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IFSP, IEP, IPP and 504 Plan: What Each One Is

Analysis by Bri Stanback, SchoolScope19 min read68 cited sourcesPublished

The short answer

Under 3, an eligible child’s plan is an individualized family service plan (IFSP), California’s Early Start plan for babies and toddlers.

From 3, school districts write the individualized education program (IEP), and Regional Centers write the individual program plan (IPP). A child can have both at once, and a 504 plan is the school’s other route.

The IEP is the special education plan. The IPP covers support at home and in the community. A 504 plan gives a student with a disability equal access to school, under a civil rights law. We read these rules in November 2026, and laws change.

Choose your child’s age to see which plans the law gives at that age.

Four plans in California · birth to age 22

At my child’s age, which plans can apply?

Choose an age. You see which plans the law gives at that age, and who is responsible for each one.

Choose your child’s age

Use the age in whole years. A child who has not turned 3 yet is 2.

Example: a child aged 4 Two plans can run side by side, the IEP and IPPIEP + IPP. In a school that gets federal money, the other route is a 504 plan.

Two agencies, two plans. The school district writes the IEP for school. The Regional Center writes the IPP for home and community life. Each agency decides for itself who qualifies. A person can qualify with both, with only one, or with neither. The state says a child who is not eligible for school services can still get Regional Center services.

The four plans, one square for each year of age

The law gives this plan at this age It depends, and the card says on what Not shown at this age

  1. IFSP Birth to the third birthday

  2. IEP 3 to 21, and part of the year a student turns 22

  3. IPP 3 and older, with no upper age

  4. 504 plan The ages follow the school or program

At age 4: the plans that can apply

  • The law gives this plan at this age

    IEP Individualized education program

    • From 3 to 5, the district serves a child who qualifies. Its duty covers children who are not enrolled in a public school program. At these ages the list of disabilities also includes an established medical disability, which the IEP team decides.
    Who writes it
    Your school district, or another local education agency. The parent is on the team that writes it.
    Which law
    Part B of the federal Individuals with Disabilities Education Act (IDEA; 34 CFR Part 300) and California Education Code 56026 and the sections after it.
    Centered on
    Your child’s education. The plan states where your child is now in school, measurable goals for the year, and the services the district will provide.
    How often it is reviewed
    At least once a year. A new assessment at least every three years, unless you and the district agree in writing to skip it. A meeting within 30 days of your written request, not counting school breaks longer than five school days.
    What you sign
    Consent to the assessment plan, then written consent before the first special education services start. You can consent to part of the IEP, and that part must start.
  • The law gives this plan at this age

    IPP Individual program plan

    • For a person with a developmental disability that began before 18, is expected to continue and is substantial. The Regional Center decides who qualifies.
    • A child under 5 can qualify provisionally, without a named diagnosis. The child needs a disability that is not only physical, with significant limits in at least two of five areas of daily life. The Regional Center reassesses the child at least 90 days before age 5. At 5 the child stays eligible only by meeting the full definition, unless an appeal was filed.
    • Since July 1, 2021, a Regional Center may again fund educational services for children aged 3 to 17.
    Who writes it
    The Regional Center. The law says decisions are made by agreement between the Regional Center and the person or, where appropriate, the parents, legal guardian, conservator or authorized representative.
    Which law
    California’s Lanterman Developmental Disabilities Services Act (Welfare and Institutions Code 4646 and 4646.5).
    Centered on
    The person’s life goals and preferences, and the family’s. The state describes it as support for home and community life.
    How often it is reviewed
    At least every three years under the Lanterman Act. A review you ask for is due within 30 days, or within 7 days when it is needed for health and safety or to keep the person at home. Every year for a person on the Medicaid home and community waiver, under a federal rule. The state’s guide also says every year for a person who lives in a licensed residential care home.
    What you sign
    A release so the Regional Center can collect records for its assessment. Then the plan itself. Services you agree to can start once you sign, and you can sign even if you do not agree to every service.
  • It depends on the school or program

    504 plan A plan under Section 504 of the Rehabilitation Act of 1973

    • The rule covers preschool, elementary, secondary and adult education programs that get federal money.
    • For these programs, a student is covered at an age when the school serves students without disabilities, at an age when state law requires services for students with disabilities, or at an age when the state must provide a free appropriate public education under IDEA (34 CFR 104.3).
    • A child with an IEP does not need a separate 504 plan. A child who does not qualify for an IEP may still qualify here.
    Who writes it
    The school district. It must evaluate a child who may need help because of a disability. A district with 15 or more employees must name a Section 504 coordinator.
    Which law
    Section 504 of the Rehabilitation Act of 1973, a civil rights law. The federal Office for Civil Rights enforces it.
    Centered on
    Equal access to school. The district must meet your child’s needs as adequately as it meets other students’ needs.
    How often it is reviewed
    The rule says “periodic” and sets no interval. The district must also evaluate before a significant change in placement.
    What you sign
    The rules we read do not say. Ask the district’s Section 504 coordinator whether the plan will be in writing, and what you will be asked to sign.

