The top line here is actually that the numbers you report would qualify her for an IEP, not just a 504, as the writing achievement is well below both normative and individual expectations.
FWIW, when our ds was evaluated for IEP eligibility, his WJ-III Achievement scores in writing and fluency subtests were lower than the scores reported by ljoy, but they were still well above the "cut-off" bars that our school district publishes as qualifying requirements for IEP. We did successfully advocate for an IEP (SLD / written expression) for our ds, but it wasn't easy. The roadblocks for us were those very low bars that the district used as a guideline for qualifying (and tried to present to parents as absolute cut-offs), combined with our ds' high ability scores and also high state testing scores (in spite of being below 1% percentile on the TOWL, he was only one or two points away from scoring "advanced" on his state writing testing - the key as an advocate is to understand not only the nitty gritty details of your child's challenge but also the specific points such as how a test is administered, what is being asked on the test, how the response is given etc - in our ds' case, he struggled with generating ideas for written expression and those were the two points he missed on the state test - everything else was a grammar or spelling etc question which he got correct. On the TOWL he couldn't produce any work to be scored from because he didn't know how to put his thoughts on paper). (aeh, I am probably not explaining this as well as you can!)
Anyway, I just wanted to point out that sometimes schools will look at absolute scores and these scores, while significantly low for the student who was tested, might also be looked at by school staff as "a-ok". That's where as a parent, we really have to be a strong advocate in understanding test scores and being able to explain them to school staff.
You are also reporting educational impact, despite her good grades, as she is having to use inordinate amounts of time and effort to complete grade-level work.
This is a really important point, and one our advocate really stressed with us. Not only the amount of time that work was taking, but also if your dd is frustrated or experiencing anxiety over the amount of time and effort her work is taking.
Best wishes,
polarbear
ps ljoy - one other thing I wanted to mention above and forgot to include - again, I don't know what your dd's specific challenge is, but as I mentioned my ds was extremely challenged with written expression - in his case the primary issue was getting his thoughts out of his head, as well as challenges with summarizing information and with organizing his thoughts once he had ideas to write about. Because he had severe challenges with these specific pieces of written expression, he also lost out on several years worth of written expression instruction and progress that his classmates were experiencing simply because he wasn't producing any written expression. So - when he was finally evaluated by an SLP in 5th grade he was really really really struggling with written expression and during middle school that resulted in him routinely spending (guesstimate here - by ds and myself) around 3 times longer than his classmates on homework every night due to his writing challenges. The really cool thing though is that after having worked with his SLP since 5th grade, and with a lot of help with scaffolding at home, he's now, at the end of 8th grade, made tremendous progress in written expression and that progress has not only helped decrease the amount of extra time he was putting into classroom work and homework, it's made a huge impact on his self confidence and self esteem.
