Your First 90 Days as a 504 Coordinator
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Inventory before you announce anything. Ranked by exposure reduced per hour spent.
You'll be tempted to announce a program. Don't. Find out what you're standing on first — the order below is deliberately unheroic, and it's ranked by how much exposure each step actually removes.
Weeks 1-2: stop the silent failures
Publish or fix your accessibility statement. Confirm your complaint route reaches a monitored mailbox and test it by sending something yourself. Open the intake log. Then go find the complaints that already died in someone's inbox — parents file these more than almost any other population in this series, because OCR's complaint process (opens in new window) is free and well known to them. Those existing complaints are your real first priorities, not whatever you were planning to start with.
Weeks 2-4: find out what you own, twice
Every site, portal, LMS, curriculum platform, and document library, with a named owner and a real count — board packets, enrollment forms, parent notices, lunch menus, permission slips, and IEP paperwork, which carries privacy obligations layered on top of its accessibility ones. Ask every department "what else do you use?" and ask again. Dozens of edtech vendors are your largest accessibility surface, and the district controls none of their underlying code — which is exactly why the next step matters more here than in most sectors.
Weeks 3-4: find who signs contracts
Get on that route now. Procurement language matters more in K-12 than almost anywhere else in this series, because your digital footprint is overwhelmingly vendor product. The clause library and vendor review workflow from later in this series are your main tools, and the renewal calendar is your main leverage.
Month 2: build the two gates
A pre-publication check so new parent- and student-facing content stops arriving broken, and a vendor review workflow so nothing new gets bought broken either. Inflow beats backlog — the backlog is finite, the inflow isn't, unless you close it.
Month 2: meet your local disability organization
Not personas — actual families, actual students, who've likely been raising this already. Offer a standing invitation and pay them for structured testing time. One genuine relationship surfaces more real barriers than a quarter of automated scanning.
Month 3: triage, score honestly, make the ask
Triage the document estate — permission slips and enrollment forms first, since a parent who can't read a permission slip can't actually consent to the field trip; that's not a compliance gap, it's a participation problem. Score your program's maturity honestly. Then take one page to whoever holds the budget, usually your technology director, since the reader of this guidance and the buyer of its fixes are often different people in your district.
If you only do four things: publish the statement, log every complaint, get accessibility language into your vendor contracts, and stop broken content at the point of publication. Almost none of it costs money, and together it removes most of your avoidable exposure.
This isn't legal advice on which regimes reach your specific district — verify against your own counsel. If you want a fast first look at whether a specific page or PDF holds up before you bring it to your technology director, ask Luke to check it. Our accessibility statement shows this same discipline applied to our own site.
Previous: the law behind the job · Next: document inventory and triage
Sources: 34 CFR Part 104 — Section 504 Regulations (opens in new window) · 28 CFR Part 35, Subpart H — Web and Mobile Accessibility (opens in new window) · OCR Resolution Agreement Example — Olentangy Local School District (opens in new window) · Web Content Accessibility Guidelines (WCAG) 2.1 (opens in new window)
About Jeff Fryer
Jeff Fryer spent years working kitchens before moving into ADA compliance work for local government. He writes from that experience -- direct, plainspoken, allergic to compliance theater. Contributing writer at accessibility.chat.
Jeff Fryer is a person, not one of the AI analyst lenses this site also publishes under. A named human is accountable for this article.
Specialization: Local government ADA compliance, contributed from direct field experience
Authorship and Editorial Process
Jeff Fryer wrote this article. AI was not used to draft it. It went through the same editorial checks as everything else published here.