Accommodations vs Modifications: Differences, Examples and Rules

Estimated reading time: 15 minutes

Accommodations vs modifications is the distinction between changing how a student learns or shows learning and changing what the student is expected to learn. An accommodation, such as an audio version of a text or extended time, keeps the expectation the same as for peers; a modification, such as fewer objectives or an easier text, changes, lowers or reduces it. This guide covers the definitions and a comparison table, examples of each by category, three examples of modifications, what modifications mean for state tests, grades and the diploma, where each appears in the IEP, 504 plans, and how an IEP team decides.

Executive Summary

Most of these decisions play out in general education classrooms: in fall 2024, 68% of school-age students (ages 5 in kindergarten through 21) served under IDEA spent 80% or more of the school day in general classes, according to the U.S. Department of Education. Every teacher responsible for an IEP must be told the specific accommodations, modifications and supports to provide (34 CFR 300.323(d)).

The stakes are highest for modifications. The Council of Chief State School Officers (CCSSO) warns that they can reduce a student’s opportunities to learn critical content, put the student at risk of not meeting state requirements and, on a state accountability test, constitute a test irregularity that invalidates the score.

What Is the Difference Between Accommodations and Modifications?

The difference between accommodations and modifications is the learning expectation: an accommodation changes the route to the same standard, while a modification changes the standard the student is held to.

What Is an Accommodation?

The CCSSO Accessibility Manual (2021) describes accommodations as changes in procedures or materials that give students equitable access to instructional and assessment content and support valid assessment results, and notes that “accommodations do not reduce expectations for learning.” The IRIS Center at Vanderbilt University adds that instructional accommodations “change how students learn but do not change what they learn.”

What Is a Modification?

CCSSO defines modifications as “practices or materials that change, lower, or reduce state-required learning expectations,” which “may change the underlying construct of an assessment.” The IRIS Center calls them “adaptations that change what students learn” and sums up the contrast: “Whereas accommodations level the playing field, modifications change the playing field.”

Neither one teaches a missing skill. That is the job of specially designed instruction, defined as adapting “the content, methodology, or delivery of instruction” (34 CFR 300.39(b)(3)), and of the goals in the complete guide to IEP goals.

Accommodations vs Modifications: Comparison Table

Sources: the CCSSO manual, the IRIS Center and the regulations cited below.

Examples of Accommodations and Modifications by Category

Accommodation Examples in the Four Categories

The IRIS Center groups accommodations into four categories. The full list is in our guide to IEP accommodations.

Modification Examples by Type

The CCSSO manual lists four kinds of modifications; the classroom examples are ours.

Same Assignment, Accommodated or Modified

Three Examples of Modifications

1. Reducing what the student must learn: fewer objectives, fewer homework questions or a shorter report. In a fractions unit, the student names and compares unit fractions while classmates add fractions with unlike denominators.
2. Making the task easier: removing some of the answer options or having the student complete only the easiest questions, both examples CCSSO gives.
3. Changing the material or assignment: a lower-level book on the same topic, or an alternate assignment, both listed by the IRIS Center.

Each changes what a grade or score means. That is a reason to decide openly, write the modification into the IEP and explain its consequences to the family, not a reason never to modify.

When an Accommodation Becomes a Modification

CCSSO counts “using an accessibility support that invalidates the intended construct” as a modification. The construct is the skill a task or test measures, so one support can fall on either side:

• Read-aloud: an accommodation on a science test, where the construct is content knowledge; a modification on a test of decoding, where CCSSO notes that read-aloud or text-to-speech supports “would not be appropriate.”
• Calculator: an accommodation on a problem-solving task where computation is not measured; a modification on a math facts test.

That is why states publish allowed accommodations test by test. Under 34 CFR 300.160(b), state guidelines must identify only accommodations that do not invalidate the score and instruct IEP teams to select only those.

What Modifications Mean for State Tests, Grades and the Diploma

The consequences depend on the state. Treat this section as the federal frame, and check your state’s assessment manual, graduation rules and district grading policy before each decision.

