Rental Housing Discrimination on 

the Basis of Mental Disabilities: 

Results of Pilot Testing 

Study of Rental Housing 

Discrimination on the Basis 

of Mental Disabilities: 

Final Report

U.S. Department of Housing and Urban Development | Office of Policy Development and Research
RENTAL HOUSING 

DISCRIMINATION ON THE BASIS 

OF MENTAL DISABILITIES: 

RESULTS OF PILOT TESTING

STUDY OF RENTAL HOUSING 

DISCRIMINATION ON THE BASIS 

OF MENTAL DISABILITIES: 

FINAL REPORT

Prepared by

Joy Hammel

Janet Smith

University of Illinois at Chicago

Susan Scovill

Consultant

Ron Campbell

M. Davis and Company, Inc.

Rui Duan

HDR, Inc.

Prepared for

U.S. Department of Housing and Urban Development

Office of Policy Development and Research

Submitted by

M. Davis and Company, Inc. 

August 2017
Acknowledgments

This project could not have been completed successfully 

without the commitment, dedication, and hard work 

of many. We particularly thank the research team and 

administrative support staff at M. Davis and Company, Inc. 

Thanks are also due to Madeline Hoffman for assisting with 

coordination, quality control, and guidance throughout 

the testing process and to May Raad of HDR, Inc., for their 

analysis contributions. Finally, this study would not have 

been possible without the work of our local testing organizations, Access Living in Chicago (Jamie Wichman, Kelly 

Chen) and The Equal Rights Center in Washington, D.C. 

(Kristen Barry and Valentine Khaminwa), and our outstanding group of testers—many of whom are members of the 

very disability community that is the focus of this study.

A panel of expert advisers made invaluable contributions 

to the authors’ understanding of the housing experiences 

and challenges faced by people with mental disability, 

reasonable accommodations, and protocol design and 

data analysis. The panel members (and their organizational affiliations at the time of the study) were Michael 

Allen, Relman, Dane & Colfax, PLLC; Anne Cameron 

Caldwell, Research and Innovations Officer and Director 

of the Autism NOW Resource Center, The ARC; Arlene 

Kanter, Co-Director of the Syracuse University Center on 

Human Policy, Law, and Disability Studies; Marti Knisely, 

Community Support Initiative, the Technical Assistance 

Collaborative; Katherine McDonald, Associate Professor, 

Syracuse University; Tia Nelis, Self-Advocacy Specialist at 

the Rehabilitation Research and Training Center, Institute 

on Disability and Human Development, University of 

Illinois at Chicago; Jan Peters, Executive Vice President 

and Chief Operating Officer, Eden Housing Inc.; Susan 

Ann Silverstein, Senior Attorney, Foundation Litigation, 

AARP; Karen Tamley, Commissioner of the Mayor’s Office 

for People with Disabilities, City of Chicago; Victoria 

Tedder, Housing Counseling and Advocacy Program, San 

Francisco Independent Living Resource Center; and Sam 

Tsemberis, Pathways to Housing. Many thanks are due to 

Kim Savage for her assistance in managing the expert panel.

Anne Fletcher from the U.S. Department of Housing and 

Urban Development, Office of Policy Development and 

Research, provided excellent guidance and oversight 

throughout this research effort.

Finally, special thanks and remembrance to Bonnie Milstein, 

a lifelong advocate for disability rights and social justice, 

who served on the initial project team and coordinated the 

expert panel.

Disclaimer

The contents of this report are the views of the contractor and do not necessarily reflect the views or policies of the U.S. Department 

of Housing and Urban Development or the U.S. government.
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Contents

Executive Summary................................................................vi

Introduction....................................................................vi

Summary of Findings.....................................................vii

Recommendations.........................................................viii

Study Overview...................................................................... 1

Purpose and Goals of the Study ...................................... 1

Background and Previous Research on Housing 

Discrimination Against People With MD.................. 1

Overview of Testing Focused on Individuals With MD.... 2

Paired Testing Protocols and Field Management ..................... 4

Overview of Testing for Housing Discrimination............. 4

Strengths and Limitations of Paired Testing in Different 

Testing Methods....................................................... 4

Overview of the Paired Testing Design and Process......... 5

Pretesting ........................................................................ 5

E-mail Testing Protocols.................................................. 6

Telephone Testing Protocols............................................ 9

In-Person Testing Protocols........................................... 12

Overall Data Collection Oversight, Management, and 

Quality Control...................................................... 16

Sampling Methods................................................................ 17

Sampling Frame............................................................ 17

Allocation of Tests Across Market Size........................... 17

Sample of Metropolitan Areas........................................ 18

Selection of Advertised Units ........................................ 20

Risk of Detection........................................................... 21

Sampling of Units ......................................................... 21

Analysis of Testing Findings ................................................. 23

Summary of Tests Conducted........................................ 23

Measuring Differential Treatment .................................. 24

Data Analysis ................................................................ 27

Measuring Discrimination............................................. 27

Findings of Incidence of Discrimination............................... 29

Data Reliability and Limitations .................................... 29

E-mail Testing Findings................................................. 29

Reasonable Accommodation Requests via E-mail............ 31

Telephone Testing Findings........................................... 32

Reasonable Accommodation Requests via Telephone ...... 34

In-Person Testing Findings............................................ 36

Findings From the Evaluation of Different Testing Modes..... 38

People With Disabilities As Testers: Is It Feasible?......... 38

Tester Profile: How Do You Isolate and Reveal Disability?.. 38

E-mail Testing: Strengths and Weaknesses..................... 40

Telephone Testing: Strengths and Weaknesses............... 41

In-Person Testing: Strengths and Weaknesses As 

Evaluated by Testers With MD and Companion 

Testers ................................................................... 42

Summary, Conclusions, and Recommendations.................... 47

Project Leadership and Design ...................................... 49

Recruitment and Selection of Testers............................. 49

Training and Data Collection......................................... 49

Appendix A: Qualitative Analyses and Findings on Overt 

and Subtle Discrimination Against People With Mental 

Disabilities by Different Testing Modes................................. 50

Qualitative Analysis Methodology ................................. 50

Data Analysis ................................................................ 51

Results .......................................................................... 53

Discussion and Conclusions.......................................... 61

Appendix B: References........................................................ 63
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List of Tables

Table 1. Testing Timeline .................................................. 5

Table 2. Subject Lines Assigned Randomly for All 

E-mail Tests......................................................... 6

Table 3. E-mail Tester Scripts............................................ 7

Table 4. Reasonable Accommodation Request by Type 

of Disability......................................................... 8

Table 5. Telephone Tester Scripts.................................... 10

Table 6. Examples of How MD May Affect Functional 

Aspects of Life and Maintenance of Housing ..... 14

Table 7. Sampling Frame for People With MD, by Test 

Type .................................................................. 17

Table 8. Rental Market Sampling Frame.......................... 17

Table 9. Allocation of Tests Across Market Size ............... 17

Table 10. Distribution of Population With Disabilities 

and Proportion With Cognitive Disabilities, 

2009–2011........................................................ 18

Table 11. Pool of Possible Markets (MSAs) Based on 

Statistical Criteria for Inclusion ......................... 19

Table 12. Selected Markets by Size and Olmstead Status.... 20

Table 13. Sample Allocation Plan Across Communities 

and Test Types by Market Size ........................... 20

Table 14. Criteria for Inclusion in/Exclusion From Unit 

Sample .............................................................. 21

Table 15. Total Tests Conducted by Test Mode.................. 23

Table 16. E-mail Sample Allocation by Market Size .......... 23

Table 17. Telephone Testing Allocation by Market Size ..... 24

Table 18. In-Person Sample Allocation by Location .......... 24

Table 19. Differential Treatment Indicator Matrix.............. 25

Table 20. Possible Outcomes Matrix ................................. 27

Table 21. Differential Treatment in Response Received 

for Renters With MD (I/DD+MI) Found in 

E-mail Testing ................................................... 29

Table 22. Summary of Differential Treatment of Renters 

With MD (I/DD+MI) Found in E-mail Testing ... 30

Table 23. Differential Treatment in Response Received 

for Renters With MI Found in E-mail Testing .... 31

Table 24. Summary of Differential Treatment of Renters 

With MI Found in E-mail Testing ...................... 31

Table 25. Summary of Reasonable Accommodation 

Requests by Testers With MD Found in E-mail 

Testing............................................................... 32

Table 26. Summary of Differential Treatment of Renters 

With MD Found in Telephone Testing............... 32

Table 27. Summary of Differential Treatment of Renters 

With MI Found in Telephone Testing ................ 33

Table 28. Summary of Differential Treatment of Renters 

With I/DD Found in Telephone Testing ............. 33

Table 29. Summary of Reasonable Accommodation 

Requests by Testers With MD Found in 

Telephone Testing.............................................. 34

Table 30. Summary of Reasonable Accommodation 

Request Responses by Specific Markets ............. 35

Table 31. Summary of Differential Treatment of Renters 

With MD Found in In-Person Testing................ 36

Table 32. Summary of Differential Treatment of Renters 

With MI Found in In-Person Testing ................. 36

Table 33. Summary of Differential Treatment of Renters 

With I/DD Found in In-Person Testing.............. 37

Table 34. Pros and Cons of E-mail Testing ........................ 41

Table 35. Pros and Cons of Telephone Testing .................. 42

Table 36. Pros and Cons of In-Person Testing ................... 46

Table A-1. Samples of Telephone and In-Person Testing ..... 51

Table A-2. Subtle Discrimination Indicator Keyword 

Groups.............................................................. 52

Table A-3. Response Difference in E-mail Content.............. 53

Table A-4. Subtle Discrimination Responses in Multiple 

Categories ......................................................... 53

Table A-5. Subtle Discrimination in E-mail Testing............. 55

Table A-6. Housing Provider Responses to RA Requests in 

E-mail Testing ................................................... 55

Table A-7. Open Door/Closed Door in E-mail Testing ........ 55
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Table A-8. Subtle Discrimination in Telephone Testing....... 57

Table A-9. Overt Discrimination in Telephone Testing........ 58

Table A-10. Housing Provider Responses to RA Requests 

in Telephone Testing.......................................... 58

Table A-11. Open Door/Closed Door in Telephone Testing... 58

Table A-12. Subtle Discrimination in In-Person Testing........ 60

Table A-13. Overt Discrimination in In-Person Testing......... 60

Table A-14. Open Door/Closed Door in In-Person Testing ... 61

List of Figures

Figure 1. Flow of Sample Selection and Testing Process ... 22

Figure 2. Response Rate of E-mail Paired Tests................. 23

Figure 3. Response Rates of E-mail Paired Tests for 

Protected Testers Identifying as a Person With 

MI.................................................................... 30

Figure A-1. E-mail Testing Responses................................... 50
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Executive Summary

Introduction

More than 15 million people in the United States have some 

type of mental disability (MD). Many of these individuals seek 

community-based housing in the rental market. As a result of the 

U.S. Supreme Court’s decision in Olmstead v. L.C., 527 U.S. 581 

(1999), an increasing number of individuals with disabilities 

are moving from nursing homes and other institutional and 

segregated settings into community-based settings. As a result, 

equality of access to the rental housing market has become 

even more of a critical policy issue.

This study represents the first comprehensive examination of 

discrimination in the rental housing market against people 

with MD, specifically focusing on people with mental illness 

(MI) and those with intellectual or developmental disability (I/

DD). The goal of the study is to increase the understanding of 

the forms and prevalence of housing discrimination against this 

community as its members seek market-rate rental housing.

The overall study design included a stepwise approach to 

testing the feasibility of involving individuals with MI and I/DD 

in discrimination testing and to obtaining data regarding their 

treatment by rental housing providers. The study was initiated 

with a comprehensive review of relevant literature and the 

convening of multiple focus groups that included individuals 

with MI and I/DD, disability and fair housing organizations, 

and policymakers. As very little discrimination research to date 

has actually included these target populations as participants in 

the process, the focus groups were particularly informative in 

identifying specific issues faced by individuals with MI and I/

DD throughout the process of seeking rental housing. Barriers 

identified by the focus group process included—

•	 Negative and stigmatizing reactions and attitudes by 

housing providers and their agents.

•	 Improper requests to disclose personal and disability-related information. 

•	 A lack of understanding about what types of reasonable 

accommodations may be needed by individuals with MD.

•	 The denial of proper requests for reasonable accommodations.

•	 Steering toward specific housing, buildings, or units based 

on an individual’s disability.

From focus group input, the authors learned that individuals 

with MI and I/DD experience potential discrimination at 

different points of time in the rental process: when initially 

attempting to gain information about available units, during the 

application process, and even after moving in and during their 

tenure in their home.

After the literature review and focus group phases were conducted, protocols for conducting discrimination testing were 

designed. A matched-pair testing design was created to examine 

differences in treatment by housing providers between individuals with MI and I/DD (protected testers) and individuals 

without such disabilities (control testers). Paired testers were 

matched on key characteristics other than disability, such as 

income, race, gender, and age. The testing sought to examine 

differences in testers’ treatment across three modes of contact 

with housing providers: e-mail, telephone, and in person. These 

modes generally represent the primary ways people, including 

individuals with MI and I/DD, might seek rental housing. In 

two of the modes, e-mail and telephone testing, a request for 

a reasonable accommodation was also made by the protected 

tester to allow for the examination of housing providers’ 

responses.

An initial set of exploratory tests was administered to examine 

and refine testing protocols before broad-scale testing. After the 

exploratory testing, broad-scale pilot testing was conducted in 

multiple urban rental markets across the United States. Testing 

in each mode was divided equally between the two subcategories of MD (MI and I/DD), and more than 1,000 matched-pair 

tests were administered—359 by e-mail in nine rental markets, 

668 by telephone in nine rental markets, and 101 in person in 

two large rental markets.

This study represents the first time that individuals with MI 

and I/DD have been enlisted to serve as in-person testers in 

a comprehensive, multicity housing discrimination study. 

As a result, this study also contributes significantly to our 

knowledge about research methodologies that are accessible, 

inclusive, and participatory to individuals with MI and I/DD. 

