Guest Accommodations & Accessibility Policy

Purpose

Urban Alchemy (UA or the organization or company) values all guests at each of our interim housing, safe rest, and safe parking villages, including guests with disabilities. There are important steps that must be taken so that accommodations and accessibility requests are reported through the correct channels, adequately documented, addressed, and provided. The goal of this policy is to create an environment where all guests can readily and efficiently request reasonable accommodations or modifications, and to report any accessibility issues to the appropriate teams at UA. These steps provide for equal opportunity for guests and provide transparency and uniformity o n the process. This guidance also complies with any of our applicable obligations under the Fair Housing Act, Section 504 of the Rehabilitation Act, other applicable state and local disability related regulations, and contract requirements.

Reasonable Accommodations and Modifications

To the maximum extent required by applicable law, Urban Alchemy will make changes to its standard policies and practices so guests with a disability have equal access to housing and housing-related services. These changes are referred to as “reasonable modifications” or “reasonable accommodations.” Reasonable modifications and accommodations will be provided subject to any restrictions and guidelines as set forth in the organization’s contracts with its city and/or state partners, and only if such modifications or accommodations do not fundamentally alter the nature of the services provided and do not impose an undue burden on the organization.

Accessibility

Urban Alchemy also complies with applicable federal and state laws requiring government-funded facilities to be physically accessible for individuals with disabilities. In some cases, providing such access may require physical alterations to existing facilities, however, the organization is not required to make any structural changes in existing facilities where other methods are effective in achieving the same or similar level of program access. Urban Alchemy is also not required to make any physical alterations that would impose an undue burden on the organization.

Examples of reasonable accommodations and modifications

The list below is examples-only, provided for illustrative purposes, and is not an exhaustive list of possible accommodations and modifications that Urban Alchemy can provide. Whether an accommodation or modification is reasonable shall be determined on a case-by-case basis, depending on the individual circumstances.

• When a guest needs an accommodation or modification to have equal access to services provided by Urban Alchemy at an interim housing site, safe parking, or safe rest village;
• When a guest needs an accommodation or modification to equally use and enjoy housing;
• When a guest requires a slight modification to a shelter policy, procedure, or process and such modification does not fundamentally alter the services provided by Urban Alchemy; and/or
• Modifications or adjustments to the physical layout of a work environment to eliminate or reduce barriers, so long as such modifications or adjustments do not impose an undue hardship and do not fundamentally alter the services provided by Urban Alchemy.

Urban Alchemy reserves the right to deny a request if it imposes an undue burden on the organization, fundamentally alters the services provided, and/or constitutes a direct threat to the health or safety of guests, the public, or others, or would cause substantial physical damage to the property of others.

Guidelines

Urban Alchemy agrees, to the maximum extent required by applicable law and contractual requirements, to:

• Treat all guests equally, with respect and dignity, including in the application of shelter policies and the grievance process;
• Provide shelter services in an environment that is safe and free of physical violence by ensuring that safety protocols are in place that include training to all shelter staff regarding de-escalation techniques; and
• Provide shelter services in compliance with the Americans with Disabilities Act (ADA).

Not All Requests Can Be Granted

Sometimes a guest may ask for an accommodation or modification that is not reasonable or necessary, that poses an “undue hardship” (i.e. too costly or disruptive) on the company or that might threaten the safety of the individual who has made the request or the safety of others. Even in those cases, the company will discuss whether some other form of accommodation or modification may be effective.

Undue hardship is determined on a case-by-case basis involving factors such as, but not limited to, the cost of any requested accommodation or modification, the financial resources of the organization, the benefits that the requested modification or accommodation would provide to the requester, and the availability of any alternative accommodations that would effectively meet the requester’s disability related needs.

Urban Alchemy is not required to provide any modification or accommodation that fundamentally alters the services provided or the organization’s operations.

Service Animal vs. Emotional Support Animal

Urban Alchemy allows guests to bring their service animal or their emotional support animal, subject to city and contract restrictions.

A “service animal” is an animal that is trained to perform specific tasks for a guest’s disability. If a service animal in training causes any damage to shelter premises or to the property of the company, a guest, or a visitor, the owner may be held legally responsible for and required to pay for the damage.

An “emotional support animal” (ESA) is any animal that provides comfort or support that alleviates one or more symptoms of a person’s disability. ESAs do not have the same access to spaces that service animals do.

