Reasonable Accommodation Policy

Chapter 13: Management of Personal Information and Confidentiality

13.1 Management of personal information in Client files

BHA will maintain records for any Client who has requested an RA in the Client’s file. Copies of the following RA-related documents will be kept pursuant to state and federal record retention requirements.

  • The Request(s) for Reasonable Accommodation;
  • The denial or approval notice(s);
  • Any final decision(s) following an informal hearing;
  • Any decision(s) of the BHA Administrator/designee;
  • Any decision(s) of an outside administrative agency or a court;
  • Any settlement agreements; and
  • Documentation that an approved Accommodation has been implemented.

13.2 Confidentiality and use of Reasonable-Accommodation-related information

All information submitted to BHA by a Client or his/her verification sources which relates to a request for Accommodation will be kept confidential and used solely to make a determination on the RA request. This protection of confidentiality will extend to all information which relates to a Client’s disability and need for Accommodation contained within a Client’s files or any other BHA file with related information.

A Client’s third-party representative may have access to the above information with the Client’s authorization.

13.3 Employee and Grievance Panel access to confidential information

Information regarding a Client’s RA request, including final decisions and any medical information provided in support of the request, will only be available to BHA employees or DGA Grievance Panel members who:

  1. Are directly involved in reviewing the RA request;
  2. Need to be aware of an approved Accommodation in order to assist with it; or
  3. Need access to the information in order to review a decision at a hearing or appeal.

13.4 Civil rights agencies’ access to Reasonable Accommodation information

Upon request, federal, state, and local civil rights enforcement agencies will be provided with such information and documents as authorized by law.

13.5 Client access to documents related to Reasonable Accommodations

Clients are entitled to copies of all documents in their BHA files related to past or current RA request(s) in accordance with applicable law.

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