Based on feedback from individuals with MI and I/DD, a testing 

methodology was developed for this study in which individuals 

without MI and I/DD were trained and accompanied protected 

testers as companions during in-person tests. These companion 

testers served three roles: first, to act as a friend and natural 

support to the protected tester during the testing; second, to 
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further disclose the MD of the protected tester to the housing 

provider; and third, to assist in preparing detailed field notes 

to document their testing experiences.

Summary of Findings

The testing conducted in this study documented significant 

levels of adverse differential treatment toward individuals with 

MI and I/DD when compared with individuals who did not 

have MD. Pilot testing revealed that individuals with MI and I/

DD were—

•	 Less likely to receive a response to their inquiry (17.55 percent 

of people without disabilities received a response compared with 9.19 percent of people with MI and I/DD in 

e-mail testing).

•	 Less likely to be told an advertised unit was available (5.94 

percent of people without disabilities were told that the 

advertised unit was available compared with 0.99 percent 

of people with MI and I/DD in in-person testing).

•	 Less likely to be invited to contact the housing provider (7.69 

percent of people without disabilities were invited to 

contact the housing provider to see the unit compared 

with 0.00 percent of people with MI and I/DD in e-mail 

testing).

•	 Less likely to be invited to inspect the available unit (21.26 

percent of people without disabilities were invited to 

inspect the unit compared with 16.47 percent of people 

with MI and I/DD in telephone testing).

•	 More likely to be encouraged to look at a different unit than the 

one advertised in telephone testing, a potential indicator 

of steering people with MI and I/DD toward specific 

buildings or areas within rental complexes, resulting in 

segregated living patterns.

•	 Treated adversely at disparate rates depending on disability 

type, with higher rates of adverse treatment found for 

individuals with MI than for individuals with I/DD. This 

finding may indicate that individuals with MI face more 

negative stereotypes and stigma from rental housing 

providers.

In both e-mail and telephone testing, a significant percentage 

of individuals with MI and I/DD also experienced adverse treatment with respect to a request for a reasonable accommodation. 

The reasonable accommodations requested were identified as 

specific to the protected tester’s functional needs, such as the 

use of an assistance animal to manage emotional and cognitive 

issues or the need for a verbal reminder from the landlord to 

pay the rent on time.

•	 The willingness of a housing provider to grant a request for an 

accommodation varied by mode of testing, with the rate of 

granting a request for a reasonable accommodation being 

significantly higher when the request was made by telephone 

(59.14 percent willing to accommodate; 40.86 percent not 

willing to accommodate) than by e-mail (15.38 percent 

willing to accommodate; 84.62 percent not willing to 

accommodate).1

•	 Regardless of testing mode, a significant percentage of people 

with MI and I/DD were given a negative response to their 

reasonable accommodation request, ranging from outright 

denials to more subtle barriers, such as an indication that 

the individual with MD would be responsible for actively 

seeking out and appealing the denial of his or her request 

with higher-level managers whose name and contact 

information were then not provided.2

The research also found that many housing providers simply 

did not respond to housing inquiries but that the probability 

of a response increased based on the interpersonal nature of 

the interaction. For example, in-person inquiries received the 

highest rates of response, followed by telephone inquiries, with 

e-mail inquiries the most likely to be ignored.

Each of the three testing modes used (e-mail, telephone, and 

in person) yielded a different form of testing data that, when 

viewed together, not only produced evidence of discrimination 

but also showed promise for bringing testing to a national scale 

and provided insights on opportunities for future testing.

Finally, this study yielded significant findings on how to conduct testing with testers with MD. In-person testing specifically 

involving a person with MD demonstrated that people with MI 

and I/DD can serve as effective testers.3 The evidence from the 

1

 In-person testing protocols did not include a request by the protected tester for a reasonable accommodation. 

2

 In addition, testing results varied by metropolitan statistical area (MSA), with the rate of granting a reasonable accommodation request being lowest in the ChicagoJoliet-Naperville, IL-IN-WI MSA (38.6 percent), and highest in the Albuquerque, NM MSA (75.5 percent).

3

 Contributing to these outcomes were training and support provided to the testers, the use of a companion tester, and the overall coordination of the testing by 

community-based disability rights organizations.
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in-person testing suggests strongly that both populations could 

also do telephone testing if the same approach to training and 

debriefing is used.

Recommendations

These findings led the authors to make the following recommendations.

•	 A broad-based education initiative should be created to 

educate housing providers, including owners and their 

agents, about fair housing rights and obligations, including appropriate policies and practices when dealing with 

individuals with MI, I/DD, and other MD.

•	 Public and private housing, disability, and civil rights 

organizations should redouble efforts to engage and educate 

the community of people with MI and I/DD about their rights 

under federal, state, and local antidiscrimination laws, how 

to recognize potential discrimination, and what actions to 

take when faced with discrimination.

•	 Additional research is necessary to better understand the 

scope and severity of the discriminatory barriers encountered 

by individuals with MI and I/DD as they seek, obtain, and 

retain accessible rental housing. Findings from this pilot 

study effort suggest that a national testing effort would be 

feasible.

•	 Individuals with MI and I/DD can and should be an integral 

part of future housing research and testing, housing discrimination education initiatives, and efforts to strengthen 

housing policy to promote equal housing opportunity.
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Study Overview

Purpose and Goals of the Study

The existing research related to housing discrimination and its 

effect on individuals with mental disability (MD)4 is particularly limited; therefore, HUD launched this study with the goal of 

increasing the understanding of the experiences of individuals 

with MD as they seek rental housing.

The following research objectives identified by HUD guided 

this study.

•	 Develop and implement different testing methods and 

approaches, evaluating their strengths and weaknesses, to 

establish a series of protocols for conducting paired testing 

to determine and measure the degree to which people 

with MD experience discrimination in the search for rental 

housing.

•	 Conduct pilot testing using different testing procedures to 

develop protocols for generating reliable estimates of any 

difference in the treatment of people with MD during the 

process of searching for rental housing.

•	 Produce a qualitative and quantitative analysis of Title VIII 

Automated Paperless Office Tracking System (TEAPOTS) 

data.5

•	 Produce five short papers that expand the understanding 

in the field of housing discrimination on the basis of MD.6

The purpose of this study was not to generate national 

estimates of housing discrimination on the basis of MD, but 

rather to pilot methods for conducting paired testing with this 

protected class with the goal of demonstrating a potentially 

feasible approach to future nationwide testing.

Additional short papers have been developed to inform 

researchers, practitioners, and consumers about the shape 

and scope of housing discrimination against people with MD. 

These papers focus on the following related topics.

•	 Short Paper 1: Systematic Literature Review of Research 

on Discrimination in Rental Housing on the Basis of Mental 

Disabilities.

•	 Short Paper 2: Getting Into and Maintaining Housing in the 

Private Rental Market: Experiences of People With Mental 

Disabilities.

•	 Short Paper 3: The Potential for Discrimination in Rental 

Housing for People With Mental Disabilities Moving Out of 

Institutions to Community Living Under Olmstead.

•	 Short Paper 4: Accessible & Participatory Methods for 

Involving People With Mental Disabilities in Housing Discrimination Testing.

•	 Short Paper 5: Rental Housing Access & Discrimination 

Experienced by People With Multiple Disabilities.

Background and Previous Research 

on Housing Discrimination Against 

People With MD

The federal Fair Housing Act (FHA)7 prohibits discrimination 

in the sale, rental, and financing of housing and in other 

housing-related transactions, on the basis of seven protected 

classes: race, color, religion, national origin, sex, familial status, 

and disability. Housing providers are prohibited from considering these protected characteristics as the basis for rejecting 

or refusing to negotiate with individuals seeking housing or 

housing-related services and from misrepresenting or limiting 

housing opportunities based on any protected characteristic.

In addition to having the basic prohibitions of the FHA against 

housing discrimination for all protected classes, people with 

disabilities have three additional protections under the FHA: 

(1) multifamily housing with four or more units, built for 

first occupancy after March 13, 1991, must meet specific, if 

4 Mental disability is defined as “(1) having a mental or psychological disorder or condition that limits a major life activity, including working; (2) any other mental 

or psychological disorder or condition that requires special education or related services; (3) having a record or history of a mental or psychological disorder or 

condition which is known to the employer or other entity covered by this part; or (4) being regarded or treated by the employer as having, or having had, any mental 

condition that makes achievement of a major life activity difficult” (Foster v. City of Oakland, 2009 U.S. Dist. LEXIS 70094).

5

 TEAPOTS provides data records regarding filed discrimination complaints. The analysis of TEAPOTS data on housing complaints based on MD is documented in a 

separate report.

6

 These papers have been published by HUD separately.

7

 Title VIII of the Civil Rights Act of 1968 as amended in 1988, 24 U.S.C. §§ 3601, et seq.
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relatively modest, accessibility requirements that allow for a 

person with disabilities to access and use both the housing 

units and associated public use and common use areas; (2) 

housing providers must make reasonable accommodations 

to their rules, policies, practices, and services necessary for 

people with disabilities to equally enjoy the property; and 

(3) housing providers must allow residents with disabilities, 

at the residents’ expense, to make reasonable modifications 

to physical structures necessary in order for them to use and 

enjoy the property.

In addition, in 1999, the United States Supreme Court ruled in 

Olmstead v. L.C., 527 U.S. 581, that unjustified segregation of 

people with disabilities constitutes discrimination in violation 

of Title II of the Americans with Disabilities Act.8 Although the 

beneficiaries of this ruling are all people with disabilities, the 

decision has had a particularly significant effect on individuals 

with MD living in restrictive and segregated settings, including 

nursing homes and institutions. As states seek to comply with 

the Olmstead ruling, people with MD are moving out of institutional settings in larger numbers and increasingly seeking 

housing in the private rental market.

Individuals with MD often face multiple challenges when they 

seek housing in the rental housing market. Challenges may 

include both economic barriers and stigma or suspicion on 

the part of housing providers that limits their access to diverse 

housing choices. Complaints based on disability make up the 

largest number of housing discrimination complaints filed with 

federal, state, and local fair housing agencies and with private 

fair housing groups (HUD, 2014a). In 2014, disability complaints made up 51.84 percent, or 14,271 of the total number 

of 27,528 fair housing complaints filed with HUD, its partner 

state and local agencies, and private fair housing enforcement 

organizations (NFHA, 2015).9 A significant portion of these 

complaints involves people with MD. For example, HUD (n.d., 

Table 1) noted that, in fiscal year 2010, fully 40 percent of the 

disability complaints involved MD, which includes people with 

psychiatric disability or mental illness (PD/MI) and intellectual 

or developmental disability (I/DD).

In the United States, the term “mental disability” includes 

a wide range of conditions. According to the U.S. Census 

Bureau’s Survey of Income and Program Participation, about 

6.3 percent of the U.S. population in 2010, approximately 15.2 

million people age 15 or older, had difficulty with cognitive, 

mental, or emotional functioning (Brault, 2012). This number 

includes people with both PD and I/DD. Using a broader definition and different methodology, however, the Substance Abuse 

and Mental Health Services Administration (SAMHSA) estimates 

a much larger number of people who have experienced some 

form of PD in a year: 44.5 million adults age 18 or older.10 This 

total comprises nearly 20 percent of the adult U.S. population. 

Of this total, about 10.4 million adults (4.6 percent) of U.S. 

population have severe MI (APA, 2000). Braddock et al. (2011) 

used a figure of 4.8 million for the population with I/DD.

Little is known about the forms of discrimination people with 

MD experience when searching for housing. According to 

NCD (2001), people with any disability are likely to encounter 

discrimination in three ways: (1) the housing is inaccessible, (2) 

the landlord assumes that renters with disabilities are unable to 

live independently, and/or (3) the housing staff are unwilling to 

modify rules and policies that exclude people with disabilities. 

For people with MD, access to housing also may be affected by 

histories of homelessness or incarceration, both of which can be 

potential sources of additional discrimination.

Overview of Testing Focused on 

Individuals With MD

Although fair housing testing related to the barriers faced by the 

disability community has been conducted in some metropolitan 

areas, research on housing discrimination against people 

with MD is particularly limited. Before this study, the most 

significant examination of the level and nature of this type of 

disability discrimination was published in a 2005 HUD Disability Discrimination Study report (DDS 2005; HUD, 2005).

DDS 2005 explored the development of methodologies in 

testing for housing discrimination on the basis of MD using a 

paired testing methodology previously used in testing for housing discrimination on the basis of race and ethnicity. DDS 2005 

employed a handful of in-person tests by individuals with MD 

and telephone tests by testers without disabilities purportedly 

calling on behalf of individuals with MD.

8

 The Americans with Disabilities Act of 1990, 42 U.S.C. §§ 12101, et seq.

9

 This percentage is an increase from 49.51 percent of all complaints submitted in 2013.

10 SAMHSA defines mental illness as the presence of mental, behavioral, or emotional disorder based on the diagnostic criteria in APA (2000).
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Key findings of DDS 2005 exploratory testing included—

•	 It is feasible to conduct in-person testing, and people with 

MD can effectively serve as testers.

•	 It is challenging to recruit people with MD who can 

handle the role of a tester, and some individuals may need 

extra support and assistance.

•	 Tests in which the person with MD was accompanied by 

a “friend” without MD proved to be credible and effective 

but significantly raised the cost of testing.

•	 Testers with MD may be more effective if they conduct 

tests relatively infrequently, and it would be preferable to 

extend the testing over a relatively long period of time, 

unless a large pool of testers with MD could be recruited.

The pilot testing documented in this report sought to build on 

the key findings observed in DDS 2005.
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Paired Testing Protocols and Field Management

Overview of Testing for Housing 

Discrimination

Testing is an investigative technique that serves as a powerful 

tool for directly observing differences in treatment in the 

practices of housing providers and their agents. Testers pose 

as individuals seeking housing, contacting housing providers 

in a variety of ways to inquire about housing opportunities. 

The origins of paired testing as a method of studying housing 

discrimination and identifying differential treatment lie in fair 

housing enforcement, in which testing is often used to identify 

individual housing providers who are violating housing 

discrimination laws.11 When paired testing is applied to large, 

representative samples and implemented with rigorous controls using a quasi-experimental research design, it can provide 

reliable estimates of the differences in treatment among 

different populations and of the prevalence of discriminatory 

behavior toward different protected classes. Paired testing also 

can be used to identify discrimination by a specific provider 

that violates the FHA.

