To use a form or not to use a form: that is the question. Shakespeare aside, discretion needs to be part of your policy when it comes to reasonable accommodations and how they are verified.
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We all like to have a standard of practice or steps to follow. But when it comes to reasonable accommodations and the use of verification forms, we need to remember that one size most certainly does not fit all.
Verification Forms for Reasonable Accommodations
If a resident has a visible disability, i.e., a mobility disorder, you do not need to do a verification request. But what do you do when the situation isn’t so straightforward? Consider this scenario: A leasing agent is approached by a resident requesting a dedicated parking spot but has no documentation of their disability. What are the appropriate next steps?
Now is the time to request that the resident complete or authorize a verification form. If they refuse, they should be informed that their request cannot be processed without verification. This can be accomplished by completing the form, or by the receipt of a letter from the resident’s verifier of choice with all the pertinent information you require for verification. Staff can fill out the form on behalf of the resident, but the information contained and the signature authorizing the verifier to provide the information must come from the resident. Once the information has been provided and verified, only then can the staff move forward with the reasonable accommodation request.
Doctor’s Note or a Verification Form?
One thing that properties see quite regularly is residents bringing in doctor’s notes when they are requesting a reasonable accommodation. Do you still require the resident to complete a verification form? If the doctor’s note gives you all the required information, you need to make a decision; you cannot insist that a resident complete one of your forms. You can only ask that a verification form be completed if there is needed information missing, with the form outlining the specific information required.
We all wish that every situation could be handled the same way. However, in fair housing, how each situation is dealt with is dependent on how it was presented. This is why training is so critical. Leadership needs to ensure that their staff has the knowledge to assess each situation and follow through with the correct steps based on that information. By providing up-to-date fair housing training, many potential problems can be avoided.
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