As your Fair Housing Defense editor reviewed the articles our loyal readers sampled the most during 2011 — it was clear that many of the most read posts had to do with reasonable accommodations and reasonable modifications as well as steps taken to ensure that residents/applicants with disabilities could have their needs met.  I have written previously that in addition to an equal housing opportunity policy, management should draft a reasonable accommodation policy.
The purpose of a policy to address reasonable accommodation and reasonable modification requests is to make certain that requests from residents/applicants are appropriately addressed.  Indeed, a number of years ago HUD published a notice mandating that owners of all HUD subsidized housing have a reasonable accommodations policy. I respectfully suggest, however, that it makes good sense for all property owners/managers have a policy to address reasonable accommodation and reasonable modification requests. 

This type of policy will typically have two components. The first is the public statement of the company’s priorities and intentions when working with applicants/residents with disabilities. This statement is similar to the fair housing policy statement, although it specifically addresses the needs of people with disabilities. For example:  "Ownership/Management at ABC Apartments welcomes all to our community and we do not discriminate against individuals with disabilities.  We offer an equal housing opportunity and provide accommodations to meet the needs of individuals with disabilities upon request, provided the accommodation/modification request is reasonable and feasible.  Requests for reasonable accommodations or reasonable modifications should be submitted in writing to the community manager.  Depending on the disability, the applicant/resident may need to provide some limited information from a medical/health care provider to verify the disability.  Management will respond to the request in a timely manner."

The second component of a reasonable accommodations policy is a list of steps for management and the applicant/resident to follow in evaluating the accommodation request.  Consistent use of this list will help ensure that each request is handled properly and consistently over time. 

My next post will specifically address some of the issues that management may want to consider in developing a reasonable accommodation/reasonable modification policy. 
Just A Thought.