PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
GENERAL REQUIREMENTS
Project Owners with 15 or more employees must:
SECTION 504 OF THE REHABILITATION ACT OF 1973, AS AMENDED
#rampupbc
The Project Owner’s self-evaluation must be submitted prior to the Agency’s Commitment of Funds.
- a description of area examined and any problems identified; and - a description of modifications made and remedial steps taken.
SELF EVALUATION
In preparation of the self-evaluation, the Project Owner must consult with individuals with disabilities (handicaps) or organizations representing them.
Item 15 – Section 504 Self-Evaluation and Transition Plan
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
SECTION 504 of the REHABILITATION ACT OF 1973, AS AMENDED
NO OTHERWISE QUALIFIED INDIVIDUAL WITH HANDICAPS IN THE UNITED STATES, ... SHALL, SOLELY BY REASON OF HIS HANDICAP, BE EXCLUDED FROM THE PARTICIPATION IN, BE DENIED THE BENEFITS OF, OR BE SUBJECTED TO DISCRIMINATION UNDER ANY PROGRAM OR ACTIVITY RECEIVING FEDERAL FINANCIAL ASSISTANCE OR UNDER ANY PROGRAM OR ACTIVITY CONDUCTED BY ANY EXECUTIVE AGENCY ...
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3
CITATIONS: U.S.C. Section 794 24 C.F.R. Part 8
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
REASONABLE ACCOMMODATION
DEFINITION: AN ADJUSTMENT IN A FEDERALLY ASSISTED OR CONDUCTED PROGRAM OR ACTIVITY IN ORDER TO ACCOMMODATE THE KNOWN PHYSICAL OR MENTAL LIMITATIONS OF AN OTHERWISE QUALIFIED INDIVIDUAL WITH A HANDICAP.
1. It must be provided unless it:
a. Imposes an undue financial or administrative burden,as determined by b. It alters the fundamental nature of the program.
HUD,or
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Yes
Does s(he) meet program eligibility requirements?
Follow the regular application procedures.
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5
Yes
No
Reject application.
Would the accommodation result in:
a) Undue financial and
administrative burden; or
b) Fundamental alteration in the
nature of the program?
No
Yes
PROGRAM ELIGIBILITY AND SECTION 504
Is the applicant an “individual with handicap” as defined by Section 504?
Yes
No
No
Could s(he) meet eligibility requirements with any kind of accommodation?
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Process the application as for any other applicant.
Process the application and provide reasonable accommodation needed for eligibility.
Applicant must indicate that he/she will be obtaining those supportive services necessary to establish his/her eligibility. Recipient may inquire as to whether the applicant will supply the necessary accommodation. If no, applicant is ineligible. If yes, applicant is eligible
Provide any other reasonable accommodation necessary for program participation.
SECTION 504 REQUIRES:
PROGRAM ACCESSIBILITY FOR QUALIFIED PEOPLE WITH DISABILITIES
No qualified individual with handicaps shall, because a recipient’s facilities are inaccessible to or unusable by handicapped persons, be denied the benefits of, or be excluded from participation in or otherwise be subjected to discrimination in any program or activity receiving Federal financial assistance.
Section 504 requires:
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
TO AVOID DISCRIMINATING AGAINST INDIVIDUALS WITH DISABILITIES, RECIPIENTS AND FEDERAL OFFICES MUST PROVIDE:
A “QUALIFIED” INDIVIDUAL WITH HANDICAPS IS ANYONE WHO MEETS ALL THE ELIGIBILITY REQUIREMENTS OF THE PROGRAM OR ACTIVITY.
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE SECTION 504 SELF-EVALUATION GUIDE
1. Introduction
Section 504 of the Rehabilitation Act of 1973 provides that no qualified handicapped person shall, on the basis of handicap, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal assistance.
All recipients of federal HOME funds must be in compliance with Section 504 and the implementing regulations, 24 CFR Part 8. 24 CFR Part 8 requires that each recipient complete a self-evaluation of its “policies and practices and the effects thereof that do not meet the requirements of this Part”. Any policy and/or practice that does not meet the requirements of this Part, must be modified.
The purpose of this self-evaluation guide is to assist project owners in evaluating their project and business operations to determine whether they conform to the requirements of Section 504 and the regulations at 24 CFR Part 8. This guide provides only an example of how a self-evaluation can be performed. Project Owners are free to use this guide or other approaches for performing the self-evaluation.
