NLIHC Submits Comment Letter Responding to HUD Section 504 Disabilities Advance Notice of Proposed Rule Making

NLIHC submitted comments in response to an Advance Notice of Proposed Rulemaking (ANPRM) regarding updating the Section 504 regulations pertaining to nondiscrimination on the basis of disability. HUD’s Office of Fair Housing and Equal Opportunity (FHEO) published the ANPRM in the Federal Register on April 25 (see Memo, 5/1). NLIHC also signed on to a more detailed comment letter submitted by the Housing Justice Network and coordinated by the National Housing Law Project. NLIHC’s letter responded to five of the 13 questions posed in the ANPRM.

Section 504 prohibits discrimination on the basis of disability in all programs and activities receiving federal financial assistance and in programs and activities conducted by federal executive agencies. The current regulations were published in 1988. FHEO requested public feedback regarding 13 questions with the intent to draft a Notice of a Proposed Rulemaking (NPRM) offering updated accessibility standards for further public review and comment. The background section of the ANPRM and the questions provide a basic primer on Section 504 and various issues that might confront people with disabilities. Comments were due by July 24.

NLIHC’s comment letter responded to five questions posed by the ANPRM regarding:

  • Appropriate steps to ensure effective communications with applicants, beneficiaries, and members of the public who have disabilities, and the requirement to provide auxiliary aids and services (Question 3).
  • Challenges households face finding available, affordable, and accessible housing (Question 4).
  • Challenges using a Housing Choice Voucher (Question 5).
  • Reasonable accommodations (Question 10).
  • Native American Tribes and tribal entities (Question 12).

Read the ANPRM at:

Find an easier-to-read version of the ANPRM at:

Read NLIHC’s comment letter at:

Read the Housing Justice Network comment letter at: