All sites – Reasonable Accommodations:
Recently, there has been a sharp increase in the amount of
requests for assigned parking, assigned accessible parking, and bathroom
modifications (including barrier-free showers). In many cases, there is a
significant delay in making a decision on the request due to the need to
clarify the needs with the verifier. In addition, there has been some
confusion on who may be considered a qualified verifier.
Although it is true that a verifier does not necessarily
have to be a physician or health care provider, this should always be our
preferred source for verification. In any case, the verifier must be
someone who we believe is reasonably capable of assessing the individual’s
disability status and need. For instance, while my friend may be able to
tell you I have a disability, they may not be able to tell you exactly how far
I am able to walk (which becomes relevant for assigning a parking space) or how
high I can safely lift my leg (which may be relevant for a tub cut). It
is reasonable for us to make inquiries related to the need of the individual
requesting an accommodation.
For this reason, I have developed two new forms, which
should be used effective immediately.
They are as follows:
You will find that both include some specific questions
designed to assess exactly what is needed. This should help us in
determining what the need is, and addressing needs in the most economic and
reasonable way possible.
Please note that while Resident Service Coordinators, in
general, can verify the need for accommodations / modifications, it is likely
that the RSC will generally not have the requisite knowledge of the specifics
necessary to verify these items.
If you have a situation where there is no physician who can
verify, or a unique situation that appears to need detailed discussion, please
don’t hesitate to contact me.
Remember, for those of you who do not have federal funding,
although you may not have to pay for accommodations / modifications, you often
still are required to permit them. Please make sure that you are
forwarding any requests.
Another important note – please take care when
a resident requests something that ordinarily would not be allowed. Make
sure you are not dealing with a Reasonable Accommodation request before you say
no. If you are unsure, please check with your RM, me, or Tammy before you
say no.
All Sites – Site Inquiries:
In my travels recently, I’ve overheard a number of telephone
conversations (or, rather, half of them) regarding inquiries about
housing. Please be very, very careful when answering questions about your
facility. Remember to use your site script. When potential
applicants begin asking about eligibility, the best answer is always “I have an
application packet that I can send to you which will answer many of your
questions. If you still have questions after you review it, please feel
free to give me a call.” Where you can potentially get yourself in significant
Fair Housing trouble is if you are perceived as discouraging someone from
applying. If you absolutely must answer questions (and again, you want to
generally refrain from discussing eligibility until you have an application in
front of you), be sure to refer to your site script and your facility
description, so that you can be sure to give the exact same answer every time,
in a manner that is consistent with program guidelines and your printed
materials.
If your wait list is closed, you may advise that the wait
list is closed when responding to inquiries. Please also advise the
caller as to how you will provide notice when the wait list opens.
HUD Sites – Deceased Tenants:
Recently, I met with a family member of a deceased
tenant. She was concerned because she reportedly had been told that they
had to vacate the unit in two weeks, even though her mother had paid the full
month’s rent for June. As this is a common area of confusion, I wish to
make it clear what happens to subsidy when the sole member of a household
dies. Please be sure that you are using Form 3-10c, the Notice Regarding
Move-Out, and that you are reviewing this with residents when they move
in. You might also want to keep a copy handy to refer to when speaking
with family.
It is NOT true that a unit must be vacated within 14 days of
the sole household member’s death. It IS true that subsidy cuts off at
that point. If items remain in the unit after that point, the estate is
charged the pro-rated unsubsidized rent for the unit. If the tenant
already paid their rent, you would simply charge the difference between what
the tenant paid, and what is owed. If you are at all unsure as to what
you need to charge in these cases, please speak with your RM or with me.
We would be happy to help you with the calculation.
All sites – AFHMP:
HUD - Recently, I received information that
conflicted with previously given HUD guidance regarding Marketing plans.
It has been recently clarified by the HUD FHEO office in Boston that if your
wait list is CLOSED, you do not have to market. However, if your
wait list is open, you must do your AFHMP marketing every year.
Please be sure to keep copies of all advertising and all letters in your AFHMP
file. This is requested at the MOR.
USDA – When I submit your AFHMP, USDA/RD requests
copies of all advertising, so be sure that you have those copies available when
I request information for your AFHMP updates.
DOH – Recently, DOH has started to request copies of
actual advertising as well, so be sure to keep copies of all ads and letters.