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Designation of responsible employee
Project Owners employing fifteen or more employees must designate a Section 504 Coordinator
Adoption of grievance procedures
(24 CFR Part 8.53(a)). Project Owners employing fifteen or more employees must establish grievance procedures that provide for the submission and resolution of complaints from employees and program beneficiaries
(24 CFR Part 8.53(b)). Project Owners employing fifteen or more employees must take initial and continuing steps to notify beneficiaries, applicants, and employees that it does not discriminate on the basis of handicap. All such notifications must be effective for those with impaired vision or hearing (24 CFR Part 8.54(a)).
Public notification requirements
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CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Public notification requirements (continued)
Recruitment materials or publications containing general information that is available to development residents, applicants, and employees must contain an appropriate non- discrimination statement (24 CFR Part 8.54(b)). Project Owners must provide assurance that its project operates in compliance with Section 504 (24 CFR Part 8.50). Project Owners must consult with handicapped persons/organizations. (Centers for Independent Living, etc.)
Assurances required
Self-evaluation
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CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
The self-evaluation must cover the development’s policies, practices, problems identified, and remedial steps taken.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Self-evaluation (continued)
Project Owners employing fifteen or more persons must maintain on file the self-evaluation for three years after its completion (24 CFR Part 8.51(b)).
Transition Plan
A transition plan is required when structural changes to facilities are required, and it must include the following:
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CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
1. Identification of physical obstacles in facilities.
2. Identification of methods used to achieve accessibility.
3. Schedule for achieving accessibility.
4. Identification of responsible official.
5. Identification of persons or groups who assisted in the preparation of the plan. (24 CFR Part 8.24(d))
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Resident marketing and outreach must ensure that interested persons (including persons with impaired hearing or vision) can obtain information concerning the development.
The owner shall use telecommunication devices for deaf persons (TDDs) and make applications and leases available in braille or on audio tape for visually impaired applicants/ residents.
(24 CFR Part 8.6) When an accessible unit becomes vacant, the unit is offered, first to a current resident of the project with handicaps requiring the features of the vacant unit, or if no such resident exists, then second, to an eligible qualified applicant on the waiting list with a
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CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
handicap requiring the features of the vacant unit. When offering an accessible unit to an applicant without handicaps requiring the features of the unit, the owner/agent may require the applicant to agree (and may include this in the lease) to move to a non- accessible unit when available.
(24 CFR Part 8.27)
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CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Residential Units
B. Accessible Units
Number By Bedroom Size
_____ Eff./O BR _____ 1 BR _____ 2 BR _____ 3 BR _____ 4 BR _____ 5 BR
_____#WC _____#WC _____#WC _____#WC _____#WC _____#WC
_____#H/V _____#H/V _____#H/V _____#H/V _____#H/V _____#H/V
C. Adaptable Units
Number By Bedroom Size
_____ Eff./O BR _____ 1 BR _____ 2 BR _____ 3 BR _____ 4 BR _____ 5 BR
_____#WC _____#WC _____#WC _____#WC _____#WC _____#WC
_____#H/V _____#H/V _____#H/V _____#H/V _____#H/V _____#H/V
*WC - Wheelchair, H/V - Hearing/Vision
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Requirements
Compliance Status
Yes No N/A
Description
Modification
A. Total Number of Units ________
CHECKLIST OF FACILITY ACCESSIBILITY
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirements Parking Lots/Spaces
Compliance Status
Yes No N/A
Description
Modification
A. Reserved Spaces
Number (Total _____ Accessible _____) Resident (Total _____ Accessible _____) Visitor (Total _____ Accessible _____) Office (Total _____ Accessible _____)
Dimensions
Handrails/Handgrips
C. PassengerLoading/Unloading Spaces
CHECKLIST OF FACILITY ACCESSIBILITY
CHECKLIST OF FACILITY ACCESSIBILITY
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Parking Lots/Spaces (continued) Signage
Location
Requirements
Compliance Status
Yes No N/A
Description
Modification
Public Telephones
A. Signage
B. Clearfloorspace(wheelchairaccess) C. Reach
D. Height
E. Controls
F. Equipment
Drinking Fountains (Interior and Exterior) A. Location
B. Clearance
C. Height
D. Spouts E. Control
CHECKLIST OF FACILITY ACCESSIBILITY
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Elevators
A. Automatic
B. Location
C. Doors
D. Control Panel
E. Emergency communications
F. Floor identification
G. Lobby call buttons
H. Outside floor/direction indicators
I. Signage Toilet/Bathing Facilities
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Compliance Status
Requirements Yes No N/A Description Modification
CHECKLIST OF FACILITY ACCESSIBILITY
Compliance
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Toilet/Bathing Facilities (continued) 3. Lavatories/sinks/water closets 4. Tubs/showers
D. Lockers
1. Number
2. Height
3. Clear floor space
Picnic Areas
A. Tables and Benches
Requirements
Status
Yes No N/A
Description
Modification
1. Number accessible to wheelchairs 2. Location (adjacent to level paths) 3. Access to open space areas
4. Back and arm rests
B. Grills
1. Height of cooking surface
2. Location (adjacent to level paths)
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Picnic Areas (continued) C. TrashReceptacles
