HUD Handbook 4350.3 § 2-42
Reasonable Accommodations – Physical Alterations (HUD Occupancy Handbook 4350.3 REV-1 CHG-4)
Operative Text
A. Generally, owners subject to Section 504 requirements must make and pay for
structural modifications to dwelling units and common areas when needed as a
reasonable accommodation based on a request by a tenant or applicant with a
disability
NOTE: Alterations and structural changes must be made in conformance with
paragraph 2-36 A, Building Standards.
B. If the owner provides a reasonable accommodation by making a requested
structural modification to a unit, this does not mean that the unit can
automatically be counted as a fully accessible unit that meets the UFAS
standard, unless the modifications made by the owner actually bring the unit into
compliance with that standard.
Example – When Owners Must Make Reasonable Accommodations
An owner has a policy of updating its waiting list by sending out letters to applicants to see if they are
still interested in being on the waiting list. If a person does not respond within a certain amount of time,
the owner removes the individual from the waiting list. Because of an individual’s disability, he is
unable to understand the nature of this communication and therefore does not respond to the letter. If
requested, the owner would have to reinstate the person to the original place on the waiting list as a
reasonable accommodation to that individual’s disability.
An owner that does not allow residents to have animals must modify the property’s policies and allow a
tenant with a disability to have an assistance animal if the animal is needed as a reasonable
accommodation. (See paragraphs 2-44, **3-29** and 4-24 B for more information about assistance
animals as a reasonable accommodation.)
An owner has a policy of only sending rent notices and other documents to tenants. An applicant with a
disability that periodically results in temporary memory loss requests as a reasonable accommodation
that a copy of all rent notices and requests for information also be sent to a relative who lives in the
community. The owner should modify this policy and send the notices to the designated individual in
order to give the resident an equal opportunity to use her dwelling and comply with her lease
obligations.
An owner requires tenants to pay rent by personal check. One resident has a disability and is unable to
manage a personal checking account. The owner must allow that resident’s request for an
accommodation to pay rent in cash or by money order, as this is a reasonable adjustment to the
property’s procedures that will allow this resident to have an equal opportunity to participate in the
housing program.
Example – Requests for Reasonable Accommodations or Housing Adjustments
An applicant who is hearing impaired has been determined to be otherwise qualified under program
requirements and the owner’s tenant selection plan. The applicant asks that her unit be fitted with a
visual smoke detector. The owner must accommodate the request unless it would result in undue
financial and administrative burden. This limitation applies to all of the examples.
An individual with a mobility impairment requests that grab bars be installed in the bathroom.
A visually impaired tenant requests a name plate/unit number in Braille on mailbox.
A hearing-impaired tenant requests visual intercom to know when guests have arrived and to receive
notice that he has messages at the office. If owner already provides some type of intercom service to
all tenants, he must accommodate this request. However, if the owner provides no such service, he
can deny the request if he determines that it would represent a support service not provided by the
project and providing this request would result in a fundamental alteration of the program.Under HUD Handbook 4350.3 REV-1 CHG-4 § 2-42, housing owners covered by Section 504 of the Rehabilitation Act are generally required to fund and carry out structural modifications to dwelling units and common areas when a person with a disability requests such changes as a reasonable accommodation. The rule also covers non-structural policy adjustments — such as allowing assistance animals, changing how rent is paid, or sending notices to a designated third party — when those adjustments give a person with a disability an equal opportunity to use and enjoy their housing. An owner may deny a request only if granting it would impose an undue financial and administrative burden or constitute a fundamental alteration of the program.
Plain English — not legal advice.
Owners subject to Section 504 requirements under HUD Handbook 4350.3 REV-1 CHG-4 § 2-42 generally bear the cost of structural modifications requested as reasonable accommodations, and all alterations must conform to the building standards outlined in paragraph 2-36 A. Compliant operators typically maintain a documented process for receiving, evaluating, and responding to accommodation requests — covering both physical modifications (such as grab bars or visual smoke detectors) and policy adjustments (such as alternative rent-payment methods or third-party notice arrangements). Operators also keep in mind that completing a structural modification does not automatically classify a unit as fully UFAS-accessible unless the work actually brings the unit into full compliance with that standard.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
Under HUD Handbook 4350.3 REV-1 CHG-4 § 2-42, tenants and applicants with disabilities at Section 504-covered properties have the right to request both physical modifications to their unit or common areas and adjustments to property policies, with the owner generally responsible for the cost of structural changes. If an owner denies or ignores a reasonable accommodation request, tenants may have the option of filing a complaint with the U.S. Department of Housing and Urban Development, raising the denial as a defense in relevant proceedings, or reaching out to a local tenant-rights or disability-rights organization for guidance. Keeping written records of any accommodation request and the owner's response can be important when pursuing any of these paths.
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 30, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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