Reduce Administrative Costs by Understanding Reasonable Accommodations

Understanding Reasonable Accommodations

Having a disability shouldn’t mean that a person’s housing situation should be intolerable. If someone has a physical or mental disability, it’s imperative they are aware of the accommodation or modification they can request from their housing that will allow them to make the most of their home life. This is not just limited to the inside of their homes but applies to any and all amenities offered as well. PHAs can see a major reduction in administrative costs by ensuring our applicants and tenants truly understand what reasonable accommodations are, and how to request them from their PHA. 

In order to communicate this properly to our disabled tenants and applicants we must first be able to help them understand the difference between modifications and accommodations.  

A reasonable modification is a structural change made to existing premises occupied or to be occupied by a person with a disability. This is done for the tenant’s full enjoyment of the premises.  This is different from reasonable accommodations, which are changes, exceptions, or adjustments to a rule, policy, practice, or service that has been deemed necessary for a person with disabilities to have an equal opportunity to use and enjoy a dwelling, including public and common use spaces, or to fulfill their program obligations. 

 

Do our Applicants/Tenants Know They Qualify? 

Let’s quickly review what having a disability means?  An individual with a disability is any person who has a physical or mental impairment that substantially limits one or more major life activities. The term physical or mental impairment may include, but is not limited to, conditions such as visual or hearing impairment, mobility impairment, HIV infection, developmental disabilities, or mental illness.  

We must disclose to our applicants that the Fair Housing Act protects people from any discrimination based on disabilities when they are renting or buying a home, getting a mortgage, seeking housing assistance, or engaging in other housing-related activities.  

What is one way HUD enforces this protection from discrimination?  

 

Reasonable Accommodations  

Reasonable accommodations eliminate barriers that may prevent persons with disabilities from fully participating in housing opportunities, including both private housing and federally assisted programs or activities. When this is communicated to applicants up front, it will reduce cumbersome paperwork and tracking by PHAs on the backend. 

It’s super important that anyone seeking housing assistance realizes, as part of the Fair Housing Act, that owners, landlords, and housing authorities must accept requests for reasonable accommodations and reasonable modifications.    

They key for PHAs is having a process for Housing Choice Voucher households to make requests for accommodations. They also must have a process for determining whether these requests are reasonable. 

 

How To Make the RA Process Easier for PHAs 

What makes the job of a PHA specialist easier is when those who come to us know exactly what they want and exactly what they need. Pipedreams, we know, but we can help this process GREATLY. 

If we make sure our applicants know the process ahead of time, it puts less pressure on us to clean up the pieces later. Before applicants or tenants may ever need a reasonable accommodation, we should be regularly communicating the requirements and the process for requesting one.  

Once a quarter, we should send out communications to our tenants, whether email blasts or mailers, explaining how to apply for reasonable accommodations and who should be requesting them. 

While PHAs are not allowed to ask direct questions about the nature of the disability, letting our applicants and tenants know that confirmation of some type of will be necessary can eliminate erroneous RA requests.  It’s also imperative that we emphasize we make REASONABLE accommodations and modifications. This is not a ticket to request to renovate a unit just because they are unhappy with it. 

Most importantly, we must let the applicants, tenants, and landlords know that this will all come at no cost to them.  

Under Section 504, reasonable accommodations must be provided and paid for by the housing provider unless providing them would be an undue financial and administrative burden or a fundamental alteration of the program. 

Speaking of landlords, this information should be communicated to them regularly as well, but with a slight twist. We should be sending out regular info cards, or email updates that let owners and landlords know they can require all modifications be completed by a professional AND be in compliance with all applicable building codes. In addition, landlords may require the household to restore the unit to its original condition before vacating.  

None of these should be long communications that take up a lot of time to create and distribute. A simple one or two well written paragraphs with a visual aid added will effectively communicate enough to make the RA intake process easier on your PHA.   

What’s most important is that these communications are sent out regularly. At least quarterly or bi-annually.  

This allows PHAs to get a head start and ensure their tenants and applicants are prequalifying themselves to an extent. When people are living with disabilities it can make many aspects of life more challenging, it’s reassuring to know that our home can be a place where we find comfort. 

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