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504 URGENT

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

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504 URGENT

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  1. 504 URGENT REVIEWS EMMINENT

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

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

  4. 1992 REQUIREMENTS • NEEDS ASSESSMENT • TRANSITION PLAN FOR: • PUBLIC HOUSING • COMMON AREAS • MUST BE COMPLIANT

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

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

  7. 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

  8. DEFICIENCIES OF REPORT • OBSTACLES? • DESCRIBE METHODS • SCHEDULE • ALL REQUIRED FOR REVIEW/AUDIT

  9. REPORT MUST DESCRIBE • BARRIERS • CORRECTIVE ACTIONS NEEDED • COSTS REQUIRED • STATUS OF CORRECTIVE ACTION • WHO IS RESPONSIBLE • ALTERNATE OR INTERIM STEPS

  10. 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

  11. 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

  12. 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

  13. 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”

  14. 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”.

  15. 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

  16. HUD MAY REVIEW • ACOP • RESIDENT SERVCES • COMMUNITY PROFILES • ORGANIZATIONAL CHART • LIST OF TRANSFERRED TENANTS • EVICTED TENANTS • GRIEVANCE POLICY • REASONABLE ACCOMODATION REQUESTS

  17. 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

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

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

  20. AND……. • RACIAL/EHTNIC DEMOGRAPHICS • PET POLICY • APPLICATIONS/APPLICATION FORM • LEASE • TENANT SELECTION PLAN • TENANT FILES • AND…ANYTHING ELSE THEY WANT

  21. INTERVIEWS • DIRECTOR • EMPLOYEES • BOARD • RESIDENTS • APPLICANTS WHO WERE DENIED

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

  23. 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

  24. 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

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

  26. 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

  27. ALSO PLAN FOR: • ALL OF THE ABOVE – PLUS • CENTRILIZE THE PROCESS • REGULAR REVIEWS AND EVALUATION

  28. 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

  29. WHAT CAN YOU DO? • SANITATION • LICENSING • INNOCULATIONS • INFORMATION CONCERNING NEED • DAILY CARE

  30. 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

  31. 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.

  32. 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.

  33. 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.

  34. 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 !!!!

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

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