Not shown at this age

These are the ages the law sets. They do not say your child qualifies. Each agency decides that from its own assessment.

See all four plans as a table
Each plan with its ages and what the law says about it. Every age from birth to 22 is covered.
PlanAges in the lawWho writes itWhich lawCentered onHow often it is reviewedWhat you sign
IFSP: individualized family service planBirth to the third birthday. For a child from birth through age 2 whose need for early intervention is documented by assessment. The child must also have a developmental delay, a condition with known harmful effects on development, or a high risk of a substantial developmental disability. The IFSP ends on the third birthday. If your child may qualify for school preschool services, Early Start arranges a conference with you and the school district, with your approval. It is held at least 90 days before the third birthday.The Regional Center, through California’s Early Start program. A school district writes it in one case. The infant’s only disability is in vision, hearing or a severe orthopedic impairment, or a mix of these. The infant is also not eligible for Regional Center services.Part C of the federal Individuals with Disabilities Education Act (IDEA), and California’s Early Intervention Services Act (Government Code 95014).The child and the family together. The plan states outcomes for both. It states the family’s own concerns and priorities if the family agrees.At least every three months in California. Federal rules add a meeting at least once a year.Written consent before the evaluation and assessment, and again before services start.
IEP: individualized education program3 to 21, and part of the year a student turns 22. For a child leaving Early Start who qualifies, the district must make sure an IEP or an IFSP is in place and in use by the third birthday. From 3 to 5, the district serves a child who qualifies. Its duty covers children who are not enrolled in a public school program. At these ages the list of disabilities also includes an established medical disability, which the IEP team decides. Goals for life after high school enter the IEP when your child starts high school, and no later than the IEP in effect at 16, where the team finds it appropriate. At 18, the rights a parent has under the special education law pass to the student. The exception is a student found incompetent under state law. The district tells both the student and the parent. From 19 to 21, the IEP continues for a student who was in special education, or eligible for it, before turning 19, and who has not graduated with a regular high school diploma. The IEP ends during the year a student turns 22, and the birthday month decides when. January to June: the student may finish the current fiscal year. July to September: the student may not start the new fiscal year. A student in a year-round program who is finishing the IEP in a term that runs into the new fiscal year may finish that term. October to December: the program ends on December 31, unless the IEP would be completed at the end of that fiscal year. Ask the district which dates its fiscal year runs between.Your school district, or another local education agency. The parent is on the team that writes it.Part B of the federal Individuals with Disabilities Education Act (IDEA; 34 CFR Part 300) and California Education Code 56026 and the sections after it.Your child’s education. The plan states where your child is now in school, measurable goals for the year, and the services the district will provide.At least once a year. A new assessment at least every three years, unless you and the district agree in writing to skip it. A meeting within 30 days of your written request, not counting school breaks longer than five school days.Consent to the assessment plan, then written consent before the first special education services start. You can consent to part of the IEP, and that part must start.
IPP: individual program plan3 and older, with no upper age. For a person with a developmental disability that began before 18, is expected to continue and is substantial. The Regional Center decides who qualifies. A child under 5 can qualify provisionally, without a named diagnosis. The child needs a disability that is not only physical, with significant limits in at least two of five areas of daily life. The Regional Center reassesses the child at least 90 days before age 5. At 5 the child stays eligible only by meeting the full definition, unless an appeal was filed. Since July 1, 2021, a Regional Center may again fund educational services for children aged 3 to 17. From 18 to 22, the Regional Center generally does not buy day programs, vocational education, work services, independent living programs or mobility training with related transportation. This applies to a student who is eligible for special education and has not received a diploma or a certificate of completion. The Regional Center can buy them if the IPP team finds the school cannot meet the need, or grants an exemption. This plan has no upper age for a person who stays eligible. The law describes Regional Center services as lasting throughout a person’s lifetime.The Regional Center. The law says decisions are made by agreement between the Regional Center and the person or, where appropriate, the parents, legal guardian, conservator or authorized representative.California’s Lanterman Developmental Disabilities Services Act (Welfare and Institutions Code 4646 and 4646.5).The person’s life goals and preferences, and the family’s. The state describes it as support for home and community life.At least every three years under the Lanterman Act. A review you ask for is due within 30 days, or within 7 days when it is needed for health and safety or to keep the person at home. Every year for a person on the Medicaid home and community waiver, under a federal rule. The state’s guide also says every year for a person who lives in a licensed residential care home.A release so the Regional Center can collect records for its assessment. Then the plan itself. Services you agree to can start once you sign, and you can sign even if you do not agree to every service.
504 plan: a plan under Section 504 of the Rehabilitation Act of 1973The ages follow the school or program. We did not find a source that gives a 504 plan to a child under 3. The rule for school services names no age in years. It sets the ages by when a school serves students, or when state law or IDEA requires services. If your child attends a program, ask the program whether it gets federal money. The rule covers preschool, elementary, secondary and adult education programs that get federal money. For these programs, a student is covered at an age when the school serves students without disabilities, at an age when state law requires services for students with disabilities, or at an age when the state must provide a free appropriate public education under IDEA (34 CFR 104.3). A child with an IEP does not need a separate 504 plan. A child who does not qualify for an IEP may still qualify here.The school district. It must evaluate a child who may need help because of a disability. A district with 15 or more employees must name a Section 504 coordinator.Section 504 of the Rehabilitation Act of 1973, a civil rights law. The federal Office for Civil Rights enforces it.Equal access to school. The district must meet your child’s needs as adequately as it meets other students’ needs.The rule says “periodic” and sets no interval. The district must also evaluate before a significant change in placement.The rules we read do not say. Ask the district’s Section 504 coordinator whether the plan will be in writing, and what you will be asked to sign.

