Slide #1 © 2008 Nan McKay & Associates Emily Wilcox Managing Non-Discrimination © 2008 Nan McKay &...

Slide #1 © 2008 Nan McKay & Associates© 2008 Nan McKay & Associates

Emily Wilcox

Managing Non-Discrimination

© 2008 Nan McKay & Associates

Slide #2 © 2008 Nan McKay & Associates

Fair Housing and Reasonable Accommodation


We Will Cover…

Resources and Factual Overview of Laws FHEO Civil Rights Review Documents Reasonable Accommodation

• Case studies • Verification and reporting best practices


We Will Cover…

Prohibitions against discrimination affecting Limited English Proficient persons

Violence Against Women Act case study scenarios

Review of select PHA Fair Housing Voluntary Compliance Agreements

Review of recent OIG PHA Audits regarding over housing/live-in aide findings


HUD Initiated - 2007

HUD had 15 Secretary initiated investigations• More than in the past ten years combined.

In FY 2007, HUD awarded 88 FHIP grants of $18.1 million to groups in 37 states and the District of Columbia to conduct fair housing enforcement, education, and outreach activities.

Fair Housing Accessibility FIRST (2003)


Home Sweet Home


DOJ – Fair Housing

www.usdoj.gov/crt/housing/fairhousing/


Home Sweet Home

Department of Justice (DOJ)- Fair Housing Initiative In 2007, the DOJ conducted a record number of

undercover housing discrimination investigations • 30 lawsuits alleging unlawful housing discrimination• Obtained settlements and judgments requiring the

payment of over $5 million in monetary damages to victims of discrimination and civil penalties


Home Sweet Home

2/2006 - Operation Home Sweet Home The initiative was inspired by the plight of large

numbers of persons displaced by Hurricane Katrina, many of them minorities, seeking new housing • Fair lending• Access forums


The Information Super Highway


Google It - WHO

Domestic Violence Service Providers• Breakfast

Fair Housing councils• Lunch

Legal Aid• Snack


Google It - WHO

Disability rights organizations• Dinner

Nonprofits/faith based groups who work with particular immigrant communities

• Dessert Nursing homes/rehab centers/mental health

institutions• Drink


Google It - WHAT

State and Local Fair Housing Law (“human rights commissions”)

Local housing law protections for victims of violence• City, County, State• Read the definitions of words such as “sex,”

“sexual orientation,” “source of income”


Steal, Cheat and Use

Has your neighbor PHA developed LEP planning (LAP)?

Has your neighbor PHA developed RA forms? Has your neighbor PHA contacted Legal Aid?


Before You Call…


Before You Call…

Have a plan• “We Want Your Help” and Education

Have specific questions• DV – How do you take referrals?

Do you work with both men and women? How can we improve confidentiality/safety

for victims at our PHA?


After You Meet…

Follow-up with a thank-you (even if there is not going to be a partnership)

Can you “formalize” an agreement? Learn: What perceptions did the groups have

of the PHA? How can those interactions be brought to your Board, Exec Dir?

Trust and accountability with the community


Helen Keller


Customer Service and Fair Housing Complaints

Can be filed with HUD, state/local human rights commission, state ct, federal ct• HUD has a duty to investigate and respond

within 100 days Actions can be brought against a PHA by an

individual, HUD, or DOJ


Customer Service - Open To Change

Ask others/Ask yourself:• How can we do better?• You are a business• Approach your work with the nonprofit

community on the offensive – don’t wait for a lawsuit!


Customer Service

Communication Respect – nonjudgmental Consistency Listening (show that you have heard what has been

said) Can’t control your families – can control a process,

expectations, and follow through


Customer Service - Language

LANGUAGE MATTERS• People with disabilities are people first • Most respectful approach – not “handicap”

Presume Competence Presume Ability

• Approach working with people with disabilities as people with different abilities


Supervisory Goals

Training (reception, maintenance, management)• What to listen for/when do I refer – listening

between the lines• Etiquette and support around tough issues

such as mental illness and domestic violence• What if I do it wrong?


Supervisory Goals - Attitude

How we ask is as important as what we ask “Program participants know the regulations

better than we do.” Zero tolerance for discrimination (comments,

jokes) ACOP/Admin Plan available


Responding to Fair Housing Complaints

1. Is there a history with this participant?2. What staff are involved?3. What is it that this participant really wants?

4. Is this really just miscommunication?5. Be eager to LEARN from complaints


WHAT IS DISCRIMINATION?