Requirements
Compliance Status
Yes No N/A
Description
Modification
1. Location (adjacent to level paths)
2. Safety and facility of equipment D. Picnic Shelters
1. Location (accessible by wide, firm path)
2. Located near accessible water fountains, trash receptacles, restrooms, parking, etc.
Trails
A. Surface
B. Dimensions C. Rails
D. Signage
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CHECKLIST OF FACILITY ACCESSIBILITY
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Play Areas
A. Equipment
1. Safe for handicapped persons B. AccesstoEquipment
1. Firm level paths
Requirements
Compliance Status
Yes No N/A
Description
Modification
2. Sufficient space between play equipment for wheelchair maneuvering
Game Areas
A. Accessible by firm and level paths
B. Accessiblepathsleadingtoandfromparking areas
C. Equipment 1. Heights
2. Dimensions
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CHECKLIST OF FACILITY ACCESSIBILITY
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirements Management Office Facilities
Compliance Status
Yes No N/A
Description
Modification
A. Access
B. Telephone(T.D.D.) C. Signage
D. Safety
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CHECKLIST OF FACILITY ACCESSIBILITY
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement Recruitment
Standards
Compliance Status
Yes No N/A
Description
Modification
Job announcements
The announcement process encompasses the following elements:
Interviews
Interviews must address the applicant’s qualifications for the position. Recipients must not make inquiries about an applicant’s handicap and its severity.
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Nondiscrimination statement on announcements;
CHECKLIST OF EMPLOYMENT REQUIREMENTS
Announcements must be posted in accessible areas;
Announcements must be effectively announced to individuals who have disabilities that impair their ability to communicate.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Personnel Actions Recruitment Selection Promotion
The criteria for processing personnel actions must not limit the eligibility of qualified handicapped employees.
Hiring Upgrading, etc.
Leave Administration
Leave of absence Sick/Annual
Policies for granting leave must not adversely affect qualified handicapped employees.
Return from leave of absence
Training
Internships Apprenticeships
Training programs must be administered in a manner that allows equal participation by qualified handicapped employees.
On-the-job training, etc.
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CHECKLIST OF EMPLOYMENT REQUIREMENTS
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement Testing
Standards
Compliance Status
Yes No N/A
Description
Modification
Medical Examination/ Questionnaires
Pre-employment medical examinations are permissible only after conditional employment offers.
Social/Recreational Program
Social/recreational programs sponsored by the owner must be accessible to handicapped employees.
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CHECKLIST OF EMPLOYMENT REQUIREMENTS
Tests and other criterion must measure essential job requirements only.
Tests must be job-related and nondiscriminatory towards persons with impaired communications abilities.
Medical history questionnaires must not request information as to the nature or severity of an applicant’s handicap.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement Fringe Benefits
Standards
Compliance Status
Yes No N/A
Description
Modification
Collective Bargaining Agreements
Terms and practices of collective bargaining agreements must not contain provisions that limit the participation of qualified handicapped employees.
Wage and Salary Administration
Employees with disabilities must not be offered different rates of compensation solely on the basis of handicap.
