OCR recently released several disability-related resolutions that give a useful window into where the agency is focusing its attention under Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act.

The cases came out of very different settings, from a high school honors decision to a field trip and an after-school program, but they share a common thread. In each one, students with disabilities were kept from opportunities that many might not think of as compliance issues at all, even though OCR clearly does.

An IEP Accommodation Nearly Disqualified a Top Student from Valedictorian

In Reydon Public Schools (Oklahoma), OCR investigated allegations that a student with a disability was denied the opportunity to be named valedictorian because the district’s policy required students to complete coursework “without modifications.” The student’s IEP provided extra time on tests, and the district initially decided that accommodation made her ineligible for the honor, even though she had earned all A’s. After OCR opened its investigation, the district recognized the student as valedictorian, revised its policy, and agreed to review prior graduating classes to determine whether other students with disabilities had been left out of valedictorian or salutatorian consideration in the same way.

OCR’s concern did not stop with this one student. The agency required the district to review years of past honors decisions and correct the record if other students had been excluded because of disability-related accommodations.

Poor Grades Kept a Student Off a Field Trip, but OCR Asked Why the Grades Were Low

In School District of Phillips (Wisconsin), OCR examined whether a student with a disability was improperly excluded from a school-sponsored field trip because of poor grades. The student’s parent alleged that the student’s academic performance was affected both by disability-related needs and by the district’s failure to fully implement portions of the student’s IEP. OCR expressed concerns about whether the district had followed through on executive functioning supports, check-ins with a case manager, and occupational therapy consultations. OCR also questioned whether the district considered reasonable modifications before denying the student the opportunity to participate in the field trip.

As part of the resolution, the district agreed to evaluate whether the student’s exclusion was related to disability and, if so, provide a comparable replacement experience.

After-School Programs Aren’t Exempt Either, as One Club Discovered

OCR’s disability enforcement efforts also reach youth-serving organizations that receive federal financial assistance, not just school districts.

In Boys and Girls Club of Aberdeen Area (South Dakota), OCR investigated whether a student with a disability was denied an equal opportunity to participate in an after-school program because of the organization’s medication policy. According to OCR, the student’s parent tried to enroll the student in the Club’s after-school program but was informed that staff could not administer medication. OCR expressed concern that the Club may not have considered reasonable modifications to its policy that would have allowed the student to participate in the program on an equal basis with other students.

The resolution required the Club to revise its disability-related policies, establish procedures for evaluating medication-related requests, train staff, and invite the student to reapply for membership under the revised procedures.

What These Resolutions Reveal About OCR’s Current Focus

None of These Cases Were About Special Education in the Traditional Sense

None of these cases centered on identification, evaluation, placement, or educational programming in the way most think of special education disputes. Instead, OCR focused on whether students with disabilities had equal access to opportunities that contribute to the broader educational experience: academic honors, enrichment activities, field trips, and after-school programming.

OCR Is Looking at What Policies Say and What They Actually Do

In each case, OCR’s concerns went beyond a single decision and extended into the policies and practices that produced the outcome in the first place. Whether it was a valedictorian eligibility requirement, a field-trip participation decision, or a medication policy, OCR examined the language or impact of institutional rules that created barriers for students with disabilities. None of these policies were written to single out students with disabilities, but each one ended up doing exactly that in practice. Expect OCR to look past individual incidents and ask whether the same barrier could affect other students too.

This focus on language and impact, rather than intent alone, runs through all three resolutions. A policy that reads as neutral on its face can still violate Section 504 or Title II if its practical effect is to deny students with disabilities equal access to an opportunity. That’s a meaningfully different standard than asking whether a school meant to discriminate, and it’s one that to keep in mind when reviewing eligibility criteria, participation rules, and similar policies across the board.

Documentation Continues to Matter

The Wisconsin resolution is a reminder that OCR often evaluates not only whether services were actually provided, but whether there is proof that they were provided. Saying that accommodations, supports, or services occurred may carry less weight when documentation is incomplete or inconsistent.

The same principle applies on the other side of the equation. When a student or family requests an accommodation or support and it is not provided, documenting that decision, along with the reasoning behind it, can matter just as much as documenting the accommodations that were approved. A written explanation of why a request was declined shows that the district or institution engaged in an individualized review rather than applying a blanket policy. It also gives anyone overseeing service provision a way to catch patterns early, such as a staff member who is declining similar requests across the board because a policy makes approval difficult. Building this kind of documentation into everyday practice can make a meaningful difference if OCR or another agency later asks how a decision was made.

Blanket Rules Keep Causing Trouble

The clearest lesson from these resolutions is that disability compliance rarely works as a set of blanket rules. OCR kept coming back to the same question in each case: did the institution consider the student’s individual circumstances, and did it think through whether reasonable modifications or accommodations were necessary? Policies that automatically disqualify students from opportunities because they receive accommodations, modifications, or disability-related services continue to create real compliance risk, regardless of the language or impact of those policies as originally written.

Tuesday Takeaways

These resolutions serve as a timely reminder that disability compliance extends far beyond the classroom. Honors recognition, field trips, extracurricular activities, after-school programs, and other opportunities are all subject to the requirements of Section 504 and Title II.

Institutions should regularly review policies governing eligibility, participation, recognition, safety, and access—not just academic programming—to ensure that students with disabilities have an equal opportunity to participate in the full range of educational and developmental experiences. The biggest compliance risks rarely come from intentional discrimination. They tend to come from longstanding policies and practices that were never evaluated through the lens of disability access and individualized consideration, no matter how reasonable those policies might have seemed when they were written.

These resolutions show why Investigators and Coordinators need training that goes beyond the basics of identification and placement. Understanding how policies can create access barriers, and how to document the reasoning behind both approvals and denials, takes practice and the right framework.

ICS offers several on-demand courses that speak directly to the issues raised in these cases, including:

• Conducting an Effective Interactive Process Under ADA Section 504
• Investigating Failure-to-Accommodate Complaints Under ADA & Section 504
• IEPs & Civil Rights Compliance: What Investigators and Coordinators Need to Know in K-12

These courses are available for individual purchase, and if your school, district, or institution is a Diamond-tier Community Partner, they’re already available to you. If you’re interested in becoming a Community Partner, reach out to learn more.