3 Types of Discrimination

1. Overt – “No _____________ here.”2. Disparate Treatment - Discrimination which occurs

when members of a protected class are treated in a different and less favorable manner than others

3. Disparate Impact - adverse effect on members of a protected class in comparison to majority

• Policy may be neutral as written but discriminatory as applied.


Even Forest…

Starts the LEP process• http://www.hud.gov/offices/fheo/promotingfh/leptranslated.cfm

Puts reasonable accommodation on applications, forms, notices Orally explains RA at annual exams Contacts families about rights under VAWA Section 504 Coordinator/VAWA coordinator Physical needs assessment


Fair Housing and Equal Opportunity (FHEO)

• 24 CFR Part 100 (FHA) and 24 CFR Part 8 (Section 504)


Discrimination under the Fair Housing Act

No person shall be subjected to discrimination because of • race, color, religion, sex, handicap, familial status or

national origin • in the sale, rental or advertising of dwellings, in the

provision of brokerage services in or in the availability of residential real estate-related transactions. 24 CFR 100.5


Websites Domestic Violence/VAWA

• www.ndvh.org (365 Days/24 Hours/140 Languages)• 1-800-799-SAFE (7233)/1-800-787-3224 (TTY)

Voluntary Compliance Agreements• http://www.hud.gov./offices/fheo/library/index.cfm

Department of Justice and HUD• http://www.usdoj.gov/crt/housing/jointstatement_ra.htm

Fair Housing• http://www.fairhousing.com/index.cfm• http://www.bazelon.org/issues/housing/infosheets/13livein.htm


Websites Disability

• http://www.hud.gov/offices/fheo/disabilities/sect504faq.cfm

Accessibility • http://www.fairhousingfirst.org• http://www.hud.gov/offices/fheo/disabilities/fhefhag.cfm

LEP• http://www.lep.gov/selfassesstool.htm• http://www.hud.gov/offices/fheo/promotingfh/lep-faq.cfm


Websites

OIG• http://www.hud.gov/offices/oig/reports/oigstate

.cfm Forms – PH Occup GB

• http://www.hud.gov/offices/pih/programs/ph/rhiip/phgb_app8.pdf (RA forms)


HUD References• Notice 2002-01-Section 504 and accessibility

compliance for people with disabilities• Notice 2003-31- Fair Housing Act of 1988, Section 504,

the ADA, Architectural Barriers Act.• Notice 2004-13 - Tracking vouchers for special

populations (disability) on Form 50058 • Notice 2005-5 - New Freedom Initiative • 05/17/2004 - HUD and DOJ Joint Statement• PIH Notice 2006-13 - Compliance with the ADA,

Section 504, the Architectural Barriers Act of 1963, and the Fair Housing Act


HCV Mobility Counseling

PHA has an affirmative duty to help the family find an accessible unit• Current listing of available units• Recruiting landlords• How does PHA attract new HCV owners with accessible

units?• Extending voucher time• Transportation• Linkage/Partnership agreements


Turnover of Accessible Units and Transfers


Turnover of Accessible Units

PHAs shall adopt notification processes to be sure that information about the availability of accessible units reaches people with disabilities

PHAs shall take steps to maximize the utilization of accessible units by eligible individuals whose disability requires the accessibility features of the unit


Section 504/24 CFR 8/ Set-Asides in Public Housing

New construction and substantial rehabilitation in PH:• 5 percent of the units (or at least one unit) must

be accessible for people with mobility impairments and

• 2 percent of the units (or at least one unit) must be accessible for people with hearing or vision impairments.


Uniform Federal Accessibility Standards (UFAS) 24 CFR § 8.32

The applicable accessibility standards for compliance under Section 504 are the Uniform Federal Accessibility Standards (UFAS).

Just because a unit meets the requirements of the Fair Housing Act does NOT mean it is an accessible unit under UFAS and Section 504.

Federally funded properties must meet both the Section 504 and FHA design requirements.