HUD has used testing as an investigative and research tool 

for more than 40 years to identify and document discriminatory housing practices.12 HUD has funded a wide variety 

of testing-based initiatives, including four national studies 

using the methodology of matched-pair testing to measure the 

levels of housing discrimination based on race and ethnicity, 

and HUD has also funded national studies on discrimination 

against same-sex couples, families with children, people who 

are deaf, and people who use wheelchairs.13 For people with 

disabilities, testing can be used to identify instances of direct 

discrimination, to obtain evidence of unequal treatment, and 

to determine whether reasonable modifications or accommodations are permitted to enable a person with a disability to fully 

enjoy living in the housing.

Strengths and Limitations of Paired 

Testing in Different Testing Methods

Testing can be conducted in a variety of configurations, 

depending on the issues being examined, but the most common 

and effective approach to observing differences in treatment 

based on a particular characteristic is matched-pair testing. 

In this type of testing, two testers are assigned profiles that 

make them similarly situated and qualified for the housing 

being tested, differing only in their membership in a protected 

class. The testers contact a housing provider and inquire 

about available housing. Matched-pair testing allows for the 

observation of housing providers’ actions and statements and 

measures whether and how people are treated differently 

during the housing search process. The tester exhibiting the 

characteristic being tested (for example, a disability) is referred 

to as the protected tester and the tester without the characteristic 

in the pair is the control tester. The key to testing is to ensure 

pairs are well matched on all variables except the one variable 

or characteristic to be tested—this procedure ensures that 

test results are unambiguous. The matched characteristics of 

the tester pairs in this study included race, gender, age range, 

education, employment, household size, and income. The 

single variable that differed between matched testers was the 

existence or absence of a particular MD.14 To minimize the risk 

of detection by housing providers during testing, some of the 

characteristics assigned to a test pair were slightly enhanced to 

favor the protected tester.

11 HUD has noted that: “Fair housing advocates have turned to testing as the most effective tool to investigate violations of fair housing law” (HUD, 2014b).

12 Testing cannot capture all forms of housing discrimination. It is most effective at the early stages of the search for housing, including contacting providers to 

inquire about housing opportunities and visiting properties to view units and obtain information about the rental (or sales, lending, and insurance) process and 

associated costs. Testers generally have fictitious profiles, and testing rarely proceeds through the actual application stage. Testing also does not effectively capture 

issues found later in the housing process, such as decisions made based on submitted applications or how residents in a protected class are treated after they move 

in, such as maintenance or lease termination.

13 See HUD (2013a) and HUD (2015).

14 Because of the need to isolate the single variable of MD (either MI or I/DD) and the need to ensure that the profiles made the testers financially qualified for the 

housing, the testing protocols could not reflect the real life experience of many people with MD searching for rental housing, whose lives and characteristics are 

much more complex than the rigors of research testing would allow.
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Overview of the Paired Testing Design 

and Process

This study included testing components in nine selected rental 

markets using matched-pair testing via e-mail, telephone, and 

in-person visits.15 The overall goals were to (1) enhance the 

understanding of the barriers faced by individuals with MD 

in their search for rental housing, (2) determine the type and 

nature of discrimination that might be encountered, (3) evaluate the utility of different approaches to paired testing when 

conducting research on housing discrimination on the basis 

of MD, and (4) assess the feasibility of employing individuals 

with MD as testers. The testing in this study was not designed 

to produce a national estimate of rental discrimination, but 

rather was designed to develop and evaluate the utility of 

different testing approaches and techniques for measuring 

housing discrimination among this particular protected class.

As shown in Table 1, the testing for this study took place over 

a 1 1/2-year period in 2013 and 2014. The timeframes for 

each mode of testing were staggered, with each new testing 

mode beginning with pretesting to confirm the effectiveness 

of that mode and to assess the need for any methodological 

adjustments. The testing protocols in this study built on the 

protocols established in previous studies; the e-mail testing 

protocols mirrored those used in a national e-mail testing 

study of same-sex couples, and the telephone testing and 

in-person testing protocols mirrored those established in the 

DDS 2005 study, which conducted a small number of exploratory telephone and in-person tests based on MD employing 

some individuals with MD as protected testers.

The e-mail and telephone testing in this study was conducted 

from a central location in Philadelphia, Pennsylvania. The 

in-person testing was performed by local testing organizations 

in two markets: Access Living in the Chicago-Joliet-Naperville, 

IL-IN-WI Metropolitan Statistical Area (MSA; hereafter, Chicago) and The Equal Rights Center in the Washington-Arlington-Alexandria, DC-VA-MD-WV MSA (hereafter, Washington, 

D.C.). These testing organizations recruited, trained, and 

managed the in-person testing in the field with support and 

supervision from the study team.

Pretesting

Before beginning the pilot testing, pretests were conducted for 

each testing mode (e-mail, telephone, and in-person testing). 

The purpose of the pretesting was to ensure that (1) data 

collection protocols and strategies were designed correctly; 

(2) testers were trained to execute the tests appropriately; (3) 

administrative procedures were effective; (4) the data entry, 

coding, and interpretation process accurately captured the 

experiences of testers; and (5) feedback was produced quickly, 

without detection, so as to permit adjustments in the testing 

protocols.

Table 1. Testing Timeline 

2013 2014

3rd Q 4th Q 1st Q 2nd Q 3rd Q 4th Q

Testing

E-mail

Pretest

Pilot testing

Washington, D.C.a/Chicagob

Remaining markets/RA request

Telephone

Pretest

Pilot testing Washington, D.C.a/Chicagob

Pilot testing remaining markets

In person

Pretest

Pilot testing

RA = reasonable accommodation.

a

 Washington-Arlington-Alexandria, DC-VA-MD-WV Metropolitan Statistical Area.

b Chicago-Joliet-Naperville, IL-IN-WI Metropolitan Statistical Area.

15 The rental markets tested were in the following metropolitan statistical areas (MSAs): the Albuquerque, NM; Chicago-Joliet-Naperville, IL-IN-WI; CincinnatiMiddletown, OH-KY-IN; Fresno, CA; Harrisburg-Carlisle, PA; Nashville-Davidson--Murfreesboro--Franklin, TN; New Haven-Milford, CT; Syracuse, NY; and 

Washington-Arlington-Alexandria, DC-VA-MD-WV MSAs.
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Focus group input and a review of relevant literature provided 

information about how people with MD engage in the housing 

search process and identified unique factors affecting their 

housing search. Information from national and local disability 

groups in Washington, D.C., and Chicago helped to identify 

the different sources used to locate housing units available for 

rent. These organizations also assisted in providing testers with 

consistent, realistic, and believable identities and backgrounds. 

In person testers with MD portrayed their own disability and 

additional characteristics consistent with the tester profile 

provided by the study team.

Testing protocols were designed so as to create identities that 

clearly disclosed the protected tester’s MD by incorporating 

supporting information such as previous hospitalization or 

institutionalization and affiliation with relevant community 

support agencies to ensure that the presence of MD was 

unambiguously communicated to the housing provider. This 

background information was also used to provide testers with 

ready answers to the typical types of questions asked by rental 

agents, such as, “Why are you looking at this property?” and 

“Where do you work?”

E-mail Testing Protocols

The e-mail testing did not use individuals serving as testers 

in the traditional sense. Replicating the protocols of HUD 

(2013a), the de facto “tester” was the text of each paired e-mail 

and not the individual sending the e-mails. Test administrators 

sent out all e-mails inquiring about advertised rental units and 

then reviewed and coded the responses. The text of the paired 

e-mails contained similar language asking about the housing 

unit for rent. The only difference between the two e-mails was 

that one e-mail stated the person making the inquiry had MD 

(either MI or I/DD). A total of 359 paired e-mail tests were administered, including 78 paired e-mail tests that incorporated 

a request for a reasonable accommodation in the e-mail of the 

protected tester.

E-mail Testing Script

A benefit of using e-mail for testing is that the message is 

completely controlled and consistent for the protected tester 

and the control tester in the pair. Moreover, an e-mail response 

from a housing provider gives verbatim statements to code and 

analyze in relation to the initial e-mail inquiry. For each e-mail 

test, the subject line (see Table 2) and the message were short 

and relatively neutral in tone, with standard information being 

requested.

Table 2. Subject Lines Assigned Randomly for All 

E-mail Tests 

1. One bedroom apartment

2. Apartment for rent

3. Unit for rent

4. Craigslist - 1br apartment

5. Craigslist Rental

6. Unit availability

7. Apartment posted on craigslist

8. Craigslist apartment posting

9. Inquiry about your apartment

10. Saw your Craigslist Apartment ad

11. In response to your Craigslist listing

A variety of e-mail “scripts” were developed to serve as the 

body of the message (see Table 3). In the body of the text, the 

protected tester discloses disability early in the text in one of 

the following direct manners.

MI—“I have a mental health issue.” 

I/DD—“I have a developmental disability.”

Control—none.

The e-mail text also contained a secondary reveal by the 

protected tester, with a parallel addition by control testers, 

referring to their previous residence.

MI—psychiatric hospital (“I have been living in a psychiatric 

center for the past year”). 

I/DD—group home (“I have been living in a group home for 

the past year”).

Control—dorm, parents, divorce (“I have been living with my 

parents, or just finished school and was living in a dorm, or just 

got divorced”).

The “dual disclosure” text samples in table 3 include reveal of 

the disability plus the alternate living scenarios, which provided 

a sufficient number of options and ensured that the text samples were comparable.

Including both a statement about having a disability and a 

type of previous living arrangement was designed to provide 

clear and unambiguous evidence to a housing provider that 

the prospective tenant had MD. Disclosing the current housing 

situation of the protected tester is important because it not 

only signals that the person has a disability (a requirement for 

that living situation), but it also signals that the applicant does 

not have experience living in the private market, which can 

make the individual appear to be more of a risk to the housing 

provider. This same justification applies to the disclosure of the 
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Table 3. E-mail Tester Scripts 

Protected Tester Control Tester

Hello. I am interested in your 1 br. Apt. on <specify address>. Is it 

available? Is there a time I could come by and see it? I have a <disability 

identifier> and have been living in <alternate housing identifier> and am 

ready to get my own apartment. Thank you. <name>

Hi, my name is <name>, and I am very interested in your 1br apt 

located at <specify address>. I have been living in <alternate housing 

identifier>. Could you let me know if it is still available and when a 

convenient time to view it would be? Thank you. <name>

Hello. Your apartment (<specify location>) seems to be what I had in 

mind. Is it still available? I’d like to come by and view the apartment; 

could you contact me with an available time to do so? I have a <disability 

identifier> and I’ve been living in <alternate housing identifier> but I want 

to get my own apartment now. Thanks, <name>

Hello. I saw your 1 br apt ad on CL at <specify address>. My name 

is <name> and I am looking for a place that matches this description. 

I’ve been living in <alternate housing identifier> and I’m ready to get 

my own apartment. Is it available and, if so, can I see the unit? Thanks, 

<name>

Hello, I am writing in response to your listing for the 1 bedroom 

apartment located at <specify address>. Is it available? May I come and 

see it? I’ve been living in <alternate housing identifier> because I have a 

<disability identifier> and I’m ready to get my own apartment. Thank you 

for your time, <name>.

I saw your ad for a 1Br apartment on Craigslist located at <specify 

location>. Is this apartment still available? I would like to set a time to 

see it. Can you tell me what hours you would be available so we can 

schedule a visit? I’m looking forward to getting my own apt. I have 

been living in <alternate housing identifier>. I can be reached at this 

return email. Thanks, <name>

I saw your ad for a 1Br apartment on Craigslist located at <specify location>. Is this apartment still available? I would like to set a time to see it. 

Can you tell me what hours you would be available so we can schedule 

a visit? I’m looking forward to getting my own apt. I have been living in 

<alternate housing identifier> due to my <disability identifier>. I can be 

reached at this return email. Thanks, <name>

Hello, I am writing in response to your listing for the 1 bedroom 

apartment located at <specify address>. Is it available? May I come 

and see it? Let me know when would be a good time to come by. I’ve 

been living in <alternate housing identifier> and I’m ready to get my 

own apartment. Thank you for your time, <name>.

Hello. I saw your 1 br apt ad on CL at <specify address>. My name is 

<name> and I have a <disability identifier>. I am looking for a place that 

matches this description. I’ve been living in <alternate housing identifier> 

because I have a <disability identifier> and I’m ready to get my own 

apartment. Is it available and, if so, can I see the unit? Thanks, <name>

Hello. Your apartment (<specify location>) seems to be what I had in 

mind. Is it still available? I’d like to come by and view the apartment; 

could you contact me with an available time to do so? I have been 

living in <alternate housing identifier> but I want to get my own apartment now. Thanks, <name>

Hello, I would like set up a time to see the place you advertised on 

<specify the address>. I was wondering, is this apartment still available? 

Also, is there any particular time that works best for a showing? I have 

a <disability identifier> and have been living in <alternate housing identifier>. Please contact me for your most convenient time to view it. Best 

regards, <name>

Hi, I am writing in response to your listing for the 1 bedroom apartment 

located at <specify address>. Is it available? May I come and see it? 

I’ve been living in <alternate housing identifier> and I’m ready to get 

my own apartment. Thank you for your time, <name>.

current housing situation of the control tester, which is necessary for parity. The inclusion of phrases such as “I’m ready to 

get my own apartment” and “I’m excited about my own place” 

provides counterbalancing information that mirrors the profile 

of the protected tester and raises a similar first apartment 

concern for a housing provider.

In 78 of the paired e-mail tests, the protected tester included a 

request for a reasonable accommodation. Table 4 summarizes 

the different reasonable accommodation requests used in those 

additional tests. A request to have an assistance animal live 

at the test property was included because it is an increasingly 

common request by people with MD, particularly for people 

with some forms of MD, and is also becoming a common 

source of fair housing complaints filed.16

The use of a request for a reminder of rent being due was an 

accommodation recommended by the study’s expert panel. It 

reflects a common housing-related concern for people with MD, 

especially because it may help a tenant keep his or her apartment. Before this study, little was known about how housing 

providers would actually respond to this type of request, which 

requires the housing provider to be actively engaged with the 

tenant on a regular basis.

