Special Education Action

Special Education Action

FAQs

Can Schools Block Students Who Use Accommodations From Receiving Academic and Other Honors?

Learn the answer and read supporting documents and/or regulations.

Callie Oettinger
Sep 25, 2026
∙ Paid

Question:

Can schools block students who use accommodations from receiving academic and other honors?

Answer:

No, not just because a student uses disability-related accommodations. Schools can set compliant rules for who qualifies for an honor. An individualized education program (IEP) or Section 504 plan doesn’t guarantee an award. It also isn’t a reason to deny one. Schools can’t discount a qualified student’s achievement simply because the student received needed support.

Supporting Documents and/or Regulations

Section 504 and Title II

Section 504 of Rehabilitation Act bars disability discrimination in programs and activities that receive federal financial assistance. Title II of Americans with Disabilities Act (ADA) bars disability discrimination by public entities, including public school districts. These protections cover school-sponsored field trips, sports teams, clubs, and other activities beyond the classroom.

Under 34 C.F.R. § 104.4 and 28 C.F.R. § 35.130, schools can’t deny qualified students equal access to benefits because they have a disability.

Title II also requires reasonable modifications to rules, practices, or procedures when needed to avoid disability discrimination. A public school may refuse a change if it can show that the change would fundamentally alter the program or activity. Two examples follow below.

  • In its Jan. 25, 2013, “Dear Colleague” letter, U.S. Department of Education’s Office for Civil Rights (OCR) gave an example of a runner who needed a visual start signal because of a hearing disability. The signal would occur at the same time as the starting pistol. OCR said this wouldn’t change the race’s basic nature or give the runner an unfair advantage.

  • In the same letter, OCR gave an example of a fundamental alteration a school could refuse. Adding an extra base in baseball would change the game.

Schools also can’t use eligibility rules that screen out students with disabilities unless those rules are necessary for the program or activity.

Reydon Public Schools’ Valedictorian Policy

May 15, 2026, U.S. Department of Education’s Office for Civil Rights (OCR) issued its letter for OCR Case No. 07-26-1328, involving Reydon Public Schools (RPS) in Oklahoma. The student’s father said RPS ruled his child out for valedictorian because the student’s IEP allowed extra time on tests. He said the student had earned all A grades for two years and otherwise qualified.

The district’s policy required students to complete coursework “without modifications.” After OCR began its investigation, RPS named the student valedictorian. The principal apologized to the student and father and gave OCR a draft handbook with the disputed words removed.

RPS signed a resolution agreement before OCR finished its investigation. It agreed to revise its valedictorian and salutatorian policies and review those honors for the 2021–22 through 2025–26 school years. For students who qualified but were unlawfully excluded under the old policy because of disability, RPS agreed to provide notice and correct their records.

OCR’s Honor-Roll Finding

OCR’s Annual Report to Congress for fiscal years 2007–08 describes a complaint alleging that a district did the following:

“[D]iscriminated against special education students at a middle school on the basis of disability by excluding special education students from recognition on its A and B honor roll or comparable honor roll.”

OCR didn’t name the district.

According to the report:

“OCR found that the district was selectively applying its unwritten honor roll policy by treating severely disabled students who met the honor roll criteria differently without a legitimate, non-discriminatory reason. The district agreed, among other things, to develop a written honor roll policy that is consistent with Section 504 and Title II and to submit evidence to OCR showing that the school uniformly applied the honor roll policy in effect and provided equal recognition to all eligible honor roll students for the previous six-week grading period, regardless of their disability status.”

OCR’s Special Education Math and Awards Case

OCR’s 2000 Annual Report to Congress describes a student who was kept off the honor roll because he took a special education math class. OCR didn’t name the district.

OCR’s review showed that the problem went beyond this student. Students receiving special education had been:

“categorically excluded from all award and recognition activities.”

This was a blanket exclusion, not a decision limited to one student’s math grade. Under an agreement with OCR:

“the district agreed to work with parents in designing a program to recognize the academic accomplishments of special education students.”

Moorestown’s Valedictorian Dispute

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