HUD Handbook 4350.3 § 2-34

A.       The Section 504 regulations required recipients of federal financial assistance to
                  conduct a self-evaluation of their policies and practices to determine if they were
                  consistent with the requirements of this section of the Rehabilitation Act of 1973.
                  The regulations required owners to have completed their self-evaluations no later
                  than July 11, 1989.

         B.       The Section 504 regulations establish owners’ ongoing responsibility to operate
                  their programs so that they are, when viewed in their entirety, accessible to and
                  usable by persons with disabilities [24 CFR 8.24]. Although the regulatory
                  deadlines for completing self-evaluations have now passed, the self-evaluation
                  continues to be an excellent management tool for ensuring that the owner’s
                  current policies and procedures comply with the requirements of Section 504.

         C.       HUD strongly recommends that owners periodically update their self-evaluations
                  as one way to help ensure compliance. Updates are particularly important if
                  there have been alterations to units or units have been added or demolished.
                  When updating the self-evaluation and implementing its results, owners should
                  take the following steps.

                  1.       Evaluate current policies and practices, and analyze them to determine if
                           they adversely affect the full participation of individuals with disabilities in
                           the owner’s programs, activities, and services.

                           NOTE: Information on technical resources regarding Section 504
                           accessibility requirements can be found in paragraph 2-26.

                                                                Nondiscrimination and Promote Accessibility

2.     Modify any policies and practices that are not or may not be in
                        compliance with Section 504.

                 3.     Take appropriate corrective steps to remedy those policies and practices
                        that are either discriminatory or have a discriminatory effect.

                 4.     Document the process and activities used to update the self-evaluation.

                 NOTE: Under Section 504 regulations, owners were required to complete one
                 self-evaluation. HUD does not review or approve any subsequent self-
                 evaluations that owners may wish to complete.

       D.        Owners, managing entities, or projects employing 15 or more persons were
                 required to maintain on file, make available for public inspection, and provide to
                 the Office of Fair Housing and Equal Opportunity upon request the information
                 below for at least three years following completion of the evaluation:

                 1.     A list of the interested persons consulted;

                 2.     A description of areas of the project the owner examined and any
                        problems identified; and

                 3.     A description of any modifications the owner made and of any remedial
                        steps taken.

       E.        Section 504 also required owners to develop a transition plan for completing
                 structural changes needed to make the property readily accessible to and usable
                 to persons with disabilities by July 11,1991. Owners were required to prepare
                 the plan by January 11, 1989.

                 1.     Although the deadlines for preparing and implementing the plan have
                        passed, transition plans are an excellent management tool for ensuring
                        continued compliance when structural alterations to a property (e.g.,
                        building additional units) require further action to continue meeting the
                        physical accessibility requirements of Section 504.

                 2.     Owners were expected to develop the plan with the assistance of
                        interested persons. HUD recommends that transition plans include the
                        following items that were originally required for inclusion in these plans.

                        a.      Identify physical obstacles in the property that limit accessibility to
                                persons with disabilities.

                        b.      Describe in detail the methods that will be used to make the
                                project accessible.

Nondiscrimination and Promote Accessibility

c.       Specify the schedule for taking steps to achieve compliance with
                                    the requirements for structural changes, including making a
                                    minimum of 5% of the units accessible to persons with mobility
                                    impairments. If the time period covered by the transition plan is
                                    longer than one year, the plan must identify steps that will be
                                    taken during each year of the transition period.

                           d.       Indicate the person (and his/her title) responsible for implementing
                                    the plan.

                           e.       Identify persons or groups who helped the owner prepare the
                                    plan.

Subsection 3: Physical Accessibility