to be eligible for special education and related services under IDEA, a child’s hearing loss must interfere with development or adversely affect their educational performance in the general education setting. A D/HOH child will be eligible for a 504 plan without establishing whether his disability adversely affects his education, but they will still need documentation of their hearing loss. Sometimes classroom teachers, school personnel, and even parents believe that the D/HOH child is doing well educationally, but may overlook some obstacles that the child faces in everyday situations within the classroom setting. These are questions you will want to consider about your child when asking, “Does my child’s hearing loss adversely affect his education?”

  • How is my child doing academically in comparison to the other students in his classroom?
  • Has my child made a year’s progress academically within the past school year?
  • Is he able to follow conversation and instruction in large groups and answer questions correctly during classroom discussions without repetition?
  • Does he currently use assistive technology such as FM amplification system in addition to his cochlear implant or hearing aids in order to understand the teacher better in the classroom?
  • If he doesn’t currently use an FM amplification system, do you feel that he would benefit from using it in the classroom?
  • Is he often confused over oral directions and need clarification?
  • Does he need more time to process information presented orally even with amplification?
  • Does he need a lot of assistance and explanation when completing homework?


Many studies have already shown that children who are D/HOH have challenges in processing linguistic information, even with amplification, which includes speech and language discrimination and reception. This adversely affects their ability to hear and understand content within the general education classroom. Something else to consider is how even though the audiogram may indicate good speech discrimination, this is a representation of how a child hears single words in a quiet setting. Also, classroom acoustics are generally poor and the potential for background noise is increased with more students in classrooms and lack of carpet and/or noise dampening materials on the walls. Students who are D/HOH have difficulty hearing speech when background noise is present. This also affects their education adversely. When school districts suggest that your child is doing well academically and does not require an IEP, parents need to consider all the specific needs your child has in the classroom.

If an ENT and audiologist have recommended the use of a personal FM amplification system for the D/HOH child, the school district is required to provide that equipment to the child as part of a Free and Appropriate Education (FAPE) if it is determined that the child has a hearing loss that is educationally significant. Some school districts have agreements with local Intermediate School Districts (ISDs) that provide personal FM amplification devices to children identified as receiving special education services and may even provide equipment to students to use on a trial basis to establish whether a child benefits from it. Other ISD’s provide FM equipment to students with 504 plans on a trial basis and continue to loan the equipment out to the students on a long term basis. Parents will want to get clarification of what assistive listening devices are available to their child with IEP’s and 504 plans and who will be fitting them and in-servicing classroom teachers about how to use and care for FM systems.

Children who are Deaf and Hard of Hearing have unique educational needs that should be addressed within the classroom environment in order for them to reach their maximum potential. It is up to parents, educators, and school districts to make sure that their needs are being met.

The Michigan Chapter of the Alexander Graham Bell Association for the Deaf and Hard of Hearing expects that this topic will be discussed in the near future due to the current educational climate in the State of Michigan. Please feel free to comment on this article and more to follow and tell us about your own personal experiences with IEPs and 504 plans.