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CHECKLIST OF EMPLOYMENT REQUIREMENTS
Handicapped employees must be given the same employee benefits as nonhandicapped employees.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Self-Evaluation of Project
NameofDevelopment: __________________________________________________ Date of this portion of the self-evaluation: ___________________________________ Names of persons evaluating this project and their organizational affiliation:
1. ___________________________________________________________________
2. ___________________________________________________________________ 6
3. ___________________________________________________________________
4. ___________________________________________________________________ 5. ___________________________________________________________________
Requirements
Is the project accessible to:
- learning impaired persons - mobility impaired persons - visually impaired persons - hearing impaired persons
Compliance Yes No
Describe current accessibility and any deficiencies
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
TRANSITION PLAN
Project Name: ______________________________
Project Facilities Needing Modification:
Scheduled for Completion
Completed
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
SAMPLE INITIAL NOTICE
POLICY OF NONDISCRIMINATION ON THE BASIS OF HANDICAPPED STATUS
(Name of Project Owner) does not discriminate on the basis of handicapped status in the admission of access to, or treatment or employment for (Name of Project).
(Name) __________________________________ (Address) _________________________________ __________________________________________
City
Telephone Number ( (
State Zip
) ______________________ Voice ) ______________________ TDD
has been designated to coordinate compliance with the nondiscrimination requirements contained in the Department of Housing and Urban Development’s (HUD) regulations implementing Section 504 (24 CFR Part 8, dated June 2, 1988).
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Item 15 – Section 504 Self-Evaluation and Transition Plan
GENERAL REQUIREMENTS
Project Owners with 15 or more employees must:
SECTION 504 OF THE REHABILITATION ACT OF 1973, AS AMENDED
#rampupbc
The Project Owner’s self-evaluation must be submitted prior to the Agency’s Commitment of Funds.
- Designate a person to oversee its Section 504 Compliance efforts.
- Keep on file for at least three years:
- a description of area examined and any problems identified; and - a description of modifications made and remedial steps taken.
SELF EVALUATION
In preparation of the self-evaluation, the Project Owner must consult with individuals with disabilities (handicaps) or organizations representing them.
- Adopt and implement a grievance procedure for timely resolution of discrimination complaints.
- Make initial and continuing efforts to notify applicants, tenants, and employees that it does not discriminate on the basis of
- Evaluation of current policies and practices relative to the Section 504 regulations.
- Modifications of any policies and practices that do not meet the Section 504 requirements.
- Corrective action to remedy any discrimination found. AREAS TO BE EVALUATED
- Buildings or facilities for physical accessibility
- Program outreach and communication
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Item 15 – Section 504 Self-Evaluation and Transition Plan
- Eligibility and admission criteria and practice
- Distribution and occupancy policy and practice
- Percentage of accessible units
- Employment (including pre-employment)
- Complaint processing procedures
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
SECTION 504 of the REHABILITATION ACT OF 1973, AS AMENDED
NO OTHERWISE QUALIFIED INDIVIDUAL WITH HANDICAPS IN THE UNITED STATES, ... SHALL, SOLELY BY REASON OF HIS HANDICAP, BE EXCLUDED FROM THE PARTICIPATION IN, BE DENIED THE BENEFITS OF, OR BE SUBJECTED TO DISCRIMINATION UNDER ANY PROGRAM OR ACTIVITY RECEIVING FEDERAL FINANCIAL ASSISTANCE OR UNDER ANY PROGRAM OR ACTIVITY CONDUCTED BY ANY EXECUTIVE AGENCY ...
Rev. 7/09
3
CITATIONS: U.S.C. Section 794 24 C.F.R. Part 8
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
REASONABLE ACCOMMODATION
DEFINITION: AN ADJUSTMENT IN A FEDERALLY ASSISTED OR CONDUCTED PROGRAM OR ACTIVITY IN ORDER TO ACCOMMODATE THE KNOWN PHYSICAL OR MENTAL LIMITATIONS OF AN OTHERWISE QUALIFIED INDIVIDUAL WITH A HANDICAP.
1. It must be provided unless it:
a. Imposes an undue financial or administrative burden,as determined by b. It alters the fundamental nature of the program.
HUD,or
- It must be equally effective.
- It should not be of a personal nature.
- It should be provided and applied on a case-by-case basis.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Yes
Does s(he) meet program eligibility requirements?
Follow the regular application procedures.
Rev. 7/09
5
Yes
No
Reject application.
Would the accommodation result in:
a) Undue financial and
administrative burden; or
b) Fundamental alteration in the
nature of the program?
No
Yes
PROGRAM ELIGIBILITY AND SECTION 504
Is the applicant an “individual with handicap” as defined by Section 504?
Yes
No
No
Could s(he) meet eligibility requirements with any kind of accommodation?
