Comprehensive Guide for ICMS Case Managers Supporting Participants with Reasonable Accommodations

Quick Start

What is a Reasonable Accommodation? A disability-related change to housing rules/policies that helps a tenant use and keep their housing.

Timeline: LA County PHA processes take 6-10+ weeks. Set realistic expectations early.

The 3 Required Elements

1. Disability

Participant has a qualifying disability (no diagnosis proof needed for request)

2. Disability Nexus

Clear connection between the disability and the accommodation request. Explain the specific barrier.

Examples:

Safety: Prevent falls, reduce health risks
Access: Enable entry, mobility, use of units or common spaces – needs to be equitable to everyone else
Quality of Life: Support routines, reduce distress, allow participation in community living

3. Reasonable

Accommodation must remove the barrier without creating undue burden:

No extreme financial cost to housing provider
Does not fundamentally change the housing program
Does not create direct safety threat to others
Does not require services outside the housing provider’s scope (e.g., cannot require PHA to provide medical care)

Who Handles What?

PHA (HACLA, LACDA, FHSP)

Handles: Voucher/subsidy policy changes, payment dates, bedroom sizes, extended deadlines

How to identify which PHA:

Check your participant’s voucher paperwork for the administering agency name
Look for letterhead on rent calculation sheets or voucher documents

Voucher types explained:

TBV (Tenant-Based Voucher): Portable voucher participant can take to any qualifying unit
PBV (Project-Based Voucher): Subsidy attached to a specific building/unit, not portable
FHSP (Flexible Housing Subsidy Pool): Special vouchers for participants with mental health or substance use needs, administered through DMH/DHS

If you’re unsure which PHA administers your participant’s voucher, call HACLA at (833) 422-5248 or LACDA at (626) 262-4433 for guidance.

Handling Denials & Appeals

Sample Language for RA Requests

When completing RA request forms, clearly address all 3 required elements (disability, nexus, reasonable). Here are examples:

Example 1 – Accessible Unit Request:

“[Participant name] has a mobility disability requiring use of a wheelchair (disability). The current second-floor unit requires navigating stairs, which creates a safety barrier and prevents independent access to the home (nexus). I am requesting a transfer to a ground-floor or elevator-accessible unit to remove this architectural barrier (reasonable accommodation).”

Example 2 – Payment Date Change:

“[Participant name] has a cognitive disability affecting executive functioning and short-term memory (disability). The current rent due date of the 1st does not align with their SSI payment date of the 3rd, creating a barrier to timely payment and risking late fees and housing instability (nexus). I am requesting the rent due date be changed to the 5th of each month to align with benefit receipt (reasonable accommodation).”

Example 3 – Live-in Aide Approval:

“[Participant name] has a physical disability requiring assistance with activities of daily living including bathing, dressing, and meal preparation (disability). They cannot independently perform these essential functions, creating a barrier to safely maintaining housing (nexus). I am requesting approval for a live-in aide to move from a 1-bedroom to a 2-bedroom unit to accommodate the aide (reasonable accommodation).”

Key tips:

Be specific about the disability’s functional impact (not the diagnosis)
Clearly explain the barrier created
Connect the accommodation directly to removing that barrier
Keep it concise but complete

Valid Denial Reasons (Only 5):

No disability
No nexus
Not necessary
Fundamental alteration
Undue burden or direct threat

Generic denials like “it’s our policy” are invalid.

Appeal Deadlines

HACLA: 30 days from denial
LACDA: 15 days from denial
FHSP: 30 days from denial

File Formal Complaints

California Civil Rights Dept (CRD)

Deadline: 1 year from discrimination
Phone: (800) 884-1684

File Online →

HUD Fair Housing (HUD-FHEO)

Deadline: 1 year from discrimination
Phone: 1-800-669-9777

File Online →

Templates

RA Request Letter Template

📄 Sample Letter

[Date] [Property Manager/PHA Name & Address] Re: Reasonable Accommodation Request Dear [Name]: I am requesting a reasonable accommodation under the Fair Housing Act due to my disability. I am requesting [SPECIFIC ACCOMMODATION]. I have a disability that substantially limits my ability to [MAJOR LIFE ACTIVITY]. [Optional: Brief explanation of limitation without diagnosis] This accommodation is necessary because [EXPLAIN BARRIER] and [HOW ACCOMMODATION REMOVES BARRIER]. [Choose one:] * My disability and need are readily apparent, so I do not believe verification is necessary. * I have attached verification from [source] confirming my disability-related need. * I can provide verification from [source] if needed. Please note I am not required to provide my diagnosis or medical records. I am available to discuss this request or alternative accommodations through the interactive process. Please respond in writing. Sincerely, [Name, Address, Phone]

RA Request Letter Template

📄 RA Request Letter Template

[Date] [Property Manager/PHA Name & Address] Re: Reasonable Accommodation Request Dear [Name]: I am requesting a reasonable accommodation under the Fair Housing Act due to my disability. I am requesting [SPECIFIC ACCOMMODATION]. I have a disability that substantially limits my ability to [MAJOR LIFE ACTIVITY]. [Optional: Brief explanation of limitation without diagnosis] This accommodation is necessary because [EXPLAIN BARRIER] and [HOW ACCOMMODATION REMOVES BARRIER]. [Choose one:] * My disability and need are readily apparent, so I do not believe verification is necessary. * I have attached verification from [source] confirming my disability-related need. * I can provide verification from [source] if needed. Please note I am not required to provide my diagnosis or medical records. I am available to discuss this request or alternative accommodations through the interactive process. Please respond in writing. Sincerely, [Name, Address, Phone]

Other Housing Authorities

If your participant’s voucher is from a PHA other than HACLA, LACDA, or FHSP:

How to identify:

Check voucher paperwork, rent calculation sheets, or inspection notices for the administering agency name
Common LA County PHAs include: Long Beach, Pasadena, Pomona, Inglewood, Redondo Beach, Santa Monica, Burbank, Torrance

Finding contact information:

Most PHAs have RA request procedures on their websites
See direct links to common LA County housing authorities below
General process is similar across PHAs, but forms and submission procedures vary

Need help identifying the PHA? Contact HACLA (833) 422-5248 or LACDA (626) 262-4433 for assistance.

Common LA County Housing Authorities – RA Resources:

City of Long Beach
RA Request Form

City of Inglewood
RA Policy & Request Form

City of Santa Monica
Housing Office – Tenants’ Rights

City of Redondo Beach
Housing Authority Info

City of Burbank
Housing Division

City of Torrance
Housing Authority

Other PHAs: If your participant’s voucher is from a different housing authority not listed above, search “[City name] housing authority reasonable accommodation” or contact the PHA directly for their specific forms and procedures.

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