16 HUD uses the term “assistance animals,” which includes emotional support animals. According to HUD’s notice on Service Animals and Assistance Animals for 

People with Disabilities in Housing and HUD-Funded Programs, an assistance animal “is an animal that works, provides assistance, or performs tasks for the benefit 

of a person with a disability, or provides emotional support that alleviates one or more identified symptoms or effects of a person’s disability” (HUD 2013b: 2).
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Table 4. Reasonable Accommodation Request by Type of Disability 

MI I/DD

1. I have a support animal, a cat, which helps me cope with my chronic 

pain. Will that be okay?

I do have some trouble remembering things and I’d like to know if you 

can call me with a reminder that my rent is due a couple of days before 

it’s due. Could you do that? 

2. I have a companion dog named Bob. He makes it possible for me 

to go outside. He will need a grassy area by the apartment. Is there 

someplace he can use?

Could you call me with a reminder that my rent is due a few days 

before? Sometimes I have trouble remembering things and staying 

organized. 

3. I have a therapeutic cat to help me deal with my illness. I want to 

make sure that’s ok with you.

I can’t always remember things. Could you come by or call me to 

remind me that my rent is due? 

4. I have some memory problems. Could you call me with a reminder 

that my rent is due a couple of days before it’s due? 

My dog is my support animal and I want to make sure she can stay 

with me in this apartment.

5. I will need a reminder that my rent is due a couple of days before. 

Could you call or come by to remind me? 

My dog provides emotional support for me and it’s important that I can 

keep her in this apartment. Will that be okay?

6. I sometimes have trouble staying organized and remembering. Could 

you call or come by to remind me that the rent is due in a couple of 

days?

I have a cat as an emotional support and companion animal. I want to 

be sure it’s ok with you for me to keep her.

I/DD = intellectual or developmental disability. MI = mental illness. 

Training for E-mail Testing

In January 2014, project training was conducted for e-mail test 

administrators. All e-mail test administrators were rigorously 

trained to ensure a common understanding of the project’s 

overall purpose, quality assurance responsibilities, and terms 

and definitions. Training topics included an introduction to 

the project, an overview of fair housing and discrimination 

testing, e-mail testing procedures, and a review of testing 

forms. Special emphasis was placed on the fact that test 

administrators were to be objective collectors of information. 

The confidential nature of all study and testing information 

was also emphasized with all study participants. This training 

conformed to standard survey research guidelines and replicated those from HUD (2013a).

E-mail test administrators also received technical training 

for e-mail generation and coding of e-mail responses. This 

training was critical to ensure team members’ understanding 

of specific coding guidelines and requirements and ensure 

consistency and efficiency during the testing process. For the 

coding component of the e-mail testing, the training approach 

involved learning a process that could be effectively and 

consistently replicated across multiple test administrators. The 

same e-mail response was initially coded by the whole team. 

Any differences were discussed and resolved. As this coding 

was critical to the success of the project, this process continued 

for several days until test administrators were uniform in their 

coding of test e-mail responses.

Conducting the E-mail Testing and Quality 

Control

Sampling of the advertised rental units within markets used 

both automated and manual methods. An automated data-mining tool (the “scraper tool”) was used to select and collect data 

from advertisements on craigslist in each study market. In 

addition to automated sampling, local newspapers and other 

materials featuring rental housing advertisements in the selected 

markets were sampled manually, with every seventh post selected. All ads were filtered using the preselected criteria including 

size of the unit, rental amount, and e-mail address. Ads that did 

not provide the necessary information, and those describing 

units set aside for low-income residents, seniors, or people with 

disabilities, were excluded from the sample. A more detailed 

description of the process for selecting advertised units for the 

overall study is provided in the Sampling Methods section.

After rental advertisements from each market were collected, 

postings from each rental market were placed in a database, 

and matched-pair e-mail testing commenced. During the data 

collection period (April through August 2014), rental advertisements were randomly assigned to matched pairs of e-mails from 

a person with MD and a person without MD.

Quality control (QC) was intrinsic to every level of the e-mail 

testing process. The procedures described in this section were 

used in identifying housing units and providers to be tested, 

in executing the tests, and in collecting test data to minimize 

the risk of detection by housing providers who might become 

involved in more than one mode of testing.
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The scraper tool provided samples from internet-advertised 

rental units for the e-mail tests. QC mechanisms were embedded in the scraper tool to remove duplicates, and the test 

administrator was responsible for providing a final QC review 

of the pooled rental advertisements generated by the scraper. 

The test coordinator reviewed randomly selected entries and 

noted any exceptions to the protocols, which were logged in 

an exception file so the same decision rules could be applied to 

subsequent exceptions. For example, if the scraper tool picked 

up an apartment listing that was actually part of a single-family 

home, this listing was removed from the sample and logged so 

that the same protocol would be followed for all future instances.

For each e-mail test, the e-mail text, subject lines, and tester 

names were designed to appear as natural housing inquiries. 

The tests were also matched at the semantic level, so that 

level of interest, length of e-mail text, and word choice were 

all similar. Thus, in all aspects, except for the disability of the 

hypothetical individual who sent the housing inquiry e-mail, 

the paired e-mail tests were matched.

The order of which e-mail was sent first, either the control or 

protected tester’s e-mail, was randomized to address the potential effect on the test outcome of the order in which the inquiry 

was received by the housing provider. The counterbalance 

device used was a Microsoft Access table, which was created 

to randomly select the order in which the control or protected 

e-mails were sent. Microsoft Access forms were used to schedule 

and generate the outgoing e-mails, ensuring consistency in 

timing of outgoing e-mails. Both parts of each pair of e-mails 

were sent to the selected housing provider within a 2-hour 

window. All outgoing e-mails were saved to a computer server 

and linked to the Access database so that accuracy could be 

confirmed.

Test administrators used a sample generation form to compose 

e-mails. The scraper tool filled in most of the required fields 

of the form. Required fields were checked for accuracy by the 

test administrator, and any fields found to be missing were 

completed based on the original advertisement. All the samples 

for e-mail testing were created within 48 hours of the posting 

of the advertisement. After e-mails were generated based on 

the sample generation form, test administrators confirmed that 

the e-mail addresses were correct, the e-mail subject lines and 

text were different between the e-mails, the e-mail addresses and 

sender names matched, and the “when to send” fields were logical.

The ordering of paired tests was randomly assigned, and both 

e-mails within a given pair were sent within 2 hours by an 

automatic scheduler. The test coordinator tracked outgoing 

inquiries from, and incoming responses to, the test e-mail 

accounts daily, and the tracking lists were compared against—

•	 The number of outgoing and incoming e-mails saved to the 

server.

•	 The number of e-mails coded for each entry in the 

tester-level table.

•	 Access-generated e-mail contents for randomly selected 

entries.

Only one inquiry was sent to each advertised property, and 

there was no followup if a housing provider did not respond to 

an e-mail. Tests remained open throughout the entire testing 

period, although most responses (90.1 percent) occurred within 

2 days of the original e-mail. If a response from the advertised 

property was received, testers did not send a return e-mail. For 

cases in which a test e-mail received multiple responses from 

the same advertised property, all were coded in the Access database.

The Microsoft Access program used for coding input was 

custom designed to ensure complete, accurate, and high-quality 

data. For example, acceptable ranges for responses were preprogrammed to help prevent data entry error. In addition, the 

possibility of incomplete or missing data was prevented by not 

allowing a coder to proceed to the next field or screen until all 

fields were complete. During the actual testing phase, data were 

examined daily and validation was performed on 20 percent 

of each test administrator’s work using double-entry coding to 

respondents’ e-mails to verify responses before inclusion in the 

final datasheet and before being signed off by the test coordinator. All tests underwent rigorous review by the study team to 

help ensure high quality, consistency, completeness, accuracy, 

clarity, and usability.

Telephone Testing Protocols

As in the MD exploratory testing of DDS 2005, the telephone 

tests in this study were conducted by people without MD purportedly calling on behalf of someone with MD. Given the large 

number of telephone tests to be conducted over a relatively 

short period of time and the challenges of recruiting, training, 

and supporting testers with MD noted in DDS 2005, practical 

considerations and concern for the burden on the testers with 

MD led to the decision to use proxy testers who did not have 

MD for the telephone testing in this study. Therefore, the 

telephone testing process involved the recruitment and training 

of people without disabilities to serve either as the control tester 

or as the protected tester in the role of a proxy calling on behalf 

of a relative or friend with MI or I/DD.
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After the pretesting, it was determined that the telephone testing would also include a request for a reasonable accommodation related to the stated disability on behalf of the person with 

MD. The two reasonable accommodation requests used were 

either (1) a request that the housing provider give the tenant 

a reminder to pay rent or (2) a request that the tenant be 

allowed to have an assistance animal in the unit.17 One of the 

two accommodation requests was made for each MI or I/DD 

telephone test. One-half of the testers for each group requested 

one of the two accommodations. Reasonable accommodation 

requests were included in all telephone test profiles and tester 

instructions. Reasonable accommodation requests were to be 

made after the information regarding availability and the rental 

unit was obtained, and thus requests were actually made in 

629 of the 668 telephone tests conducted, because in 39 of the 

tests, the conversation with the provider ended before reaching 

the accommodation request.

Procedures and Scripts for Tester 

Telephone Calls

The order of telephone calls to the housing provider by the 

protected tester and the control tester was randomized, and the 

call placements occurred no less than 1 hour and no more than 

4 hours apart. The timing strategy was designed to increase the 

likelihood of speaking with the same housing provider or agent 

and to minimize the possibility of an incomplete test because 

the unit was rented between the paired calls.

Proxy Relationships

The telephone testing protocol originally included the use of 

proxies calling on behalf of both the control and protected 

testers. During the telephone exploratory testing, however, it 

was determined that use of a proxy for both testers within the 

short timeframe created an unacceptable risk of detection by 

housing providers, and thus the proxy caller for control testers 

was dropped and the control testers called on their own behalf.

The tester calling as the proxy for the person with MD posed as 

a friend or family member (and not a mental health professional 

or case manager) of the potential renter. Protected proxies 

expressly stated that they were calling for a person with MD 

(“My friend/sibling has a mental health disability or illness” for 

MI or “has a developmental disability” for I/DD).18

As with e-mail tests, the disclosure of the protected tester’s disability occurred early in the communication and was designed 

to be unambiguous. Table 5 includes the text of the telephone 

testing scripts used by the proxy tester to disclose disability. 

The profiles for both the protected proxy and the control tester 

included that neither potential renter was currently living in his 

or her own rental unit. The proxy caller for the individual with 

MD was instructed to state that the person with MD had been 

living in a psychiatric center for the past year (MI) or had been 

living in a group home in the community for the past year (I/

DD). The control tester was instructed to state that he or she 

was returning from school or relocating to the area.

Reveal of Disability

Although the proxy for the protected tester disclosed the MD to 

the housing provider very clearly and early in the conversation, 

the proxy was instructed not to provide a specific diagnosis (for 

example, schizophrenia). Instead, any elaboration if requested 

would be provided in the form of information on functional 

aspects of the disability using common descriptions provided 

by the focus groups and identified in the literature review 

(for example, has emotional issues, difficulty remembering or 

organizing, or needs help with taking care of self or managing 

payments).

Table 5. Telephone Tester Scripts 

Control Tester Protected Tester

My name is <first name> and I’m calling about the apartment. I’ve been 

in school and I’m looking for my first place.

I’m <first name>. My <brother/sister> has a <disability identifier>. He/

she has been living in <alternate housing identifier> and I’m helping 

him/her look for an apartment.

I’m <first name>. I just moved to town and I’m looking for my first 

apartment.

My name is <first name>. My friend has a <disability identifier> and has 

been living in <alternate housing identifier> and I’m helping him/her 

look for an apartment. 

17 In the pretesting, one of the reasonable requests used was for an additional key for a caregiver, but this request was determined to be too “soft;” that is, no housing 

provider objected to providing an additional key, and their consideration of the key request seemed unrelated to the issue of MD—anyone who wanted an additional 

key could get one. This accommodation request was then changed for the pilot testing to a request that the housing provider give the tenant a reminder to pay rent.

18 The decision to have the proxy be a friend or family member, as opposed to a mental health professional or a case manager, was based on previous research that 

identified a set of concerns or assumptions that might be triggered by a call from a mental health professional or case manager (for example, severity of disability, 

need for active treatment, or anticipation of need for significant accommodations).
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Examples of functional aspects that were evaluated in the pilot 

test included—

•	 Goes to “X” for mental health treatment/services/support 

(MI); or receives I/DD services in the community from 

“X.” Control proxies said nothing about this issue.

•	 Requires assistance to cognitively or emotionally manage 

or experiences difficulty with remembering or emotionally 

managing; has someone who comes in 2 days a week to 

help take care of him or her and the apartment (MI and I/

DD); only if asked by the landlord, additional details may 

include that the person helps with paying bills, managing 

money, cooking, and laundry. Control proxies said 

nothing about this issue.

Statements about the functional aspects of the disability did 

not request or require any action on the part of the housing 

providers and, more importantly, were designed not to be confused 

or conflated with a request for a reasonable accommodation.

Reasonable Accommodation Requests

Any request for a reasonable accommodation was made at 

the end of the telephone call after all other information for 

the test had been collected. The intent of the design was to 

provide a second level of analysis related to the reasonable 

accommodation request. As with the e-mail testing, reasonable 

accommodation requests were designed to reflect the types of 

accommodations commonly requested by people with MD as 

part of the search for rental housing. Reasonable accommodation requests specifically avoided issues of “source of income” 

or poverty that could introduce other variables into the test. 

The accommodations sought in this test were—

•	 Need for an assistance animal and a waiver of any 

associated fees.

•	 Request for a reminder from the housing provider by 

telephone or in person to the person with the MD that 

rent was due, as they have difficulty remembering.

