AN ACT CONCERNING OVERSIGHT OF PLANS PURSUANT TO SECTION 504 OF THE REHABILITATION ACT OF 1973 AND SPECIAL EDUCATION NEEDS IN THE STATE.

Senate
sSB424 / File No. 361 1

General Assembly File No. 361
February Session, 2026 Substitute Senate Bill No. 424

Senate, April 2, 2026

The Committee on Government Oversight reported through
SEN. GADKAR-WILCOX of the 22nd Dist., Chairperson of the
Committee on the part of the Senate, that the substitute bill
ought to pass.

AN ACT CONCERNING OVERSIGHT OF PLANS PURSUANT TO
SECTION 504 OF THE REHABILITATION ACT OF 1973 AND SPECIAL
EDUCATION NEEDS IN THE STATE.
Be it enacted by the Senate and House of Representatives in General
Assembly convened:

Section 1. (NEW) (Effective July 1, 2026) For the fiscal year ending June 1
30, 2027, and each fiscal year thereafter, the State Department of 2
Education shall annually compile and make publicly available on its 3
Internet web site data organized by school district showing the number 4
of students in a public school, grades kindergarten to twelve, inclusive, 5
with a plan pursuant to Section 504 of the Rehabilitation Act of 1973, as 6
amended from time to time. The department shall track trends in such 7
data. All local and regional boards of education shall provide any 8
information necessary for the department to compile such data. The 9
department shall disaggregate and post such information in a manner 10
that complies with the requirements of the Family Educational Rights 11
and Privacy Act, 20 USC 1232g, as amended from time to time. 12
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Sec. 2. (Effective July 1, 2026) (a) The Commissioner of Education shall, 13
within available appropriations, convene a working group to review 14
how local and regional boards of education are providing 15
accommodations to students under plans pursuant to Section 504 of the 16
Rehabilitation Act of 1973, as amended from time to time, including the 17
use of staff and the amount of staff time dedicated to the development 18
and implementation of such plans. The working group shall include, but 19
need not be limited to, representatives from the Connecticut Education 20
Association, Connecticut School Counselor Association, American 21
Federation of Teachers-Connecticut, Connecticut Association of Boards 22
of Education, Connecticut Association of Public School 23
Superintendents, Connecticut Chapter of the National Association of 24
Social Workers and Connecticut Association of School Psychologists. 25
(b) Not later than January 1, 2027, the Commissioner of Education 26
shall submit a report, in accordance with the provisions of section 11-4a 27
of the general statutes, to the joint standing committees of the General 28
Assembly having cognizance of matters relating to education and 29
government oversight. Such report shall include, but need not be 30
limited to, any best practices for plans pursuant to Section 504 of the 31
Rehabilitation Act of 1973, recommendations for statutory changes, if 32
applicable, and a summary and analysis of the impact of such plans and 33
their usage since 2020. 34
Sec. 3. Section 10 -15o of the 2026 supplement to the general statutes 35
is repealed and the following is substituted in lieu thereof (Effective 36
October 1, 2026): 37
(a) There is established an Office of the Educational Ombudsperson, 38
which shall be within the Office of Governmental Accountability for 39
administrative purposes only. The Office of the Educational 40
Ombudsperson shall serve students and families of students in the 41
pursuit of preschool, elementary and secondary education, special 42
education, vocational education and adult education. The Office of the 43
Educational Ombudsperson shall be under the direction of an 44
Educational Ombudsperson who shall be appointed by the Governor 45
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and be selected from among individuals with expertise and experience 46
in educational advocacy, special education and educational law. 47
(b) The Office of the Educational Ombudsperson shall: 48
(1) Receive, review and attempt to resolve any complaints from 49
students and students' families, including, but not limited to, attempts 50
to resolve such complaints in collaboration with schools and educators; 51
(2) Compile and analyze data on students and young people, through 52
available data systems, including, but not limited to, the Connecticut 53
Preschool through Twenty and Workforce Information Network, 54
established pursuant to section 10a-57g; 55
(3) Assist employees of local and regional boards of education 56
involved in planning and placement team meetings; 57
(4) Provide information to the public, agencies, legislators and others 58
regarding the issues and concerns of students and make 59
recommendations for resolving such issues and concerns; 60
(5) Analyze and monitor the development and implementation of 61
federal, state and local laws, regulations and policies relating to students 62
