Initial Development and Validation of the School Counselor 504 Activities Scale

Abstract

The purpose of this study was to develop and validate the School Counselor 504 Activities Scale, a practical tool to assess how often school counselors engage in various ASCA recommended and non-recommended duties. Utilizing a sample of 379 practicing school counselors, this process resulted in two subscales: (a) Collaboration, Advocacy, and Development and (b) Consultation, Clerical, and Administrative Tasks. This instrument can serve as a vital resource to support school counselors’ role congruence and advocacy efforts specific to Section 504 involvement. We describe implications for preparation and practice, and discuss limitations and future directions for research.

Introduction

The American School Counselor Association (ASCA, 2019) states that “advocacy and other work of school counselors should lead to changes in the school culture to create the optimal environment for learning” (p. x). Similarly, on her book cover, Holcomb-McCoy (2022) emphasized that “school counselors can play a powerful role in closing opportunity gaps and addressing the social, emotional, and academic needs of students.” Thus, school counselors are school-based leaders who advocate for systemic change and socially just schools. They remove opportunity gaps, ensuring all students have equitable access to K–12 education. As such, ASCA (2019) calls on school counselors to implement a comprehensive school counseling program across three tiers of supports: engaging in Tier 1 prevention efforts (e.g., classroom instruction, school-wide initiatives), with further supports at the Tier 2 and 3 levels (i.e., short-term group and individual instruction). Through their comprehensive program, school counselors also collaborate with school staff, families, and community-based professionals via consultation, psychoeducation, advocacy, and membership on school-based teams. Overall, one of the most critical needs in K–12 education is addressing opportunity gaps and ensuring all students have equitable access to education (Holcomb-McCoy, 2022); one of many ways school counselors can engage in this work is supporting students through Section 504 of the Rehabilitation Act of 1973.

Section 504 of the Rehabilitation Act of 1973

The U.S. Department of Education’s Office for Civil Rights (OCR, nd) defines Section 504 of the Rehabilitation Act of 1973 as a federal law designed to safeguard the protection of inalienable rights for students with disabilities (this act is often referred to as Section 504). Any entity receiving federal funds (e.g., K–12 public schools, institutions of higher education, businesses) are beholden to this law and face strict federal consequences for noncompliance. Under Section 504, individuals with disabilities shall not face discrimination based on their disability. Further, to the fullest extent possible, individuals with disabilities should receive the same resources and access to resources as individuals without disabilities. Logically, these protections have been extended into school settings. To ensure compliance with federal guidelines, it is customary for public schools to create specialized plans for eligible students, often referred to as 504 Plans or 504s, that remove barriers to learning. Specifically, to be eligible under Section 504, students must “(1) have a physical or mental impairment that substantially limits one or more major life activities; or (2) have a record of such an impairment; or (3) be regarded as having such an impairment” (OCR, nd, “Students Protected Under Section 504” section). Students found eligible under Section 504 and who receive related services are entitled to a free and appropriate public education (FAPE; OCR, 2023a). Under FAPE, students’ accommodations (e.g., visual aids, assistive technology) must be free of charge, and the child’s educational program should be catered to the child’s unique assortment of needs. Moreover, FAPE mandates that students with disabilities must be educated in the same setting as their typically developing peers, to the fullest extent possible.

Overall, 504 Plans ensure equitable access to the general education curriculum for students with a range of needs and differing abilities (OCR, nd). Specifically, 504s may address physical and/or mental needs that adversely affect life functioning, such as dyslexia, diabetes, hearing differences, attention deficit hyperactivity disorder, and mental health concerns. They can also support students with temporary concerns, such as those with severe seasonal allergies or with broken limbs. Hence, 504 Plans provide accommodations to address each student’s unique needs. For instance, a student with depression might benefit from breaks during the school day, additional time on tests and quizzes, and a reduced workload. A student with anxiety could receive accommodations such as small-group testing and early transition reminders.

