Section 504 of the Rehabilitation Act of 1973 is a broadly worded statement that addresses discrimination in schools and other settings. Enacted at about the same time as the Individuals with Disabilities Education Act (IDEA), Section 504 has been used sparingly in elementary and secondary schools. Section 504 presents an opportunity to redress educational inequities for struggling students because it can provide support for students with disabilities and impairments not covered by IDEA. However, due to vague wording, unclear case law, and limited training for school divisions and practitioners, schools are unsure how to implement and to comply with Section 504. These issues may have the effect of barring qualified students from coverage. The purpose of the present study was to ascertain the state of implementation and understanding of Section 504 in the Commonwealth of Virginia's elementary and secondary schools. Data were gathered from a survey administered to 323 Section 504 school administrators and 34 Section 504 division coordinators, due process hearing officers' decisions, Office for Civil Rights complaint resolution letters and federal judicial decisions. Analysis of these items indicated that while Virginia fared better in some areas than did other states, concern about the equity of educational opportunity for Virginia's students with impairments remains.