and recommend any changes the Educational Ombudsperson deems 63
necessary; 64
(6) Disseminate information concerning the availability of the Office 65
of the Educational Ombudsperson to assist students and families of 66
students, as well as local and regional boards of education with 67
educational resource concerns; 68
(7) On and after July 1, 2027, prioritize the office's efforts on those 69
school districts that have been identified in the study conducted 70
pursuant to section 10 -76ooo as disproportionately or over -identifying 71
minority students for special education and related services; [and] 72
(8) Employ legal staff and legal counsel as necessary to perform the 73
duties and responsibilities under subdivision (1) of this subsection; 74
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(9) Hold hearings, subpoena witnesses and compel their attendance, 75
administer oaths, take the testimony of any person under oath and 76
require the production for examination of any books and papers relating 77
to any matter under investigation or in question; 78
(10) Require written answers to interrogatories under oath relating to 79
any complaint under investigation pursuant to this chapter alleging any 80
discriminatory practice, as described in subdivision (6) of subsection (b) 81
of section 46a -64, as amended by this act, and adopt regulations, in 82
accordance with the provisions of chapter 54, for the procedure for the 83
issuance of interrogatories and compliance with interrogatory requests; 84
(11) Utilize such voluntary and uncompensated services of private 85
individuals, agencies and organizations as may from time to time be 86
offered and needed and with the cooperation of such agencies to carry 87
out the provisions of this section; and 88
[(8)] (12) Take any other actions necessary to fulfill the duties of the 89
Office of the Educational Ombudsperson and the Educational 90
Ombudsperson as set forth in this subsection. 91
(c) On or before January 1, [2026] 2027, and annually thereafter, the 92
Educational Ombudsperson shall submit a report, in accordance with 93
the provisions of section 11 -4a, to the Office of Governmental 94
Accountability and the joint standing committees of the General 95
Assembly having cognizance of matters relating to education and 96
children. The Educational Ombudsperson shall report on: (1) The 97
implementation of this section; (2) the overall effectiveness of the 98
Educational Ombudsperson position; [and] (3) the number of 99
complaints received pursuant to subdivision (1) of subsection (b) of this 100
section during the prior year, how many complaints were substantiated 101
or unsubstantiated, whether any corrective action was taken and the 102
average of time it took to process such complaints; and (4) additional 103
steps that need to be taken for the Educational Ombudsperson to be 104
more effective. 105
Sec. 4. Section 46a -64 of the 2026 supplement to the general statutes 106
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is repealed and the following is substituted in lieu thereof (Effective 107
October 1, 2026): 108
(a) It shall be a discriminatory practice in violation of this section: (1) 109
To deny any person within the jurisdiction of this state full and equal 110
accommodations in any place of public accommodation, resort or 111
amusement because of race, creed, color, national origin, ancestry, sex, 112
gender identity or expression, marital status, age, lawful source of 113
income, intellectual disability, mental disability, physical disability, 114
including, but not limited to, blindness or deafness, status as a veteran, 115
status as a victim of domestic violence, status as a victim of sexual 116
assault or status as a victim of trafficking in persons, of the applicant, 117
subject only to the conditions and limitations established by law and 118
applicable alike to all persons; (2) to discriminate, segregate or separate 119
on account of race, creed, color, national origin, ancestry, sex, gender 120
identity or expression, marital status, age, lawful source of income, 121
intellectual disability, mental disability, learning disability, physical 122
disability, including, but not limited to, blindness or deafness, status as 123
a veteran, status as a victim of domestic violence, status as a victim of 124
sexual assault or status as a victim of trafficking in persons; (3) for a 125
place of public accommodation, resort or amusement to restrict or limit 126
the right of a mother to breast -feed her child; (4) for a place of public 127
accommodation, resort or amusement to refuse entry to a person with a 128
disability who is accompanied by a service animal; or (5) to deny any 129
person with a disability or any person training an animal as a service 130
animal to assist a person with a disability, accompanied by such service 131
animal, full and equal access to any place of public accommodation, 132