Developing a 504 Plan for eligible students is often a multistage process. Generally, once it is determined that a student meets one of the four aforementioned eligibility criteria, a meeting is convened comprising individuals with intimate knowledge of the student, such as school counselors, building administrators, teachers, and parents (OCR, nd). These individuals collaborate to discuss the student’s strengths and areas for growth, culminating in a list of accommodations the student will receive to ensure FAPE. Common accommodations include (a) extra time on tests, (b) small-group testing, and (c) preferential seating near the point of instruction. These plans often include granular information such as identifying the person(s) providing the accommodation, how often and for how long accommodations will be provided, and additional considerations. Unlike individualized education programs (IEPs), 504 Plans are not subject to triennial reevaluation; rather, reevaluations occur periodically to ensure adequate progress monitoring and FAPE (OCR, 2023a). According to the most recent 10 years of OCR data, 504 Plans have been increasing nationwide (OCR, 2018, 2023b; Zirkel & Weathers, 2016), underscoring their growing prevalence in K–12 education. Ultimately, 504 Plans and related accommodations aim to make achievement more attainable for students while mitigating barriers to learning. This focus is aligned with the role of the school counselor.

School Counselors and Section 504 Plans

Given that 504 Plans have increased in frequency and that school counselors’ work includes ensuring just and equitable schools for all students, ASCA (2019, 2022b, 2024) outlines specific school counseling recommended and non-recommended 504 activities, as part of a comprehensive school counseling program. Specifically, ASCA recommends that school counselors engage in the following 504 activities: (a) serving on schools’ multidisciplinary teams to share their expertise on and advocate for students’ needs and potential 504 accommodations, (b) helping identify students eligible for a 504 Plan, and (c) collaborating with school staff on 504 services, mainly accommodations and academic, career, and transition plans. At the same time, ASCA clearly lists 504 activities that school counselors should not be performing (i.e., non-recommended activities) due to role and interpersonal conflicts, such as “coordinating, writing or supervising a specific plan under Section 504 of Public Law 93-112” (ASCA, 2022a, para. 7) and serving as the school’s 504 coordinator/case manager (ASCA, 2024). The 504-specific activities discussed by ASCA are further reinforced by the ASCA Ethical Standards for School Counselors (2022a). Mainly, school counselors “advocate for a school counseling program free of non school-counseling assignments identified by The ASCA National Model: A Framework for School Counseling Programs” (ASCA, 2022a, B.2.c) and “avoid inappropriate roles and relationships such as … accepting administrative duties in the absence of an administrator” (ASCA, 2022a, A.5.i). Thus, 504-specific activities suggested for school counselors are not only recommended across several key ASCA statements and documents, but also outlined as an ethical expectation.

With the recent increase in 504 Plans in K–12 education, and school counselors’ recommended and non-recommended roles, scholars have published preliminary research pertaining to school counselors and the Section 504 process (Goodman-Scott & Boulden, 2020; Kolodinsky et al., 2009; Madaus & Shaw, 2008; Romano et al., 2009). Two of these studies were broad, with elements tangentially related to 504s and school counseling: a state-level survey on school counseling job satisfaction (Kolodinsky et al., 2009) and a state-level survey on 504 involvement according to a range of K–12 educational professionals (Madaus & Shaw, 2008). Specifically focused on school counseling and the 504 process, Romano and colleagues (2009) facilitated a regional survey of school counselors to understand their attitudes and preparation for providing 504 services. Most recently, Goodman-Scott and Boulden (2020) completed a phenomenological investigation of school counselors’ lived experiences with the Section 504 process.

Across these studies (Goodman-Scott & Boulden, 2020; Kolodinsky et al., 2009; Madaus & Shaw, 2008; Romano et al., 2009), school counselors largely communicated overseeing/coordinating the 504 process at their schools despite expressing wishes to not be in this role. In fact, school counselors in Goodman-Scott and Boulden’s (2020) study found that their role caused relational strain with teachers, students, and families. School counselors throughout these studies also shared that their involvement with 504 Plans was taxing and time consuming; school counselors specific to Goodman-Scott and Boulden’s (2020) study also found their role to be in contradiction to the school counselor roles recommended by ASCA. Examining findings across these four studies revealed that school counselors echoed a lack of 504-specific training, more recently describing limited support, isolation, and fear of liability (Goodman-Scott & Boulden, 2020). Last, although school counselors reported many struggles and strains with their 504 involvement, a limited number of school counselors reported that, aligned with best practices, they appreciated being a member of the multidisciplinary 504 team, and utilized that opportunity to advocate for students (Goodman-Scott & Boulden, 2020).