State Tests

• Accommodations: states must include students with disabilities in their assessments with the accommodations the IEP team determines are necessary (34 CFR 200.6(a)-(b)).
• Modifications: CCSSO states that a modification during a state accountability assessment “constitutes a test irregularity, invalidates test scores,” and leads to a state investigation of the school’s or district’s testing practices.
• No modified standards: states may not adopt modified academic achievement standards (34 CFR 300.160(c)(3) and 200.6(c)(6)).
• Alternate assessments: students with the most significant cognitive disabilities may take an alternate assessment aligned with alternate achievement standards, capped statewide at 1.0% of assessed students per subject; a district above 1.0% must justify it to the state (34 CFR 200.6(c)). Low past achievement or a past need for accommodations cannot, on its own, qualify a student (200.6(d)(1)(ii)).

Grades and Transcripts

IDEA’s regulations do not set grading rules for modified work; grading and credit policies come from the state and the district. The Office for Civil Rights’ 2008 letter on report cards and transcripts sets one limit: report cards may contain information about a student’s disability, including special education services, as long as they inform parents about progress, but transcripts, which inform postsecondary institutions and employers, may not disclose a disability.

The Diploma

A regular high school diploma is the standard diploma “awarded to the preponderance of students in the State that is fully aligned with State standards”; it cannot be aligned to alternate achievement standards, and a certificate of completion or attendance does not count (34 CFR 300.102(a)(3)(iv)). Graduating with one ends the obligation to make FAPE available and is a change in placement that requires prior written notice; the obligation continues after a lesser credential.

ESSA’s four-year and extended-year graduation rates also count students with the most significant cognitive disabilities who take the alternate assessment and earn a state-defined alternate diploma that is standards-based, aligned with the state’s regular diploma requirements, and obtained while the student is eligible for FAPE (20 U.S.C. 7801(23) and (25)); check whether your state offers one. States must tell IEP teams and parents how taking the alternate assessment may delay or otherwise affect completing a regular diploma, and may not stop the student from attempting it (34 CFR 300.160(d)-(e)).

Where Accommodations and Modifications Appear in the IEP

The regular education teacher on the team must, to the extent appropriate, help determine supplementary aids and services and program modifications (34 CFR 300.324(a)(3)(ii)), and every teacher responsible for the IEP must then be informed of “the specific accommodations, modifications, and supports” to provide (34 CFR 300.323(d)). The decisions themselves belong in the IEP meeting.

Accommodations and Modifications Under a 504 Plan

CCSSO notes that all IDEA students are also covered by Section 504, but not all Section 504 students are eligible under IDEA, and that Section 504 requires public schools to provide certain accessibility supports even to students who do not qualify for special education. The Section 504 regulation defines an appropriate education as regular or special education and related aids and services designed to meet individual needs as adequately as the needs of students without disabilities are met (34 CFR 104.33(b)).

CCSSO observes that lists of the accommodations a student can use on assessments are often an important part of 504 plans, and for state tests a 504 student’s accommodations are set by the placement team (34 CFR 200.6(b)(1)(ii)). When a 504 team finds that a student needs lowered expectations or specially designed instruction to make progress, ask whether an IDEA evaluation is due, and follow your district’s Section 504 procedures. The IEP accommodations guide compares IEP and 504 accommodations.

How an IEP Team Decides Between an Accommodation and a Modification

CCSSO’s five steps start with expecting students to achieve grade-level standards and end with evaluating the use of accessibility supports. Applied to this choice:

1. Start from the grade-level expectation for the task or course.
2. Name the barrier from the present levels, not the disability label; see PLAAFP examples.
3. Try accommodations first. CCSSO cautions that more is not necessarily better.
4. Look at the data, comparing results “when accessibility supports are used, versus when they are not used,” as CCSSO suggests.
5. Modify only what must change, for a named task or course, and write down the modified expectation.
6. Explain the consequences for grades, state tests and the diploma to the parents and, as appropriate, the student.
7. Pair each modification with a goal and instruction aimed at the skill, and review it at every annual review.

Funding and Staffing

IDEA Part B funds may pay only the excess costs of special education and related services (34 CFR 300.202). Assistive technology must be provided when the IEP requires it, including home use of school devices when needed for FAPE (34 CFR 300.105). The scarce resource is staff time to adapt materials: Learning Policy Institute data for 2024-25 show 45 states with special education teacher shortages.

