504 URGENT

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504 URGENT

• REVIEWS EMMINENT

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UFAS

• UNIFORM FEDERAL ACCESSIBILITY STANDARDS
• EFFECTIVE JULY 11, 1988
• DESIGN, CONSTRUCTION OR ALTERATION
• HEARING AND/OR VISUALLY IMPAIRED

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QUALIFIED INDIVIDUALS

• 504 SUBTITLE A OF TITLE II PROTECTS INDIVIDUALS
  FROM DISCRIMINATION IN
• SERVICES
• PROGRAMS
• ACTIVITIES
• RIGHT TO SERVICES FROM HUD FUNDED ENTITIES

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1992 REQUIREMENTS

• NEEDS ASSESSMENT
• TRANSITION PLAN FOR
• PUBLIC HOUSING
• COMMON AREAS
• MUST BE COMPLIANT

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INGRIEDIENTS

• IDENTIFY NEEDS OF RESIDENTS
• NEEDS OF APPLICANTS
• ASSESS ACCESSIBILITY
• ARE UNITS AVAILABLE?
• NEEDS OF COMMUNITY AND
• CURRENT RESIDENTS

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IF NEEDED

• TRANSITION PLAN REQUIRED
• IDENTIFY OBSTABLES LIMITS ACCESSIBILITY
• DESCRIBE METHODS TO MAKE ACCESSIBLE
• SPECIFY SCHEDULE TO COMPLY WITHIN FOUR YEARS
  (1996)
• GOT RECORDS?????

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FRIENDLY REMINDER

• 1999 PHAS REMINDED ABOUT OBLIGATIONS
• ADDITIONAL INFORMATION ABOUT MODIFICATIONS TO
  EXISTING UNITS
• REQUIREMENTS FOR RAMPS, MODIFICATIONS
• PAY MOVING EXPENSES IF MORE COST EFFECTIVE THAN
  REDOING APARTMENT

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DEFICIENCIES OF REPORT

• OBSTACLES?
• DESCRIBE METHODS
• SCHEDULE
• ALL REQUIRED FOR REVIEW/AUDIT

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REPORT MUST DESCRIBE

• BARRIERS
• CORRECTIVE ACTIONS NEEDED
• COSTS REQUIRED
• STATUS OF CORRECTIVE ACTION
• WHO IS RESPONSIBLE
• ALTERNATE OR INTERIM STEPS

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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

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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 DONT
  COUNT TOWARD PERCENTAGES

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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

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SPECIFIC AREAS

• PUBLIC RESTROOMS SIGN PRINT MUST CONTRAST WITH
  BACKGROUND, TEST RAISED OR INCISED. CANT HAVE
  COMPUTER PRINTED SIGNS TAPED TO DOOR. MUST BE
  54 TO 66 ABOVE FLOOR
• DOORS CANT SLAM AFTER OPENING
• DRINKING FOUNTAINS/WATER COOLERS HAVE TO HAVE
  KNEE CLEARANCE. WATER FLOW HEIGHT MUST BY AT
  LEAST 4

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KITCHENS

• COUNTER HEIGHT CANT 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 CANT EXCEED 48.

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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

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HUD MAY REVIEW

• ACOP
• RESIDENT SERVCES
• COMMUNITY PROFILES
• ORGANIZATIONAL CHART
• LIST OF TRANSFERRED TENANTS
• EVICTED TENANTS
• GRIEVANCE POLICY
• REASONABLE ACCOMODATION REQUESTS

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AND MORE

• 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

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AND MORE

• REQUESTS FOR ACCOMODATIONS
• PHYSICAL ACCESSIBILITY
• DENIALS OR TERMINATION OF ASSISTANCE
• WORK ORDERS
• LABOR PRACTICES FOR ACCOMODATIONS
• VERIFICATION OF DISABILITY
• TRANSFER POLICIES

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AND.

• LIVE-IN AIDE POLICY
• ELIGIBILITY FOR HOUSING
• DENIAL OF ADMISSIONS
• MOVE IN/OUTS
• VACANCIES
• OVER/UNDER HOUSED

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AND.

• RACIAL/EHTNIC DEMOGRAPHICS
• PET POLICY
• APPLICATIONS/APPLICATION FORM
• LEASE
• TENANT SELECTION PLAN
• TENANT FILES
• ANDANYTHING ELSE THEY WANT

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INTERVIEWS

• DIRECTOR
• EMPLOYEES
• BOARD
• RESIDENTS
• APPLICANTS WHO WERE DENIED

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STANDARD TO MEET

• NOT JUST HAVE POLICIES/PLANS, ETC
• BUT
• IMPLEMENTED THAT ENSURES NONDISCRIMINATION BASED
  UPON DISABILITY.

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THE REQUEST FOR ACCOMODATION

• FORM OR ORAL
• FOLLOW-UP
• IINVESTIGATION
• TRACK STATUS AND TIME
• COMPLETED, GRANTED OR DENIED
• STAFF MUST KNOW PROCEDURE, NOT JUST EXECUTIVE
  DIRECTOR

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RESIDENTS/APPLICANTS

• MADE AWARE OF POLICY
• AWARE OF LAW
• UNDERSTAND PHAS OBLIGATION TO PROVIDE REASONABLE
  ACCOMODATION AND MODIFICATION
• COPY OF POLICY WHEN APPLY AND
• AT RECERTIFICTION

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THE POLICY

• HOW TO REQUEST
• TIMETABLES AND BENCHMARKS TO PROCESS
• APPEAL OF DECISION GRIEVANCE
• FILE FORMAL COMPLAINT OR REQUEST THE GRIEVANCE
• SEPARATE GRIEVANCE PROCEDURE?????

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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

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ALSO PLAN FOR

• ALL OF THE ABOVE PLUS
• CENTRILIZE THE PROCESS
• REGULAR REVIEWS AND EVALUATION

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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

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WHAT CAN YOU DO?

• SANITATION
• LICENSING
• INNOCULATIONS
• INFORMATION CONCERNING NEED
• DAILY CARE

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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

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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.

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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.

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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.

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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 !!!!

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CONCLUSION

• REVIEW POLICIES
• GRIEVANCE
• SIGNAGE
• ARCHITECTURE PLANS
• GET EVERYTHING TOGETHER AND READY FOR REVIEW
• CONSULT WITH ATTORNEY
• NOTIFY INSURANCE COMPANY IF REPORTED