Overall, Goodman-Scott and Boulden (2020) recommended that school counselors engage in 504 activities aligned with best practices (ASCA, 2019, 2020, 2022b) and refrain from 504 coordination or the supervision of 504 plans. Further, scholars repeatedly stated the need for increased research and advocacy on this topic, to support school counselors implementing ASCA-recommended 504 activities, rather than 504-specific tasks that detract from their work implementing school counseling programs (Goodman-Scott & Boulden, 2020; Kolodinsky et al., 2009; Madaus & Shaw, 2008; Romano et al., 2009).

Rationale and Research Question

School counselors strive for equitable and just schools, removing barriers to student opportunities and success (ASCA, 2019; Holcomb-McCoy, 2022). Similarly, 504 Plans also ensure that students with diverse needs receive a free and appropriate education, removing barriers to student learning (OCR, 2023a). As such, school counselors are in a prime position to assist with the 504 process in K–12 schools, in alignment with their work implementing comprehensive school counseling programs. However, emerging research shows that, overall, school counselors’ roles in 504s often counter ASCA’s recommendations, putting them at odds with the expectations of implementing comprehensive school counseling programs (Goodman-Scott & Boulden, 2020; Kolodinsky et al., 2009; Madaus & Shaw, 2008; Romano et al., 2009). This may be especially problematic due to the rise in 504s in recent years. As such, scholars recommended increased research and advocacy pertaining to school counselors’ 504 activities (Goodman-Scott & Boulden, 2020; Kolodinsky et al., 2009; Madaus & Shaw, 2008; Romano et al., 2009). Specifically, Goodman-Scott and Boulden (2020) suggested creating and validating an assessment to determine school counselors’ roles in the 504 process, both to assess the type of 504 roles being completed and to strengthen related advocacy needs. As a result, the following questions guided our study:

• Research Question 1: Does the School Counselor 504 Activities Scale demonstrate factorial validity?

• Research Question 2: Does the School Counselor 504 Activities Scale possess internal consistent reliability?

Method

Instrumentation

The School Counselor 504 Activities Scale is a brief, valid instrument that measures how often school counselors implement various Section-504-related duties. The instrument can serve as a helpful advocacy tool for school counselors to assess and quantify their duties related to Section 504 for greater self-awareness, and to share findings with key constituents (e.g., their direct supervisors, such as school building administrators). Ideally, these efforts will support greater school counseling role congruence and remove roles detracting from implementing comprehensive school counseling. In creating and developing this tool, we followed empirically grounded steps for instrument development and validation (Kalkbrenner, 2021; Mvududu & Sink, 2013): item creation, expert review and feedback integration, participant recruitment, factor extraction, factor retention, factor rotation, and factor naming. In alignment with the first step, we completed a thorough review of the extant school counseling literature on Section 504, students with diverse abilities/disabilities, and school counselors’ recommended role (e.g., ASCA, 2019, 2022a, 2022b; Goodman-Scott & Boulden, 2020; Kolodinsky et al., 2009; Madaus & Shaw, 2008; Romano et al., 2009), solidifying the need for this instrument, the empirical framework, and theoretical blueprint. After identifying and defining these key constructs, the first author used this information to draft potential items. Then, the second author reviewed the list of items and provided feedback; the two authors engaged in a dialogue until reaching consensus on all drafted items. To support content validity, we then consulted four individuals with expertise in both school counseling and students with diverse abilities/disabilities (e.g., researchers, practicing school counselors), requesting detailed feedback regarding the preliminary 26 items, mechanics (e.g., flow, readability, clarity), and practicality (Dimitrov, 2012). This process resulted in the addition of two items, for a total of 28 items; the added items were “Assist in the transition planning process for students with Section 504 plans (e.g., transferring school districts, postsecondary planning)” and “Advocate to ensure students receive appropriate Section 504 accommodations.” Following the first round of feedback and revisions from expert reviewers, we obtained feedback from four additional practicing school counselors to ensure the instrument’s practicality and usability. In response to their feedback, we made a few minor mechanical revisions, such as providing examples for clarity and restating items for concision. For practicality, the four practicing school counselors suggested organizing the items into two sections: recommended 504 activities and non-recommended 504 activities, and offered input on these categories. We then cross-referenced these expert reviewers’ suggestions with the ASCA (2022a) position statement regarding students with diverse abilities/disabilities and the ASCA National Model (ASCA, 2019) guidance on recommended and non-recommended school counseling activities. We discuss participant recruitment in the subsequent sections.