resort or amusement. Any person with a disability or any person 133
training an animal as a service animal may keep such service animal at 134
all times in such place of public accommodation, resort or amusement 135
at no extra charge, provided such service animal is in the direct custody 136
and control of such person. When it is not obvious what service an 137
animal provides, staff of a place of public accommodation, resort or 138
amusement may inquire of the owner or keeper whether such animal is 139
a service animal required because of a disability and what work or task 140
the animal has been trained to perform. Nothing in this subsection shall 141
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preclude a business owner's ability to recover for damage caused to a 142
person or property by a service animal. For the purposes of this 143
subsection, "disability" and "service animal" have the same meanings as 144
provided in section 22 -345 and "place of public accommodation, resort 145
or amusement" has the same meaning as provided in section 46a-44. 146
(b) (1) The provisions of this section with respect to the prohibition of 147
sex discrimination shall not apply to (A) the rental of sleeping 148
accommodations provided by associations and organizations which 149
rent all such sleeping accommodations on a temporary or permanent 150
basis for the exclusive use of persons of the same sex , or (B) separate 151
bathrooms or locker rooms based on sex. 152
(2) The provisions of this section with respect to the prohibition of 153
discrimination on the basis of age shall not apply to minors or to special 154
discount or other public or private programs to assist persons sixty 155
years of age and older. 156
(3) The provisions of this section with respect to the prohibition of 157
discrimination on the basis of physical disability shall not require any 158
person to modify his property in any way or provide a higher degree of 159
care for a physically disabled person, including, but not limited to blind 160
or deaf persons, than for a person not physically disabled. 161
(4) The provisions of this section with respect to the prohibition of 162
discrimination on the basis of creed shall not apply to the practice of 163
granting preference in admission of residents into a nursing home as 164
defined in section 19a -490, if (A) the nursing home is owned, operated 165
by or affiliated with a religious organization, exempt from taxation for 166
federal income tax purposes , and (B) the class of persons granted 167
preference in admission is consistent with the religious mission of the 168
nursing home. 169
(5) The provisions of this section with respect to the prohibition of 170
discrimination on the basis of lawful source of income shall not prohibit 171
the denial of full and equal accommodations solely on the basis of 172
insufficient income. 173
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(6) The provisions of this section with respect to the prohibition of 174
discrimination on the basis of intellectual disability, mental disability or 175
physical disability that concern a student with an individualized 176
education program or a plan pursuant to Section 504 of the 177
Rehabilitation Act of 1973, as amended from time to time, and where the 178
place of public accommodation is a public school, shall be enforced by 179
complaint made to the Office of the Educational Ombudsperson in lieu 180
of the commission. 181
(c) Any person who violates any provision of this section shall be 182
guilty of a class D misdemeanor. 183
Sec. 5. Subsection (a) of section 46a -82 of the 2026 supplement to the 184
general statutes is repealed and the following is substituted in lieu 185
thereof (Effective October 1, 2026): 186
(a) Any person claiming to be aggrieved by an alleged discriminatory 187
practice, except for an alleged violation of section 4a -60g or 46a-68, [or] 188
the provisions of sections 46a-68c to 46a-68f, inclusive, or section 46a-64, 189
as amended by this act, that is described in subdivision (6) of subsection 190
(b) of section 46a-64, as amended by this act, may, by himself or herself 191
or by such person's attorney, file with the commission a complaint in 192
writing under oath, except that a complaint that alleges a violation of 193
section 46a -64c need not be notarized. The complaint shall state the 194
name and address of the person alleged to have committed the 195
discriminatory practice, provide a short and plain statement of the 196
allegations upon which the claim is based and contain such other 197
information as may be required by the commission. The commission 198
whenever it has reason to believe that a person who is named as party 199
to a discriminatory practice complaint has engaged or is engaged in 200
conduct that constitutes a violation of part VI, of chapter 952, may refer 201
such matter to the Office of the Chief State's Attorney and said office 202
shall conduct a further investigation as deemed necessary. After the 203
