Well, as a long-time parent advocate w/r/t food allergy issues (and atopic conditions just in general), your procedural protections will always be better under IDEA rather than under Section 504.

In other words, if they are willing, I'd definitely keep this under the OHI umbrella as part of an IEP.

Also-- you can formalize your accommodations for food allergy by including the health plan already developed (emergency action plan, yes?) as an addendum/part of the IEP or 504 plan. No reason to not make use of the work that has been done there, KWIM?

I'd also add to that, though, some additional information about INCLUSIVE practices and the cold urticaria/food allergies. You're right-right-right to be worried about escalating risks in larger groups and with the longer day in K+. That doesn't even get into the entire birthday cupcake thing, or food-based curricular elements. Trust me, you'll be glad that you've dotted i's and crossed t's in another few years.

I also know of a really helpful online source to get a LOT of strategic help for those particular issues. I'll PM you. smile

Schrödinger's cat walks into a bar. And doesn't.