What does each of the four names mean?

Each name is a plan for one child, and the laws behind them differ.

The IFSP and the IEP come from different parts of one federal law, the Individuals with Disabilities Education Act (IDEA). The IPP and the 504 plan each come from a law of their own. A Regional Center writes the IFSP in Early Start, and the IPP after that. A school district usually writes the IEP and the 504 plan. In some cases a county office of education is the responsible agency. A Regional Center is a private nonprofit agency under contract with the state. Our Regional Center guide explains how to find yours.

The IEP and the 504 plan are both school plans. An IEP is for a child with one of 13 listed kinds of disability who needs special education. From ages 3 to 5, an established medical disability also counts. A 504 plan covers more conditions. The Legislative Analyst’s Office gives diabetes and severe allergies as conditions that can qualify a student for one.

What does each of the four names mean?
IFSP IEP IPP 504 plan
Who it is for A child from birth through age 2 whose need for early intervention is documented by assessment. The child has a developmental delay, a condition with known harmful effects on development, or a high risk of a substantial developmental disability A student aged 3 through 21, and part of the year a student turns 22, with a listed disability who needs special education. Ages 3 to 5 add an established medical disability A person aged 3 or older with a developmental disability that began before 18, is expected to continue and is substantial. A child under 5 can instead qualify provisionally, without a named diagnosis A student with an impairment that substantially limits a major life activity, such as learning
Who writes it The Regional Center. A school district writes it when the infant’s only disability is in vision, hearing or a severe orthopedic impairment, or a mix of these, and the infant is not eligible for Regional Center services The school district, with the parent on the team. At 18, a parent’s rights pass to the student The Regional Center, by agreement with the person or, where appropriate, the parents or other representative The school district, in a program that gets federal money
The law Part C of the federal Individuals with Disabilities Education Act, and California’s Early Intervention Services Act Part B of the federal Individuals with Disabilities Education Act (34 CFR Part 300) and California Education Code 56026 and the sections after it California’s Lanterman Act (Welfare and Institutions Code 4646 and 4646.5) Section 504 of the Rehabilitation Act of 1973
Centered on The child and the family together The child’s education: where the child is now, goals for the year, and services The person’s life goals and preferences, and the family’s Needs met as adequately as other students’ needs
Reviewed At least every three months in California, with a meeting at least once a year At least once a year, with a new assessment at least every three years, unless the parent and the district agree in writing that it is unnecessary At least every three years. Every year on the Medicaid waiver, and, says the state’s guide, for a person in a licensed residential care home “Periodic” re-evaluation, with no set interval
How a decision is made Written consent from the parent before the evaluation and assessment, and before services start By the IEP team. The parent can consent to part of the plan By agreement between the Regional Center and the person or, where appropriate, the parents or other representative The district must evaluate before it places a child who may need services because of a disability

Source: California Government Code, Education Code and Welfare and Institutions Code, federal regulations, and the U.S. Department of Education, read November 2026. The California regulations were read on Cornell’s mirror of the official text.