filing of a complaint, the commission shall provide the complainant 204
with a notice that: (1) Acknowledges receipt of the complaint; and (2) 205
advises of the time frames and choice of forums available under this 206
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chapter. 207
Sec. 6. (NEW) (Effective from passage) The Commissioner of Education 208
shall implement changes to the special education data system 209
developed by the Department of Education to better adapt its use for 210
plans pursuant to Section 504 of the Rehabilitation Act of 1973, as 211
amended from time to time, and the differing requirements of such 212
plans compared to individualized education programs. Such changes 213
shall ensure, at a minimum, that the reporting requirements for plans 214
pursuant to Section 504 of said act be limited to: (1) Student 215
demographic information, (2) the evaluation period, (3) identification of 216
behavioral, social and emotional needs of students, (4) the type of 217
accommodation provided, (5) requirements related to case management 218
or social workers, (6) any additional testing performed, (7) the 219
identification of accessibility technologies utilized, and (8) any other 220
information required under sections 10 -76a to 10 -76h, inclusive, of the 221
general statutes, to the extent permitted by the Family Educational 222
Rights and Privacy Act, 20 USC 1232g, as amended from time to time. 223
Sec. 7. (NEW) ( Effective July 1, 2026) Not later than July 1, 2027, and 224
annually thereafter, each local and regional board of education shall 225
report to the Department of Education, for students of the school district 226
who have plans pursuant to Section 504 of the Rehabilitation Act of 227
1973, as amended from time to time and for which the board is 228
responsible for implementing such plan: (1) The number of students 229
with such plan by grade level, (2) the types of supports given to 230
students, and (3) the number of complaints made by parents of the 231
students with such plans. The department shall disaggregate such 232
information in a manner that complies with the requirements of the 233
Family Educational Rights and Privacy Act, 20 USC 1232g, as amended 234
from time to time. 235
Sec. 8. (NEW) ( Effective July 1, 2026 ) The Department of Education 236
shall provide increased oversight and coordination with local and 237
regional boards of education to support students with plans pursuant 238
to Section 504 of the Rehabilitation Act of 1973, as amended from time 239
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to time. 240
Sec. 9. ( Effective from passage) (a) Not later than January 1, 2027, the 241
Department of Education shall perform a needs assessment of the 242
number of social workers and school counselors required to attain an 243
ideal student-to-counselor and social worker ratio, specified by 244
elementary, middle and high school student need, for students with 245
individualized education programs and plans pursuant to Section 504 246
of the Rehabilitation Act of 1973, as amended from time to time. 247
(b) Not later than January 1, 2027, the Commissioner of Education 248
shall submit a report, in accordance with the provisions of section 11-4a 249
of the general statutes, to the joint standing committees of the General 250
Assembly having cognizance of matters relating to education and 251
government oversight. Such report shall include the results of the needs 252
assessment and recommendations for the ideal student-to-counselor 253
and social worker ratio, specified by elementary, middle and high 254
school for students with such programs or plans. 255
Sec. 10. ( Effective from passage ) The Commissioner of Social Services 256
shall identify any services that local and regional boards of education 257
provide that could be eligible for Medicaid reimbursement to leverage 258
federal funding for school or support services. Not later than December 259
31, 2026, the commissioner shall submit a report, in accordance with the 260
provisions of section 11 -4a of the general statutes, to the joint standing 261
committees of the General Assembly having cognizance of matters 262
relating to human services, government oversight and appropriations 263
and the budgets of state agencies. Such report shall include a detailed 264
listing of any identified services that could be eligible for such 265
reimbursement. 266
Sec. 11. (Effective from passage) Not later than December 31, 2026, the 267
Chief Workforce Officer of the Office of Workforce Strategy shall 268
develop and report a strategic assessment plan to increase the capacity 269
of school social workers and school counselors in the state to the General 270
Assembly, in accordance with the provisions of section 11 -4a of the 271
general statutes. 272
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This act shall take effect as follows and shall amend the following
sections:

Section 1 July 1, 2026 New section
Sec. 2 July 1, 2026 New section
Sec. 3 October 1, 2026 10-15o
Sec. 4 October 1, 2026 46a-64
Sec. 5 October 1, 2026 46a-82(a)
Sec. 6 from passage New section
Sec. 7 July 1, 2026 New section
Sec. 8 July 1, 2026 New section
Sec. 9 from passage New section
Sec. 10 from passage New section
Sec. 11 from passage New section

Statement of Legislative Commissioners:
In Section 1, the first sentence was reworded for clarity, in Section 2,
"establish" was changed to "convene" and " how local and regional
boards of education are providing accommodations to students under"
was added for clarity, in Sections 6, 8 and 9, references to the Bureau of
Special Education were deleted for statutory consistency, in Se ctions 6
and 7 references to FERPA were added to avoid potential conflicts with
federal law, and in Section 7 the first sentence was reworded for clarity.

GOS Joint Favorable Subst. -LCO

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The following Fiscal Impact Statement and Bill Analysis are prepared for the benefit of the members of
the General Assembly, solely for purposes of information, summarization and explanation and do not
represent the intent of the General Assembly or either chamber thereof for any purpose. In general,
fiscal impacts are based upon a variety of informational sources, including the analyst’s professional
knowledge. Whenever applicable, agency data is consulted as part of the analysis, however final
products do not necessarily reflect an assessment from any specific department.

OFA Fiscal Note

State Impact:
Agency Affected Fund-Effect FY 27 $ FY 28 $
Education, Dept. GF - Cost 581,100 131,100
Office of Workforce Strategy GF - Cost Up to
100,000
None
State Comptroller - Fringe
Benefits1
GF - Cost 90,900 90,900
Governmental Accountability,
Off.
GF - Cost 86,000 86,000
Note: GF=General Fund

Municipal Impact: None
Explanation
The bill, which makes various changes relating to student plans
pursuant to section 504 of the Rehabilitation Act of 1973 (504 plans),
results in the fiscal impacts described by section below.
Sections 1 and 7 result in a one-time cost of $150,000 in FY 27 to the
State Department of Education (SDE) related to collecting and reporting
data regarding 504 plans . The funding is required to build systems to
integrate data from CT-SEDS (state special education data system) into
SDE's data warehouse to facilitate the reporting requirements.
Section 2 establishes a working group to review how boards of
education are developing and implementing 504 plans, which results in
no fiscal impact as the work group has the necessary resources and

1The fringe benefit costs for most state employees are budgeted centrally in accounts
administered by the Comptroller. The estimated active employee fringe benefit cost
associated with most personnel changes is 41.82% of payroll in FY 27.
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expertise to fulfil the requirements.
Sections 3 – 5 empower the Office of the Educational Ombudsperson2
(OEO) to employ legal staff to conduct hearings, subpoena witnesses,
and require depositions, as well as designate OEO to receive complaints
related to discrimination against students with IEPs or 504 plans,
resulting in a General Fund cost of $122,000 an nually beginning in FY
27.
This cost is associated with hiring one additional position3 within the
Office of Governmental Accountability (OGA) and includes an ongoing
annual salary cost of $86,000 and an associated fringe cost of $36,000
beginning in FY 27. This position is necessary to support the expanded
scope of work created with additio nal legal and investigative
responsibilities created by these sections.
Section 6 requires SDE to update the CT -SEDS system to include
reporting for various information about students with 504 plans and
such 504 plans. This results in a one-time development cost of $300,000
to SDE in FY 27 to modify the CT -SEDS system for such data collection
and integration.
Section 8 requires SDE to provide increased oversight of and
coordination with school districts regarding 504 plans, which results in
a cost of $1 31,100 to SDE and corresponding fringe benefits of $ 54,900
annually beginning in FY 27 to hire one full time education consultant.
Section 9 requires SDE to perform a needs assessment of the number
of social workers and school counselors required to attain an ideal
student to counselor ratio. This has no fiscal impact as SDE is currently
developing a workload analysis that studies this topic.
Section 10 requires the Department of Social Services to identify and
report on Medicaid-eligible school services by December 31, 2026, which
results in no fiscal impact as the department already possesses the

2 The Office of the Educational Ombudsperson is currently vacant.
3 This position is a Staff Attorney I.
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necessary resources and expertise to fulfill the requirements of the bill.
Section 11 results in a one -time cost of up to $100,000 in FY 27 only
by requiring the Office of Workforce Strategy (OWS) to develop a
strategic assessment plan to increase the capacity of school social
workers and school counselors in the state . In order to complete this
plan by December 31, 2026, OWS will require consulting services which
are anticipated to cost up to $100,000.
The Out Years
The annualized ongoing fiscal impact identified above would
continue into the future subject to inflation.

