Monitoring for Section 504 Compliance

2014 Annual Report

Grantee Name:

Grant Number(s):

  1. What is the current a disabled/handicap population in the housing jurisdiction, geographic area, or population affected or encountered?
  2. What is the frequency of encounters with disabled/handicappersons? Please check a box. If other, please check the box and describe below.

Daily Weekly Monthly Other (Specify)

  1. What is the nature and importance of activities to disabled/handicap persons? Important: Determine whether denial or delay of access to services or information could have serious implications to the disabled/handicap customer. Please describe below.
  1. Number of Reasonable Accommodations(non-structural changes, exception, or adjustment to a rule, policy, practice, or service) request(s) to non-housing facilities and programs. Insert a number or “No Requests made”
  1. Methods of Reasonable Accommodation conducted for request(s)Please check all boxes that apply. If other, please check the box and describe below.

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Use of Telecommunications Device for the Deaf (TDD)/ Teletypewriter (TTY) devices
Qualified sign-language interpreters and oral interpreters
Readers / Tapes/Recordings / Note-takers
Large print / Braille materials / Closed-captioned video
Flexible work scheduling / Modification of employment policies / No Activity
Other (Specify Below)
  1. Indicate the availability of resources for reasonable accommodation, including technological advances and sources of additional resources, and the costs imposed.

Resources (Describe) / Cost ($)
  1. Does staff know and understand Section 504 compliance and how to implement? - e.g.Have employees been trained on your policies and procedures regarding qualified persons with disabilities? Please check a box and explain below your answer below.

Yes No

If yes, please indicate how and how often. If no, please explain why not.

  1. Identify sources for assistance available and viable- Describe the tool or method used being used to collect data on participant satisfaction with program accessibility services.
  1. Have there been any complaints filed based on disability discrimination?

Yes No

If yes, please describe below, including number of complaints, nature of complaints, and resolution of complaints.

  1. How many Section 504 training/workshops/meetings/conferences have local government staff attendedin the last year for technical assistance? (Insert a number)
  1. How many Section 504 training/workshops/meetings/conferences have local government staff conducted in the last year for public outreach? (Insert a number)

Monitoring for Section 504 Compliance

2014 Annual Report Instructions

This report should clearly describe the reasonable steps and due diligence to assist the qualified persons with disabilities (24 CFR 8) within the Community Development Block Grant (CDBG), CDBG-Recovery (CDBG-R) and/or Neighborhood Stabilization (NSP) programs. This report should clearly describe if there were any limitations to assist the disabled/handicap population and why. Complete this report by local government, not by grant number, but indicate what grant numbers are active by the grantee.

BELOW YOU WILL FIND SOME OPTIONS AND SUGGESTIONS TO ENSURE THE DISABLED POPULATION IS ASSISTED WHEN IS REQUIRED

The availability of resources, including technological advances and sources of additional resources, and the costs imposed:

  • Hiring/training staff to act as interpreters and translators
  • Sharing information through industry groups, telephonic and video conferencing interpretation services
  • Pooling resources and standardizing documents to reduce needs
  • Using qualified translators and interpreters to ensure that inaccurate interpretations do not cause delay or other costs
  • Centralizing interpreter and translator services to achieve economies of scale or using qualified community volunteers in a formalized manner
  • Smaller entities with more limited budgets are not expected to provide the same level of language services as larger entities with larger budgets
  • Utilizing advances in technology
  • Sharing assistance materials and services among and between other recipients, advocacy groups or federal grant agencies; and using reasonable business practices

Using Oral Interpretation and Written Translation Services

  • Ensuring Competence of the Interpreters - When using interpreters, ensure that they:

–Demonstrate proficiency and the ability to communicate information accurately and appropriately

–Have knowledge of specialized terms or concepts of the program or activity

–Understand and follow confidentiality and impartiality rules to the same extent the employee for whom they are interpreting and/or to the extent the employee's position requires

–Understand and adhere to their role as interpreters without deviating into a role as a counselor, legal advisor, etc.

–Allow you to provide service in a timely manner

  • Hiring Staff Interpreters
  • Contracting for Interpreters
  • Using Telephone Interpreter Lines
  • Using Community Volunteers
  • Using Family Members or Friends - You should not plan to rely on a disabled person’s family members, friends, or other informal interpreters to provide language assistance services to important programs and activities.However, where disabled persons so desire, they should be permitted to use, at their own expense, an interpreter of their own choosing in place of, or as a supplement to, the free language services you offer.
  • Determine documents to be translated- Determine which documents are “vital,” such as:

–Applications, consent forms and complaint forms

–Tests

–Letters containing important information regarding participation in a program or activity

–List of partners and services provided

–Notices pertaining to reduction, denial or termination of services or benefits and of the right to appeal such actions

–Notices that require a response from beneficiaries

–Information on the right to file complaints of discrimination

–Information on the provision of services to individuals with disabilities

–Notices advising persons of the availability of free assistance

–Explanation of how to file complaint and complaint process

–Other outreach materials

  • Examples of practices that may violate Section 504 are:

–Providing services to disabled persons that are more limited in scope or are lower in quality than those provided to other persons

–Subjecting disabled persons to unreasonable delays in the delivery of services

–Limiting participation in a program or activity on the basis of disability

–Providing services to disabled persons that are not as effective as those provided tothose who are proficient in English, or

–Failing to inform disabled persons of the right to receive free interpreter servicesand/or requiring disabled persons to provide their own interpreter

Definitions

Accessible - Any site, building, facility or portion thereof that is approachable, functional, and can be used by people with disabilities independently, safely, and with dignity.

Qualified person with disabilities - Any person who has a physical or mental disability that substantially limits one or more major life activities; has a record of such an impairment; or is regarded as having such an impairment [24 CFR 8.3].

Reasonable Accommodation - A change, exception, adaptation or modification to a policy, practice, program, service, or workplace which will allow a qualified person with a disability to have an equal opportunity to participate fully in a program, take advantage of a service, perform a job, enjoy a dwelling, public, or common space

Please visit United States Department of Housing and Urban Development (HUD)’s website for frequently asked questions about Section 504 compliance.

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