When an accessible unit becomes vacant:(1) First, offer the unit to a current occupant who

requires the accessibility features of the vacant unit (if the current occupant does not have such accessibility features in their current unit)



(2) Second, if there is no current resident in the same development who requires the accessible unit, PHA will offer the unit to: • current resident with disabilities residing in

another development that requires the accessibility features of the vacant unit



(3) Third, if there is no current resident who requires the accessibility features of the vacant, accessible unit: • offer the unit to an eligible, qualified

applicant with disabilities on the wait list who can benefit from accessible features of the unit



(4) Fourth, if no eligible resident or applicant with disabilities on wait list who wishes to reside in the accessible unit, offer the unit to an applicant on the wait list who:• does not need the accessible features of the

unit



When offering an accessible unit to applicants/residents without disabilities:• PHA may require such applicants to agree to

move to a non-accessible unit when the accessible unit is needed by a disabled familyAt least 30 days notice At PHA’s expense


Transfers

If a resident needs a transfer due to a verified medical condition or for a reasonable accommodation, what priority does that person have on your move/transfer list?

How many move/transfer offers will be given? Hierarchy of transfers set out in ACOP

• Ex. Emergency transfers, priority admin transfers, family composition transfers

Slide #46 © 2008 Nan McKay & AssociatesSection 504/ADA Needs Assessments and Accessibility

Plans Initial issuance of regulations implementing Section

504 at 24 CFR Part 8 in 1988,• PHAs required to conduct needs

assessments, transition plans and implementation strategies meeting the needs of applicants and residents with disabilities


Needs Assessment - ADA

PHA self-evaluation was required after the passage of the ADA - effective as of Jan 1992.

Many PHAs followed through w/ implementation plans in the 1990s, some did not:• Some PHAs continue to be in noncompliance with fair

housing accessibility laws with non-accessible admin offices, PHA office properties, and too few public housing units which are accessible


PIH Notice 2006-13

FHEO will continue to request copies of self-evaluations, needs assessments and transition plans in every compliance review and complaint investigation conducted of a HUD recipient.

To ensure compliance, PHAs are encouraged to conduct self-evaluations yearly with local advocacy groups – updating plan and units


Atlanta - Chicago – Seattle – Your Name Here?


Voluntary Compliance Agreements

VCA Checklist _________________________________ _________________________________ _________________________________ _________________________________


VCA

Checklist Cont.


Steve Gold

http://www.stevegoldada.com/stevegoldada/archive.php?mode=N&id=157


Steve Gold “What follows is the list of HAs that have entered into VCAs with

HUD. Disability advocates in the listed locales should obtain a copy of both the Letters of Findings and the VCA (either from your HA or the regional HUD office under which the VCA was entered). You should check whether or not the HA has complied with the VCA. If the VCA required a specific number of units, ask your HA for the addresses so you could visually determine if they really were made accessible and if persons who require the accessible units are actually residing in them….If your local HA is not listed, you should telephone your regional HUD Office, ask for the Fair Housing official, and find out whether or not a Section 504 compliance review occurred recently.”


PHA Civil Rights Monitoring


Civil Rights MonitoringCivil Rights Monitoring 11/9/2006 & 3/1/2007 – Fed Reg Notices 6/13/2007 – Final civil rights review

documents posted on www.hudclips.org• Joint effort by PIH and FHEO to increase

oversight of fair housing issuesTwo checklists – attachment A & B


Attachments A & B

• PIH is planning to conduct civil rights monitoring reviews

• Reasonable accommodation and LEP issues• Data collected helps HUD evaluate PHA

compliance with civil rights and fair housing laws and regulations

• Expires 2010


Attachment A – General FH

Very broad criteria that is being examine:• (Part II) “Is there anything else that is related to civil

rights or fair housing that should be noted…?”• Form suggests for PIH reviewers to gather

information from “media reports” and “racial/ethnic tensions” complaints at developments


Attachment B

Checklist purpose “serves as an alert to PIH and FHEO to certain PHA practices regarding Section 504”• Results are referred to FHEO for follow-up


Attachment B

Specific questions regarding:• Section 504 coordinator• Units meeting UFAS-accessibility standards• Distribution of accessible units• Reasonable accommodation policy/process

Including how/when RA policy is given to applicants and residents


Attachment B

Additional inquiry into (are you documenting this?):• Service animals• Deposits• TTY• Alternative forms of communication• Mobility support, voucher exts, FMR exceptions for

HCV applicants/participants


Attachment B

Final question is very broad:• “What other rules or policies has the PHA

implemented that affect persons with disabilities?”

