The Office of Inspector General recently concluded an audit of HUD’s oversight of its public housing agencies’ (PHA) reasonable accommodation policies and procedures. The audit was initiated because of an identified increase over an eleven-year period, from 2009 to 2019, in housing discrimination complaints based on a failure to provide a reasonable accommodation, even as the total number of all housing discrimination complaints was decreasing.
The objective of the audit was to determine whether HUD had adequate policies and procedures for ensuring that PHAs properly addressed, assessed, and fulfilled requests for reasonable accommodation, including COVID-19-related requests.
The Report recommends that HUD’s Deputy Assistant Secretary for Public Housing and Voucher Programs:
- update compliance monitoring guidance to include a requirement for personnel to review PHA reasonable accommodation policies and procedures;
- update and consolidate reasonable accommodation policies and procedures to ensure that there is centralized guidance available for the field offices and PHAs;
- conduct additional outreach efforts to educate tenants and PHAs on their rights and
responsibilities related to requests for reasonable accommodation;
- require PHAs to track requests for reasonable accommodation, including the date of the request, the type of request, and the disposition and date of any action taken that should be made available to HUD at its request;
- review the joint agreement with HUD FHEO, and related Section 504 checklist, and modify, update, or recommit to it to ensure that the roles and responsibilities of the Office of Public and Indian Housing for conducting civil rights front-end reviews is clearly defined; and
- ensure that personnel receive training on how to conduct the civil rights front-end reviews, including a review of PHA reasonable accommodation policies and procedures.
More from this Newsletter Issue: Spring 2022
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