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Process the application as for any other applicant.
Process the application and provide reasonable accommodation needed for eligibility.
Applicant must indicate that he/she will be obtaining those supportive services necessary to establish his/her eligibility. Recipient may inquire as to whether the applicant will supply the necessary accommodation. If no, applicant is ineligible. If yes, applicant is eligible
Provide any other reasonable accommodation necessary for program participation.
SECTION 504 REQUIRES:
PROGRAM ACCESSIBILITY FOR QUALIFIED PEOPLE WITH DISABILITIES
No qualified individual with handicaps shall, because a recipient’s facilities are inaccessible to or unusable by handicapped persons, be denied the benefits of, or be excluded from participation in or otherwise be subjected to discrimination in any program or activity receiving Federal financial assistance.
Section 504 requires:
- Equal opportunity for participation;
- Equal opportunity to receive program benefits and services;
- The most integrated setting appropriate;
- Equally effective benefits;
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
- Physical accessibility; and
- Reasonable accommodation.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
- Physically accessible sites - Programs, activities, and workplaces must be physically accessible;
- Administrative accommodation - Alternatives or modifications should be made as needed.
TO AVOID DISCRIMINATING AGAINST INDIVIDUALS WITH DISABILITIES, RECIPIENTS AND FEDERAL OFFICES MUST PROVIDE:
- Program accessibility - No one may be denied access solely by reason of disability;
- Program benefits - Benefits may not be denied solely because of disability;
- Most integrated setting appropriate - Judgment should be based on individual need;
- No support to discrimination - Provide no assistance or support to entities that discriminate;
- Opportunity to serve on boards - Board membership must be open to all qualified persons;
- Equal Rights and privileges - Disabled individuals may not be denied equal treatment;
A “QUALIFIED” INDIVIDUAL WITH HANDICAPS IS ANYONE WHO MEETS ALL THE ELIGIBILITY REQUIREMENTS OF THE PROGRAM OR ACTIVITY.
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE SECTION 504 SELF-EVALUATION GUIDE
1. Introduction
Section 504 of the Rehabilitation Act of 1973 provides that no qualified handicapped person shall, on the basis of handicap, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal assistance.
All recipients of federal HOME funds must be in compliance with Section 504 and the implementing regulations, 24 CFR Part 8. 24 CFR Part 8 requires that each recipient complete a self-evaluation of its “policies and practices and the effects thereof that do not meet the requirements of this Part”. Any policy and/or practice that does not meet the requirements of this Part, must be modified.
The purpose of this self-evaluation guide is to assist project owners in evaluating their project and business operations to determine whether they conform to the requirements of Section 504 and the regulations at 24 CFR Part 8. This guide provides only an example of how a self-evaluation can be performed. Project Owners are free to use this guide or other approaches for performing the self-evaluation.
Rev. 7/09 9
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Designation of responsible employee
Project Owners employing fifteen or more employees must designate a Section 504 Coordinator
Adoption of grievance procedures
(24 CFR Part 8.53(a)). Project Owners employing fifteen or more employees must establish grievance procedures that provide for the submission and resolution of complaints from employees and program beneficiaries
(24 CFR Part 8.53(b)). Project Owners employing fifteen or more employees must take initial and continuing steps to notify beneficiaries, applicants, and employees that it does not discriminate on the basis of handicap. All such notifications must be effective for those with impaired vision or hearing (24 CFR Part 8.54(a)).
Public notification requirements
Rev. 7/09
10
CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Public notification requirements (continued)
Recruitment materials or publications containing general information that is available to development residents, applicants, and employees must contain an appropriate non- discrimination statement (24 CFR Part 8.54(b)). Project Owners must provide assurance that its project operates in compliance with Section 504 (24 CFR Part 8.50). Project Owners must consult with handicapped persons/organizations. (Centers for Independent Living, etc.)
Assurances required
Self-evaluation
Rev. 7/09
11
CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
The self-evaluation must cover the development’s policies, practices, problems identified, and remedial steps taken.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Self-evaluation (continued)
Project Owners employing fifteen or more persons must maintain on file the self-evaluation for three years after its completion (24 CFR Part 8.51(b)).
