Providing Safe Home Modifications for Residents Aging in Place

With the aging of the U.S. population, you may find that the average age of your residents and applicants seeking units is older. Helping residents to age in place safely is a win-win for both owners and residents. Residents typically want to live independently for as long as possible, and stable occupancy reduces management costs.

However, as older adults age and their needs and abilities change, the features and configuration of their home can present challenges to living safely and independently. Adaptations of the living environment, called home modifications, can help improve the comfort and safety of older persons or people with disabilities, allowing them to thrive in independent housing.

Increasingly, research is showing that, In addition to helping older adults live more comfortably and independently, home modifications can reduce individuals’ fall risk. It’s estimated that one in four older adults falls each year, with more than half of all falls occurring in the home. Injurious falls can cause people to move to institutional settings. Home modifications can reduce fall risks and may promote longer tenure in independent housing, and less unit turnover.

We’ll discuss owner responsibilities for home modification and list some modifications that can make a big difference to the health and safety of your older residents, as well as resources to assist your residents with home modification.

Resident-Made Modifications

These are simple modifications residents could make themselves with no additional help:

• Remove clutter from the floor and increase storage;
• Secure cords to walls or floors;
• Remove throw rugs or secure them with gripper rug pads or gripper tape;
• Mark uneven thresholds with contrasting tape or paint;
• Install nightlights in the bedroom and bathroom;
• Stick motion sensor LED lights on baseboards;
• Purchase a shower seat and place adhesive anti-slip treads on shower or tub floors; and
• Add seating in the bedroom to assist with dressing and in the kitchen for cooking prep.

Modifications Done by Staff

These are low-cost modifications that require a maintenance person to perform:

• Replace knob-style door and faucet handles with lever-style handles;
• Securely install grab bars around tubs, showers, and toilets; raise toilet seats;
• Install adjustable hand-held shower heads and anti-scald water devices;
• Replace bulbs with bright, non-glare lighting;
• Replace traditional light switches with rocker switches; and
• Install double hinges to widen doorways.

Modifications Requiring Professional Installation, Higher Cost

These modifications require professional installers and cost a significant amount:

• Widen the frames of entryways and doorways;
• Remodel bathroom to include a shower with supports and no threshold;
• Install slip-resistant flooring in the bathroom; and
• Create level flooring by removing thresholds and other uneven areas

Owner Responsibilities for Home Modification

A request for a reasonable modification may be made at any time during the tenancy. Your LIHTC site may be subject to Section 504 of the Rehabilitation Act of 1973, which provides rights to people with disabilities in housing programs that receive federal assistance (see “Does Section 504 Apply to Your Site?,” below).

Under Section 504, owners have a responsibility to provide reasonable accommodations to residents with disabilities who need such accommodation to be able to participate fully in the housing. Structural changes needed by an applicant or resident with a disability in housing receiving federal financial assistance are considered reasonable accommodations. They must be paid for by the owner unless providing them would be an undue financial and administrative burden or a fundamental alteration of the program, or unless the housing provider can accommodate the individual’s needs through other means.

Unless Section 504 applies, fair housing law requires owners to permit applicants or residents with a disability, at their expense, to make reasonable modifications to the housing if necessary to afford them full enjoyment of the premises. Site owners not subject to Section 504 must permit the modification; the resident is responsible for paying the cost of it.

When you get a request for a modification, attend to it promptly. If you drag your heels, your delay may be deemed a denial—and a violation of the resident’s rights under Section 504 or fair housing law.

In October 2018, for example, HUD charged the owner of a Virginia-based site and three managers with discriminating against a resident with disabilities when they unreasonably delayed her request to install an automatic door opener on her front door to make it easier to use her wheelchair.

According to HUD’s charge, the resident had a physical disability and used a wheelchair for mobility. Based on her physician’s advice, she allegedly asked for permission to install an automatic door opener on the entrance door to her unit and indicated that she had acquired funding for the modification that would cover all expenses to purchase and install the door opener, at no cost to the housing provider. With the request, the resident said she submitted the contact information for the licensed contractor who agreed to install the door opener, a video showing the operation of the opener, and the specifications and installation instructions for the opener. Her physician filled out the site’s form attesting to the resident’s disability-related need for the automatic door opener. In addition, according to the charge, the owner denied her reasonable accommodation request for extra time, because of illness, to complete the site’s annual income and family composition certification and evicted her, leaving her without housing.

To help you assess and process reasonable modification requests, we’ve prepared two Model Forms: Set Written Reasonable Modification Policy for Individuals with Disabilities and Get Reasonable Modification Requests in Writing, below. You can adapt and use these forms to apprise applicants and residents of your policy on requests for reasonable modifications and to get relevant information you need from a resident who requests a modification and to inform the resident of her responsibilities with regard to the modification.

