Sorry none of us responded earlier!
FWIW, your district's GT program doesn't sound like it would do a ton for her anyway. It's very much the antique pull-out enrichment model, from what you describe. (I was in one of these many many decades ago, and the only real benefits I received per se were a break from the tedium of the regular classroom, and some fun activities with other active minds.) So yeah, a dead end, but not only for program entry reasons.
And to some of the comments about GT admissions, yes. I was part of the GT admissions process in one of my previous districts, and intellectual ability often was not the primary driver of teacher nominations. More than once, I was called in to provide the IQ documentation to support a teacher nomination, only to have to report that the student was very fast, but not actually much above average in reasoning ability. Finishing first does not equal finishing best. At the secondary level, teachers often make recommendations for advanced academics (honor, AP, etc.) based mainly on executive functions, rather than quality of response, divergent thinking, creativity, higher-level reasoning, etc--any of which would be more indicative of actual giftedness.
If your DD does not already have a health plan, that would be a good place to start from, in addition to clarifying the 504. (She can and probably should have both.) Extra time and reduced work load (e.g., eliminate low-level reinforcement items) are entirely reasonable, based on the fatigue and frequent medically-excused absences directly attributable to her health disability. And you may wish to remind the 504 team that reasonable access in her case is not limited to grade-level achievement. She has documented (by the district) abilities well above average, and there is sufficient precedent at this point to support her legal right to educational progress at her own level of ability. (See the Endrew decision.) Here's a quote from the USDOE website Q&A on Endrew (
https://sites.ed.gov/idea/questions...f-v-douglas-county-school-district-re-1/):
"While the Court did not specifically define “in light of the child’s circumstances,” the decision emphasized the individualized decision-making required in the IEP process and the need to ensure that every child should have the chance to meet challenging objectives. The IDEA’s focus on the individual needs of each child with a disability is an essential consideration for IEP Teams. Individualized decision-making is particularly important when writing annual goals and other IEP content because “the IEP must aim to enable the child to make progress. (7)
For example, the Court stated that the IEP Team, which must include the child’s parents (8) as Team members, must give “careful consideration to the child’s present levels of achievement, disability, and potential for growth.”"
Note the reference to potential for growth. The DOE's implication would appear to be that districts should take into account whether the child is achieving at their own potential, not only meeting grade-level standards. If she is not, and the reason is that obstacles to effective progress arising from her identified health disability are not being addressed by her current disability-based accommodations and services, then the district needs to take action to remediate this. If they are unsure of what is actually causing the gap between potential and achievement, then child-find requires them to do a full evaluation of all suspected areas of need.
On a practical, your-child-focused level, it is very possible that nothing available in your district (given what passes for GT services there) will truly address her needs for challenging instruction, and you may have to lean primarily on extracurriculars. In that case, the aim for in-school becomes simply helping formal education not to be aversive, focusing on whatever social or other needs are appropriately met there, and keeping her love for learning alive elsewhere. (This, btw, is one of the reasons so many of us chose to homeschool our kiddos at some point along the K-12 journey.)