A guest with a service animal does not need to disclose that they have a service animal. The only two questions a housing provider can ask is (1) whether the animal is required because of a disability, and (2) what work or task has the animal been trained to perform? Urban Alchemy will not ask for proof of training or certification, but Urban Alchemy may ask that the animal be under the control of the handler. “Under control” means that a guest must have the service animal harnessed, leashed, or tethered while in public spaces, unless it must be unleashed to perform a task and then it must be re-leashed when the task is complete. The owner must use signals to effectively instruct the service animal and the service animal must be well-behaved, must not bark repeatedly, nor wander off without the owner. Guests are hereby notified that misrepresenting an animal as a trained service animal is a misdemeanor, subject to a fine, and may result in temporary or permanent denial of service, subject to city and contract restrictions.

A guest with an emotional support animal (ESA) may be required to provide documentation that they have a disability and a disability-related need for an ESA. Urban Alchemy may request that the guest provide updated medical verification of their need for an ESA from a medical professional (such a note must not disclose details of a guest’s diagnosis).

Urban Alchemy reserves the right to require that guests obtain all legally required licenses and vaccinations for a service animal and/or ESA.

If Urban Alchemy is legally or contractually required to maintain a “No Pets” policy for any shelters UA is managing or operating, service animals are not subject to such a rule. Guests with ESAs, however, need to request and undergo the reasonable accommodation process to bring their ESAs to the housing, safe rest, or safe parking site. Urban Alchemy will promptly respond to any reasonable accommodation request and provide approvals or denials in writing.

The company reserves discretion to deny a request for an accommodation if such accommodation imposes an undue hardship.

Complaint Process

Urban Alchemy provides client complaint forms in common areas of the shelter. Complaint forms can also be provided to guests upon request. Where applicable, guests can also file grievances or complaints with local supportive housing agencies.

Guest grievance and complaint forms are also available online at the Urban Alchemy website.

Any interim housing staff member can accept and investigate written client complaints from guests. Grievances and complaints shall be acknowledged within two business days. Urban Alchemy will review and respond to written guest complaints within five business days. If a grievance or complaint under this policy has not been responded to, guests can escalate their concerns to any supervisor or director at the company. If a guest is not satisfied with a response, they can appeal internally with a deputy director or director, or directly to the local supportive housing agency.

Confidentiality in the reasonable accommodation process

Urban Alchemy shall keep confidential and secure any medical information obtained in connection with a request for reasonable accommodation, as well as the confidentiality of all associated communications as required by applicable law. Any information disclosed will only be shared with individuals on a need-to- know basis.

Requesting an Accommodation or Modification

To receive a reasonable accommodation or modification, a guest is responsible for making such request. Even though a guest does not need to use the words “reasonable accommodation” or “reasonable modification,” it is a good idea to use both words so that requests can be directed to the appropriate person or department without delay. Urban Alchemy prefers that requests are done in writing by email, however, each shelter has available accommodation and modification forms.

After making an accommodation or modification request, Urban Alchemy may request supporting medical documentation to corroborate that a guest has a qualifying disability (unless the request is related to a service animal). The organization may also request additional information about how the requested accommodation or modification is related to a disability. Accommodations may be requested without a guest having to disclose their diagnosis, but guests are required to make known what limitations they are experiencing due to their disability.

An individual’s receipt or denial of an accommodation does not preclude the individual from making another request at a later time if circumstances change or due to any evolving limitations arising from a disability (e.g., existing limitations worsen due to the disability).

Administrative Complaints

Title II of the ADA is enforced by the U.S. Department of Justice (DOJ). Section 504 can be enforced by individual federal agencies, which may have arrangements for shared enforcement with the DOJ.

If you believe that you have been discriminated against for making a good-faith request for an accommodation or modification, or for receiving a modification or accommodation, Urban Alchemy strongly recommends you report such discrimination to any Director at the site or facility, or, in the alternative, to make a report directly with HR at hr@urban-alchemy.us. You can also file an administrative complaint with the agencies responsible for enforcing such laws. At the federal level, this is the U.S. Department of Justice or the U.S. Department of Housing and Urban Development. Reports may also be made at the state or city level to the appropriate agency.

Review and Updates

This policy will be reviewed periodically by the Executive Team to ensure alignment with legal, regulatory, and business requirements. Updates will be made as necessary to reflect changes in legislation, industry best practices, contract requirements, and operational needs.