Common Mistakes District Leaders Make

1. Calling a modification an accommodation. Fewer problems or an easier text lowers the expectation, whatever the form calls it.
2. Modifying before accommodating. A lower-level text is chosen before anyone tries an audio version of the grade-level one.
3. Modifying across the board. A student who needs a modified math curriculum may need only accommodations in science.
4. Carrying a classroom modification into a state test, which CCSSO calls a test irregularity that invalidates the score.
5. Not telling parents what a modification means for grades, credit and the diploma.
6. Leaving modifications open-ended, with no goal aimed at the skill and no review date.

Questions District Leaders Should Ask

• How many of our IEPs list modifications, and in which subjects?
• Are any modifications recorded as accommodations on our IEP forms?
• Do parents hear how a modification affects grades and the diploma before they agree?
• How many students use a classroom support their state test does not allow?
• Do we assess more than 1.0% of our assessed students in any subject with the alternate assessment, and can we justify it?

Frequently Asked Questions

What are three examples of modifications?

Three common examples are reducing what the student must learn (fewer objectives, fewer homework questions or a shorter report), making the task easier (fewer answer options, or only the easiest questions), and replacing the material (a lower-level book on the same topic or an alternate assignment). Each lowers or changes the learning expectation, which is what makes it a modification.

Does an IEP have accommodations or modifications?

It can have both. The IEP must state the supplementary aids and services and the program modifications or supports for school personnel the student will receive (34 CFR 300.320(a)(4)), and any accommodations needed on state and districtwide tests (300.320(a)(6)). Many students need only accommodations; modifications belong only where the team decides the expectation itself must change.

What are the four types of accommodations?

The IRIS Center uses four categories: presentation (how information is given, such as audio or large print), response (how the student answers, such as speech-to-text), setting (where the student works, such as a small group) and timing and scheduling (how long and when, such as extended time or breaks). The full list is in our IEP accommodations guide.

What are the five types of accommodations?

There is no federal list of five. Federal regulations do not sort accommodations into types, and the IRIS Center uses four: presentation, response, setting, and timing and scheduling. Longer lists split timing from scheduling, which gives five, or add groups; the Bureau of Indian Education’s special education quick guide, for example, uses six, adding organization. Follow the categories in your state’s assessment manual.

Can AI help teachers adapt materials?

AI tools can help a teacher reformat a handout without changing its content, for instance by adding headings, a glossary of key terms or a two-column layout, which the teacher then checks for accuracy. Ask for the same content in a new format, not easier content, unless the IEP calls for a modification. Keep student information out of unapproved tools; see the ChatGPT for teachers guide.

Related Resources

• IEP Accommodations: List by Category
• Specially Designed Instruction Examples
• IEP Goals: How to Write Measurable Goals
• IEP Meeting Guide
• PLAAFP Examples
• Prior Written Notice Examples

Conclusion

The line between accommodations and modifications is the learning expectation, and the rest follows from it: how a state test is scored, what a grade means and which diploma a student can earn. Districts that define the line clearly, accommodate before they modify, explain each modification to families and pair it with instruction keep more students on the path to grade-level work.

Sources: CCSSO, Accessibility Manual: How to Select, Administer, and Evaluate Use of Accessibility Supports for Instruction and Assessment of All Students (2021); IRIS Center, Accommodations: Instructional and Testing Supports for Students with Disabilities; 34 CFR 300.320, Definition of individualized education program; 34 CFR 300.160, Participation in assessments; 34 CFR 300.102, Limitation, exception to FAPE for certain ages; 34 CFR 200.6, Inclusion of all students; 34 CFR 104.33, Free appropriate public education (Section 504); 20 U.S.C. 7801, ESEA definitions; U.S. Department of Education, Office for Civil Rights, Dear Colleague Letter on Report Cards and Transcripts (October 17, 2008); Bureau of Indian Education, Special Education Quick Guide: Accommodations; U.S. Department of Education, OSEP, 2024-25 Static Tables (Part B Child Count & Educational Environments). Other sections of 34 CFR Part 300 are linked where they are cited.

Join the 2027 Special Education Pilot

Accommodations and modifications decide how a student reaches grade-level work, but the skills that would let a modification be faded still come from many repetitions of practice, and adult 1-on-1 time is limited in every classroom. Telo AI is being adapted for students with IEPs: patient, 1-on-1 practice aligned to each student’s IEP goals and pace. We are inviting districts to shape it with us in a 2027 pilot.

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