HUD HCV Guidebook § 3.2.3

Since individuals must be informed of their right to ask for reasonable accommodations, PHAs may create or
adopt standardized forms or processes that clearly and simply ask for all the information. Asking the same
questions of everyone is one way to assure consistency in the process. However, a person with disabilities is
not required to use a specific form or format to request a reasonable accommodation.

As a best practice, PHAs may create or adopt standardized forms or processes that clearly and simply ask for
all the information in order to easily facilitate the accommodation requests. Asking the same questions of
everyone is one way to assure consistency in the process; however, PHAs must understand that disabilities
are varied and so PHAs must adapt to the methods of communication, provision and solicitation of
information to and by individuals with disabilities. In some circumstances, PHAs may be required to engage in
interactive process discussions to better understand a requested accommodation or to discuss what
accommodations may be equally effective in meeting the individual’s disability-related need; however, the
individual is not obligated to accept an alternative accommodation if it would not meet their disability-related
need and a PHA must provide the requested accommodation if it is not an undue administrative and financial
burden or a fundamental alteration to the essential nature of the program or activity. PHAs must accept
requests either orally or in writing, and written requests do not have to be on the form provided by the PHA. A
request cannot be refused simply because the person did not use the PHA’s standardized form or procedures.
Regardless of how the request is made, it is important to consistently document the date and type of request
in the tenant file or a separate tracking log, which must be made available to HUD upon request.87 As a best

86 Notice PIH 2011-31; HUD/DOJ Joint Statement on Reasonable Accommodations, 5/17/04.
87 24 CFR 8.55(c); 24 CFR 146.27; 2 CFR 200.337

Fair Housing and Nondiscrimination Requirements                                                        22
US Department of Housing and Urban Development                                                 April 2025

practice, a separate tracking log, which can only be accessed by staff who need to know the information, may
better ensure the confidentiality of individuals with disabilities. Another best practice includes providing the
requester with a copy of the documentation relating to their request at the time it was made.

Additionally, PHAs must use caution that such forms do not make illegal or unnecessary inquiries of
individuals with disabilities beyond what is appropriate for a reasonable accommodation request. An
individual with a disability may request a reasonable accommodation at any time during the application
process, tenancy period, or eviction process.88

An individual with a disability may make as many reasonable accommodation requests as needed; there is no
limit to the number of reasonable accommodation requests that may be granted to someone. A PHA may not
deny a reasonable accommodation request on the grounds that the requester has made prior reasonable
accommodation request(s).

 The need for an accommodation can come to the PHA’s attention in many ways other than a formal
 request. A PHA’s policies must be sufficient to provide reasonable accommodations throughout its
 programs, services, and activities regardless of a formal request being made.

 For example, a PHA may learn of the need for an accommodation in the course of looking into potential
 noncompliance with program requirements, and must work through the reasonable accommodation
 process before moving forward with any adverse action based on the potential noncompliance, as
 illustrated by the following scenario: a person misses two annual reexamination appointments, and when
 confronted with the possibility that their assistance could be terminated for failing to complete the annual
 reexamination process, the PHA learns that they could not keep their appointments due to hospitalization
 or other disability-related need. In this case, the PHA must not take any adverse action against the
 individual. The PHA engages in its reasonable accommodation process with the individual and
 determines it will provide the person another appointment date as a reasonable accommodation instead
 of simply moving forward with an adverse action.