• Be prepared to show affirmative steps the PHA has taken to market to and support people with disabilities in the community


Heard on the Street

Accessible Units - UFAS HCV Mobility Supports for People with

Disabilities Reasonable accommodation process LEP


PHA Obligation to Notify

Must inform applicants and participants of right to request a reasonable accommodation• Forms, letters, posters, signs

Which forms? Which letters? All? Some?• “If you or anyone in your family is a person with

disabilities, and you require a specific accommodation in order to fully utilize our programs and services, contact…”


Forms

PHA creates or adopts standardized forms• Ask the same questions of everyone• NOTE: PHA must still give consideration to

requests for reasonable accommodation if requester makes the request orally or doesn’t use PHA’s preferred forms or procedures


PHA ProcessBest Practice Idea

TWO TYPES OF REPORTING:(1) All accommodation requests that are granted and denied (obvious) are reported(2) All accommodation requests in which you need assistance with final decision


New Freedom Initiative


New Freedom Initiative

Executive Order 13217 (Issued 6/18/01)• U.S. Supreme Court case Olmstead v. L.C.• Purpose: “de-institutionalize” persons with

disabilities • Purpose: to improve community integration• Serve people with disabilities in the most

integrated settings (ADA & 24 CFR Part 8)


PIH Letter 2007-01

PIH Letter (Issued May 2007)• Extension of PIH 2006-21 (HA), reinstated PIH

2005-5 (HA), New Freedom Initiative, Executive Order 13217

• See Sec. Jackson’s Letter to PHAs (Oct 2006)http://www.hud.gov/offices/pih/publications/me

dicareinitiative.pdf


July 9, 2007 Letter

HUD “strongly supports expanding accessible, affordable and integrated housing options…”http://www.hud.gov/offices/fheo/disabiliti

es/MFP-RebalancingMemo.PDF


People with Disabilities and Reasonable Accommodation


Communication

Some disabilities affect an applicant’s or participant’s ability to read or understand

TTY/Vision impairments (what are your PHA’s resources here – who do you call?)

PHA must take “appropriate steps to ensure effective communication…” • 24 CFR § 8


Section 504

PHAs administering public housing will incur costs to fully comply with the law • Modifications to a unit for a person with a

physical disability• Costs for assisted communication


Section 504 – 24 CFR Part 8 Program access 504 Coordinator Transition plans Notice of non-discrimination Communications Grievance procedures Reasonable accommodation Physical accessibility standards - UFAS


Fair Housing Act - Definitions

Person with a disability (handicapped):1.Has a physical or mental impairment which

substantially limits one or more of such person’s major life activities; or

2.Has a record of having an impairment; or3.Is regarded as having such an impairment


Disability

(1) Substantially limits one or more of the major life activities…• Caring for one's self, performing manual

tasks, walking, seeing, hearing, speaking, breathing, learning, and working


Disability

(2) A record of such an impairment…• Person who has a history of an impairment

that substantially limited a major life activitysuch as someone who has recovered from an

impairment includes persons who have been misclassified

as having an impairment


Disability

(3) Being regarded as having an impairment…• Person is treated as if he has an impairment

Perception test: if PHA refused to serve the person because it perceived that the person had an impairment • Remember: we presume competence!


Excluded Under FHA Current drug users When alcohol use interferes with the rights of

others A person with a disability that poses a direct

threat or substantial risk of harm to others See HUD/DOJ Memorandum


Who Determines Disability Status


RA Verification Form

Include: ____________________________________ ____________________________________ ____________________________________ ____________________________________


Disability - 3 DefinitionsABC…Easy as…123


HUD’s Definition of Disability

HUD’s Definition of Disability (24 CFR 5.403):(A) Person meets the Social Security Administration definition of a person with disabilities as defined in 42 U.S.C. 423; or(B) Person has a physical, mental or emotional impairment that:

is expected to be of long-continued and indefinite duration; substantially impedes their ability to live independently; and is of such a nature that the ability to live independently could

be improved by more suitable housing conditions; or(C) Person has a developmental disability as defined in the Developmental Disabilities Assistance and Bill of Rights Act of 2000: “A severe, chronic disability that…


HUD Definition of “Disabled Family”