Participant Characteristics

Participants’ (N = 379) ages ranged from 25 to 68 (M = 41.64, SD = 9.92). Most participants (74.4%; n = 282) identified as female; the remainder of the sample either identified as male (5.0%; n = 28) or did not provide a response (20.6%; n = 78). For race/ethnicity, 67.7% of participants (n = 234) identified as White, 8.7% (n = 33) as Black, 3.2% (n = 12) as Latinx, 1.3% (n = 5) as more than one race, 0.8% (n = 3) as another race, and 23.7% (n = 90) did not respond to the item. The sample averaged 10.38 years of school counseling experience (SD = 7.92). Participant caseloads averaged 432.13 students per school counselor, exceeding ASCA’s 250:1 recommendation, and participants reported an average of 32 students with 504 Plans on their caseloads. Next, regarding urbanicity, 12.1% (n = 46) worked in urban settings, 1.1% (n = 4) worked in rural settings, 62.8% (n = 238) worked in suburban settings, 3.7% (n = 14) selected “other,” and 20.3% (n = 77) did not provide a response. Participants reported an average of 33.98% students of color in their school buildings. In terms of school level, 28.8% (n = 109) of participants worked in elementary schools, 20.3% (n = 77) worked in middle schools, 24.8% (n = 94) worked in high schools, 5.8% (n = 22) worked in an alternate setting (e.g., alternative school, K–12 school), and 20.3% (n = 77) did not provide a response. Last, when asked about the percentage of time spent completing 504-related tasks, 57.3% (n = 217) of participants reported spending 1%–25% of their time, 12.9% (n = 49) reported 26%–50% of their time, 1.3% (n = 5) reported 51%–75% of their time, 0.8% (n = 3) reported at least 76% of their time, and 27.7% of participants (n = 105) did not provide a response.

Data Collection Procedures

Following university institutional review board approval, we entered the 28 items into a Qualtrics survey housed by the primary researcher’s institution. The survey contained three parts. First, upon clicking the recruitment link, participants were directed to a Qualtrics survey. After reviewing and acknowledging the informed consent, participants responded to 28 items, indicating how frequently they provide various Section-504-related tasks as a part of their school counselor role, using a 5-point Likert-type scale. The options were: 1 = I never perform this task; 2 = I rarely perform this task; 3 = I sometimes perform this task; 4 = I often perform this task; 5 = I very often perform this task. Last, following these items, participants provided demographic information, such as age, gender, years of school counseling experience, and urbanicity.

Participant recruitment transpired through multiple methods simultaneously. These included recruitment through word of mouth, informing people of this research opportunity and asking individuals to share widely to individuals who may fall within the inclusion criteria. We also utilized ASCA’s online ASCA Member Community, informing school counselors nationwide of the opportunity to participate in Section-504-related research. Social media was another recruitment mechanism; we used social media platforms (e.g., X, Facebook) to expand the pool of potential participants, drawing a more diverse sample to include ASCA members and nonmembers. Combined, these recruitment strategies resulted in 391 raw completions.

Exploratory Factor Analysis

Following data collection cessation, we exported all data into SPSS 26.0. Aligned with Kalkbrenner’s (2021) steps for instrument development, and following the steps outlined by Mvududu and Sink (2013), we executed an exploratory factor analysis (EFA) to determine the factor structure of the School Counselor 504 Activities Scale. Specifically, as a first step, we utilized the following cut-offs to determine the number of factors to retain: factor loadings greater than .30, communalities greater than .80, and cross-loadings less than .30. To confirm the number of factors to retain and rotate, we both visually inspected the scree plot and utilized Horn’s (1965) parallel analysis. Last, given the propensity for correlation in counseling and educational settings, we utilized the direct oblimin factor rotation method (Mvududu & Sink, 2013).

