Section 504 applies to private schools that receive federal funds, which are defined in the regulations as, "any grant, loan, contract (other than a procurement contract or a contract of insurance or guaranty), or any other arrangement by which the [U.S. Education] Department provides or otherwise makes available assistance in the form of: 1) Funds; 2) Services of Federal personnel; or 3) Real or personal property or any interest in the use of such property." 34 CFR 104.3 (h).

This begs the question: If private schools are accepting COVID-19 relief federal funding, do they have to follow Section 504 and the ADA?