The first IPP is due within 60 days of the day the assessment is completed. After that, the Lanterman Act says the plan is reviewed at least every three years. Some people get a yearly review. A federal Medicaid rule requires one for people on a home and community waiver. The state’s guide says the same for that group, and for people in a licensed residential care home.

You can ask for a review of the IPP. It must happen within 30 days of your request. A review needed for health and safety, or to keep the person at home, must happen within 7 days. At the end of a meeting, the Regional Center gives you a list of the agreed services. You can choose to receive that list 15 days later, in your preferred language. On request, you also get a written copy of the whole plan within 45 days. That copy comes in a “threshold language”, a term the statute takes from a state regulation. Ask the Regional Center whether your language is one.

Which plan goes with my child’s age?

The IFSP covers birth through age 2, and the IEP and the IPP start at 3.

The IEP ends in the year a student turns 22. The IPP has no upper age for a person who stays eligible. A 504 plan follows the school or program.

Under 3, an eligible child has one plan. For an eligible infant or toddler, California law says the IFSP is used in place of an IPP and an IEP. The state says all Early Start services end when a child turns 3.

At 3, the state’s packet describes three paths. A child may qualify with both agencies, with the school district only, or with neither. The state’s FAQ adds that a child who does not qualify for school services can still get Regional Center services. The child must be provisionally eligible or eligible under the Lanterman Act. Some children leave Early Start and qualify for special education. For them, the district must make sure an IEP or an IFSP is in place and in use by the third birthday. Our guide to the handoff at age 3 has the dates.

The IEP’s ages come from one section of the Education Code. From 19 to 21, it covers a student who was in special education, or eligible for it, before turning 19. The student must not have graduated with a regular high school diploma.

At 18, the rights a parent has under the special education law pass to the student. The exception is a student found incompetent under state law. The district must tell both the student and the parent.

In the year a student turns 22, the birthday month decides the last day. A student who turns 22 from January to June may finish the current fiscal year. A student who turns 22 in July, August or September may not start the new fiscal year. The exception is a student in a year-round program who is finishing the IEP in a term that runs into the new fiscal year. That student may finish the term. For a birthday from October to December, the program ends on December 31. The statute makes one exception, for a student who would complete the IEP at the end of that fiscal year.

The IPP begins at 3 for a child the Regional Center finds eligible. A child under 5 can qualify provisionally, without a named diagnosis. The child needs a disability that is not only physical, with significant limits in at least two of five areas of daily life. The Regional Center reassesses the child at least 90 days before age 5. At 5 the child stays eligible only by meeting the full definition, unless an appeal was filed. The law describes Regional Center services as lasting throughout a person’s lifetime.

Section 504 covers preschool, elementary, secondary and adult education programs that get federal money. Its rule names no age in years. It sets the ages by when a school serves students, or when state law or IDEA requires services. So the question to ask is whether your child’s school or program gets federal money. From 3, the ages overlap, and so can the plans. We did not find a source that gives a 504 plan to a child under 3.

Can my child have more than one plan?

Yes, from age 3 a child can have an IEP from the school district and an IPP from the Regional Center.

The state’s own packet for families says a child who qualifies with both agencies “will now have two plans”. It says the school provides services for educational benefit. The Regional Center supports life at home and in the community.

Qualifying with one agency does not mean qualifying with the other. The Regional Center’s test is narrower. It covers a developmental disability that began before 18, is expected to continue and is substantial. A child under 5 can qualify provisionally under a different test. The state’s guide says a learning disability or a mental health diagnosis is not enough on its own. So a child can have an IEP for a learning disability and not qualify for an IPP.

An IEP and a 504 plan work differently. The federal Office for Civil Rights says a child who qualifies for an IEP does not also need a 504 plan. Carrying out the IEP is one way to meet Section 504. The same office says a child who does not qualify for an IEP may still qualify under Section 504. If the district says no to an IEP, we’d ask about a 504 plan in the same conversation.

The sources we read do not address a 504 plan and an IPP together. The two come from different agencies under different laws.

When a child has an IEP and an IPP, two agencies each owe the child something. The next question is which agency pays for which service.

If my child has an IEP and an IPP, who pays for what?

The school district provides the services in the IEP, and Regional Center money generally cannot replace a school’s budget.

The statute has several parts, and they are not equally strict. Three of them apply to schools.

  • Regional Center money “shall not be used to supplant the budget” of a public agency. The statute means an agency that must serve everyone and gets public money to do it.
  • The Regional Center must “identify and pursue all possible sources of funding”. The statute names school districts among them.
  • A Regional Center may not buy behavioral services called applied behavioral analysis (ABA) or intensive behavioral intervention “for purposes of providing respite, daycare, or school services”.