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OLR Bill Analysis
sSB 424

AN ACT CONCERNING OVERSIGHT OF PLANS PURSUANT TO
SECTION 504 OF THE REHABILITATION ACT OF 1973 AND
SPECIAL EDUCATION NEEDS IN THE STATE.

SUMMARY
This bill transfers jurisdiction over certain claims alleging disability
discrimination in a public school from the Commission on Human
Rights and Opportunity (CHRO) to the Office of the Educational
Ombudsperson (OEO) (§§ 3-5). PA 25 -93, § 27, established this office,
effective July 1, 2025, but it has not yet been established in practice.
The transfer applies only to complaints concerning a student with an
individualized education program (IEP) or a Section 504 plan that allege
a violation of state law prohibiting discrimination based on an
intellectual, mental, or physical disability. It does not apply to alleged
violations of the federal laws governing these plans (the Individuals
with Disabilities Education Act (IDEA) or Section 504 , see
BACKGROUND).
Under current law, in addition to various public outreach duties,
OEO can receive, review, and attempt to resolve complaints from
students and their families, including by collaborating with schools and
educators. The bill appears to give OEO additional responsibility for
processing legal complaints (for example, by holding hearings and
subpoenaing witnesses), but it does not specify a process for filing
complaints with the office or authorize the ombudsperson to order any
remedies or relief. It is unclear what recourse people will have for these
state discrimination law violations if OEO is not established by the date
enforcement responsibility shifts from CHRO to OEO (October 1, 2026).
The bill also requires the State Department of Education (SDE) to:
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1. post data on students with 504 plans on its website (and requires
school boards to submit specified 504 plan data to SDE ) (§§ 1 &
7),
2. create a working group to review how school boards are
providing accommodations under Section 504 plans (§ 2),
3. modify the special education data system (CT -SEDS) to better
adapt for Section 504 plan use (§ 6),
4. increase oversight and coordination with school boards to
support students with 504 plans (§ 8), and
5. determine the number of social workers and school counselors
needed to get to an ideal ratio of counselors and social workers
to students with IEPs or 504 plans (§ 9).
The bill also requires the (1) Department of Social Services (DSS) to
identify services schools provide that might be eligible for Medicaid
reimbursement (§ 10) and (2) Office of Workforce Strategy to develop
and report a strategic assessment plan to increase the capacity of school
social workers and school counselors (§ 11).
EFFECTIVE DATE: Various, see below.
§§ 1 & 7 — SHARING 504 PLAN DATA
Starting in FY 27, the bill requires SDE to post on its website the
number of students with 504 plans in grades kindergarten to 12,
organized by district. School boards must give SDE any information it
needs to compile the data, and SDE must disaggregate t he data and
make sure it complies with the federal Family Educational Rights and
Privacy Act (FERPA). The bill also requires SDE to track trends in this
data.
The bill requires, starting by July 1, 2027, each school board to submit
to SDE the (1) number of students with 504 plans by grade, (2) types of
supports given to these students, and (3) number of complaints made
by students with the plans. (It is unclear what constitutes a
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“complaint.”)
EFFECTIVE DATE: July 1, 2026
§ 2 — WORKING GROUP ON 504 PLANS
The bill requires SDE, within available appropriations, to create a
working group to review how school boards are providing
accommodations for students through Section 504 plans. The review
must include the use of staff and the amount of staff time dedicated to
developing and implementing the plans.
The group must include, at a minimum, representatives from the:
1. Connecticut Education Association,
2. Connecticut School Counselor Association,
3. American Federation of Teachers-Connecticut,
4. Connecticut Association of Boards of Education,
5. Connecticut Association of Public School Superintendents,
6. Connecticut Chapter of the National Association of Social
Workers, and
7. Connecticut Association of School Psychologists.
By January 1, 2027, SDE must report to the Education and
Government Oversight committees. The report must include (1) best
practices for Section 504 plans, (2) any recommended statutory changes,
and (3) a summary and analysis of 504 plans’ impact and usage s since
2020.
EFFECTIVE DATE: July 1, 2026
§§ 3 -5 — DISABILITY DISCRIMINATION COMPLAINTS
CONCERNING STUDENTS WITH AN IEP OR 504 PLAN
Existing law prohibits (1) discriminating against, segregating, or
separating someone based on his or her intellectual, mental, or physical
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disability and (2) denying someone full and equal accommodation in a