Telephone Tester Recruitment

Recruitment of telephone tester candidates began in late 

November 2013. Local fair housing advocacy organizations 

and social work departments at universities in the tristate area 

of Delaware, New Jersey, and Pennsylvania were contacted, 

and recommendations for tester candidates were solicited. 

The recruitment goal was to have both male and female 

African-American and Caucasian matched pairs of testers 

participate in training and testing.

All candidates were administered a telephone screening by the 

test coordinator. This screening was followed by an in-person 

interview during which the candidates’ voices were recorded. 

The purpose of the recordings was to identify and screen out 

candidates with discernible regional accents or other vocal 

idiosyncrasies that might contribute to bias.

A review of testing background and experience level of each 

candidate informed the preliminary decision on tester suitability. Demographic information, which was used to determine 

tester pairings, was provided by every candidate. The final 

decisions on tester pairings—that is, which of the two testers in 

a pair would assume the control and the protected-class roles 

and who would be paired with whom—were based on the race, 

age, gender, and experience levels of each tester and were made 

by the project’s subject matter experts (SMEs) and the test coordinator. As a result of these screening efforts, the initial training 

class consisted entirely of experienced fair housing testers, all of 

whom had previously conducted telephone testing.

Training for Telephone Testers

Classroom and practical training were conducted in late 

January 2014, over a 2-day period in Philadelphia. The first day 

of training consisted of a classroom orientation that covered a 

variety of topics, including—

•	 A history of housing discrimination testing. 

•	 Types of discriminatory housing practices. 

•	 The process of fair housing testing. 

•	 The strategic goals of the project.

•	 The telephone testing data collection process. 

•	 Tester instructions and guidelines. 

•	 Review of tester forms.

•	 Completion of testing assignments. 

•	 Narrative writing.

•	 QC practices.

Practical training was conducted on the second day of training 

in the call center where the telephone testing would be implemented. Testers were given hands-on instruction on the use of 

tester assignment and test report forms and were instructed on 

how to use the data repository computer application to store 

test result data. The training also included instruction on call 

center telephone use and inbound voicemail access procedures. 

Each trainee made practice test calls to SMEs on site and at 

remote locations using carefully constructed tester profiles. 

Trainees received immediate feedback from the test coordinator, SMEs, or both after each call.
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Supplemental and Review Training

At times during the 9-month exploratory and pilot testing period, additional telephone testers were trained to maintain the 

demographic consistency of available testing pairs. Additional 

Caucasian male and female paired teams were added after data 

collection had begun. Supplemental trainings were led by the 

test coordinator and included practice telephone tests to offsite 

SMEs and hands-on telephone and computer training.

At the midpoint of the data collection period, SMEs conducted 

a second classroom training session for all testers, during 

which critical testing protocols and QC procedures were reviewed and emphasized.19 This 1-day mandatory training was 

conducted at the training facility for all telephone testers.

Conducting Telephone Pilot Testing and 

Quality Control Procedures

Telephone tests were not conducted by individuals with MD, 

but instead relied on a proxy design. Proxies posed as a friend 

or family member seeking rental housing on behalf of an individual with MD. Control testers contacted the housing provider on their own behalf. Proxies calling on behalf of an individual with MD were provided detailed background information 

on the profile of the person on whose behalf they were calling. 

Control testers were provided similar background information 

for testing purposes. As in all matched-pair testing, the profiles 

of the individuals whose treatment is to be compared (here, 

the people on whose behalf the proxies were calling) were 

matched to the control tester on all relevant characteristics 

except the variable being tested—the presence of MD. Thus, 

paired potential renters’ profiles were of the same gender and 

race and assigned personal and financial characteristics that 

were as similar as possible, such as approximate move-in 

date, desired rent range, credit score, current employment, 

and income level. To avoid detection by housing providers as 

a result of two testers representing individuals with identical 

characteristics, the profiles of potential renters with disabilities 

showed them to be slightly more qualified for the housing—for 

example, having a higher income level or credit score—than 

the paired potential renter without a disability. In addition, 

to avoid bias caused by the proxies, proxies were of the same 

gender, race, and approximate age as control testers.

Telephone tests were designed so that the proxy was to reveal 

the protected potential renter’s MD to the housing provider at 

the beginning of the conversation using a direct reveal of the 

disability and a description of functional needs without providing an actual diagnosis.20 The type of functional issues identified 

matched the designated disability group (MI or I/DD).

All telephone testers were briefed on the nature of the QC 

procedures instituted for this study. Some QC processes were 

embedded in the selection of rental housing assignments and 

test order. For example, the order of the calls within each telephone test (control call made first or protected call made first) was 

randomized to address any potential influence on test outcomes.

Rental housing assignments in the various markets were automatically screened via data-mining tools using criteria such 

as rent range, market location, and property owner or agent 

uniqueness. The test assignment forms were automatically 

populated with information from this data-mining process, then 

printed and provided to each pair of proxies and testers. Testers 

reviewed the test assignment forms and made telephone calls 

based on a randomized order. The second telephone call in 

each test was made within 1 to 4 hours after the initial test call 

to reduce the chance of detection but to increase the likelihood 

of speaking to the same property owner or agent.

QC procedures also were in place at the tester level. Proxies and 

testers were trained that, after the completion of each telephone 

engagement with a property owner or agent and before the 

completion of a test narrative, the tester would be debriefed by 

the onsite test coordinator and test details would be discussed. 

Only after this debriefing would the proxy or tester complete 

the test narrative and enter the results from the telephone test 

form into the database.

Finally, all test forms and narratives for each paired test were 

sent to SMEs for review and approval. Only after this approval 

would a paired test be considered complete.

In-Person Testing Protocols

People with MD served exclusively as protected testers for the 

in-person testing in this study. For in-person tests, which had 

a smaller sample size and a longer execution period than other 

modes of testing, the testers with MD (both MI and I/DD) were 

19 Although a variety of issues were covered in this training, the importance of the timing of the protected tester’s identification of disability and the completion of the 

matched control test were particularly stressed.

20 To compare the results of each paired test, it was essential that the housing provider unambiguously know from the beginning of the call that the protected 

potential renter had MD. The proxies clearly and directly stated to the housing provider at the start of the conversation that they were calling on behalf of someone 

with MD (MI or I/DD).
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accompanied by someone without MD posing as a friend. This 

protocol of a companion accompanying the protected tester 

replicates what was adopted in the DDS 2005 for in-person 

testing. The protected tester-and-companion team approach 

provided support and assistance for the testers with disabilities 

to ensure that test protocols were followed and that reporting 

was complete and accurate.

Control testers were people without MD and were not accompanied. The tests were designed to reveal whether rental housing providers treated testers differently on the basis of MD. In 

each test, the protected tester’s MD was revealed to the housing 

provider by the protected tester at the beginning of the visit 

to the property. In making this disclosure, the protected tester 

used a direct reveal and description of functional needs without providing an actual diagnosis. The disability identified was 

the same for all testers in each disability group (MI or I/DD). 

As in all matched-pair testing, the paired testers were matched 

as to all relevant characteristics except for the variable being 

tested—the MD. Paired testers were of the same gender and 

race and were assigned personal and financial characteristics 

designed to be as similar as possible, including, as described in 

more detail subsequently, unit size needed, potential move-in 

date, desired rent range, credit, current employment, and income level. To avoid detection by housing providers as a result 

of two testers having identical characteristics, protected tester 

profiles were slightly more qualified for the housing being 

sought; for example, having a slightly higher income level or 

length of employment.

Procedures and Scripts for In-Person Tests

Advance calls were made by test coordinators before each 

in-person visit to confirm that the housing unit remained 

available, the location, and office hours and to determine 

whether an appointment would be needed to see the unit. The 

need for appointments differed in the two cities, with nearly 

all Chicago properties requiring appointments but most of 

the Washington, D.C. properties not (allowing for the testers 

to “walk in” to visit the properties). Appointment contacts, if 

necessary, were made primarily by telephone calls within 3 

days of the publication of the advertisement by the companion 

testers (for MI and I/DD testers) and by the control testers. 

Testers’ companions did not reveal that they were looking 

for an apartment for someone else, and no disclosure of any 

disability was made during the call.

Test coordinators created test assignments based on the information in the rental advertisements and developed profiles for 

test assignments that matched the paired control and protected 

testers on their relevant personal and financial characteristics—

for example, gender, race, approximate age, income, credit, 

financial resources, employment, household composition, and 

housing preferences such as the unit size, rent, and date needed—and included an assigned e-mail address and telephone 

number for each tester (which were monitored by the test 

coordinators). Assignment forms for protected testers included 

instructions on revealing their MD. All testers were seeking 

their first apartment and were financially qualified for the units 

they sought. The protected testers were either living in the 

community (in a group home or with family) or coming out of 

an institutional setting. Control testers had been living at home 

with family or away at school. To avoid identical characteristics 

that might lead to detection, protected testers’ profiles made 

them slightly more qualified for the housing being sought; for 

example, having a slightly higher income level or length of 

employment. Test coordinators reviewed the assignment forms 

with testers before each test.

Protected testers were accompanied on property visits by 

companions who provided support to testers during data collection. For example, when testers forgot to ask a question of a 

property owner or agent, “got off track,” or “froze,” companion 

testers were able to naturally prompt the tester or provide a 

response. Companion testers also reassured testers and helped 

them feel less nervous when in a new area of their community. 

Companion testers also assisted by taking notes, organizing 

and remembering information, helping out when unanticipated 

situations arose, and in some cases providing transportation. 

Both testers and companions approved of this model, reporting 

that a companion’s presence helped some testers feel less 

anxious because immediate support was available, that testers 

and companion testers complemented one another during data 

collection by offering different ideas, and that working as a pair 

made the experience more enjoyable.21 Testers and companion 

testers also noted that the presence of a companion may also 

have added credibility to the disclosure of a disability by testers.

Paired testers attempted to visit an assigned property on the 

same day, but always visited within 24 hours of each other. 

The order for whether the control or protected tester visited 

the property first was randomized, as previously described. 

21 The study team thought it was important to ask testers in what situations they believed they needed assistance (for example, writing, reading, or having a quiet 

room in which to complete forms) and to be flexible in responding to testers’ emergent needs. The need for support decreased over time as testers increased their 

skills and comfort. This support improved project efficiencies by better enabling a smaller group of testers to comfortably conduct multiple tests rather than having a 

larger pool of testers who might conduct only a single test.
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Testers used protocols designed to allow for an assessment of 

differential treatment; for example, protected testers revealed 

their MD very early in the conversation, before information on 

the unit was obtained. During site visits, testers inquired about 

the advertised property and gathered information on the availability of the advertised unit or other similar units, addresses 

and unit numbers, rental amounts, the application process, 

fees, utilities, other terms and conditions, and amenities. 

Testers asked to see the unit advertised and were willing to see 

a model unit or other similar units. Testers were encouraged to 

take notes during their visits.

Immediately after each test, the testers notified the test 

coordinator that the test was completed, filled out the test 

report form, and wrote a narrative. Protected testers and their 

companions completed test reports and narratives together. 

Testers turned their reports into the test coordinator by midnight of the day of the test and the narrative within 24 hours. 

Test coordinators reviewed the completed test reports and 

narratives and debriefed each tester. Test results were entered 

into the testing database by the study team, and a weekly 

report of completed tests was produced to monitor progress. 

All documentation from in-person tests was reviewed and 

approved by a designated member of the testing QC team.

Tester Profile and Reveal Strategy

It was critical to the test design that protected testers reveal 

their disability at the beginning of the interaction so that the 

presence of their MD was known to the housing providers or 

agents before information about the unit was discussed. To 

accomplish this reveal, protected testers were instructed to 

greet a housing provider or agent, identify themselves by first 

name, and state either “I have a developmental disability” or “I 

have a mental health disability.” Their companions were then 

introduced as someone who was helping them to find rental 

housing and specifically was tasked with remembering what 

questions to ask about the unit and helping to take notes about 

the apartment.22

The protected testers were not to name their specific disability 

by providing a diagnosis or condition but were to reveal only 

the broad category of “developmental disability” or “mental 

health disability.” Test assignment forms provided each tester 

with information about how the disability affected the tester’s 

daily life (for example, difficulty remembering things or 

difficulty staying organized). This information was mentioned 

during the course of the test. See Table 6 for examples.

Test assignment forms also provided information about 

protected testers’ current housing situation (for example, living 

with family or in an institution, such as a nursing home or psychiatric facility), which was also revealed at some point during 

the test. Test assignment forms for control testers also included 

information about their current housing situation. Control 

testers were instructed to tell a housing provider or agent that 

this was their first apartment search because they had been 

living in the housing assigned in their profile (for example, with 

family or away at school).

Table 6. Examples of How MD May Affect Functional Aspects of Life and Maintenance of Housing 

Functional Aspects of MD

MI I/DD

Affiliation with a 

community service 

provider 

Goes to “X” for mental health treatment/services/support Receives I/DD services in the community from “X”

Needs supports 

with housing-related 

management activities 

(1) Requires assistance to help with organizing and 

keeping track of things.

(1) Requires assistance to help with organizing and 

keeping track of things.

(2) Has difficulty with remembering. (2) Has difficulty with remembering.

(3) Has someone who comes in 2 days a week to help 

take care of him or her and the apartment (both).

(3) Has someone who comes in 2 days a week to help 

take care of him or her and the apartment (both).

Only if asked by the landlord, additional details may 

include that the person helps with paying bills, managing 

money, cooking, and laundry.

Only if asked by the landlord, additional details may 

include that the person helps with paying bills, managing 

money, cooking, and laundry.

I/DD = intellectual or developmental disability. MD = mental disability. MI = mental illness.

22 Pretesting was used to evaluate the manner in which the MD was conveyed to the housing provider and to highlight any detection issues that might arise either 

when setting up an appointment to visit a property or during the actual visit.
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In-Person Tester Recruitment and 

Training

Test coordinators from community-based fair housing testing 

organizations in the two metropolitan areas selected for 

in-person testing, Access Living in Chicago and The Equal 

Rights Center in Washington, D.C., recruited potential testers 

from their existing tester pools (particularly for control testers 

with no disability) and from a variety of community groups 

and organizations in which people with MI and I/DD actively 

participated or from whom they received housing or community living services. These organizations’ extensive contacts and 

continual networking with community groups and people with 

disabilities were essential to this effort and would be difficult 

for organizations not familiar with, and embedded within, 

disability communities to replicate. The use of these community-based testing organizations was a critical component of the 

project and a key to success in actively supporting people with 

I/DD and PD during the in-person testing.