A fourth part is stricter, and it does not name schools. A Regional Center “shall not purchase any service that would otherwise be available from” Medi-Cal, Medicare, the military health program, In-Home Support Services, California Children’s Services, private insurance or a health plan. That bar applies when a family qualifies for the coverage “but chooses not to pursue” it. The list in section 4659 covers health programs and insurance. Disability Rights California, which publishes a manual on these rights, reads the wider rule to cover school districts too.

The Regional Center still has a job while your child is in school. Since July 1, 2021, Regional Centers may again fund “educational services for children three to 17”. Disability Rights California says the Regional Center must make sure a child gets the services the IPP goals need, “even if your child is in school”. From 18 to 22, a separate rule applies to a student who is eligible for special education. The student must not have received a diploma or a certificate of completion. The Regional Center generally does not buy day programs, vocational education, work services, independent living programs or mobility training for that student. It can if the IPP team finds the school cannot meet the need, or grants an exemption.

Can the Regional Center coordinator come to the IEP meeting?

You can invite the coordinator. The Education Code lets a parent bring “other individuals who have knowledge or special expertise regarding the pupil”. The parent decides whether a person fits. Disability Rights California names the Regional Center coordinator as someone a parent can bring.

Whether the coordinator comes is a different matter. We found one sentence of statute about it. It says the coordinator “may attend” the IEP meeting at the request of the person or, where appropriate, the parent. That sentence sits in the section about 18- to 22-year-olds. We found nothing that requires a Regional Center to send someone.

Do the two agencies share my child’s records?

A Regional Center asks for your written approval to contact schools. Disability Rights California says it “cannot get copies of your records without your approval”. Regional Center records are confidential by statute, and the statute lists the only cases where they may be disclosed. The list includes communication between professionals who provide services, a claim for a benefit, and a court. A federal rule requires a parent’s consent before a school discloses special education records, and it lists exceptions.

What is the Self-Determination Program?

It is another way to carry out an IPP. The statute says it gives families, “within an individual budget, increased flexibility and choice, and greater control over decisions, resources, and needed and desired services and supports to implement their IPP”. It has been open to eligible Regional Center clients since July 1, 2021, and it is “fully voluntary”. A child who is only provisionally eligible does not qualify.

Two agencies also means two ways to disagree.

What if I disagree with a plan?

Disagreeing with the school district and disagreeing with the Regional Center are two separate processes with different deadlines.

With both, you can agree to part of a plan. The parts of an IEP you consent to must start. The IPP services you agree with are not held up by the ones you dispute.

What if I disagree with a plan?
School district (IEP) Regional Center (IPP)
Your routes A complaint to the California Department of Education, a mediation, or a due process hearing (CDE) An informal meeting, a mediation or a fair hearing, in any combination (section 4710.5)
Your deadline A complaint covers a violation from the past year. A hearing request is due within two years of when you knew or had reason to know the facts. The limit does not apply to a parent who was kept from asking because the district said it had solved the problem when it had not, or held back information it had to give you 60 days from the notice
Keeping things as they are While a hearing is pending, your child stays in the present placement, unless you and the district agree otherwise. Some discipline cases are an exception Appeal within 30 days after you receive the notice, and no later than the day the change takes effect. Services in your IPP then continue during the appeal
Where it goes The complaint, and a request to mediate it, go to the Department of Education. A request for mediation only, or for a hearing, goes to the Office of Administrative Hearings The appeal form goes to the Department of Developmental Services (DDS)
How long it takes A complaint decision within 60 days, unless exceptional circumstances extend it. A hearing decision 45 days after the 30-day resolution period ends. A hearing officer can extend that for good cause A hearing within 50 days of DDS receiving your request, unless a continuance is granted. Your first request for a continuance is granted, and the center can ask for one if it shows good cause. A decision no later than 80 days after the appeal. A continuance you ask for adds time

Source: California Education Code, Welfare and Institutions Code and the California Department of Education, read November 2026.

The Regional Center column has two deadlines, and they do different jobs. Sixty days keeps your right to appeal. Thirty days keeps current services running while you appeal. Count the 30 days from the day you receive the notice. The appeal must also be postmarked or received no later than the day the change takes effect.

A child who has turned 3 and is applying for first school services is treated differently. The Education Code says the district is not required to keep providing the early education services the child had been getting. Until the student turns 18, a parent holds these school rights. They then generally pass to the student.

The other two plans have their own routes. An Early Start dispute can go to a mediation or a due process hearing. Each is meant to finish within 30 days. A hearing officer can extend a hearing at either party’s request. For a 504 plan, a district must offer notice, a chance to see records, an impartial hearing and a review procedure. The steps for each are in the IEP guide, the Regional Center guide and the Early Start guide.

