Kingsbury Corporation's Twin Towers
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Reasonable Accommodations / Modification
Policy & Procedures with Samples of
Reasonable Accommodation Methods

If an individual with a disability requires an accommodation to a building policy or a modification such as a change in structural feature, Kingsbury’s Twin Towers will provide such accommodation unless doing so would result in a fundamental alteration in the nature of the program; an undue financial and administrative burden. In such a case, the community will offer an alternative accommodation that would not result in a financial and administrative burden.

Kingsbury's Twin Towers is committed to ensuring that its policies and procedures do not deny individuals with disabilities the opportunity to participate in, or benefit from nor otherwise discriminate against individuals with disabilities in connection with the operations of its programs, services and activities.

A copy of this Reasonable Accommodation Policy and Procedures will be posted in the Management office and provided to applicants and residents as described in the policy.

  1. STATUTES AND REGULATIONS

Kingsbury’s Twin Towers is subject to Federal civil rights laws and regulations. This Reasonable Accommodation Policy is based on the following statutes or regulations. Section 504 of the Rehabilitation Act of 1973 (Section 504); Title II of the Americans with Disabilities Act of 1990 (ADA); the Fair Housing Act of 1968, as amended (Fair Housing Act); the Architectural Barriers Act of 1968, and the respective implementing regulations for each Act.

  1. MONITORING AND ENFORCEMENT

The Management Companies’ Section 504/ADA Coordinator is responsible for monitoring this community’s compliance with this policy. Individuals who have questions regarding this Policy, its interpretation or implementation should contact the management’s Section 504/ADA Coordinator in writing, by telephone, or by appointment, as follows:

Name of Section 504/ADA Coordinator: Deborah M. Gershen

Address: P.O. Box 3709 Princeton, NJ 08543

Telephone Number: (609) 989-8500 x112

Dedicated Toll-Free Telephone Number: 1-888-437-7436

TDD/TTY Number – or State Relay Service Number: 1-800-852-7899

Facsimile Number: (609) 802- 0148

  1. STAFF TRAINING

The Section 504/ADA Coordinator will ensure that all appropriate community staff receives training on the Reasonable Accommodation Policy and Procedures, including all applicable Federal, state and local requirements regarding reasonable accommodation. All staff will complete a course with exam at least every three years.

  1. DEFINITIONS:

  1. PERSONS WITH A DISABILITY

A person with a disability means an individual who has a physical or mental impairment that substantially limits one or more major life activities; or has a record of such an impairment; or is regarded as having an impairment. This definition is identical in all applicable federal civil rights statutes and regulations, As used in this definition, the phrase “physical or mental impairment” includes:

  1. Any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: Neurological; musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and endocrine; or

  1. Any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities. The term “physical or mental impairment” includes, but is not limited to, such diseases and conditions as orthopedic, visual, speech, and hearing impairments, cerebral palsy, autism, epilepsy, muscular dystrophy, multiple sclerosis, cancer, heart disease, diabetes, mental retardation, emotional illness, drug addiction and alcoholism.

  1. Major life activities” means functions such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing and learning.

The definition of disability does not include any individual who is an alcoholic whose current use of alcohol prevents the individual from participating in the housing program or activities; or whose participation would constitute a direct threat to property or the safety of others.

  1. REASONABLE ACCOMMODATION

A reasonable accommodation is a change, alteration or adaptation in policy, procedure, practice, or program that provides a qualified individual with a disability the opportunity to participate in, or benefit from, a program (housing or non-housing) or activity.

A person with a disability, or any individual or organization duly and properly authorized to act on their behalf, may request a reasonable accommodation at any time during the application process or term of their residency.

The decision to approve or deny a request for a reasonable accommodation is made on a case-by-case basis and takes into consideration the disability and the needs of the individual as well as the nature of the program or activity in which the individual seeks to participate. See section below about procedures for verification of accommodation.

Examples of reasonable accommodations may include, but are not limited to:

(a) Permitting a family to have a service or assistance animal necessary to assist a family member with a disability;

(b) Allowing a resident and the approved live in aide to reside in an appropriately sized unit;

(c) Transferring a resident to a larger size unit to provide a separate bedroom for a person with a disability;

(d) Transferring a resident to a unit on a lower level or a unit that is completely on one level;

(e) Making documents available in large type, computer disc or Braille;

(f) Providing qualified sign language interpreters for applicant or resident meetings with office staff; or at resident meetings; and,

(g) Permitting an outside agency or family member to assist a resident or an applicant in meeting screening criteria or meeting essential lease obligations.

  1. REASONABLE MODIFICATION

A reasonable modification is a structural change that provides a qualified individual with a disability the opportunity to participate in, or benefit from, a housing program.

A person with a disability may request reasonable modifications at any time during the application process or during the term of their residency.

The decision to approve or deny a request for a reasonable modification is made on a case-by-case basis and takes into consideration the disability and the needs of the individual as well as the nature of the program or activity in which the individual seeks to participate. See section below about procedures for verification of accommodation.

Examples of reasonable modification may include, but are not limited to:

(a) Making a unit, part of a unit or public and common use element accessible for the head of household or a household member with a disability who is on the lease; or

(b) Installing strobe type flashing lights and other such equipment for a family member with a hearing impairment.

  1. PROCESSING OF REASONABLE ACCOMMODATION/ MODIFICATION REQUESTS

  1. Individuals may submit their reasonable accommodation request(s) in writing, orally or by any method of communications. Kingsbury’s Twin Towers will ensure that all reasonable accommodation requests will be reduced to writing. If needed, as a reasonable accommodation, the staff at Kingsbury’s Twin Towers will assist the individual in completing the Request Form.

