The aim of this case study was to describe the distinct approaches used by physical education (PE) teachers to accommodate students with disabilities in New York elementary school PE classes. The participants included 1 adapted PE specialist, 5 PE teachers, and 5 elementary school students with various impairments. Through thematic analysis, observations and interviews revealed 3 main approaches: (a) normalized instruction—traditional curriculum with no differentiation in the program; (b) differentiated instruction—adaptations tailored specifically to the needs of each student with disability; and (c) universally designed instruction based on the principles of Universal Design for Learning (UDL) and accessibility to all students. Differentiated instruction, entailing modifications in the program and pedagogical accommodations, was the most prevalent approach at the research site, but lessons based on UDL principles were also observed. In association, the 2 approaches (differentiated instruction and UDL) represented significant resources to accommodate students with disabilities in PE.