Results

Following data collection, we employed a multipronged approach to data cleaning and screening (Mvududu & Sink, 2013). First, we inspected P-P plots and Q-Q plots for potential univariate outliers. We then utilized Mahalanobis distance to assess for multivariate outliers; this process reduced the number of cases from 391 to 379. Next, we inspected the interitem correlation matrix to confirm that correlations were above .30, resulting in no items being deleted. We then replaced missing data with the item mean. A preliminary reliability analysis followed, to assess the instrument’s initial internal consistency. This process yielded strong alpha and omega coefficients of .97 each. Further inspection of the reliability analysis indicated that no items, if removed, would significantly improve these coefficients. Last, we utilized Bartlett’s Test of Sphericity and Kaiser–Meyer–Olkin Measure of Sampling Adequacy (KMO) to confirm the items’ favorability. This resulted in favorable KMO (.96) and Bartlett’s Test of Sphericity values (p < .001).

Factor Retention

We utilized principal factor analysis, a type of EFA, to investigate the scale’s dimensionality. The following criteria were used to determine factor retention: the Kaiser criterion, removing factors explaining less than 5% of the variance in the model, scree plot inspection, and parallel analysis (Horn, 1965; Mvududu & Sink, 2013). As a first step, we examined the communalities of the initial 28 items. All 28 items had suitable communalities with values ranging from .35 to .88; hence, we removed no items. Following extraction, the factors were rotated by way of the direct oblimin method (Δ = 0), appropriate for educational research (Mvududu & Sink, 2013).

This process resulted in a two-factor solution. The first factor, Collaboration, Advocacy, and Development, contains 16 items that explain 51.7% of the variance in the total model. Sample items include: “Assist in transition planning process for students with Section 504 plans (e.g., transferring school districts, postsecondary planning),” “Collaborate with students with Section 504 plans to encourage active involvement in Section 504 processes,” and “Attend professional development regarding Section 504 content and processes.” The second factor, Consultation, Clerical, and Administrative Tasks, contains 12 items that explain 7.2% of the variance in the model. Sample items include “Lead Section 504 annual review meetings,” “Complete paperwork pertaining to Section 504 plans/meetings,” and “Distribute 504 plans to school staff.” The scale contains a whole-scale alpha coefficient of .97. The first and second factors contain alpha coefficients of .93 and .95, respectively. Thus, this instrument has sound reliability (Beavers et al., 2013; Cortina, 1993).

Discussion

Section 504 Plans provide students with physical and mental accommodations for a host of needs (e.g., dyslexia, diabetes, hearing loss; OCR, nd). ASCA (2019, 2022b) states that school counselors are involved in K–12 students’ 504 processes, suggesting roles aligned with implementing a comprehensive school counseling program and thereby advocating for greater student access to equitable and just educational opportunities. Such recommended roles include membership on the 504 multidisciplinary team; advocating for student accommodations; and collaborating and consulting with staff, families, and community providers. At the same time, ASCA (2022b, 2024) has been very clear in the activities it believes detract from serving students through a school counseling program. Examples of these non-recommended activities are coordinating, overseeing, and writing 504 Plans and implementation. Despite best practices, the growing literature base shows that school counselors’ actual 504 activities are quite different from those recommended. Mainly, school counselors reported overseeing/coordinating their school’s 504 process (Goodman-Scott & Boulden, 2020; Kolodinsky et al., 2009; Madaus & Shaw, 2008; Romano et al., 2009). Further, according to some of the school counselors in these studies, their non-recommended 504 activities required extensive time and adversely impacted their relationships with constituents including teachers, students, and families. However, echoing best practices, a small number of school counselors in Goodman-Scott and Boulden’s (2020) study shared the benefits of being on the multidisciplinary 504 team, particularly for the purpose of student advocacy and support.

