HUD HCV Guidebook § 3.2.5

The PHA will need to determine whether there is a nexus, or identifiable relationship, between the disability
and the accommodation being requested. In other words, is there a disability-related need for the reasonable
accommodation that is requested? If a person’s disability is obvious92, or otherwise known to the PHA, and if
the need for the requested accommodation is also readily apparent or known, then the PHA cannot request
any additional information about the requester’s disability or the disability-related need for the
accommodation, and must grant the request unless doing so would result in an undue administrative and

90 28 CFR 35.101.
91 See HUD/DOJ Joint Statement on Reasonable Accommodations 5/17/04.
92 HUD/DOJ Joint Statement on Reasonable Accommodations 5/17/04, Q&A 12.

Fair Housing and Nondiscrimination Requirements                                                         24
US Department of Housing and Urban Development                                                  April 2025

financial burden or fundamental alteration in the essential nature of the program or activity. Depending on
the PHA’s own policies described in its Administrative Plan, the PHA must have a method for noting where an
accommodation meets a disability-related need and is granted.

If the requester’s disability is known or readily apparent to the PHA, but the need for the accommodation is
not readily apparent or known, the PHA may request only information that is necessary to evaluate the
disability-related need for the accommodation.93 In most cases, this information can be provided by the
individual making the request. In some cases, additional third party information may be necessary. This third
party may be a doctor or other medical professional, a peer support group, a non-medical service agency, or a
reliable third party who is in a position to know about the individual’s disability and the need for the
accommodation. In most cases, an individual’s medical records or detailed information about the nature of a
person’s disability is not necessary for this inquiry and may be inappropriate.