Transition Plan
A transition plan is required when structural changes to facilities are required, and it must include the following:
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12
CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
1. Identification of physical obstacles in facilities.
2. Identification of methods used to achieve accessibility.
3. Schedule for achieving accessibility.
4. Identification of responsible official.
5. Identification of persons or groups who assisted in the preparation of the plan. (24 CFR Part 8.24(d))
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Resident marketing and outreach must ensure that interested persons (including persons with impaired hearing or vision) can obtain information concerning the development.
The owner shall use telecommunication devices for deaf persons (TDDs) and make applications and leases available in braille or on audio tape for visually impaired applicants/ residents.
(24 CFR Part 8.6) When an accessible unit becomes vacant, the unit is offered, first to a current resident of the project with handicaps requiring the features of the vacant unit, or if no such resident exists, then second, to an eligible qualified applicant on the waiting list with a
Rev. 7/09
13
CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
handicap requiring the features of the vacant unit. When offering an accessible unit to an applicant without handicaps requiring the features of the unit, the owner/agent may require the applicant to agree (and may include this in the lease) to move to a non- accessible unit when available.
(24 CFR Part 8.27)
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14
CHECKLIST OF ADMINISTRATIVE REQUIREMENTS
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Residential Units
B. Accessible Units
Number By Bedroom Size
_____ Eff./O BR _____ 1 BR _____ 2 BR _____ 3 BR _____ 4 BR _____ 5 BR
_____#WC _____#WC _____#WC _____#WC _____#WC _____#WC
_____#H/V _____#H/V _____#H/V _____#H/V _____#H/V _____#H/V
C. Adaptable Units
Number By Bedroom Size
_____ Eff./O BR _____ 1 BR _____ 2 BR _____ 3 BR _____ 4 BR _____ 5 BR
_____#WC _____#WC _____#WC _____#WC _____#WC _____#WC
_____#H/V _____#H/V _____#H/V _____#H/V _____#H/V _____#H/V
*WC - Wheelchair, H/V - Hearing/Vision
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Requirements
Compliance Status
Yes No N/A
Description
Modification
A. Total Number of Units ________
CHECKLIST OF FACILITY ACCESSIBILITY
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirements Parking Lots/Spaces
Compliance Status
Yes No N/A
Description
Modification
A. Reserved Spaces
Number (Total _____ Accessible _____) Resident (Total _____ Accessible _____) Visitor (Total _____ Accessible _____) Office (Total _____ Accessible _____)
- Location (in relation to facility)
- Vehicle access clearance
- Signage
Dimensions
Handrails/Handgrips
C. PassengerLoading/Unloading Spaces
CHECKLIST OF FACILITY ACCESSIBILITY
CHECKLIST OF FACILITY ACCESSIBILITY
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Parking Lots/Spaces (continued) Signage
Location
Requirements
Compliance Status
Yes No N/A
Description
Modification
Public Telephones
A. Signage
B. Clearfloorspace(wheelchairaccess) C. Reach
D. Height
E. Controls
F. Equipment
Drinking Fountains (Interior and Exterior) A. Location
B. Clearance
C. Height
D. Spouts E. Control
CHECKLIST OF FACILITY ACCESSIBILITY
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Elevators
A. Automatic
B. Location
C. Doors
D. Control Panel
E. Emergency communications
F. Floor identification
G. Lobby call buttons
H. Outside floor/direction indicators
I. Signage Toilet/Bathing Facilities
- Number (according to gender)
- Location/Signage
- Doors/Fixtures/Dispensers
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Compliance Status
Requirements Yes No N/A Description Modification
CHECKLIST OF FACILITY ACCESSIBILITY
Compliance
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Toilet/Bathing Facilities (continued) 3. Lavatories/sinks/water closets 4. Tubs/showers
D. Lockers
1. Number
2. Height
3. Clear floor space
Picnic Areas
A. Tables and Benches
Requirements
Status
Yes No N/A
Description
Modification
1. Number accessible to wheelchairs 2. Location (adjacent to level paths) 3. Access to open space areas
4. Back and arm rests
B. Grills
1. Height of cooking surface
2. Location (adjacent to level paths)
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Picnic Areas (continued) C. TrashReceptacles
