Reasonable Accommodation Request

Language for Limited English Proficiency Persons (LEP) can be a barrier to accessing important benefits or services, understanding and exercising important rights, complying with applicable responsibilities, or understanding other information provided by the public housing program. In certain circumstances, failure to ensure that LEP persons can effectively participate in or benefit from federally-assisted programs and activities may violate the prohibition under Title VI against discrimination on the basis of national origin. This part incorporates the Final Guidance to Federal Assistance Recipients Regarding Title VI Prohibition against National Origin Discrimination Affecting Limited English Proficient Persons, published January 22, 2007, in the Federal Register.

The PHA will take affirmative steps to communicate with people who need services or information in a language other than English. These persons will be referred to as Persons with Limited English Proficiency (LEP). LEP persons are defined as persons who do not speak English as their primary language and who have a limited ability to read, write, speak or understand English. For the purposes of this Admissions and Continued Occupancy Policy, LEP persons are public housing applicants and resident families, and parents and family members of applicants and resident families.

In order to determine the level of access needed by LEP persons, the PHA will balance the following four factors:

1. the number or proportion of LEP persons eligible to be served or likely to be encountered by the public housing program;
2. the frequency with which LEP persons come into contact with the program;
3. the nature and importance of the program, activity, or service provided by the program to people’s lives; and
4. the resources available to the PHA and costs. Balancing these four factors will ensure meaningful access by LEP persons to critical services while not imposing undue burdens on the ECC.

As a result of Elm City Communities/Housing Authority of New Haven’s (ECC/HANH) analysis of (1) the number and proportion of LEP persons serviced or encountered in ECC/HANH’s eligible service population, and (2) the frequency with which LEP persons come into contact with ECC/HANH’s programs, ECC/HANH has determined that ECC/HANH has particular obligations to ensure communication with Spanish-speaking persons.

Accordingly, it is ECC/HANH’s policy that ECC/HANH will provide bilingual Spanish speaking staff as necessary to provide oral language/interpreter services for Spanish speaking LEP applicants, program participants, or other members of the public interested in ECC/HANH’s services.

Elm City Communities/Housing Authority of the City of New Haven (ECC/HANH) is a public agency that provides equal access to housing, facilities, and services for employees, residents, and/or applicants. ECC/HANH is not permitted to discriminate against applicants on the basis of their race, religion, sex, color, national origin, age, disability or familial status. In addition, ECC/HANH has a legal obligation to provide “reasonable accommodations” to applicants if they or any family members have a disability.

A reasonable accommodation is some modification or change ECC/HANH can make to its apartments or employees work environment for procedures that will assist an otherwise eligible applicant with a disability to take advantage of ECC/HANH’s programs, facilities, services, and classes.

Examples of reasonable accommodations would include:

• Making alterations to ECC/HANH unit so it could be used by a family member with a wheelchair;
• Installing strobe type flashing light smoke detectors in an apartment for a family with a hearing-impaired member;
• Making large type documents, cassettes or a reader available to an applicant with a vision impairment during the application process;
• Making an interpreter available to an applicant with an impairment during the interview;
• Permitting an outside agency to assist an applicant with a disability to meet ECC/HANH’s applicant screening criteria.