Will a plan cost us, label my child or affect our immigration case?

The first services under an IFSP, an IEP or an IPP need your consent. In a public school, the IEP and the 504 plan are free.

Here is what the law says on each worry, and what we could not confirm.

What does a plan cost?

In a public school, the IEP and the 504 plan are part of a “free appropriate public education”. That phrase is in California’s special education law and in the federal office’s Section 504 guidance. Section 504 states the free-education duty for public elementary and secondary programs. A private school that gets federal money may not charge more for a student with a disability than for other students. The exception is a charge that a substantial rise in the school’s cost justifies.

At a Regional Center, the state says there is “no charge for the diagnosis and eligibility assessment”. It says most services are free at any income. Three family fee programs have ended, two on July 1, 2024 and one on July 1, 2025.

In Early Start, evaluation, assessment and coordination cost nothing. Public or private insurance is used for some therapy services, and the Early Start guide explains how.

Who is told about my child?

What a school and a Regional Center share is in the section on who pays. There is one notice for which we found no way for a parent to object. It concerns a toddler in Early Start who may qualify for special education. The program must tell the school district at least 90 days before the child turns 3. The notice says the child may be eligible for special education. Federal rules set different steps for a child found eligible less than 90 days before that birthday. A referral fewer than 45 days before it needs the parent’s consent. The federal rule lists the child’s name, date of birth and the parents’ contact information for the routine notice, and DDS also lists where the child lives. California reports that it has no written opt-out policy for it. Sending evaluations and plans to the district needs your permission, the same state FAQ says.

For an older child, we found no source on whether a school is told the child is a Regional Center client.

Can I say no to a plan?

Yes, for the three plans whose consent rules we read. Agreeing to a school assessment is not agreeing to special education. A parent can refuse the first offer of an IEP, and can withdraw consent in writing later. After the student turns 18, these rights generally pass to the student. In Early Start, the evaluation, the assessment and the services need your written consent. At a Regional Center, the services you agree to can start once you sign the plan. The Section 504 rules we read do not say what a parent signs.

Does immigration status matter?

The state says immigration status does not affect eligibility for Early Start or for Regional Center services. A Regional Center does require California residency. Disability Rights California advises a family on a temporary visa to talk to an immigration attorney before claiming residency.

We did not read a federal immigration source on whether using Regional Center services counts in an immigration decision. Our research on the two school plans did not cover immigration status.

What if an agency says my child does not qualify?

Each agency decides for itself, so one agency’s no does not settle the other’s answer. If a district finds your child does not qualify for an IEP, ask about Section 504. If you disagree with the district’s assessment, you can ask for an independent one at public expense. If a Regional Center says no, you can appeal. You can also apply again with new information, such as new test results.

This guide is information, and it is not legal advice. It cannot tell you whether your child qualifies for a plan. For a Regional Center question, the Office of Clients’ Rights Advocacy gives free legal information and advice, and it can represent clients. It looks at the merits of the case and its own resources when it decides how to help. Its number is (800) 390-7032. For the school plans, Disability Rights California’s manual, Special Education Rights and Responsibilities, is online.

What should I ask the school district and the Regional Center?

Ask each agency about its own plan, and ask for the answer in writing. Where a question comes from a source, the source is linked.

Ask the school district:

  • Will you assess my child for an IEP, and for a 504 plan if my child does not qualify? The federal office says a child who does not qualify for an IEP may qualify under Section 504.
  • Who is the Section 504 coordinator, and will the 504 plan be in writing? The rules we read do not say that a 504 plan must be written.
  • My child turns 22 this school year. On which date does the IEP end?

Ask the Regional Center:

  • Is my child’s IPP reviewed every year or every three years, and which rule applies?
  • Which services will you pay for, and which will you help me get from the school, Medi-Cal or insurance? The plan should list every service, including one from another agency.
  • Will the coordinator come to my child’s IEP meeting?
  • My child is under 5 and has no diagnosis. Will you also check provisional eligibility?
  • Which records are you asking the school for?