Overall, 504 Plans have been on the rise in recent years (OCR, 2018, 2023b; Zirkel & Weathers, 2016), and school counselors are often engaging in 504 activities that counter recommendations from ASCA. As such, scholars suggested further research to bolster school counselors completing 504 activities aligned with their professional roles; the most recent study suggested the creation of a validated instrument (Goodman-Scott & Boulden, 2020). The present study followed these recommendations. To do so, we created and initially validated the first known assessment on school counseling 504 activities, the School Counselor 504 Activities Scale. The process resulted in a two-factor model, organizing a list of commonly completed school counseling 504 activities. Factor 1, Collaboration, Advocacy, and Development, includes items depicting ways school counselors engage with internal (e.g., students, school staff) and external (e.g., outside providers, caregivers) partners in the Section 504 process while monitoring data and staying abreast on best practices. Then, in Factor 2, Consultation, Clerical, and Administrative Tasks, items describe processes school counselors employ before, during, and after Section 504 meetings to ensure 504 implementation and compliance with procedural safeguards. In alignment with best practices, all items within these two factors were categorized as recommended or non-recommended school counseling 504 activities (as described in the Method section). Thus, following scholarly recommendations, we created an instrument to allow school counselors to practically measure their engagement in 504 activities recommended and non-recommended by ASCA documents and statements (2019, 2022b) and by school counseling ethical standards (ASCA 2022a). Completing this assessment could assist school counselors in highlighting areas of their 504-specific strengths and areas in which advocacy and change may be needed.

The School Counselor 504 Activities Scale includes items related to collaboration, advocacy, and consultation, which are commonly recommended for school counselors to complete as part of a comprehensive program (ASCA, 2019, 2022b) and noted as an ethical responsibility (ASCA, 2022a). Further, these results echoed findings by Goodman-Scott and Boulden (2020), who also reported that their school counseling participants appreciated consulting and collaborating as members of their schools’ multidisciplinary 504 team and utilizing that team as a method to advocate for students. At the same, several items in this instrument were identified by ASCA (2019, 2022b) as non-recommended activities, particularly clerical and administrative roles, and also listed as unethical activities (ASCA, 2022a). These findings support all known research on school counseling 504 work (Goodman-Scott & Boulden, 2020; Kolodinsky et al., 2009; Madaus & Shaw, 2008; Romano et al., 2009), underscoring that such 504-related activities, though not recommended, are commonplace.

In sum, the School Counselor 504 Activities Scale is, to the best of our knowledge, the first validated instrument to measure school counselors’ 504-specific activities, and the first available study on the topic to use a large national sample of school counselors. This assessment provides a unique and critical tool for practicing school counselors, enabling them to quantifiably measure their 504 activities, identified by recommended and non-recommended status according to the ASCA National Model (ASCA, 2019) and school counseling ethical standards and best practices (ASCA, 2022a, 2024). Not only does this research fill a void in the scholarship, but this investigation also meets a critical need for practicing school counselors: a tool for data-informed assessment and advocacy, to better serve students and implement an ethical comprehensive school counseling program. Moreover, it supports school counselors’ commitment to helping ensure all students have K–12 educational access and opportunities (Holcomb-McCoy, 2022).

Implications

Overall, the study’s findings yielded meaningful implications for school counseling practice and preparation. Regarding practice, this new instrument can be an important tool school counselors can utilize to support their advocacy efforts, aligning their actual work with recommendations from ASCA. To illustrate, upon completing the instrument, a school counselor may utilize the results to increase their awareness of their 504 Plan involvement and communicate results with partners (e.g., school building administrators). Specifically, this intervention acts as a tool to assist school counselors in sharing the recommended 504-related tasks they are completing, and bringing attention to those activities that are not recommended by ASCA and their potentially adverse impact on the school’s comprehensive school counseling program (e.g., direct services, student availability, visibility).

Likewise, the instrument makes a beneficial adjunct to comprehensive school counseling program development and implementation. To offer an example, in preparing for an upcoming annual administrative conference, school counselors could first individually inventory their 504 involvement and organize the results based on the present tool. During the annual administrative conference, the inventory’s results can help frame administrator–school counselor conversations, particularly around the anticipated use of time for the forthcoming school year. If, for instance, a school counselor discovered that they spend substantial time performing non-recommended 504-related duties, they could discuss this with their assigned administrator and, ideally, work toward greater alignment with contemporary school counseling practices (e.g., recommended duties, 80/20 alignment) that would support the direct services provision. As another ASCA National Model alignment example, this inventory complements and clarifies school counselors’ completion of the use of time calculator (ASCA, 2019), thereby providing administrators further context regarding their work. Finally, the instrument’s disaggregation of recommended and non-recommended Section 504 duties provides greater context regarding the scope of school counselors’ 504 tasks, supporting advocacy efforts for improved role congruence.

