Reasonable Accommodation Policy

Chapter 2: General Overview

This Chapter provides a basic overview of the RA process. More detail may be found in the Chapters that follow.

2.1  What is a Reasonable Accommodation and what purpose does it serve?

An RA is 1) a change, exception, or adjustment that BHA can make to its rules, policies, practices or procedures, or 2) (for purposes of this policy) a physical modification2 to a public housing Resident’s unit or common area which may be necessary to provide a Client with a disability an equal opportunity to use and enjoy BHA housing and programs.

Clients may seek an RA at any time. BHA will only decide whether to grant or deny an RA after undertaking the analysis described in the following pages.

2.1.1  Leased Housing Participants and physical modifications

While this policy applies when Leased Housing Participants ask BHA to alter its policies, rules, and practices as an RA, it does not apply to Participants’ requests for physical changes to their units or changes to their landlords’ policies, rules, and practices.3 Please see Section 6.2 for information on how BHA may be able to assist when a private landlord is not able to accommodate a Participant at his/her current unit.

2.2  Examples of Reasonable Accommodations

The following is a list of examples of RA requests:

  • A Resident or Applicant with a disability that prevents him or her from climbing stairs requests a unit located on a first floor or in an elevator-equipped building.

  • A Resident or Applicant with a disability that makes walking and standing difficult requests grab bars for his/her unit’s bathroom (Resident) or a unit with such features (Applicant).

  • A Resident or Applicant with a mental disability that makes travel on public transportation difficult requests a unit close to his/her service provider who he/she visits on a frequent basis.

  • A Resident with a mental disability who disrupts his/her neighbors when off of his/her medication requests that the BHA not seek an eviction in exchange for an agreement to follow a treatment plan that will prevent further disruptions.

  • A Voucher Holder with a disability requiring the use a wheelchair requests extra time to use a Section 8 mobile voucher because he/she is having difficulty finding a wheelchair-accessible apartment.

  • A Voucher Holder with a disability requests a higher payment standard for his/her Section 8 mobile voucher because he/she is having difficulty locating an apartment that meets his/her disability-related needs within the limits of the regular payment standard.

  • A Client with a hearing impairment requests that BHA provide a sign language interpreter for a meeting, private conference, or hearing with BHA staff.

  • A Client who cannot attend a meeting, conference, or hearing due to a disability requests that BHA allow the meeting to be conducted at an alternative time or location, or by alternative means such as telephone or email exchanges.

  • A Client who has difficulty writing due to a disability requests that a BHA staff member assist him or her with filling out a required form.

  • An Applicant with a disability that makes keeping appointments difficult misses a screening appointment for this reason and requests that he or she not be removed from the waitlist and instead be given another opportunity to attend.

  • An Applicant with items on his/her CORI that would lead to a finding of ineligibility, but which resulted from a then-untreated disability, requests that BHA find him/her eligible because he/she is now being treated and can provide evidence that the acts are unlikely to happen again.

2.3  The interactive process

Before deciding on a Client’s request for an Accommodation, BHA must engage in an “interactive process” with the Client. This non-adversarial process is based on communicating with the Client about his/her needs in a cooperative and solution-oriented manner. During the interactive process, BHA may seek additional information about the nature of the request, as well as verify the needs of the Client from reliable third parties. The interactive process also allows the BHA and Client to discuss alternative Accommodations when a Client proposes an Accommodation that the BHA thinks may be burdensome, unreasonable, or ineffective in addressing the concerns at issue.

2.4  Who pays for a Reasonable Accommodation?

If BHA grants an RA, it is responsible for the cost. BHA will not require Clients to pay extra fees or deposits as a condition of receiving an RA.4 In addition, BHA is responsible for any costs associated with determining whether to grant an RA during the interactive process.


2Physical modifications are known as “reasonable modifications” under the law. This policy will use the term “reasonable accommodation” to cover physical changes as well.

3For additional information on the responsibilities and rights of Leased Housing Participants and landlords in such situations, please review the Joint Statement of the Department of Housing and Urban Development and the Department of Justice: Reasonable Modifications under the Fair Housing Act, which is available at

4Note that if Leased Housing grants an increased payment standard as an RA for a Participant, the Participant’s rent share may increase.

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