Resources to Assist with Home Modification

Increasingly, programs and funding are available to help renters modify their home environments to support independent living. Here are some resources you can share with your residents and service coordinators to help them access funding.

Area Agencies on Aging (AAAs), Aging and Disability Resource Centers (ADRCs), and Centers for Independent Living (CILs). These agencies maintain information and resources on home accessibility and available programs to finance home modifications. The programs are funded by the U.S. Administration for Community Living (ACL). To find the AAAs and ADRCs in your area, visit the eldercare locator or call 1-800-677-1116.

State ACL grant programs. All states receive federal grants through ACL to support programs that increase access to assistive technology devices and services for individuals with disabilities and older adults. To find out more, including whether the program in your state includes resources for home modification and accessibility, visit the Assistive Technology Act Technical Assistance and Training (AT3) Center web page at www.at3center.net.

Department of Veteran’s Affairs grants. The Department of Veteran’s Affairs offers Home Improvements and Structural Alterations (HISA) grants to veterans and service members for medically necessary home modifications. Renters are eligible for the grants if they have a signed and notarized statement from the owner authorizing the improvement or structural alteration.

Nonprofit organization programs. Many communities offer comprehensive home modification programs, often operated through nonprofit organizations, that help older adults determine the environmental modifications they need and then carry out the modifications free of charge. Some of these programs such as Community Aging in Place—Advancing Better Living for Elders (CAPABLE) include a visit from an occupational therapist or nurse to ensure the modifications meet the needs of the resident and are part of a comprehensive approach to helping the resident continue to live independently and safely.

The www.homemods.org website maintained by the University of Southern California Leonard Davis School of Gerontology and supported in part by ACL, provides a directory of home modification and repair programs by state.

Medicare Advantage Plans. These plans may pay for home safety inspections conducted by a qualified health professional and safety devices, such as shower stools, hand-held showers, grab bars, and raised toilet seats, to prevent injuries in the home or bathroom. Medicare Advantage Plans are a type of Medicare health plan offered by a private company approved by Medicare to provide Medicare Part A and Part B benefits. The Medicare.gov website provides information on Medicare Advantage as well as organizations to contact by state.

Medicaid. Medicaid home and community-based services (HCBS) provide opportunities for Medicaid beneficiaries to receive services in their own home or community rather than institutions or other isolated settings. States have flexibility to cover a variety of HCBS services under their Medicaid state plans that improve home accessibility for Medicaid-eligible individuals. For more information on Medicaid HCBS programs, visit the HCBS page on Medicaid.gov.

Doctor prescriptions. When prescribed by a doctor, or as part of their discharge plan when returning from a hospital stay, residents may receive in-home visits from an occupational therapist, physical therapist, or nurse. During these visits, the health professionals often identify specific equipment and environmental modifications that residents need for safety and independence. HUD encourages service coordinators to work with the health professionals and residents to ensure the resident’s needs are met.

Does Section 504 Apply to Your Site?

Section 504 of the Rehabilitation Act of 1973 bans disability-based discrimination in any program or activity that receives federal financial assistance from any federal agency (including HUD) or in any programs conducted by federal agencies. If Section 504 applies to your site and you don’t know it, you risk HUD investigations and possible penalties.

Section 504 applies to “recipients of federal assistance,” including tax credit and market-rate sites that get some federal assistance. Participation in the tax credit program alone doesn’t mean that a site gets federal assistance. But if your tax credit site is also financed under, say, HUD’s Community Development Block Grant (CDBG) or the Home Investment Partnership Program (HOME), Section 504 applies to your site. Section 504 applies to tax credit and market-rate sites that participate in project-based Section 8, Section 202. And those sites that receive direct funding through the Tax Credit Assistance Program (TCAP) or the LIHTC Exchange Program also must comply with Section 504 requirements. If you’re not sure whether your site gets federal financing, it’s best to talk to the owner.

In some respects, you comply with Section 504 in the same way you comply with the Fair Housing Act. But there are some key differences. If Section 504 applies to your site:

• Your site—not your households—must pay for reasonable accommodations and modifications that prospects and residents request in connection with a disability (unless you can show financial hardship);
• At least 5 percent of your units (or one unit, whichever is greater) generally must be accessible to residents with mobility impairments, and at least 2 percent of your units must be accessible to residents with hearing or vision impairments;
• You must furnish appropriate auxiliary aids needed to give disabled residents an equal opportunity to enjoy their housing; and
• You must choose at least one employee at your site to coordinate compliance with Section 504 (if your site has at least 15 employees).

If you determine that Section 504 applies to your site, talk to your attorney for a full rundown on its requirements to make sure you’re in compliance.