Disabled family means a family whose head, spouse, co-head, or sole member is a person with disabilities 24 CFR 5.403


HUD Disability - 3 Definitions

Your verification forms must reflect these different definitions• Meaning: different verification forms

necessary for reasonable accommodation versus disability status for HUD program eligibility and rent calc deductions


“Disabled”

Community service exemption Working family preference Medical deductions Disability assistance deduction Mainstream voucher program/Mixed Population or

Designated Disabled PH properties EID – Voucher program


Reasonable Accommodation


Short Version of RA

1. Was an accommodation requested?2. Is this a person with a disability?3. Nexus between disability and the specific

request?4. Is the request reasonable?5. Is RA in your application, occupancy, recertification

and termination notices?


Reasonable Accommodation

Three most important words: document, document, and document.

From moment applicant or occupant requests an accommodation…• a paper trail must be created documenting

dates, times, conversations and paperwork exchanged


Mini-Procedural List

PHA should have written procedures:• Notification of all applicants and participants – when?• Standardized forms (live-in aide documentation)• Training front line staff – such as reception staff• PHA staff responsible for receiving request• PHA staff who oversees and reviews verification• Decision-making process

Ex. Who determines if a RA is an undue administration and financial burden? How is this documented? Where?


Mini-Procedural List

PHA should have written procedures:• Time periods for decision and implementation• Right of appeal/hearing processes• Handling confidential information

What is a “need to know” basisWhat happens when medical records or detailed

disability information is received by the PHA?


Request Starts Process

ART OF THE REASONABLE ACCOMMODATION CONVERSATION:• Process may involve fluid negotiations on a

case-by-case basis• PHA may offer alternative options• Document from the beginning


Treat Each Case Individually

Treat each case on individual merits Requestor’s choice accommodation should be

carefully considered Not legit reason for denial: floodgates will

open (they will all want it)


PHA Can Not Ask If person has a disability (unless determining

qualification for program or type of development)

Nature or extent of disability Any question requiring waiving or disclosing

medical condition or history Can’t require tenant be able to live independently


Consideration of Reasonableness – Reasons to Deny


Denying Requests

Requests for accommodations are not reasonable if • They impose undue administration and

financial burden on PHA or • The request fundamentally alters the nature of

PHA work


Fundamental Change

• Fundamentally alters the nature of PHA work…

• a substantial change in the primary purpose or benefit of a program or activity

• Requesting supports outside housing services• Is person requesting social services?• Person requesting nonpayment of rent/no inspection?• Removing a load bearing structure?


Direct Threats

The assessment should consider: (1) the nature, duration, and severity of the risk of

injury; (2) the probability that injury will actually occur; and (3) whether there are any reasonable accommodations that will eliminate the threat.

OBJECTIVE DECISION


Live-In Aides Screening your aides? Verify the need for an “aide” versus a “helper” Live-in Aide Criteria and Live-in Aide Housing

Agreement Live-in aide signs addendum making clear:

• Only for employment/no property interest in unit• Family is accountable for any lease violations by

the live-in aide


Office of Inspector General


OIG

Live-in Aide Checklist __________________________ __________________________ __________________________ __________________________


OIG

Checklist Cont.


Service Animals


Service Animals

May the PHA choose to require animals to have formal training or certification in order to be considered service animals? NO (unless?)

Language: Companion animals, emotional support animals, therapy animals, assistance animals (make it easy!)• All animals could be support animals…


Federal Register Notice – Service Animals

October 15, 2007, HUD published a proposed rule on assistance animals • to improve the consistency between its pet

ownership regulations that cover public housing and assisted housing programs


VAWA


Violence Against Women Act

Violence Against Women Reauthorization Act of 2005 (VAWA) signed into law January 5, 2006, as Public Law 109-162.• Technical Amendments signed into law August

12, 2006 as Public Law 109-271.• NO HUD REGULATIONS


HUD Notice PIH 2006-23

Issued on June 23, 2006, HUD reinforced that PHAs are to implement the VAWA requirements immediately (Jan 2006).

HUD will be developing regulations to make conforming changes to existing regs and will provide guidance.