To establish a pool of testers, test coordinators needed to allocate significant time to the tester recruitment process, initially 

recruiting about three times the number of testers needed 

and continuing to recruit and train additional testers during 

the actual testing period. For example, in some cases, most 

notably among potential testers with I/DD, availability and 

reliability were issues (for example, scheduling training, not 

showing up for scheduled training, the availability of reliable 

transportation, and the need to navigate new transportation 

routes without support). The lack of availability and reliability 

was particularly problematic given the need to coordinate the 

schedules of protected testers with companion testers for initial 

training, practice testing, and conducting each in-person test. 

Because of employment disparities among the populations, 

people with MD were found to be more available to work 

as testers, but the ability to recruit control testers was more 

challenging because of their higher employment rate.

Test coordinators communicated extensively with potential 

testers to determine whether the tester’s abilities matched the 

testing and reporting responsibilities involved in the testing 

process, to assess whether candidates could complete the 

essential tasks required of a tester. In these interactions, test 

coordinators provided potential testers a candid and thorough 

description of the project and their expected role (including an 

emphasis on the responsibilities of being a tester versus other 

roles within the project), assessing how the potential tester 

understood his or her role, and the potential tester’s comfort 

with pretending to be searching for an apartment and disclosing 

his or her disability during the housing search process.

Test coordinators also noted the importance of identifying candidates who would be good companion testers. Strong rapport 

between a tester with disabilities and his or her companion was 

key to the tester’s comfort and to the quality and efficiency of 

testing. This rapport was accomplished by creating opportunities throughout the project—from initial training, to during 

practice tests, and through the completion of all test assignments—for each protected tester and the assigned companion 

to get to know and become comfortable with each other. Test 

coordinators regularly monitored how these relationships 

progressed. If one member of a pair was not comfortable, pairs 

were rematched.

Separate training sessions were held for each of the three 

groups of testers—MI, I/DD (together with their companions), 

and control testers. Based on initial insights from multiple focus 

groups and discussions with the expert panel at the start of the 

project, training approaches were modified for each group to 

maximize their learning. For example, testers with I/DD had 

project information broken into smaller units, followed immediately by opportunities to practice a small skill, leading up to 

practicing a full test under controlled circumstances, and finally 

moving on to an actual practice test in the field. Testers with 

MI received initial information in one sitting and then practiced 

different scenarios.

The study team maintained flexibility in the tester training 

protocols, simplifying and limiting the quantity of background 

information and lecture for the MI and I/DD groups and 

focusing on role-play, practice exercises, and open discussions 

to enable the testers to gain a level of comfort with both the 

testing process and working with a companion.23 For the MI 

and I/DD groups, training materials deemphasized complicated 

text, reduced the number of ideas presented at one time, and 

incorporated graphics, photos, and images to illustrate more 

abstract points such as civil rights.

Frequent breaks were provided during all training sessions to 

allow for testers to assimilate new information and experiences.

The training sessions also helped test coordinators in making 

final determinations about a potential tester’s involvement in 

the actual in-person tests.

23 Trainings included opportunities first for testers to observe testing skits performed by test coordinators and project staff, and then for testing pairs to actively 

engage in several different testing scenarios with role-play (moving from working in pairs with an assigned project staff member to role-play in front of the whole 

group and getting feedback afterward). 
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Conducting In-Person Pilot Testing and 

Quality Control Procedures

The in-person pilot testing was conducted in Chicago and 

Washington, D.C., from June to November 2014. Samples of 

available rental units were gathered from rental advertisement 

contact data extracted from online rental advertisements by the 

automated scraper tool and weekly random selections of approximately 20 to 25 rental property advertisements provided 

by the study team to the test coordinators in each city.

Overall Data Collection Oversight, 

Management, and Quality Control

For each mode of testing, testers received training and 

retraining as needed during the data collection period. During 

initial training, testers engaged in role-playing, using the actual 

testing protocols. This process facilitated learning and was the 

basis for the evaluation of tester capabilities and an assessment 

of whether additional training was needed. This process of 

evaluation continued throughout training, exploratory testing, 

and actual pilot testing.

E-mail Testing

The research team used a proprietary Microsoft Access program 

that was customized for this particular paired testing data 

collection. Logic and other QC checks are imbedded in the program 

to facilitate a high level of accuracy when recording data. In 

addition, e-mail testers were assigned specific markets to facilitate familiarity with local address formats and to reduce errors.

Telephone Testing

Telephone testers were paired into teams, and the team configuration remained the same over the course of the testing, absent 

illness or other uncontrollable events. After the completion of 

each test, results were reviewed at least two times, once by the 

QC supervisor and a second time by senior testing experts. The 

reviews validated the tests, ensured protocols were followed, 

and confirmed that the information recorded was complete, 

clear, and unambiguous.

In-Person Testing

In-person tests were reviewed by the test coordinator within 

24 hours of test completion. In addition, each paired test was 

reviewed by senior testing experts to ensure the complex testing 

protocols were followed and to confirm that the information 

recorded was complete, clear, and unambiguous.

In all testing modes, overall, QC was implemented with stringent 

reviews of protocol and processes throughout the data collection period.
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Sampling Methods

Sampling Frame

The sampling frame for the paired testing in this project was 

designed with the goal of completing 1,000 matched-pair tests: 

500 matched-pair tests to assess discrimination against people 

with MI and 500 matched-pair tests to assess discrimination 

against people with I/DD (Table 7). An additional 100 paired 

tests were to be conducted by e-mail specifically to assess the 

willingness of housing providers to make reasonable accommodations for people with the two identified categories of MD.

Table 8 summarizes the sampling frame for the project and 

how the 1,000 matched-pair tests were allocated among the 

three selected rental market strata—medium-sized markets 

(population of 500,000 to 1,250,000), large-sized markets 

(population of 1,250,000 to 2,500,000), and very large-sized 

markets (population of 2,500,000 or more). As noted, tests 

in all markets were equally divided between those focused on 

individuals with MI and those with I/DD.

To avoid issues of detection, small markets with populations 

less than 500,000 were excluded from all pilot testing. Telephone and e-mail testing were conducted in all three market 

size types, whereas in-person testing was conducted only in the 

very large markets.

Allocation of Tests Across Market Size

Test allocation was guided by market and population characteristics. As shown in Table 9, the number of test markets 

selected within each stratum for the pilot testing mirrors the 

distribution of the population across metropolitan statistical 

Table 7. Sampling Frame for People With MD, by Test Type 

Matched-Pair Test Type Total MI I/DD

E-mail 200 100 100

E-mail + reasonable accommodation 100 50 50

Telephone 600 300 300

In person 100 50 50

Total 1,000 500 500

I/DD = intellectual or developmental disability. MD = mental disability. MI = mental illness.

Table 8. Rental Market Sampling Frame 

Matched-Pair Test Type Total

Market Population Size

Medium

(500,000 to 1,250,000)

Large

(1,250,000 to 2,500,000)

Very Large

 (2,500,000 or more)

n = 4 n = 2 n = 2

E-mail 300 20 40 240

Telephone 600 200 200 200

In person 100 0 0 100

Total 1,000 220 240 540

Table 9. Allocation of Tests Across Market Size

Market Population Size

Medium Total

(500,000 to 1,250,000)

Large

(1,250,000 to 2,500,000)

Very Large

(2,500,000 or more)

U.S. distribution

Percent of population 21 21 58 100

Percent of all markets 56 23 21 100

Pilot testing

Number of markets 4 2 2 8a

Percent of markets 50 25 25 100

Percent of paired tests 20 20 60 100

a

 Although the plan was to test in four medium-sized markets, possible detection before the completion of data collection in one of the markets, 

New Haven-Milford, CT, caused the addition of Syracuse, NY. Thus, nine total markets were included in the final analysis.

Source of U.S. population and market distribution: 2010 American Community Survey, SF1, Table P1
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areas (MSA) and micropolitan statistical areas based on 2010 

American Community Survey (ACS) data. The percentage 

distribution of paired tests across strata similarly mirrors the 

population percentage distribution based on 2010 census data. 

For example, because approximately 20 percent of the U.S. 

population resides in markets with populations ranging from 

0.5 to 1.25 million, 20 percent of the total number of paired 

tests was implemented across markets of this size.

Sample of Metropolitan Areas

Based on the sampling design and sample frame, the selection 

of markets and allocation of tests across markets were conducted in two stages: (1) identify and characterize the pool of 

potential markets for inclusion and (2) select the markets for 

testing.

Stage 1: Identifying and Characterizing 

Potential Markets

Using MSA population data, 374 MSAs were divided into four 

categories based on size—270 small-sized markets (population 

less than 500,000), 58 medium-sized markets (population of 

500,000 to 1,250,000), 25 large-sized markets (population 

of 1,250,000 to 2,500,000), and 22 very large-sized markets 

(population of 2,500,000 or more).24

To further differentiate these markets, the proportion of people 

with any disability and proportion of people with cognitive 

disabilities, based on the 2009–2011 ACS and the 2010 

census, were considered.25 These data were included to ensure 

that each selected market contained a typical (within a range) 

proportion of people with MD and a sufficient population from 

which testers for in-person testing could be drawn. These data 

are summarized in Table 10.

Markets were also differentiated by whether the state had an 

Olmstead Plan, any active Olmstead-related lawsuits, or both26

and by if the state received Centers for Medicare and Medicaid 

Services, or CMS, funds to transition people with MD out of 

institutions to the community via a Money Follows the Person 

grant. If the state met either of these conditions, markets were 

further differentiated by how many people had transitioned and 

whether the state had met its transition goals.27 The presence 

and strength of state-level efforts to move individuals with 

disabilities from institutional settings to community-based 

settings was presumed to have an effect on rental markets by 

increasing awareness of the rights of people with disabilities 

under the Fair Housing Act and the Americans with Disabilities 

Act among both housing providers and prospective tenants, 

thus potentially affecting testing.

Stage 2: Selecting the Study Markets

This study used a purposive sampling approach to identify 

specific markets for testing based on population size and certain 

characteristics, as described previously. A purposive approach 

was used for several reasons.

•	 The selected markets had to reflect a proportion of people 

with MD that was typical (in other words, an unusually 

high or low percentage of people with disabilities should 

not reside in the market). 

Table 10. Distribution of Population With Disabilities and Proportion With Cognitive Disabilities, 2009–2011 

MSA

Size

Number 

of MSAs

Proportion of Population With Disabilities

(%)

Proportion of Population With Cognitive Disabilities 

(%)

Median Average Minimum Maximum Median Average Minimum Maximum

Very large 22 9.6 10.2 7.8 13.6 30.5 31.1 20.8 48.2

Large 25 11.5 11.9 7.7 19.8 22.6 24.9 9.3 53.6

Medium 58 12.2 12.2 7.2 16.4 22.9 23.9 15.0 40.0

MSA = metropolitan statistical area.

Sources: 2009–11 American Community Survey; 2010 census

24 To avoid issues of detection, the 270 small-sized markets were excluded from all pilot testing.

25 The ACS and census count an individual as having a cognitive disability if he or she reported that, due to a physical, mental, or emotional condition, they had 

“serious difficulty concentrating, remembering, or making decisions.” The term “cognitive disabilities” is formally used within census data to be inclusive of the same 

categories as the term “mental disabilities” as used by HUD. It includes MI and I/DD. As the source of the data in Table 9 is from census data, the term cognitive 

disabilities is used. For all other purposes of this study, the term “mental disabilities” is used.

26 This grouping includes any plan instituted as a result of a judgment or settlement, or any pending litigation, arising out of the U.S. Supreme Court’s ruling in 

Olmstead v. L.C., 527 U.S. 581 (1999) (unjustified segregation of people with disabilities constitutes discrimination in violation of Title II of the Americans with 

Disabilities Act).

27 Data for these measures were attained from Ng, Wong, and Harrington (2013), on Olmstead Plan and active lawsuits, and from Denny-Brown et al. (2011), on 

People transitioned as of June 2011 and 2010 Transition Goal achieved.
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•	 The selected markets for in-person testing had to contain 

a sufficient population of people with MD from which 

testers could be drawn.

•	 The selected markets for in-person testing had to include 

local fair housing and enforcement agencies that had 

expertise in working with people with MD.

•	 To the extent possible, the research team sought to measure 

any effects of Olmstead on differential treatment of people 

with MD; thus, at least one market in a state that is implementing an Olmstead Plan was intentionally selected.

After applying these criteria to produce a pool of potential 

markets, the list was narrowed further by identifying those 

markets that represent a typical mix of people with disabilities 

relative to the rest of the population and specifically a typical 

mix of people with cognitive disabilities (as defined by ACS 

and the census) as a proportion of all people with disabilities.28

Using these data and the previously discussed criteria, the final 

market pool contained 17 medium and 7 large MSAs (see Table 

11) based on those rates that fell approximately between the 

25th and 75th percentiles for disability and cognitive disability.

These markets preliminarily selected were then discussed with 

the expert panel regarding any specific factors such as Olmstead

implementation activities and disability-related fair housing 

litigation that might bias sample selection and results. The 

panel’s feedback was taken into consideration in making the 

final market selections. As a final step, an analysis of secondary 

data on key characteristics relevant to the testing process of 

each market was conducted, including an assessment of the 

percentage of total housing that was available for rent, rental 

vacancy rates, and craigslist coverage of housing rentals.

