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Section 504 · Nonprofits with federal money
A nonprofit that receives federal financial assistance and has fifteen or more employees has to designate at least one person to coordinate its Section 504 compliance and adopt a grievance procedure. The money often arrives through a city or state contract, which is why the duty is easy to miss.
Four details decide whether it applies to you, and one signature you've likely already given makes the gap hard to explain.
Section 504 reaches any program or activity that receives federal financial assistance from any federal agency. These are the points where organizations read themselves out of it by mistake.
01
When a private organization's main work is education, health care, housing, social services, or parks and recreation, or when federal money goes to the organization as a whole, Section 504 covers all of its operations, not only the funded program. A Head Start grant brings in the gym, the website and the event registration too. Other private organizations are covered at the facility the money reaches.
29 U.S.C. 794(b)(3)
02
A recipient is any organization federal assistance reaches directly or through another recipient. Federal money that arrives through New York State, a city agency or another nonprofit makes you a recipient. A city contract can be paid with federal dollars without saying so on its face.
45 CFR 84.10, “Recipient”
03
Grants, subgrants, cooperative agreements and loans count, and so does money passed through a state or city. A direct federal procurement contract doesn't, and neither does a contract of insurance or guaranty. Organizations that sell to the federal government answer to Section 503 instead, which is an employment obligation.
45 CFR 84.10, “Federal financial assistance”; 41 CFR Part 60-741
04
Each federal agency writes its own Section 504 rule. HHS, the Education Department and HUD each require a designated coordinator and a grievance procedure at fifteen employees. The Justice Department's rule sets the line at fifty employees and $25,000 in Department funding. An organization with several funders answers to each rule, and one coordinator can hold all of them.
45 CFR 84.7; 34 CFR 104.7; 24 CFR 8.53; 28 CFR 42.505
Every application for this money carries a signed assurance that the program will operate in compliance with Section 504. For HHS funding it's form HHS-690, and the Education Department and HUD rules require the same. An organization with no named coordinator has already certified to the government that it does something it doesn't.
When a complaint arrives, the questions start with who coordinates compliance and how complaints are handled. If the answer is nobody and nowhere, the organization can't argue it didn't know the rule applied, because it signed that it did.
The fifteen-employee line measures the organization's size. It doesn't limit the coordinator to staff matters. The coordinator holds compliance with the whole rule.
Participants, patients, students, families and visitors: program access, effective communication, and the request that comes in at the front desk or on the sign-up page.
Program access
Section 504 also covers employment, so staff accommodation sits with the same coordinator.
One part of the role
The grievance procedure, the complaints it receives, how each was resolved, and the notice that tells people their rights.
45 CFR 84.7(b); 84.8
The fifteen in Section 504 is not the ADA Title I employer threshold. They are the same number for unrelated reasons. Title I sets no coordinator requirement, and neither does Title III.
The answer is on paper, so it doesn't depend on anyone's memory of the contract.
The organization names its designee. The practice performs the coordinator function under that designation: it administers the request path and the grievance procedure, produces the notice and the policy, and maintains the record and the yearly review. One function covers every funder's rule at once.
ADA Access for All is not a law firm. This page is built to be usable by counsel. Citations read on eCFR and the U.S. Code on October 14, 2026.
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