Although the instrument is indeed beneficial at the individual school counselor level, it can also serve as an integral puzzle piece in effecting school-district-level change. District-level supervisors, specifically, can request that all school counselors in the district complete the inventory, to better understand the breadth and depth of 504 involvement from a higher level. Once compiled, this data can help in district-level advocacy efforts, potentially influencing changes in policies, practices, and unwritten norms. Taking another step, to further contextualize school counselors’ 504 involvement, district supervisors may consider employing a mixed-methods approach. For example, a district supervisor may first collect quantitative data through the district-wide completion of the School Counselor 504 Activities Scale. Next, they could conduct a series of focus groups or open-ended survey questions with a random sample of school counselors across building levels to glean more information. This approach will provide rich, descriptive data that better illustrates the extent of district-wide school counseling 504 duties and the impact on school counselors’ comprehensive programing, expanding upon the inventory.

This instrument also has implications for school counselor preparation. In particular, preservice school counselors can utilize the inventory as a conversation starter during practicum and internship, as they work in schools. Namely, they may converse with their site supervisor to explore their Section 504 involvement. They also may explore how/whether site supervisors have advocated for fewer non-recommended 504 roles and how this advocacy impacted their comprehensive school counseling program and accessibility to students. Similarly, site supervisors can candidly share 504 advocacy successes and challenges, increasing preservice school counselors’ awareness of barriers they may encounter. Outside of field experiences, this instrument can be incorporated in didactic school counseling coursework, particularly when discussing school counselors’ involvement with students with diverse abilities/disabilities. When discussing Section 504 Plans specifically, instructors can use the School Counselor 504 Activities Scale to clarify recommended and non-recommended duties. Given longstanding Section 504 challenges, the prudent school counselor educator can proactively explore sensible strategies that preservice students could employ to advocate for recommended 504 duties, perhaps supported by vignettes and role plays. Overall, these preservice dialogues could further equip future school counselors with a better understanding of the key role for school counselors in supporting students with 504 Plans within the context of school counseling best practice.

Limitations and Future Research

This study has several limitations. First, although we attempted to recruit a diverse cross section of school counselors, participant demographics will not reflect the backgrounds and lived experiences of all school counselors in every school district. This could challenge generalizability for district-level supervisors considering utilizing this instrument and require future investigations. Further, the strong feelings connected with 504 Plans within the school counseling profession (see Goodman-Scott & Boulden, 2020) could have impacted participants’ responses. Relatedly, another limitation is self-report, which may introduce bias or inaccuracies in participants’ responses. Last, exploratory factor analysis is a common first step in instrument validation. Although these initial results are promising, conducting a confirmatory factor analysis with a different sample would be prudent to confirm the instrument’s factor structure. Hence, the findings should be interpreted with caution until further confirmatory factor analysis is conducted with an independent sample.

The study’s findings warrant additional research regarding school counselors’ involvement in the Section 504 process. Qualitatively, researchers may interview school counselors to investigate how they advocate for recommended Section-504-related duties and responsibilities. Studies could also explore how decreases in non-recommended 504-related duties can support improvements in outcomes such as student well-being (e.g., mental health, attendance, school connectedness), burnout, and ASCA National Model alignment. Last, quantitative researchers may conduct a nationally representative study examining differences in school counselors’ 504 involvement across building levels, urbanicities, and regions (e.g., Midwest, Northeast, South).

Conclusion

Given the diverse needs of today’s youth, school counselors need to have the resources to advocate for ASCA-recommended duties that champion equity and student success. Although school counselors indeed play a pivotal role in supporting students with 504 plans, engaging in non-recommended duties (e.g., serving as Section 504 coordinator) limits school counselor availability and comprehensive school counseling program implementation (Goodman-Scott & Boulden, 2020). The School Counselor 504 Activities Scale is a novel tool, not only filling a gap in the literature but addressing a longstanding professional need to advance the field for practicing school counselors, thereby offering a practical resource to promote school counselor advocacy and role congruence. Although not a panacea, the instrument serves as a key step in affirming school counselors’ positioning in K–12 settings and their role advocating that all students have equitable access to educational opportunities.