Transcript 504 URGENT - AAHRA-Alabama Association of Housing

504 URGENT
REVIEWS EMMINENT
UFAS
• UNIFORM FEDERAL ACCESSIBILITY
STANDARDS
EFFECTIVE JULY 11, 1988
DESIGN, CONSTRUCTION OR ALTERATION
HEARING AND/OR VISUALLY IMPAIRED
QUALIFIED INDIVIDUALS
• 504 SUBTITLE A OF TITLE II PROTECTS
INDIVIDUALS FROM DISCRIMINATION IN:
• SERVICES
• PROGRAMS
• ACTIVITIES
• RIGHT TO SERVICES FROM HUD FUNDED
ENTITIES
1992 REQUIREMENTS
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NEEDS ASSESSMENT
TRANSITION PLAN FOR:
PUBLIC HOUSING
COMMON AREAS
• MUST BE COMPLIANT
INGRIEDIENTS
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IDENTIFY NEEDS OF RESIDENTS
NEEDS OF APPLICANTS
ASSESS ACCESSIBILITY
ARE UNITS AVAILABLE?
NEEDS OF COMMUNITY AND
CURRENT RESIDENTS
IF NEEDED
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TRANSITION PLAN REQUIRED
IDENTIFY OBSTABLES: LIMITS ACCESSIBILITY
DESCRIBE METHODS TO MAKE ACCESSIBLE
SPECIFY SCHEDULE TO COMPLY WITHIN FOUR
YEARS (1996)
• GOT RECORDS?????
FRIENDLY REMINDER
• 1999: PHA’S REMINDED ABOUT OBLIGATIONS
• ADDITIONAL INFORMATION ABOUT
MODIFICATIONS TO EXISTING UNITS
• REQUIREMENTS FOR: RAMPS,
MODIFICATIONS
• PAY MOVING EXPENSES IF MORE COST
EFFECTIVE THAN REDOING APARTMENT
DEFICIENCIES OF REPORT
• OBSTACLES?
• DESCRIBE METHODS
• SCHEDULE
• ALL REQUIRED FOR REVIEW/AUDIT
REPORT MUST DESCRIBE
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BARRIERS
CORRECTIVE ACTIONS NEEDED
COSTS REQUIRED
STATUS OF CORRECTIVE ACTION
WHO IS RESPONSIBLE
ALTERNATE OR INTERIM STEPS
REQUIRED PERCENTAGES
• MOBILITY IMPAIRED – 5%
• HEARING OR VISION – 2%
• HUD CAN INCREASE BASED ON CENSUS OR
NEEDS AT PARTICULAR PHA
• MUST BE DISTRIBUTED THROUGHOUT
DIFFERENT SITES
• MUST BE IN DIFFERENT SIZES
• AND AMENITIES SO TENANT CAN CHOOSE
TRAPS
• REAR EXITS TO REAR COMMON AREAS
• CONCRETE SLAB PATIOS MUST NOT BE TOO
HIGH FOR PERSONS WITH DISABILITIES
• RAMPS CAN BE USED FOR PATIOS.
• UNITS MODIFIED FOR PARTICULAR TENANT
NEEDS DON’T COUNT TOWARD PERCENTAGES
ADDITIONAL INVENTORY
REQUIREMENTS
• PHA MUST MAINTAIN MINIMUM NUMBER OF
UNITS IN INVENTORY
• THAT CAN BE USED BY INDIVIDUALS
• WITH WIDE VARIETY OF PHYSICAL
DISABILITIES
• READILY AVAILABLE AND IMMEDIATELY
USABLE
• IN SAME MANNER AS WITHOUT DISABILITIES
SPECIFIC AREAS
• PUBLIC RESTROOMS: SIGN PRINT MUST
CONTRAST WITH BACKGROUND, TEST RAISED
OR INCISED. CAN’T HAVE COMPUTER
PRINTED SIGNS TAPED TO DOOR. MUST BE
54” TO 66” ABOVE FLOOR
• DOORS CAN’T SLAM AFTER OPENING
• DRINKING FOUNTAINS/WATER COOLERS:
HAVE TO HAVE KNEE CLEARANCE. WATER
FLOW HEIGHT MUST BY AT LEAST 4”
KITCHENS
• COUNTER HEIGHT CAN’T EXCEED 34” ABOVE
FLOOR
• MUST HAVE AT LEAST ONE 30” SECTION OF
COUNTER SPACE WITH KNEE CLEARANCE OF
AT LEAST 27” HIGH
• SINK AREA MUST HAVE KNEE CLEARANCE AT
LEAST 30” WIDE AND 27” HIGH.
• BOTTOM SHELF OF WALL CABINET CAN’T
EXCEED 48”.
PARKING
• ACCESS AISLE ON SIDE, NOT FRONT
• SIGNAGE MUST BE CORRECT: MOUNTED AT
LEAST 60” ABOVE SPACE
• DIMENSIONS MUST BE CORRECT
• SPECIFIC DESIGNATIONS WHEN NEEDED
HUD MAY REVIEW
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ACOP
RESIDENT SERVCES
COMMUNITY PROFILES
ORGANIZATIONAL CHART
LIST OF TRANSFERRED TENANTS
EVICTED TENANTS
GRIEVANCE POLICY
REASONABLE ACCOMODATION REQUESTS
AND MORE
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OUTREACH FOR DISABLED TENANTS
JOB DESCRIPTIONS
EMPLOYEE TRAINING INFORMATION
REQUEST FOR ACCOMODATION FORM
NOTICE OF ACCOMODATION FOR DISABLED
POLICIES RELATED TO DISABLED
DEFINITION OF REASONABLE ACCOMODATION
AND MORE
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REQUESTS FOR ACCOMODATIONS
PHYSICAL ACCESSIBILITY
DENIALS OR TERMINATION OF ASSISTANCE
WORK ORDERS
LABOR PRACTICES FOR ACCOMODATIONS
VERIFICATION OF DISABILITY
TRANSFER POLICIES
AND…….
