Documenting
Be sure to track Reasonable
Accommodations using the log form (Procedure 3-25 on the Forms and Procedures page of this blog)
I was
recently told by USDA/RD that they want Reasonable Accommodations kept in a
separate file, all on their own. SO,
from this point onward, rather than
keeping the Reasonable Accommodations in the “Personal” file, keep all accommodations
in one separate file. Keep the log in that file as well. A binder
is acceptable, and may be more workable for you.
Be sure to keep my approval email in the file. You will want to sign a Reasonable Accommodation Agreement for anything that has limiting conditions - modifications to policies, etc. Grab bars do not require an agreement.
Parking
Remember that assigned parking
spaces are, for the most part, easily granted and do not pose a burden. The exception is when people are requesting
that we make a new handicap space, or are asking that we assign them one of the
already labeled handicap spaces.
Some things to keep in mind:
The mandated handicapped spaces MUST
be available on a first-come, first-served basis to anyone with a permit – at all
times. We cannot in any way, or at any time, restrict their use. Even if someone is
assigned a space, if they have a handicapped permit, they can park in a handicapped
space (in some cases, the
reserved space may be further away from the handicap space). If there is a specific concern, please bring
it to my attention.
Response Requirements
We should have an initial response
back to the resident within 10 days of receiving all needed documentation. Sometimes, that response may be “We are
researching…and expect to get back to you by…” but they must get a
response. If verification has not been received in two weeks, you should follow up as you would for any missing verification - and should advise the Resident that we have not received verification yet. Feel free to nag me if you
need to. I am now tracking
response times – I am using Outlook to monitor my own responses, and suggest
that you utilize this resource for yourself.
I should receive a copy of all
Reasonable Accommodation requests – grab bars, parking, transfers – everything. Some of you may install grab bars upon any
request, without going through the RA process, and that’s fine, as long as you
follow the same rule for everyone. But
anything that constitutes a Reasonable
Accommodation should be copied to me.
Verification
RSCs can serve as verifiers – they have
received direction from Lee as to what items and under what circumstances they
can and cannot “sign off” on a
request. I trust their judgment on
whether they feel they can do so. If you
have concerns, bring them to my attention, and I will discuss those with
Lee.
Remember, with “obvious or known”
disabilities, and/or “obvious or known” relationships between the item
requested and a known disability, there may be no
need for third-party documentation. When
in doubt, check with me before sending out a third-party verification.
Undue Burden
The
decision on whether something is an undue burden, or must be put off pending
additional funds, must be reached in consultation with me. There may indeed be times we decline to
do an accommodation or modification due to substantial cost and low resources,
but there is a process to be followed in such cases.
Additional Note:
Please understand that my involvement is not meant to imply that I
don’t trust our staff. I do. You are competent professionals and do your
jobs with great care. My involvement is
to ensure that we comply with the rules – and to ensure that you all have the
resources that you need. In short, (and to adapt the "Scrubbing Bubbles" slogan) I
worry about this stuff so you don’t have to. When in doubt, I am only a phone call or email away.
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