HUD HCV Guidebook § 3.2.3
Reasonable Accommodation Requests (HUD HCV Guidebook)
Operative Text
Since individuals must be informed of their right to ask for reasonable accommodations, PHAs may create or adopt standardized forms or processes that clearly and simply ask for all the information. Asking the same questions of everyone is one way to assure consistency in the process. However, a person with disabilities is not required to use a specific form or format to request a reasonable accommodation. As a best practice, PHAs may create or adopt standardized forms or processes that clearly and simply ask for all the information in order to easily facilitate the accommodation requests. Asking the same questions of everyone is one way to assure consistency in the process; however, PHAs must understand that disabilities are varied and so PHAs must adapt to the methods of communication, provision and solicitation of information to and by individuals with disabilities. In some circumstances, PHAs may be required to engage in interactive process discussions to better understand a requested accommodation or to discuss what accommodations may be equally effective in meeting the individual’s disability-related need; however, the individual is not obligated to accept an alternative accommodation if it would not meet their disability-related need and a PHA must provide the requested accommodation if it is not an undue administrative and financial burden or a fundamental alteration to the essential nature of the program or activity. PHAs must accept requests either orally or in writing, and written requests do not have to be on the form provided by the PHA. A request cannot be refused simply because the person did not use the PHA’s standardized form or procedures. Regardless of how the request is made, it is important to consistently document the date and type of request in the tenant file or a separate tracking log, which must be made available to HUD upon request.87 As a best 86 Notice PIH 2011-31; HUD/DOJ Joint Statement on Reasonable Accommodations, 5/17/04. 87 24 CFR 8.55(c); 24 CFR 146.27; 2 CFR 200.337 Fair Housing and Nondiscrimination Requirements 22 US Department of Housing and Urban Development April 2025 practice, a separate tracking log, which can only be accessed by staff who need to know the information, may better ensure the confidentiality of individuals with disabilities. Another best practice includes providing the requester with a copy of the documentation relating to their request at the time it was made. Additionally, PHAs must use caution that such forms do not make illegal or unnecessary inquiries of individuals with disabilities beyond what is appropriate for a reasonable accommodation request. An individual with a disability may request a reasonable accommodation at any time during the application process, tenancy period, or eviction process.88 An individual with a disability may make as many reasonable accommodation requests as needed; there is no limit to the number of reasonable accommodation requests that may be granted to someone. A PHA may not deny a reasonable accommodation request on the grounds that the requester has made prior reasonable accommodation request(s). The need for an accommodation can come to the PHA’s attention in many ways other than a formal request. A PHA’s policies must be sufficient to provide reasonable accommodations throughout its programs, services, and activities regardless of a formal request being made. For example, a PHA may learn of the need for an accommodation in the course of looking into potential noncompliance with program requirements, and must work through the reasonable accommodation process before moving forward with any adverse action based on the potential noncompliance, as illustrated by the following scenario: a person misses two annual reexamination appointments, and when confronted with the possibility that their assistance could be terminated for failing to complete the annual reexamination process, the PHA learns that they could not keep their appointments due to hospitalization or other disability-related need. In this case, the PHA must not take any adverse action against the individual. The PHA engages in its reasonable accommodation process with the individual and determines it will provide the person another appointment date as a reasonable accommodation instead of simply moving forward with an adverse action.
Under HUD Housing Choice Voucher Guidebook § 3.2.3, Public Housing Authorities (PHAs) are required to accept reasonable accommodation requests from individuals with disabilities in any format — oral or written — and cannot reject a request simply because it was not submitted on a standardized form. PHAs must engage in an interactive process when needed, document all requests consistently, and refrain from taking adverse action against a person until the reasonable accommodation process has been completed. There is no cap on the number of reasonable accommodation requests a person may make, and a prior request history cannot be used as grounds for denial. The need for an accommodation may arise informally, and PHAs are obligated to recognize and respond to it regardless of whether a formal request was made.
Plain English — not legal advice.
Under HUD Housing Choice Voucher Guidebook § 3.2.3, compliant PHAs and property operators participating in the Housing Choice Voucher program generally maintain flexible intake processes that accept accommodation requests in any form — oral or written — and do not condition processing on the use of a specific form. Operators typically document the date and type of each request in a tenant file or a separate, confidential tracking log that is accessible only to staff with a need to know, and that log must be made available to HUD upon request. Before moving forward with any adverse action related to potential program noncompliance, operators generally pause to determine whether a disability-related need may be involved and work through the reasonable accommodation process first.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
Under HUD Housing Choice Voucher Guidebook § 3.2.3, individuals with disabilities participating in the Housing Choice Voucher program have the right to request a reasonable accommodation at any stage — including during the application process, tenancy, or even an eviction proceeding — and are not required to use any particular form or format to do so. There is no limit on the number of requests a person may make, and a PHA cannot deny a request solely because prior requests were made. If a PHA takes or threatens adverse action without first working through the reasonable accommodation process, that may constitute a violation of this provision; tenants can raise this as a defense, file a complaint with HUD, or consult a local tenant-rights or fair housing organization to understand available options.
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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