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LIVE-IN AIDE POLICY
ELIGIBILITY FOR HOUSING
DENIAL OF ADMISSIONS
MOVE IN/OUTS
VACANCIES
OVER/UNDER HOUSED
AND…….
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RACIAL/EHTNIC DEMOGRAPHICS
PET POLICY
APPLICATIONS/APPLICATION FORM
LEASE
TENANT SELECTION PLAN
TENANT FILES
AND…ANYTHING ELSE THEY WANT
INTERVIEWS
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DIRECTOR
EMPLOYEES
BOARD
RESIDENTS
APPLICANTS WHO WERE DENIED
STANDARD TO MEET
• NOT JUST HAVE POLICIES/PLANS, ETC
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• IMPLEMENTED THAT ENSURES
NONDISCRIMINATION BASED UPON
DISABILITY.
THE REQUEST FOR ACCOMODATION
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FORM OR ORAL
FOLLOW-UP
IINVESTIGATION
TRACK STATUS AND TIME
COMPLETED, GRANTED OR DENIED
STAFF MUST KNOW PROCEDURE, NOT JUST
EXECUTIVE DIRECTOR
RESIDENTS/APPLICANTS
• MADE AWARE OF POLICY
• AWARE OF LAW
• UNDERSTAND PHA’S OBLIGATION TO PROVIDE
REASONABLE ACCOMODATION AND
MODIFICATION
• COPY OF POLICY WHEN APPLY AND
• AT RECERTIFICTION
THE POLICY
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HOW TO REQUEST
TIMETABLES AND BENCHMARKS TO PROCESS
APPEAL OF DECISION: GRIEVANCE
FILE FORMAL COMPLAINT OR REQUEST THE
GRIEVANCE
• SEPARATE GRIEVANCE PROCEDURE?????
THE SYSTEM
• APPLY IN WRITING, IN PERSON OR TELEPHONE
• RECORD AND EVALUATE REQUESTS FROM
APPLICANTS AND RESIDENTS
• TRACK THROUGH FINAL DISPOSITION
• KEEP STATS: GRANTED AND DENIED
• REJECTED AND APPEALS
• TRACK MODIFICATIONS
ALSO PLAN FOR:
• ALL OF THE ABOVE – PLUS
• CENTRILIZE THE PROCESS
• REGULAR REVIEWS AND EVALUATION
PETS OR SERVICE ANIMALS?
• MUST HAVE POLICY FOR SERVICE ANIMALS
• DEFINE SERVICE ANIMALS
• DO NOT HAVE TO BE PROFESSIONALLY
TRAINED
• DEFINE EMOTIONAL SUPPORT OR
COMPANION ANIMAL
• NEED NOT HAVE SPECIAL TRAINING
• NO FEE CAN BE CHARGED
WHAT CAN YOU DO?
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SANITATION
LICENSING
INNOCULATIONS
INFORMATION CONCERNING NEED
DAILY CARE
COMMUNICATION POLICY !!!!
• NOTICE TO APPLICANTS AND RESIDENTS OF
RIGHT TO QUALIFIED SIGN LANGUAGE
INTERPRETER OR OTHER AUXILIARY AID.
• LETTERHEAD/INFORMATION ABOUT AIDS AND
SERICES
• TDD OR MEMBER OF RELAY SERVICE
• LARGE PRINT, BRAILLE OR COMPUTER DISK
• STAFF MUST BE TRAINED IN ALL OF THIS
MAY DENY REQUEST FOR REASONABLE
ACCOMMODATION IF:
• NOT MADE BY OR ON BEHALF OF A DISABLED
PERSON
• NO DISABILITY RELATED NEED FOR
ACCOMODATION
• IF PROVIDING WOULD IMPOSE UNDE
FINANCIAL AND ADMINISTRATION BURDEN
OR FUNDAMENTALLY ALTER NATURE OF
OPERATIONS.
TRANSFER ISSUES
• MAY REQUEST RELIABLE DISABILITY RELATED
INFORMATION NECESSARY TO VERIFY THAT
THE PERSON MEETS THE DEFINITION.
• DESCRIBES NEEDED ACCOMMODATION
• SHOWS RELATIONSHIP BETWEEN THE
DISABILITY AND NEED FOR REQUESTED
ACCOMMODATION.
TO TRANSFER
• PHA CANNOT REQUIRE RESIDENT
REQUESTING TRANSFER TO BE EXAMINED BY
PHA CHOSEN DOCTOR
• REQUIRE RESIDENT TO BE CURRENT ON ALL
RENT, UTILITIES AND OTHER CHARGES PRIOR
TO APPROVAL TO TRANSFER FOR DISABILITY.
GRIEVANCE POLICIES
• MUST HAVE PROVISION ABOUT NOT
DICRIMINATING AGAINST QUALIFIED
APPLICANTS, RESIDENTS AND EMPLOYEES
WITH DISABILITIES
• POLICY SHOULD HAVE SECTION ON
DISCRIMINATION BASED ON DISABILITY.
• I RECOMMEND A SEPARATE POLICY !!!!
CONCLUSION
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REVIEW POLICIES
GRIEVANCE
SIGNAGE
ARCHITECTURE PLANS
GET EVERYTHING TOGETHER AND READY FOR
REVIEW
• CONSULT WITH ATTORNEY
• NOTIFY INSURANCE COMPANY IF REPORTED