place of public accommodation because of these disabilities. CHRO has
jurisdiction over state anti -discrimination laws and is charged with
following statutory procedures for processing complaints alleging
violations of the laws.
The bill requires OEO, rather than CHRO, to receive, investigate, and
“attempt to resolve” complaints concerning a student with an IEP or a
504 plan that claim discrimination based on an intellectual, mental, or
physical disability in a public school. Unlike the law on CHRO, the bill
does not create a formal complaint process, give OEO specific
enforcement powers, or specify how an OEO decision is appealed. Thus,
it appears that OEO lacks the powers and procedures necessary to
adjudicate the claims the bill makes it responsible for.
Scope of Jurisdiction Transfer
The transfer of jurisdiction applies only to complaints from students
with IEP or 504 plans alleging violations of state discrimination law; it
does not apply to complaints about a student’s 504 plan or IEP. Neither
CHRO nor OEO has the authority to enforce Section 504 (because it is
federal law), and federal and state law generally make SDE responsible
for initially hearing IDEA-related complaints. The IDEA and state case
law generally require students with disabilities who are seeking relief
available u nder IDEA (such as additional services or a change in
placement) to exhaust administrative remedies under IDEA before
filing a complaint under other discrimination laws (see
BACKGROUND).
It also appears that, under the bill, CHRO would retain jurisdiction
over some complaints involving discrimination against students with
disabilities in public school. For example, the bill does not transfer
jurisdiction over claims of discrimination based on learning disability
(such as dysl exia or dysgraphia), and it does not appear to apply in
instances where a student without an IEP or a 504 plan is denied a
requested accommodation.
Additional OEO Powers and Duties
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PA 25 -93 (§ 27) places OEO within the Office of Governmental
Accountability for administrative purposes only. The governor must
appoint an ombudsperson, who must have expertise and experience in
educational advocacy, special education, and educational law. (The
ombudsperson has not yet been appointed and the office has not been
established.)
Under current law, the office is not charged with investigating
violations of law; instead, it is required to assist students and families
with resolving education -related concerns. The law requires the office
to (1) receive and review complaints from students and families related
to preschool, elementary and secondary education, special education,
vocational education, and adult education and (2) attempt to resolve any
complaints it receives, including by collaborating with schools and
educators.
The bill expands the duties of the educational ombudsperson, giving
them various powers and duties related to investigating legal
complaints. Specifically, the bill requires the ombudsperson to:
1. employ legal staff and legal counsel necessary to receive, review,
and attempt to resolve complaints from students and their
families (the scope of the expansion of the office’s authority to
investigate legal complaints, other than the discrimination claims
the bill specifically transfers to it, is unclear);
2. hold hearings, subpoena witnesses and compel their attendance,
administer oaths and take testimony, and require parties to turn
over any books or papers relating to an investigation so they may
be examined;
3. require written answers to interrogatories under oath that relate
to disability discrimination complaints that the bill places under
the office’s jurisdiction;
4. adopt regulations on the procedure for issuing interrogatories
and complying with interrogatory requests; and
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5. use voluntary and uncompensated services from private
individuals, agencies, and organizations to carry out the office’s
duties.
Complaint Procedures. The bill specifically exempts the
discrimination claims transferred to the ombudsperson’s jurisdiction
under the bill from procedures for filing and adjudicating complaints
with CHRO , but it does not establish any complaint procedures for
OEO. It is also unclear (1) who would decide cases filed with OEO or (2)
whether the office has the authority to order any remedies.
Annual Report. The bill also requires the ombudsperson, as part of
the office’s annual report, to include the number of complaints it
received during the year, how many were substantiated or
unsubstantiated, whether corrective action was taken, and the average
time to p rocess complaints. Under existing law, OEO’s annual report
must be submitted to the Children and Education committees.
EFFECTIVE DATE: October 1, 2026
§ 6 — CT-SEDS CHANGES FOR 504 PLANS
The bill requires SDE to modify the special education data system
(CT-SEDS) to better align it with Section 504 plans, which have different
requirements compared to IEPs. (In practice, CT-SEDS has two separate