Table 11. Pool of Possible Markets (MSAs) Based on Statistical Criteria for Inclusion 

MSA

State-Level Data

Has an 

Olmstead Plan

Active Disability 

Lawsuits

People Transitioned 

as of June 2011

2010 Transition 

Goal Achieved

Large markets

Cincinnati-Middletown, OH-KY-IN Yes Yes 1,139 Yes

Memphis, TN-MS-AR No No NA NA

Milwaukee-Waukesha-West Allis, WI Yes Yes 145 No

Nashville-Davidson--Murfreesboro--Franklin, TN No No NA NA

Providence-New Bedford-Fall River, RI-MA No No NA NA

Sacramento--Arden-Arcade--Roseville, CA Yes Yes 537 No

Virginia Beach-Norfolk-Newport News, VA-NC No No 269 Yes

Medium markets

Albany-Schenectady-Troy, NY Yes Yes 370 Yes

Albuquerque, NM No No NA NA

Allentown-Bethlehem-Easton, PA-NJ No Yes 719 Yes

Bakersfield-Delano, CA Yes Yes 537 No

Baton Rouge, LA No No 164 No

Buffalo-Niagara Falls, NY Yes Yes 370 Yes

Cape Coral-Fort Myers, FL No Yes NA NA

Columbia, SC No No NA NA

Fresno, CA Yes Yes 537 No

Greenville-Mauldin-Easley, SC No No NA NA

Harrisburg-Carlisle, PA No Yes 719 Yes

Jackson, MS Yes Yes NA NA

New Haven-Milford, CT Yes Yes 561 Yes

New Orleans-Metairie-Kenner, LA No No 164 No

North Port-Bradenton-Sarasota, FL No Yes NA NA

Rochester, NY Yes Yes 370 Yes

Syracuse, NY Yes Yes 370 Yes

MSA = metropolitan statistical area. NA = data not reported or available for that MSA.

Source: Final Research Design & Data Collection Plan, approved September 13, 2013

28 As shown in Table 10, the range of people with disabilities varies across the MSAs (the range is the difference between minimum and maximum values) and is 

much narrower than ranges observed in the distribution of people with cognitive disabilities within the group with disabilities. The data on cognitive disabilities from 

the ACS are imputed. The observed higher variability in the percentage of people with cognitive disabilities within the population with disabilities per market may be 

a result of how the imputation was done, or it may be representative of the true distribution.
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The nine MSA markets selected for this project are identified in 

Table 12.29

Table 13 shows the planned sample allocation of paired 

tests across the selected markets within each size category. 

Approximately 60 percent of the allocated matched-pair tests 

fall within the very large markets and 20 percent fall in each of 

the large- and medium-sized markets.

Selection of Advertised Units

Analysis of 2011 American Housing Survey (AHS) data reveals 

that most people who moved into a rental housing unit in the 

previous year reported they found their current apartment via 

word of mouth (34 percent), followed by a sign outside of a 

building (11 percent), craigslist (11 percent), and the large 

category of “other.”30 For the purpose of this study, neither 

word of mouth nor signs on buildings were effective means for 

identifying the large numbers of available units necessary for 

paired testing. Housing providers also use multiple outlets to 

advertise their available units, however—especially in online 

markets, such as craigslist and other sources.

Table 12. Selected Markets by Size and Olmstead Status

Olmstead Status Market (MSA) Size

Very Large Large Medium

Olmstead Plan or active Olmsteadrelated settlement

Chicago-Joliet-Naperville, IL-IN-WI Cincinnati-Middletown, OH-KY-IN Fresno, CA

New Haven-Milford, CT

Syracuse, NY

No Olmstead Plan Washington-Arlington-Alexandria, 

DC-VA-MD-WV

Nashville-Davidson--Murfreesboro--

Franklin, TN

Albuquerque, NM

Harrisburg-Carlisle, PA

MSA = metropolitan statistical area.

Table 13. Sample Allocation Plan Across Communities and Test Types by Market Size 

MatchedPair Test 

Type

Very Large Markets

(2,500,000 or more)

Large Markets

(1,250,000 to 2,500,000)

Medium Markets

(500,000 to 1,250,000)

Total

ChicagoJolietNaperville, 

IL-IN-WI

WashingtonArlingtonAlexandria, 

DC-VA-MDWV

NashvilleDavidson--

Murfreesboro-

-Franklin, TN

CincinnatiMiddletown, 

OH-KY-IN

Albuquerque, 

NM Fresno, CA HarrisburgCarlisle, PA

New HavenMilford, CT/ 

Syracuse, NYa

MI I/DD MI I/DD MI I/DD MI I/DD MI I/DD MI I/DD MI I/DD MI I/DD

Matched-pair tests with reasonable accommodation request

E-mail 10 10 10 10 10 10 10 10 3 3 3 3 2 2 2 2 100

Telephone 50 50 50 50 50 50 50 50 25 25 25 25 25 25 25 25 600

Total 60 60 60 60 60 60 60 60 28 28 28 28 27 27 27 27 700

Matched-pair tests without reasonable accommodation request

E-mail 50 50 50 50 — — — — — — — — — — — — 200

In person 25 25 25 25 — — — — — — — — — — — — 100

Total 75 75 75 75 — — — — — — — — — — — — 300

Total matched-pair tests

E-mail 60 60 60 60 10 10 10 10 3 3 3 3 2 2 2 2 300

Telephone 50 50 50 50 50 50 50 50 25 25 25 25 25 25 25 25 600

In person 25 25 25 25 — — — — — — — — — — — — 100

Total 135 135 135 135 60 60 60 60 28 28 28 28 28 27 27 27 1,000

I/DD = intellectual or developmental disability. MI = mental illness.

a

 Possible detection in one of the markets, the New Haven-Milford, CT Metropolitan Statistical Area (MSA), before the completion of data collection 

caused the addition of the Syracuse, NY MSA. Thus, nine total markets were included in the final analysis.

29 The MSA selection process placed priority on including markets consistent with the expert panel’s criteria for sufficient Craigslist coverage, including markets 

with and without Olmstead provisions, and on accounting for the number of rental units and vacancy rates. The MSA selection process also considered geographic 

representation. Given the total number of markets included in the sampling frame and the need to delineate by Olmstead status for markets with sufficient Craigslist 

coverage, however, those factors took precedence over a perfect regional distribution of study markets.

30 Note that, given the challenges of determining in the AHS if a person has a disability, these data were not further manipulated to produce cross-tabulations by 

disability. Also, the data include all people with disabilities, which means they include people with both physical disabilities and MD.
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Therefore, the sample of units for possible testing was drawn 

primarily from craigslist. Print sources were also included as 

possible sources of rental advertising, particularly in markets 

where craigslist is not sufficient and local newspapers did 

not have an online presence for apartment rental listings to 

generate a sufficient sample.31

Basing their observations on the literature review and focus 

group feedback, the study team noted that people with MD 

use a variety of outlets to search for available rental housing, 

including mental health and social service agencies. The study 

team intentionally sampled from sources used by all renters, 

excluding any outlets that specifically help people with MD get 

into subsidized housing, that have access to a pool of landlords 

with whom the agency has an existing relationship, or both. 

These sources were excluded to obtain a neutral market sample 

of units that had not been prescreened to accept people with 

disabilities and that would therefore reflect the rental search 

experience in the general market.

Risk of Detection

A key concern when selecting properties to test was detection 

by housing providers that testing was under way in their market. For example, testing for discrimination against two subgroups (MI and I/DD) within the same market could increase 

the risk of detection if the same housing provider is contacted 

for each subgroup. Craigslist and local online newspaper apartment rental ads can likewise contain multiple advertisements 

from the same housing provider. For example, in housing 

markets where realty agencies list available rental units, such 

agencies can post multiple advertisements by multiple agents 

within the same company. If those agents received inquiries 

for different available rental units from testers using the same 

or similar profiles, they might have detected the testing, which 

could have, in turn, affected the results of the study.

One strategy to minimize the likelihood of detection by a housing 

provider during testing would have been to sample housing 

providers only once within each MSA. This strategy, however, 

would have resulted in a dramatic reduction in the pool of 

housing providers and testable properties, given that housing 

providers may have multiple sites within a market, use a 

management company or leasing agent that represents many 

properties, or both. Instead of adopting this strategy, other 

precautions to avoid detection were taken. These precautions 

included—

•	 Using software to track and filter out duplicate rental 

advertisements within a specified timeframe (for example, 

3 weeks). 

•	 Ensuring that no housing provider was tested more than 

once for the same type of MD.

•	 Lengthening the timeframe between tests if an advertised 

unit was selected for both MI and I/DD testing.

•	 Staggering the tests to ensure that the different modes of 

testing (e-mail, telephone, and in person) were conducted 

sequentially—e-mail first, then telephone, then in-person—

with the e-mail and telephone testing in the Chicago and 

Washington, D.C. markets administered first, before the 

in-person testing in those markets began.

Sampling of Units

Sampling of the advertised rental units within MSAs was 

accomplished using two methods—one automated and the 

other manual.

Under the automated method, to streamline the sampling of 

advertised housing units, a data scraper tool was used to select 

and collect data from advertisements on craigslist in each study 

MSA. The tool filtered the advertisements using the preselected 

criteria in table 14, excluding advertisements that did not 

Table 14. Criteria for Inclusion in/Exclusion From Unit 

Sample 

Criteria for inclusion in unit sample

1. Proper unit size (studio, one bedroom, or two bedrooms).a

2. Rent within specified range.

3. Adequate provider contact information available, including—

•	 Unit address (for in-person testing).

•	 Telephone number (for telephone and in-person testing).

•	 E-mail address (for e-mail testing).

Criteria for exclusion from unit sample

1. Housing restricted solely to seniors and/or people with disabilities 

(for example, single-site housing).

2. Rents outside specified range (highest and lowest 10% were 

thrown out, to exclude misplaced or misleading listings).

3. For in-person testing sample, recent (within 30 days) selection for 

e-mail or telephone testing.

a

 Two-bedroom units, a unit size still credibly sought by an individual, 

were included because of a limited number of available one-bedroom 

units, especially for in-person tests.

31 A multipronged approach to marketing units is encouraged by various resources for rental housing providers. See, for example, Wagner (2008).
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provide the rent or other pertinent information for each testing 

mode. Table 14 summarizes the criteria for inclusion and 

exclusion used in this sampling.

Under the manual sampling method, local newspapers and 

other materials featuring rental housing advertisements in the 

selected markets were sampled, with every 7seventh post selected. Filters analogous to those identified for the data scraper 

tool were also applied in the manual sampling process.

The automatically and manually mined advertisements were 

loaded daily into a Microsoft Access database. Data entry 

personnel then reviewed and removed any new advertisement 

that met one of the following three conditions: (1) included 

data for a housing provider that was already in the database 

(phone number, address, agent/owner name, e-mail addresses, 

and so on), (2) referenced units that had already been included 

in the study sample, or (3) included contact information in the 

advertisement that matched any of the contact information for 

an advertisement that had been included in the study within 

the previous 3 weeks. Information on properties ultimately 

selected for testing were then provided weekly to test coordination teams for each MSA for assignment to testers.32

Figure 1 illustrates the data collection process, from the identification of sample rental unit advertisements, through the testing, 

to the analysis of results.

Figure 1. Flow of Sample Selection and Testing Process

Sample/Testing Process Flow

E-mail testing

Telephone testing

In-person testing

Automated and 

manual aggregation 

of craigslist local 

listing sample

Conduct 200 

paired tests

(0.5–1.25M, 1.25–2.5M, 

2.5M+ markets)

Conduct 100 paired 

tests w/RA request*

(0.5–1.25M, 1.25–2.5M, 

2.5M+ markets)

*Protected tester only

Analysis database

Testing data, tester forms, 

original housing posts, etc.

Sampling database

Manual aggregation of 

other (e.g. newspaper) 

local listing sample

Conduct 600 paired 

tests

(0.5–1.25M, 1.25–2.5M, 

2.5M+ markets)

Conduct 100 paired 

tests

(2.5M+ markets only)

RA = reasonable accommodation.

32 This method of avoiding detection was successful in M. Davis and Company, Inc.’s most recent housing discrimination study (HUD, 2013a).
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Analysis of Testing Findings

Summary of Tests Conducted

During the pilot testing period, 1,128 paired tests were administered. Paired testing was conducted using three different 

modes of testing protocols: e-mail, telephone, and in-person 

testing. Some subset of both telephone tests and e-mail tests 

included a request for a reasonable accommodation by the 

protected tester. Table 15 summarizes the distribution of tests 

by test mode.

Table 15. Total Tests Conducted by Test Mode 

Test Mode Tests

E-mail 359

(Subset of e-mail tests with a reasonable accommodation 

request)

(78)

Telephone 668

(Subset of telephone tests with a reasonable accommodation 

request)

(629)

In person 101

Total tests 1,128

E-mail Testing

Table 16 summarizes the number and distribution of e-mail 

tests administered for people with MI and people with I/DD 

across three distinct market sizes. Via e-mail, 359 matched-pair 

tests were administered, with approximately 73.54 percent of 

the tests conducted within the very large markets, 17.5 percent 

within the large markets, and the remaining 8.9 percent within 

the medium markets.

Figure 2 represents the response rates of the 359 paired e-mail 

tests that were conducted during the pilot testing.

Based on the existence, nature, and extent of response from 

housing providers, paired testing using an e-mail protocol 

enables researchers to observe two different levels of differential 

treatment. The first level of differential treatment that can be 

observed is the disparity between the number of tests for which 

the control tester received a response from the housing provider 

and the protected tester did not. The lack of a response to the 

protected tester when the control tester received a response is 

considered in measuring discrimination.

Figure 2. Response Rate of E-mail Paired Tests

Control 

tester 

received a 

response 

n = 154

Only control 

tester 

received a 

response 

n = 63

Both 

testers 

received a 

response

n = 91

Protected 

tester 

received a 

response 

n = 124

No response from provider

n = 172

Some response from provider

n = 187

Total e-mail tests conducted

n = 359

Only 

protected 

tester 

received a 

response 

n = 33

Table 16. E-mail Sample Allocation by Market Size 

Matched-Pair Test Type

Market Size

Very Large Total

(2,500,000 or More)

Large

(1,250,000 to 2,500,000)

Medium

(500,000 to 1,250,000)

Matched-pair tests

MI 120 15 8 143

I/DD 121 10 7 138

Total 241 25 15 281

Matched-pair tests with request for reasonable accommodation

MI 13 19 8 40

I/DD 10 19 9 38

Total 23 38 17 78

Sum total 264 63 32 359

I/DD = intellectual or developmental disability. MI = mental illness.
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The second level of differential treatment that can be observed 

is the difference in how the housing providers interact with the 

testers by tracking the incidence of positive treatment, such as 

stating whether the unit was available or inviting the potential 

renter to contact the housing provider. To be included in the 

second-level analysis for differential treatment, both members 

of the pair needed to receive an e-mail response within a given 

time period. In this study, in 91 paired e-mail tests, both 

testers in the pair received a response from the housing provider within the requisite timeframe. The outcomes observed 

in these pairs were used to measure different dimensions of 

discrimination against people with MD.