Sources

68sources · 13 government · 46 law · 9 organizations

  1. California Department of Developmental Services — Early Start FAQ (opens in a new tab)dds.ca.gov · last updated December 2025; includes the answer on Regional Center services for a child who is not eligible for school services
  2. California Department of Developmental Services — Early Start Information Packet (opens in a new tab)dds.ca.gov · August 2025; the three paths at age 3
  3. California Department of Developmental Services — What is Early Start (opens in a new tab)dds.ca.gov
  4. California Department of Developmental Services — Early Start annual performance report, federal fiscal year 2024 (opens in a new tab)dds.ca.gov · no written opt-out policy for the notice to school districts
  5. California Department of Education — special education complaint process (opens in a new tab)cde.ca.gov
  6. California Department of Education — dispute resolution: where to send a complaint, a mediation request or a hearing request, and the 60-day and 45-day clocks (opens in a new tab)cde.ca.gov
  7. California Department of Developmental Services — A Guide to California's Regional Center Services System (opens in a new tab)dds.ca.gov · February 2025
  8. California Department of Developmental Services — restoration of camping, social recreation and other services (opens in a new tab)dds.ca.gov · directive of October 7, 2021
  9. California Department of Developmental Services — eligibility (opens in a new tab)dds.ca.gov · last modified June 10, 2026
  10. California Department of Developmental Services — family fee programs ended (opens in a new tab)dds.ca.gov · October 28, 2025
  11. California Department of Developmental Services — provisional eligibility FAQ (opens in a new tab)dds.ca.gov
  12. U.S. Department of Education, Office for Civil Rights — Section 504 questions and answers (opens in a new tab)ed.gov
  13. Legislative Analyst's Office — Overview of Special Education in California (opens in a new tab)lao.ca.gov
  14. California Government Code 95014 — who Early Start serves, birth through age 2, and which agency (opens in a new tab)leginfo.legislature.ca.gov
  15. California Government Code 95018 — IFSP reviewed at least every three months (opens in a new tab)leginfo.legislature.ca.gov
  16. California Government Code 95020 — the IFSP is used in place of an IPP and an IEP (opens in a new tab)leginfo.legislature.ca.gov
  17. 34 CFR 303.342 — IFSP review and yearly meeting (opens in a new tab)ecfr.gov
  18. 34 CFR Part 303 — notice to the school district before age 3 (303.209, 303.401) (opens in a new tab)ecfr.gov
  19. 17 CCR 52162 — written consent in Early Start (read on the Cornell mirror) (opens in a new tab)law.cornell.edu
  20. 17 CCR 52172 — Early Start mediation and hearings (read on the Cornell mirror) (opens in a new tab)law.cornell.edu
  21. California Education Code 56026 — who an IEP is for, ages 3 through 21, and the year a student turns 22 (opens in a new tab)leginfo.legislature.ca.gov
  22. California Education Code 56041.5 — at 18 a parent's rights pass to the student (opens in a new tab)leginfo.legislature.ca.gov
  23. California Education Code 56441.11 — eligibility at ages 3 to 5, which adds an established medical disability (opens in a new tab)leginfo.legislature.ca.gov
  24. California Education Code 56426.9 — an IEP or an IFSP in place by the third birthday (opens in a new tab)leginfo.legislature.ca.gov
  25. California Education Code 56341 — the IEP team and who a parent may bring (opens in a new tab)leginfo.legislature.ca.gov
  26. California Education Code 56345 — what an IEP contains (opens in a new tab)leginfo.legislature.ca.gov
  27. California Education Code 56343 — IEP reviewed at least once a year (opens in a new tab)leginfo.legislature.ca.gov
  28. California Education Code 56381 — reassessment at least every three years (opens in a new tab)leginfo.legislature.ca.gov
  29. California Education Code 56321 — the assessment plan and consent (opens in a new tab)leginfo.legislature.ca.gov
  30. California Education Code 56346 — consent to all or part of an IEP (opens in a new tab)leginfo.legislature.ca.gov
  31. California Education Code 56329 — independent educational assessment (opens in a new tab)leginfo.legislature.ca.gov
  32. California Education Code 56500.2 — compliance complaints (opens in a new tab)leginfo.legislature.ca.gov
  33. California Education Code 56505 — due process hearings, the 45-day decision clock, the two-year limit and staying in the present placement (opens in a new tab)leginfo.legislature.ca.gov
  34. 5 CCR 3030 — the 13 disability categories (read on the Cornell mirror) (opens in a new tab)law.cornell.edu
  35. 34 CFR 300.8 — child with a disability (opens in a new tab)ecfr.gov
  36. 34 CFR 300.622 — consent before school records are shared (opens in a new tab)ecfr.gov
