11.1 General
Clients may always seek assistance from the departments reviewing their RA requests. BHA will also employ a Reasonable Accommodation Coordinator (“RAC”), who will report to the Director of Civil Rights.
11.2 The Reasonable Accommodation Coordinator
11.2.1 General role
The RAC will be responsible for overseeing the implementation of this policy and for coordinating BHA’s efforts to comply with the various provisions of federal, state and local law governing RAs in housing. The RAC will be available to BHA Clients as well as staff to answer questions and assist with issues regarding RA requests. The RAC shall also continually work with the various departments of the BHA to develop procedures to better track and monitor the agency’s processing of RA requests.
The RAC does not issue RA decisions but is available for advice to the BHA staff who do. As discussed above, however, the RAC is a member of OCR’s RARC, and will have input on whether proposed RA denials, partial denials, and alternative Accommodations should go forward.
BHA will notify all Clients on an initial and continuing basis of the availability of the RAC and provide them with his/her contact information.
11.2.2 Addressing concerns and complaints
Where the RAC believes that certain corrective action is necessary, he/she will directly advise BHA staff involved or make a recommendation to the Director of Civil Rights who will in turn advise the staff.
The RAC may receive complaints or other reports of non-compliance with this policy from BHA Clients, staff, advocates, or other interested persons outside BHA and will investigate such complaints promptly. The RAC will report his/her findings and any recommendations for remedial action to the Director of Civil Rights, who will take further action as necessary. These investigations are separate from the appeals process discussed above.
11.2.3 Status inquiries
Any BHA Client who has submitted an RA request other than a transfer may contact the Reasonable Accommodation Coordinator for a status inquiry. The RAC will reply within five (5) business days.
11.2.4 Access to files and information
The RAC shall have access to all files and information relevant to RA requests s/he is investigating. BHA staff must provide the RAC with such files and information within five (5) business days of his/her request for them.
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