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.
Common RA Scenarios
Live-in Aide
1BR → 2BR for ADL support
Nexus: Cannot independently perform bathing, dressing, meals
Grab Bars
Install safety modifications
Nexus: Mobility impairment creates fall risk
Unit Transfer
Move due to PTSD/accessibility
Nexus: Current unit triggers symptoms or has barriers
Assistance Animal
ESA or service animal approval
No pet deposits/rent for assistance animals
Payment Schedule
Adjust rent due date
Nexus: Match SSI/SSDI payment dates
Accessible Unit
Ground floor or elevator access
Nexus: Mobility impairment prevents stair use
Accessible Parking
Assigned close parking spot
Nexus: Long-distance walking difficult/dangerous
Extended Deadlines
Extra time for paperwork
Nexus: Cognitive disability affects processing
Verification Requirements
You Can Verify: Case managers with direct knowledge of functional limitations can provide verification. You don’t need a clinician for every request.
When is VOD Needed?
Only when disability is not obvious AND nexus is not in file
✓ Housing Providers CAN Ask
- Confirmation disability exists
- Confirmation RA is needed
- How accommodation addresses barrier
✗ Housing Providers CANNOT Ask
- Specific diagnosis
- Medical records
- Treatment details
Remember: VOD confirms a disability exists, but does NOT establish nexus.
SSI/SSDI recipients have a confirmed disability—but you still need to explain why the specific RA is needed.
Who can provide nexus verification:
✓ Case managers with direct knowledge can verify if they personally observe functional limitations (e.g., “I have witnessed participant’s difficulty climbing stairs due to mobility impairment”)
✓ Medical/clinical professionals should verify if specialized knowledge is needed: doctor, psychiatrist, psychologist, therapist, social worker, occupational therapist
The verification must explain: HOW the disability creates a barrier that this specific accommodation will address. Just confirming a disability exists is not enough.
Forms & Submission
HACLA
Forms: New Intake (S504-02) OR Annual Review (Section 504)
Phone: (833) 422-5248
FHSP
Flexible Housing Subsidy Pool
How to identify FHSP participants:
- Voucher documents will show “FHSP” designation
- Often involves DMH (Department of Mental Health) or DHS (Department of Health Services)
- Participant may be enrolled in Full Service Partnership (FSP) or similar programs
Finding your FHSP coordinator:
- FHSP participants are assigned to specific regional coordinators
- Check participant’s most recent FHSP correspondence for coordinator name/contact
- If unknown, call the general FHSP line: [INSERT PHONE NUMBER IF AVAILABLE]
- Your agency may have a FHSP liaison who tracks coordinator assignments
Contact your FHSP coordinator for current forms and submission procedures.
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 Housing Authority, Pasadena Housing Department, Pomona Housing Authority
Finding contact information:
- Most PHAs have RA request procedures on their websites
- Search “[PHA name] reasonable accommodation request”
- 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.
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
HUD Fair Housing (HUD-FHEO)
Deadline: 1 year from discrimination
Phone: 1-800-669-9777
Free Legal Aid Resources
When to Seek Legal Aid
Refer participants to legal aid resources when:
✓ RA request has been denied and you need help understanding the denial or filing an appeal
✓ Appeal has been denied and participant wants to pursue further action
✓ Complex legal questions arise during the RA process
✓ Participant faces potential housing loss related to disability accommodation issues
✓ You suspect discrimination or unfair treatment based on disability
✓ Housing provider is not responding to RA requests or dragging out the process
Legal aid organizations listed below can provide free representation, advocacy, and legal advice.
Inner City Law Center (ICLC)
(213) 891-2880 | Mon-Fri, 9am-5pm
1309 E. 7th St, LA, CA 90021
Homelessness prevention and housing rights advocacy
California Civil Rights Department (CRD)
Handles housing discrimination complaints including RA denials
Deadline: 1 year from discrimination
Phone: (800) 884-1684
HUD Fair Housing Equal Opportunity (HUD-FHEO)
Federal fair housing enforcement for disability discrimination
Deadline: 1 year from discrimination
Phone: (800) 669-9777
When to file a complaint:
- RA request denied for invalid reasons (see Denials & Appeals tab)
- Housing provider refuses to engage in RA process
- Retaliation after requesting accommodation
- Pattern of discrimination or disability-based harassment
Filing a complaint does not prevent you from also seeking legal aid assistance.
Templates
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.