Yes. An OCR Memorandum written April 29, 1993, addresses this question: Is a child…who has a disability within the meaning of Section 504 but not under the IDEA, entitled to receive special education services?Yes. If a child…is found to have a disability within the meaning of Section 504, he or she is entitled to receive any special education services the placement team decides are necessary. [19 IDELR 876.]
Districts generally are not aware of this OCR legal interpretation. If you believe your child needs special education services to receive FAPE, you should inform the 504 planning team of the above memo before meeting.