Too often public schools do not have, within their educational structure, someone who is trained to provide direct one to one tutoring, nor do they have the staffing to provide such.
Tutoring is typically provided at least one period per day if the child attends a private special education school, such as one of the Orton-Gillingham based (reading) programs around the country. This period of tutoring is not viewed as either an accommodation or modification, but a direct educational service.
Tutoring and/or direct one to one remediation of a required academic skill, such as reading, is clearly supported in IDEA 2004.
If you do not have an IEP, I think it can be argued as necessary as part of a 504 Plan in that the child needs to be taught how to read in order to be able to access the curriculum in the same manner as typical non special education, regular education children.
Tutoring in IDEA 2004
For tutoring in IDEA 2004, see 20 U.S.C. 1401.
Read the definitions of a child with a disability, related services, and special education.
(3) Child With A Disability
(A) In General. The term ‘child with a disability’ means a child
(i) with [various labels] …and
(ii) who, by reason thereof needs special education and related services.
(26) Related Services
(A) The term ‘related service’ means . . . and such developmental, corrective and other supportive services, including . . . services, . . . therapy, . . . designed to enable a child with a disability to receive [FAPE and] . . . benefit from special education . . .
(29) Special Education
The term ‘special education’ means specially designed instruction, at no cost to parents, to meet the unique needs of a child with a disability, including…
The Related Services definition supports individualized remediation, i.e., tutoring. Also “specially designed instruction” supports tutoring as such.
In other words, a child with a disability needs specially designed instruction which includes corrective supportive services and therapy, i.e., tutoring.
Either definition 26 or 29 in IDEA, independent of each other, support tutoring as an appropriate service for FAPE (or for access/equal opportunity under Section 504).
Excerpt from article posted 11/10/2016 by Pete Wright on http://www.wrightslaw.com/blog/tutoring-as-a-direct-service-in-idea/