Reasonable accommodation requests are where fair housing law meets daily operations — and mishandling them is one of the most common sources of HUD complaints. The process protects residents; following it protects you.
What counts as a request
There's no magic form. Any communication — verbal, written, from the resident or someone acting for them — that connects a disability to a needed change in rules, policies, or services is a request. "I need a live-in aide" said at the front desk counts. Requiring your official form before processing is itself a violation; you can offer the form, not demand it.
What you can and can't verify
- Obvious disability + obvious need: no verification allowed
- Non-obvious: you may request reliable disability-related information confirming the disability and the nexus to the accommodation — from a medical professional, peer support group, or other reliable third party
- Never: diagnoses details, medical records, or the nature/severity beyond what's needed
The interactive process
If a specific request poses an undue burden, you can't just deny — you must engage in an interactive dialogue about alternatives that meet the need. Document every step: the request, communications, decision, and reasoning.
Grant, and act promptly
Undue delay is treated as denial. Approvals should be implemented and documented; denials require legitimate, documented reasons (undue financial/administrative burden or fundamental alteration) — and they're rare in defensible practice.
Accommodation vs. modification
Accommodations change rules; modifications change the physical unit. In most HUD-assisted housing, the owner bears modification costs where reasonable — different from the private-market default.
Facing a request you're unsure about? 59AI answers fair housing questions instantly, with citations — $19.99/month.
FAQ
Can we charge a pet deposit for an assistance animal? No. Assistance animals aren't pets — no pet deposits, pet rent, or breed/weight restrictions apply, though residents remain responsible for actual damage.
Must we grant every request? You must grant reasonable ones. Undue burden and fundamental alteration are the narrow exceptions, and both demand documentation and the interactive process first.
59AI's accredited fair housing courses train teams on the full process.