HUD HCV Guidebook § 3.6
Section 504 Coordinators (HUD HCV Guidebook)
Operative Text
If a PHA employs fifteen or more people, one employee must be designated to coordinate compliance with
Section 504.118 Written communication must identify the coordinator for Section 504. Depending on the size
of the agency and how the agency is organized, the 504 Coordinator position may be a full-time position
where this is the only role the individual performs. Alternatively, the 504 Coordinator may also perform other
roles, such as the role of a manager or supervisor. Even in smaller agencies that employ fewer than fifteen
people, the PHA must ensure coordination of Section 504 responsibilities, whether the duties are spread
among several employees or are handled by one person. The goal of 504 coordination is to ensure
compliance in providing equal opportunity to otherwise qualified persons with disabilities.
504 coordination includes several other areas of PHA operations, not just reviewing reasonable
accommodation requests by employment applicants, employees, housing applicants and participants. Areas
where 504 coordination must be involved include marketing and community outreach for housing and
employment applicants. The responsibilities of the 504 coordinators include ensuring compliance with
various accessibility requirements, such as:
• Physical accessibility of the premises including designated accessible units,119 common areas,
facilities, parking lots, walkways, and units;
• PHA’s policies and procedures for program management and employment for compliance with Section
504 requirements; and
116 See 24 CFR 5.110 and Notice PIH-2018-16, Regulatory Waivers, available at
https://www.hud.gov/sites/dfiles/PIH/documents/PIH-2018-16.pdf.
117 https://www.hud.gov/sites/documents/OLMSTEADGUIDNC060413.PDF.
118 See 24 CFR Part 8 Subpart D; 24 CFR 8.53(a), 8.54.
119 See 24 CFR 8.20, 8.22, 8.23; see also https://www.hud.gov/program_offices/fair_housing_equal_opp/physical_accessibility.
Fair Housing and Nondiscrimination Requirements 31
US Department of Housing and Urban Development April 2025
• Of all aspects of HCV program operations.
PHAs that employ fifteen or more persons are required to adopt grievance procedures120 that incorporate
appropriate due process standards and that provide for the prompt and equitable resolution of complaints
alleging any action prohibited under Section 504.121HUD Housing Choice Voucher Guidebook § 3.6 establishes that any Public Housing Authority (PHA) employing fifteen or more people must designate a specific employee as a Section 504 Coordinator, whose identity must be disclosed in written communications. This coordinator is responsible for overseeing compliance with Section 504 of the Rehabilitation Act across all aspects of PHA operations, including physical accessibility, program policies, marketing, and outreach. PHAs of this size must also maintain formal grievance procedures that allow for prompt, fair resolution of complaints about actions prohibited under Section 504. Even smaller PHAs with fewer than fifteen employees are required to ensure that Section 504 responsibilities are covered, though they are not required to designate a single named coordinator.
Plain English — not legal advice.
Under HUD Housing Choice Voucher Guidebook § 3.6, PHAs operating as housing providers with fifteen or more employees generally designate a Section 504 Coordinator and ensure that person's identity appears in written communications to applicants and participants. Compliant agencies typically extend the coordinator's oversight to all program operations, including physical accessibility of units and common areas, parking, walkways, and facilities, as well as internal policies and outreach activities. PHAs of the applicable size also maintain written grievance procedures that meet due process standards and allow for timely, equitable resolution of Section 504 complaints.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
HUD Housing Choice Voucher Guidebook § 3.6 gives housing applicants and program participants the right to know who the Section 504 Coordinator is at their PHA, as that information must appear in written communications. If a tenant or applicant believes a PHA has taken an action that violates Section 504—such as failing to provide an accessible unit or denying a reasonable accommodation—the grievance procedures that PHAs with fifteen or more employees are required to maintain offer a formal path for raising that concern. Tenants and applicants may also contact the U.S. Department of Housing and Urban Development or a local tenant-rights organization to learn more about available options under this provision.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated September 26, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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