HUD HCV Guidebook § 9.2
Reasonable Accommodation and Insufficient Funding (HUD HCV Guidebook)
Operative Text
In cases where a PHA determines it has insufficient funding to allow a move (provided that all of HUD
requirements are met; see Section 3.3 for more information) the PHA must consider a request for a
reasonable accommodation. A PHA must110 grant a reasonable accommodation request unless it constitutes
an undue financial and administrative burden, a fundamental alteration to the program, or results in a direct
threat that cannot be reduced or eliminated by another reasonable accommodation. Such determination is
subject to review by HUD.
108
24 CFR § 8.33; PIH Notice 2016-09 (3)(a)
109
24 CFR § 8.33; PIH Notice 2016-09 (3)(a)
110
24 CFR § 8.33; PIH Notice 2016-09 (3)(a)
Moves and Portability 30Under HUD Housing Choice Voucher Guidebook § 9.2, when a Public Housing Authority (PHA) determines it lacks sufficient funding to approve a participant's move, it is still required to consider any request for a reasonable accommodation related to a disability. The PHA must approve such a request unless doing so would impose an undue financial or administrative burden, fundamentally alter the Housing Choice Voucher program, or result in a direct threat that cannot be mitigated by another accommodation. Any PHA determination on this matter is subject to review by HUD.
Plain English — not legal advice.
Although § 9.2 of the HUD Housing Choice Voucher Guidebook primarily governs PHA obligations, property owners participating in the program should be aware that a voucher holder's ability to move—even under funding constraints—may be protected by reasonable accommodation requirements. Compliant operators generally maintain familiarity with the reasonable accommodation process so they can respond appropriately if a tenant's move request intersects with disability-related needs. Understanding that HUD retains review authority over PHA determinations under this provision helps operators anticipate how accommodation disputes may be resolved.
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 § 9.2, if a PHA cites insufficient funding as a reason to deny a move, a tenant with a disability has the right to formally request a reasonable accommodation, and the PHA is generally required to grant it unless specific narrow exceptions apply. Tenants can submit a written reasonable accommodation request to their PHA and, if dissatisfied with the outcome, may seek review through HUD, since § 9.2 explicitly makes such determinations subject to HUD oversight. Tenant-rights organizations and fair housing agencies can help individuals understand the accommodation request process and available review 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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