Memo to Members

The Kelsey Releases Advocate’s Guide on Advancing Disability-Forward Housing in the Low-Income Housing Tax Credit Program

Apr 07, 2025

The Kelsey, a non-profit housing developer and advocacy organization, has released a new resource: An Advocate’s Guide to Advancing Disability-Forward Housing through Qualified Allocation Plans.  

According to The Kelsey, “disability-forward housing is housing that is inclusive, affordable, and accessible for people with and without disabilities. This approach goes beyond minimum compliance with accessibility laws to create integrated, community-driven solutions that prioritize universal design, affordability, and housing equity.” 

Qualified Allocation Plans (QAPs) are the tools by which state housing finance agencies allocate Low-Income Housing Tax Credits (LIHTC). These agencies have discretion in their policy priorities and lay out the criteria for a competitive selection process through their QAPs. The QAPs can include requirements and incentives for various building features, including accessibility features. 

Because the LIHTC program is a tax credit administered by the IRS at the federal level, housing built or preserved with LIHTC is not subject to the same accessibility requirements as other publicly subsidized housing. For example, it is not subject to Section 504 of the “Rehabilitation Act,” which protects individuals from discrimination based on their disability and requires federally funded housing to have at least five percent of units accessible to people with mobility disabilities and two percent accessible to people with sensory disabilities.  

The Kelsey’s new guide provides information about the LIHTC program and QAP process, and how advocates can work with their state agencies and other stakeholders to push for more accessibility features and other aspects of disability-forward housing in LIHTC properties. 

Check out the guide here.