Requirements
Compliance Status
Yes No N/A
Description
Modification
1. Location (adjacent to level paths)
2. Safety and facility of equipment D. Picnic Shelters
1. Location (accessible by wide, firm path)
2. Located near accessible water fountains, trash receptacles, restrooms, parking, etc.
Trails
A. Surface
B. Dimensions C. Rails
D. Signage
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CHECKLIST OF FACILITY ACCESSIBILITY
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Play Areas
A. Equipment
1. Safe for handicapped persons B. AccesstoEquipment
1. Firm level paths
Requirements
Compliance Status
Yes No N/A
Description
Modification
2. Sufficient space between play equipment for wheelchair maneuvering
Game Areas
A. Accessible by firm and level paths
B. Accessiblepathsleadingtoandfromparking areas
C. Equipment 1. Heights
2. Dimensions
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CHECKLIST OF FACILITY ACCESSIBILITY
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirements Management Office Facilities
Compliance Status
Yes No N/A
Description
Modification
A. Access
B. Telephone(T.D.D.) C. Signage
D. Safety
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CHECKLIST OF FACILITY ACCESSIBILITY
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement Recruitment
Standards
Compliance Status
Yes No N/A
Description
Modification
Job announcements
The announcement process encompasses the following elements:
Interviews
Interviews must address the applicant’s qualifications for the position. Recipients must not make inquiries about an applicant’s handicap and its severity.
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Nondiscrimination statement on announcements;
CHECKLIST OF EMPLOYMENT REQUIREMENTS
Announcements must be posted in accessible areas;
Announcements must be effectively announced to individuals who have disabilities that impair their ability to communicate.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement
Standards
Compliance Status
Yes No N/A
Description
Modification
Personnel Actions Recruitment Selection Promotion
The criteria for processing personnel actions must not limit the eligibility of qualified handicapped employees.
Hiring Upgrading, etc.
Leave Administration
Leave of absence Sick/Annual
Policies for granting leave must not adversely affect qualified handicapped employees.
Return from leave of absence
Training
Internships Apprenticeships
Training programs must be administered in a manner that allows equal participation by qualified handicapped employees.
On-the-job training, etc.
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CHECKLIST OF EMPLOYMENT REQUIREMENTS
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement Testing
Standards
Compliance Status
Yes No N/A
Description
Modification
Medical Examination/ Questionnaires
Pre-employment medical examinations are permissible only after conditional employment offers.
Social/Recreational Program
Social/recreational programs sponsored by the owner must be accessible to handicapped employees.
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CHECKLIST OF EMPLOYMENT REQUIREMENTS
Tests and other criterion must measure essential job requirements only.
Tests must be job-related and nondiscriminatory towards persons with impaired communications abilities.
Medical history questionnaires must not request information as to the nature or severity of an applicant’s handicap.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Requirement Fringe Benefits
Standards
Compliance Status
Yes No N/A
Description
Modification
Collective Bargaining Agreements
Terms and practices of collective bargaining agreements must not contain provisions that limit the participation of qualified handicapped employees.
Wage and Salary Administration
Employees with disabilities must not be offered different rates of compensation solely on the basis of handicap.
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CHECKLIST OF EMPLOYMENT REQUIREMENTS
Handicapped employees must be given the same employee benefits as nonhandicapped employees.
PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
Self-Evaluation of Project
NameofDevelopment: __________________________________________________ Date of this portion of the self-evaluation: ___________________________________ Names of persons evaluating this project and their organizational affiliation:
1. ___________________________________________________________________
2. ___________________________________________________________________ 6
3. ___________________________________________________________________
4. ___________________________________________________________________ 5. ___________________________________________________________________
Requirements
Is the project accessible to:
- learning impaired persons - mobility impaired persons - visually impaired persons - hearing impaired persons
Compliance Yes No
Describe current accessibility and any deficiencies
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
TRANSITION PLAN
Project Name: ______________________________
Project Facilities Needing Modification:
Scheduled for Completion
Completed
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PHFA 2009 Commitment Processing Manual
Item 15 – Section 504 Self-Evaluation and Transition Plan
SAMPLE INITIAL NOTICE
POLICY OF NONDISCRIMINATION ON THE BASIS OF HANDICAPPED STATUS
(Name of Project Owner) does not discriminate on the basis of handicapped status in the admission of access to, or treatment or employment for (Name of Project).
(Name) __________________________________ (Address) _________________________________ __________________________________________
City
Telephone Number ( (
State Zip
) ______________________ Voice ) ______________________ TDD
has been designated to coordinate compliance with the nondiscrimination requirements contained in the Department of Housing and Urban Development’s (HUD) regulations implementing Section 504 (24 CFR Part 8, dated June 2, 1988).
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