Accessibility, Reasonable Accommodation and Language Access During Relocation

Relocation is when accessibility and language-access failures are most likely: residents are moving, units are changing, and communication volume spikes. Section 4 of HUD's RAD relocation Notice makes clear that accessibility requirements apply at every stage of a conversion, including relocation.

Reasonable accommodations follow the household

Accommodations a resident already has must continue through the move. Common examples during relocation include:

• direct help with packing and moving as an accommodation,
• a larger unit to fit a live-in aide or equipment,
• temporary housing near public transportation,
• exceptions to no-pet rules for assistance animals.

Unit modifications move too

When a resident with a disability has accessibility modifications in their current unit, the PHA or Project Owner must provide and pay for comparable modifications in the new unit, whether temporary or permanent, no matter who originally installed them. Identify these early from resident records and the needs survey so replacement units can be prepared in time.

Language access

PHAs and owners must take reasonable steps to give residents with limited English proficiency meaningful access to meetings and to every relocation notice and document. In practice that means translated notices, competent interpreters at meetings, and covering the cost.

Effective communication and accessible meetings

• Provide notices in alternative formats as needed, such as large print, Braille, audio or accessible electronic files.
• Offer sign language interpreters and assistive listening at meetings.
• Hold meetings in accessible locations, preferably on site, even if that means more, smaller sessions.

Budget for it

These are not optional extras. Build line items into the relocation budget for interpretation and translation, alternative formats, accommodation-related moving services, and unit modifications. HUD Handbook 1378, Exhibit 3-1, offers additional guidance on relocation assistance for persons with disabilities.

Start with the survey

Everything starts with a thorough resident needs survey covering accessibility features, accommodations, language and communication preferences. Record the results in the resident log so every move, notice and meeting reflects them.