HUD HCV Guidebook § 3.6

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 504.121