  37. California Welfare and Institutions Code 4512 — developmental disability and provisional eligibility (opens in a new tab)leginfo.legislature.ca.gov
  38. California Welfare and Institutions Code 4514 — Regional Center records are confidential (opens in a new tab)leginfo.legislature.ca.gov
  39. California Welfare and Institutions Code 4620 — services throughout a person's lifetime (opens in a new tab)leginfo.legislature.ca.gov
  40. California Welfare and Institutions Code 4646 — the IPP, its first deadline and the list of agreed services (opens in a new tab)leginfo.legislature.ca.gov
  41. California Welfare and Institutions Code 4646.5 — IPP review and the written copy (opens in a new tab)leginfo.legislature.ca.gov
  42. California Welfare and Institutions Code 4648 — Regional Center money may not replace another agency's budget (opens in a new tab)leginfo.legislature.ca.gov
  43. California Welfare and Institutions Code 4648.55 — ages 18 to 22 with no diploma or certificate of completion, and the coordinator at an IEP meeting (opens in a new tab)leginfo.legislature.ca.gov
  44. California Welfare and Institutions Code 4659 — other funding sources (opens in a new tab)leginfo.legislature.ca.gov
  45. California Welfare and Institutions Code 4685.8 — the Self-Determination Program (opens in a new tab)leginfo.legislature.ca.gov
  46. California Welfare and Institutions Code 4686.2 — behavioral services (opens in a new tab)leginfo.legislature.ca.gov
  47. California Welfare and Institutions Code 4710.5 — 60 days to appeal a Regional Center decision (opens in a new tab)leginfo.legislature.ca.gov
  48. California Welfare and Institutions Code 4712 — fair hearing within 50 days (opens in a new tab)leginfo.legislature.ca.gov
  49. California Welfare and Institutions Code 4712.5 — hearing decision within 80 days, and what a continuance adds (opens in a new tab)leginfo.legislature.ca.gov
  50. California Welfare and Institutions Code 4715 — keeping services during an appeal (30 days after the notice, and no later than the day the change takes effect) (opens in a new tab)leginfo.legislature.ca.gov
  51. 42 CFR 441.301 — Medicaid waiver plans reviewed at least every 12 months (opens in a new tab)ecfr.gov
  52. 34 CFR 303.437 — Early Start hearing in 30 days, which a hearing officer can extend (opens in a new tab)ecfr.gov
  53. 34 CFR 104.3 — who Section 504 protects, and the ages for school services (opens in a new tab)ecfr.gov
  54. 34 CFR 104.7 — the Section 504 coordinator (opens in a new tab)ecfr.gov
  55. 34 CFR 104.31 — the programs Section 504 covers (opens in a new tab)ecfr.gov
  56. 34 CFR 104.33 — an appropriate education under Section 504, free in a public elementary or secondary program (opens in a new tab)ecfr.gov
  57. 34 CFR 104.39 — Section 504 and private schools that get federal money (opens in a new tab)ecfr.gov
  58. 34 CFR 104.35 — evaluation and periodic re-evaluation (opens in a new tab)ecfr.gov
  59. 34 CFR 104.36 — Section 504 procedural safeguards (opens in a new tab)ecfr.gov
  60. Disability Rights California — Office of Clients' Rights Advocacy (OCRA) (opens in a new tab)disabilityrightsca.org · free legal information, advice and representation to Regional Center clients; how it decides how to help
  61. Disability Rights California — Rights Under the Lanterman Act, what generic services are (opens in a new tab)rula.disabilityrightsca.org
  62. Disability Rights California — Rights Under the Lanterman Act, how special education and the Regional Center work together (opens in a new tab)rula.disabilityrightsca.org
  63. Disability Rights California — Rights Under the Lanterman Act, residency (opens in a new tab)rula.disabilityrightsca.org
  64. Disability Rights California — Rights Under the Lanterman Act, chapter 2 (opens in a new tab)rula.disabilityrightsca.org · records need your approval; the Office of Clients' Rights Advocacy phone number
  65. Disability Rights California — Rights Under the Lanterman Act, chapter 3 (opens in a new tab)rula.disabilityrightsca.org · applying again with new information
  66. Disability Rights California — Rights Under the Lanterman Act, chapter 4 (opens in a new tab)rula.disabilityrightsca.org · the coordinator and the IEP meeting; services from other agencies
  67. Disability Rights California — Special Education Rights and Responsibilities, question 1.25 (opens in a new tab)serr.disabilityrightsca.org · who a parent may bring to an IEP meeting
  68. Disability Rights California — Special Education Rights and Responsibilities, chapter 4 (opens in a new tab)serr.disabilityrightsca.org

Published November 11, 2026 · Analysis by Bri Stanback, SchoolScope · Report a data issue

Cite this guide

Stanback, Bri. “IFSP, IEP, IPP and 504 Plan: What Each One Is.” SchoolScope, November 11, 2026. https://schoolscope.co/guides/ifsp-iep-ipp-504-differences