  1. Kingsbury’s Twin Towers will provide all applicants with the Request Form as an attachment to the community application.

  1. Reasonable Accommodations will be made for applicants during the application process. Applicants will be provided to applicants with appropriate auxiliary aids and services, including qualified sign language interpreters and readers, upon requests

(c) Kingsbury’s Twin Towers will provide all residents with the Request Form during the annual re-certification, and upon request.

(d) Residents seeking accommodation(s) may contact the management office or the Section 504/ADA Coordinator’s office directly to request the accommodation(s).

(e) Within seven (7) business days of receipt, the management office will forward the resident’s reasonable accommodation request(s) to the verifying authority and the Office of the Section 504/ADA Coordinator. See section below.

(f) Within twenty (20) business days or receipt of the verification, the Office of the Section 504/ADA Coordinator responds to the Resident’s Request.

(g) If additional information or documentation is required, the Section 504/ADA Coordinator’s office will notify the resident, in writing, of the need for the additional information or documentation. The Section 504/ADA Coordinator’s Office will provide the resident with the “Request for Information or Verification Form” The written notification should provide the resident with a reply date for submission of the outstanding information or documentation.

(h) Within thirty (30) business days of receipt of the request and, if necessary, all supporting documentation, Kingsbury’s Twin Towers will provide written notification to the resident of its decision to approve or deny the resident’s request(s).

  1. If Kingsbury’s Twin Towers approves the accommodation request(s), the resident will be notified of the projected date for implementation.

(j) If the accommodation is denied, the resident will be notified of the reasons for denial. In addition, the notification of the denial will also provide the resident with information regarding grievance procedures.

All requests for reasonable accommodation that are approved will promptly be implemented or begin the process of implementation.

  1. VERIFICATION OF REASONABLE ACCOMMODATION REQUEST

Kingsbury’s Twin Towers may request documentation of the need for a Reasonable Accommodation as identified on the Request for Reasonable Accommodation Form. In addition, Kingsbury’s Twin Towers may request that the individual provide suggested reasonable accommodations.

Kingsbury’s Twin Towers may verify a person’s disability if the disability is not known to management, only to the extent necessary to ensure that individuals who have requested a reasonable accommodation have a disability-based need for the requested accommodation/ modification.

Kingsbury’s Twin Towers may only request documentation to confirm the disability-related need(s) for the requested reasonable accommodation(s). Kingsbury’s Twin Towers may not require individuals to disclose confidential medical records in order to verify a disability. In addition, Kingsbury’s Twin Towers may not require the individual to disclose the specific disability (ies); or the nature or extent of the individual’s disability (ies).

The following may provide verification of a resident’s disability and the need for the requested accommodation(s):

(a) Physician;

(b) Licensed health professional;

(c) Professional representing a social service agency; or

(d) Disability agency or clinic.

Upon receipt, the manager of Kingsbury’s Twin Towers will forward the recommendation, including all supporting documentation, to the Section 504/ADA Coordinator within seven (7) days of receipt.

  1. DENIAL OF REASONABLE ACCOMMODATION/ MODIFICATION REQUEST(S)

Requested accommodations will not be approved if one of the following would occur as a result:

(a) A violation of State and/or federal law;

(b) A fundamental alteration in the nature of Kingsbury’s program;

(c) An undue financial and administrative burden on Kingsbury;

(d) A structurally infeasible or potentially dangerous alteration; or

(e) An alteration requiring the removal or alteration of a load-bearing structural member.

  1. TRANSFER AS REASONABLE ACCOMMODATION

If a resident with a disability requests dwelling unit modifications that involve structural changes, including, but not limited to widening entrances, rooms, or hallways, and there is a vacant, comparable, appropriately sized assistive unit in the community, Kingsbury’s Twin Towers may offer to transfer the resident to the vacant unit

Kingsbury’s Twin Towers shall make modifications to the resident’s unit unless doing so would be structurally impracticable or would result in an undue financial and administrative burden.

If the resident accepts the transfer, Kingsbury’s Twin Towers will work with the resident to obtain moving expenses from social service agencies or other similar sources. If that effort to obtain moving expenses is unsuccessful within thirty (30) days Kingsbury’s Twin Towers shall pay the reasonable moving expenses, including utilities fees and deposits.

  1. SERVICE OR ASSISTANCE ANIMALS

Residents of Kingsbury’s Twin Towers with disabilities are permitted to have assistance animals, if such animals are necessary as a reasonable accommodation for their disabilities. Kingsbury’s Twin Towers residents or potential residents who need an assistance animal as a reasonable accommodation must request the accommodation in accordance with the reasonable accommodation policy. Assistance animals are not subject to the requirements of Kingsbury’s Twin Towers’s Pet Policy.

  1. RIGHT TO APPEAL/GRIEVANCE PROCESS

(a) Any resident may file a complaint in accordance with the Grievance Procedure following a formal determination by the ADA/504 Coordinator.

(b) An applicant or resident may, at any time, exercise their right to appeal a Property Kingsbury's Twin Towers.

decision through the local HUD office or the U.S. Department of Justice.


Individuals may contact the local HUD office at:

U.S. Department of Housing and Urban Development

Newark Field Office
Address: One Newark Center, 1085 Raymond Boulevard 13th Floor
City/State/Zip Code: Newark, NJ 07102-5260
Telephone: (973) 622-7900
Facsimile: (973) 645-2323
TDD/TTY Number: (973) 645-3298