processes within the system, one for IEPs and one for 504 plans.)
The changes must limit the components required for Section 504
plans to:
1. student demographic information;
2. the evaluation period;
3. behavioral, social, and emotional needs identification;
4. accommodation types;
5. requirements related to case management or social workers;
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6. additional testing performed;
7. identification of accessibility technology used; and
8. any other information require d by laws that generally apply to
IEPs.
EFFECTIVE DATE: Upon passage
§ 8 — OVERSIGHT BY THE BUREAU OF SPECIAL EDUCATION
The bill requires SDE to increase oversight and coordination with
school boards to support students with 504 plans. (The bill does not
further specify what this entails.)
EFFECTIVE DATE: July 1, 2026
§ 9 — SCHOOL SOCIAL WORKER AND COUNSELOR NEEDS
ASSESSMENT
Under the bill, SDE must determine, through a needs assessment, the
number of social workers and school counselors needed to get to an
ideal ratio of counselors and social workers to students with IEPs or 504
plans. By January 1, 2027, SDE must report on t he needs assessment to
the Education and Government Oversight committees, including the
ideal student to counselor and social worker ratio s for elementary
school, middle school, and high school.
EFFECTIVE DATE: Upon passage
§ 10 — MEDICAID REIMBURSEMENT FOR SERVICES
The bill requires the DSS commissioner to identify services that
school boards provide that might be eligible for Medicaid
reimbursement to leverage federal funding for school or support
services. By December 31, 2026, DSS must submit a detailed listing of
any services identified to the Appropriations, Government Oversight,
and Human Services committees.
EFFECTIVE DATE: Upon passage
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§ 11 — PLAN TO INCREASE SCHOOL COUNSELORS’ AND SOCIAL
WORKERS’ CAPACITY
By December 31, 2026, the Office of Workforce Strategy’s chief
workforce officer must develop and report a strategic assessment plan
to increase the capacity of school social workers and school counselors
in the state. (Presumably, this is their capacity to provide core services.)
EFFECTIVE DATE: Upon passage
BACKGROUND
IDEA Compared to Section 504
IDEA is the main federal law governing special education (20 U.S.C.
§ 1400 et seq.; 34 C.F.R. § 300.1 et seq.). It authorizes grants to states and
school districts and attaches a series of conditions to funding, which
states agree to adhere to by accepting funding. IDEA guarantees
students with qualifying disabilities the right to a free appropriate
public education ( FAPE) that is tailored to their unique needs and
implemented under a planning document called an IEP. It also requires
school districts to identify and evaluate students who may need special
education, educate students with disabilities with their nondisabled
peers to the maximum extent possible, and follow certain procedural
safeguards, among other things.
Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794; 34 C.F.R.
§ 104.1 et seq.) protects individuals with disabilities from discrimination
in programs and activities that receive federal financial assistance,
including public schools. Unlike under IDEA, Section 504 does not
require schools to write down the accommodations or modifications it
will provide students in a formal plan; however, in practice, Connecticut
schools develop “504 plans” to ensure compliance with the law.
Resolving Violations of Federal IDEA and Section 504 Rights
Under IDEA, states must establish procedures for resolving disputes
between parents and school districts over the provision of a FAPE
(including evaluation, identification, and educational placement ).
Connecticut has adopted an SDE-administered process that conforms to
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federal law (CGS § 10 -76h). Further, federal law specifies that parents
and students must exhaust administrative remedies available under
IDEA before filing a complaint under federal discrimination laws (such
as Section 504) if the relief they seek is available through the IDEA
administrative process (20 U.S.C. § 1415). The Connecticut Supreme
Court has held that a similar requirement applies to the denial of a FAPE
under state law (Graham v. Friedlander, 334 Conn. 564 (2020)).
There is no state-level enforcement procedure for Section 504. Under
Section 504, schools must adopt due process standards to provide for
prompt and equitable resolution of complaints. These must include an
opportunity for parents to examine relevant records, an impartial
hearing opportunity, and a review procedure (34 C.F.R. § 104.36 ).
Federal regulations allow individuals aggrieved by violations of Section
504 to file a complaint with the applicable federal agency (for
discrimination in schools, the U.S. Department of Education’s Office of
Civil Rights (OCR)) (29 U.S.C. § 794a(a)(2)).
COMMITTEE ACTION
Government Oversight Committee
Joint Favorable
Yea 9 Nay 3 (03/17/2026)