Issued on Dec. 27, 2006 Provides optional certification form. (HUD-

50066). • Tenant permitted to self-certify - policy • Other documents can be used in place of or

together with HUD-50066 - policy• Third party documentation not required - policy



Issued on Feb. 27, 2007 Provides the revised HAP Contract and

Tenancy Addendum, and includes instructions Note: Public Housing lease provisions not

included


Federal Register Notice on VAWA (published March 16, 2007)

All denials and terminations of assistance conducted must be in compliance with VAWA protections (landlords must be aware of this)

Authority to bifurcate a lease applies to all leases; PHAs & owners still follow state or local eviction procedures for eviction proceedings.


Certifications

PHAs are not required to demand that an individual produce official documents or physical proof that they are a victim• PHA are permitted to accept the individual’s

statement alone.But then individual could claim victim status even if

they are not a victim?


VAWA Scenario 1 We have a family where the wife has taken the

children and fled an abusive husband. We have given her a voucher under VAWA. Now we have to terminate the HAP contract that we have on the unit where the husband lives. What should we tell the husband? We know that we should not tell him that his wife has a voucher somewhere else. We also know that we should not create a situation where he might become more violent. How do we explain why he is no longer being subsidized? Any suggestions?


VAWA – Scenario 2

Woman with children applies to the PHA for housing. She is otherwise eligible except that she owes the PHA $300 on a lease where she was the “spouse” 11 years ago. She reports that her husband controlled the finances, she has since left him and has documentation from a DV agency that she was a victim of DV. Do we accept her application? May we deny her housing? Can we require she pay back the $300?


VAWA Scenarios

I use drugs because I am a victim of domestic violence – you can’t kick me out

What if both partners in an assisted family point fingers…who does the PHA support?

“He’s been living with me. I did not tell the PHA. Now he won’t leave and is abusing me. He is stealing from me and I cannot pay my rent.”


VAWA Scenarios

I have a bad boyfriend who abuses me. PHA moves me. I find another bad boyfriend. PHA moves me. I find another bad boyfriend. PHA moves me…

The CRAZY Ex-Girlfriend…


Limited English Proficient Persons (LEP)


LEP

Persons who, as a result of national origin, do not speak English as their primary language • Limited ability to speak, read, write, or

understand English• Under Title VI and LEP Guidance may be

entitled to language assistance with respect to a particular service, benefit, or encounter


Who determines LEP status?

• Generally, a person self-identifies as LEP in order for the PHA to provide assistance

• There is no one way to determine whether a person’s command of English is “limited”Q: How does a LEP person know to identify

himself as needing assistance?


LEP

Can a person be LEP only “part-time?”• Yes. “Limited” English Proficiency could

depend on circumstances • Example: A person may identify as LEP if

there are legal issues involved and special vocabulary, but could feel comfortable doing an annual recertification without assistance


Why Do We Have LEP Obligations?

Executive Order 13166 (Aug 2000)• Affects all federal agencies and recipients• DOJ instructed HUD to produce guidance

HUD published proposed LEP Guidance Dec 19, 2003 in Federal Register

HUD published final LEP Guidance Jan 22, 2007 in Federal Register ( see HUD FAQs)


LEP and Citizenship

U.S citizenship does not determine whether a person is LEP• Title VI applies to citizens, documented non-

citizens, and undocumented non-citizens• A person who is a citizen may be LEP • A person who is not a citizen may be fluent in English

http://www.hud.gov/offices/fheo/promotingfh/lep-faq.cfm


Three Steps to LEP Compliance

1. Four Factor Analysis (number, frequency, importance, costs)

2. Draft a Language Assistance Plan (LAP) (who will you serve, how, staff training)

3. Implement Plan (and be prepared to revise – demographics change, technology changes)


Family Members as Interpreters

Question: May recipients rely upon family members or friends of the LEP person as interpreters?

Answer: Generally, recipients should not rely on family members, friends of the LEP person, or other informal interpreters….• Communication cost burdens are on PHA• “Please bring an interpreter…” (No Good!)


Question Time

No one was born knowing Fair Housing laws and regulations…ASK.

Encourage your staff to ask [email protected]


Thank you for attending!

Upcoming Lunch ‘n’ Learns: Mar 20th – HCV Financial Management for

Non-Financial Managers Mar 28th – Finance for the Public Housing

Director

Slide #1 © 2008 Nan McKay & Associates Emily Wilcox Managing Non-Discrimination © 2008 Nan McKay &...

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