Telephone Testing

Table 17 summarizes the number and distribution of telephone tests conducted for people with MI and I/DD across 

three market sizes. Data are differentiated into three sets of 

tests: (1) the total number of all matched-pair tests with and 

without an accompanying reasonable accommodation request, 

(2) the number of matched-pair tests with an accompanying 

reasonable accommodation request, and (3) the number of 

matched-pair test without a reasonable accommodation request.

Of the 668 telephone tests conducted, the protected tester made 

a reasonable accommodation request in 629 (94.2 percent). 

Approximately 30.4 percent of the tests were conducted in the 

very large markets, 39.4 percent in the large markets, and the 

rest in the medium markets.

In-Person Testing

Table 18 summarizes the number and distribution of in-person 

matched-pair tests, which were conducted only in the two very 

large markets. This mode of testing did not include a reasonable 

accommodation request.

Table 18. In-Person Sample Allocation by Location 

Matched-Pair 

Test Type

Market

Total

Chicago Washington, D.C.

MI 26 24 50

I/DD 26 25 51

Total 52 49 101

I/DD = intellectual or developmental disability. MI = mental illness.

The 101 tests completed exceeded the target goal. The distribution across disability types was virtually equal, with one extra 

test in the I/DD sample. The pairs were matched so that both 

testers within a pair had the same race and gender; however, 

the total tester pool was not evenly split across race or gender. 

Overall, the sample had more women than men for the MI tests 

and more men than women for the I/DD tests. MI testing pairs 

were also more likely to be African-American, and I/DD testing 

pairs were more likely to be Caucasian.

Measuring Differential Treatment

Results from the e-mail, telephone, and in-person tests were 

analyzed to determine whether the protected tester with MD 

was treated unfavorably relative to the control tester. This 

determination was based on information received by the testers 

during their interactions with the housing provider, which 

were characterized by the research team as either favorable or 

unfavorable. Previous studies of housing discrimination have 

Table 17. Telephone Testing Allocation by Market Size 

Matched-Pair Test Type

Market Size

Very Large Total

(2,500,000 or More)

Large

(1,250,000 to 2,500,000)

Medium

(500,000 to 1,250,000)

Total matched-pair tests

MI 110 142 105 357

I/DD 92 121 98 311

Total 202 263 203 668

Matched-pair tests with reasonable accommodation requests

MI 106 128 105 339

I/DD 88 108 94 290

Total 194 236 199 629

Matched-pair tests without reasonable accommodation requests

MI 4 15 0 19

I/DD 4 12 4 20

Total 8 27 4 39

I/DD = intellectual or developmental disability. MI = mental illness.
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shown that housing providers can respond in various favorable 

or unfavorable manners to an applicant. In this study, the 

following indicators of favorable or unfavorable responses that 

testers could receive included—

•	 Whether testers received a response to their inquiry, for 

the first level of unfavorable treatment testing (e-mail 

testing mode).

•	 If testers were told the advertised unit or similar unit in 

the same building or development was available.

•	 How many available units testers were told about.

•	 If testers were invited to inspect the unit.

•	 If testers were advised to call the housing provider (e-mail 

only).

•	 Whether testers were asked to provide additional information regarding their qualifications as an applicant (that is, 

their credit score/income/employment).

•	 Whether testers were reminded about qualifications they 

must possess to rent the unit.

•	 Whether the unit was available and, if not, whether testers 

were given a reason for the unit not being available.

•	 If testers were given the same information on rents, 

security deposits, application fees, or other fees.

•	 If testers were given the same information on specials or 

incentives to rent.

•	 If testers were given the same information on amenities 

and services available.

•	 Whether testers were encouraged to look at a different unit 

owned by the same landlord (that is, “This unit actually isn’t 

available, but I have another unit in the same building you 

might be interested in”).

•	 Whether testers were referred to a different complex altogether.

•	 Whether the housing provider was willing to grant a 

reasonable accommodation (only when applicable).

Table 19 summarizes a treatment indicator matrix, showing the 

behavior observed in the testing that was assessed to determine 

how the outcomes data from all tests were analyzed by testing 

mode—e-mail, telephone, and in person. Although some indicators are shared by all three modes, each also has indicators 

unique to that mode. The data were broken out into four categories: 

(1) contact with housing providers, (2) availability, (3) tester 

engagement, and (4) reasonable accommodation, each of which 

are described in detail in Table 19.

Table 19. Differential Treatment Indicator Matrix (1 of 2) 

Outcome 

Category

Outcome 

Subcategory

Test Modality

E-mail Telephone In Person

Contact with 

housing provider

Initial contact Housing provider/agent 

responded

Able to speak to housing 

provider/agent

Able to meet with housing provider/agent

Number of responses

Meeting with housing provider/agent in group 

or as individual

Housing provider/agent 

requests contact information

Housing provider/agent 

requests contact information

Housing provider/agent requests contact 

information

Timing Amount of time between 

housing inquiry and first 

response

Amount of time between arrival and first 

greeting by housing provider/agent/staff

Amount of time between arrival and meeting 

with housing provider/agent

Duration of in-person test

Availability of 

housing unit

Original unit(s) Advertised unit(s) available Advertised unit(s) available Advertised unit(s) available

Unit(s) within “desired housing request” 

available

Number of units Number of units Number of units within “desired housing 

request” 

Other units Additional available unit(s) Additional available unit(s) Unit(s) outside “desired housing request” 

available

Number of units? Number of units? Number of units outside “desired housing 

request” 

Total units Total number of available 

units

Total number of available 

units

Total number of available units

Waiting list Offered to be placed on 

waiting list

Offered to be placed on 

waiting list

Offered to be placed on waiting list
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Table 19. Differential Treatment Indicator Matrix (2 of 2)

Outcome 

Category

Outcome 

Subcategory

Test Modality

E-mail Telephone In Person

Tester 

engagement

Unit selection 

method

Method(s) for selection of unit(s) to view

Agent or tester selects unit(s) to view

Details of 

discussed unit(s)

Address Address Address

Apt. number Apt. number Apt. number

Type Type Type

Number of bedrooms Number of bedrooms Number of bedrooms

Rent Rent Rent

Security deposit Security deposit Security deposit

Date of availability Date of availability Date of availability

Fees Fees Fees

Apartment shown

Apartment condition ready for move in 

(assessed only for vacant units)

Total number of shown apartments that meet 

tester needs

Information 

disclosed by 

agent/housing 

provider

Application mentioned Application mentioned Application mentioned

Application offered Application offered Application offered

Duration of application 

process

Duration of application 

process

Duration of application process

Co-signer mentioned? Co-signer mentioned? Co-signer mentioned?

Security deposit? Security deposit? Security deposit?

Other fees Other fees Other fees

Amenities Amenities Amenities

Incentives Incentives Incentives

Encouraging/discouraging 

remarks

Encouraging/discouraging 

remarks

Encouraging/discouraging remarks

Disability comments Disability comments Disability comments

Referred to alternative 

residence type

Referred to alternative 

residence type

Referred to alternative residence type

Comments/questions 

on race, color, national 

origin, religion, sex, disability, 

children, age, marital status, 

source of income, or sexual 

orientation

Comments/questions 

on race, color, national 

origin, religion, sex, disability, 

children, age, marital status, 

source of income, or sexual 

orientation

Comments/questions on race, color, national 

origin, religion, sex, disability, children, age, 

marital status, source of income, or sexual 

orientation

Future contact Future contact Future contact

Unit location comments Unit location comments Unit location comments

Other 

qualifications

Escorted to apts

Proof of citizenship prior to showing

Require personal ID Require personal ID Require personal ID

Housing provider/agent 

indicated applicant is “not 

qualified”

Housing provider/agent 

indicated applicant is “not 

qualified”

Housing provider/agent indicated applicant is 

“not qualified”

References References References

Credit check (as part of 

application)

Credit check (as part of 

application)

Credit check (as part of application)

Criminal background check Criminal background check Criminal background check

Reasonable 

accommodation

Housing provider/agent 

responded to request?

Housing provider/agent 

responded to request?
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Data Analysis

Analysis of the responses of housing providers observed during 

the testing followed the approach used in the 2000 Housing 

Discrimination Study (HUD, 2002) and DDS 2005 studies, 

which assessed the extent to which one tester is consistently 

favored over the other in the treatment received from housing 

providers based on their inquiries. For example, tests are classified as “control tester favored” if the control tester received 

favorable treatment on at least one indicator of interest and the 

protected tester received no favorable treatment on the same 

indicator(s).Tests are conversely classified as “protected tester 

favored” if the protected tester received favorable treatment on 

at least one indicator of interest and the control tester received 

no favorable treatment on the same indicator(s).

Typical treatment indicators that have been tracked in past 

housing discrimination studies, including HUD (2013a), a 

paired e-mail testing study, include whether each tester (1) 

received a response, (2) in a pair received a response, (3) was 

told the unit was available, (4) was told to contact the provider, and (5) was invited to inspect the unit. In addition to tracking these five indicators, this study explored other indicators 

related to quality of applicant, costs, and encouragement using 

a validated qualitative approach to analyze e-mail data (see 

Appendix A, Qualitative Analyses and Findings on Overt and 

Subtle Discrimination Against People With Mental Disabilities 

by Different Testing Modes).

The testing conducted in this study estimates the incidence 

of discrimination by studying favorable and unfavorable outcomes for each test dimension. A favorable outcome represents 

a response in which the tester received an affirmative value on 

the test dimension, and an unfavorable outcome represents a 

response in which the tester received a negative value on the 

test dimension. Each test had four possible combinations of 

outcomes: (1) both the control and protected testers received 

favorable outcomes, (2) both testers received unfavorable 

outcomes, (3) only the control tester received a favorable 

outcome, or (4) only the protected tester received a favorable 

outcome. The relationships among the four combinations are 

summarized in Table 20.

Table 20. Possible Outcomes Matrix 

Possible Outcomes

Protected

Favorable Unfavorable

Control Favorable (1) Both (3) Control favored

Unfavorable (4) MI or I/DD favored (2) Both

I/DD = intellectual or developmental disability. MI = mental illness.

Discrimination is assumed when the proportion of tests that 

favors control testers is greater than the proportion that favors 

protected testers. The difference in the percentages between 

outcomes 3 and 4 represents the net difference in outcomes. 

The value of the net difference is what is assessed in the 

hypothesis test. The hypothesis is declared formally in the 

following equations.

H0: %3 = %4 or %3 – %4 = 0.

HA: %3 > %4 or %3 – %4 > 0.

Measuring Discrimination

In this study, discrimination was estimated separately by test 

mode (e-mail, telephone, and in person) for each disability 

group. The measure of discrimination is expressed as—

D = p10 – p01.

In this expression, p10 is the proportion of pairs in which 

the control applicant receives a favorable outcome and the 

applicant with disabilities receives an unfavorable outcome, 

and p01 is the proportion of pairs in which the control applicant 

receives a negative outcome and the applicant with disabilities 

receives a positive outcome. The standard error of D is—

= n

n10 + n01 p10 – p01

n SE (D) =

n

n10 + n01

n10 + n01

n10 + n01

(n10 – n01)

( |n10 – n01| – 1)

p10 – p01

n D

X1

± Zc = D Z ± c

=2

2

2

X1 =2

,

where n is the total number of pairs. Given that D is approximately normally distributed, we may compute confidence 

intervals using—

= n

n10 + n01 p10 – p01

n SE (D) =

n

n10 + n01

n10 + n01

n10 + n01

(n10 – n01)

( |n10 – n01| – 1)

p10 – p01

n D

X1

± Zc = D Z ± c

=2

2

2

X1 =2

,

where Zc is the appropriate critical value of the standard normal 

distribution.

The test statistic for McNemar’s Test is—

= n

n10 + n01 p10 – p01

n SE (D) =

n

n10 + n01

n10 + n01

n10 + n01

(n10 – n01)

( |n10 – n01| – 1)

p10 – p01

n D

X1

± Zc = D Z ± c

=2

2

2

X1 =2

.

In this expression, n10 is the number of pairs in which the control tester receives a favorable outcome and the protected tester 

receives an unfavorable outcome, and n01 is the number of pairs 

in which the control tester receives an unfavorable outcome and 

the protected tester receives a favorable outcome. Under the null 

hypothesis of no discrimination, with a sufficiently large number 

of discordant samples (n10 and n01), the test statistic has an 

asymptotic chi-squared distribution with one degree of freedom. 

If either n10 or n01 is small (n10 + n01 < 25), then an exact binomial 

test can be used where n10 is compared to the binomial distribution 
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with size parameter n = n10 + n01 and probability 0.5. The 

binomial exact p-value can be approximated with the following 

continuity-corrected version of McNemar’s Test.

n

n10 + n01

n10 + n01

n10 + n01

(n10 – n01)

( |n10 – n01| – 1)

p10 – p01

n D

X1

± Zc = D Z ± c

=2

2

2

X1 =2 .

The test statistic has an asymptotic chi-squared distribution 

with one degree of freedom. In this study, a one-tailed version 

of this test was done by dividing the two-tailed p-value from the 

chi-squared or exact binomial test by 2. The estimates of incidences of discrimination are provided at 99-, 95-, and 90-percent 

levels of significance by protected subclass (MI or I/DD).
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Findings of Incidence of Discrimination

This section presents the data generated by the three testing 

modes (e-mail, telephone, and in person) and summarizes 

findings from the tests using the dimensions described in the 

previous section to determine the incidence of discrimination 

identified in each mode.

Data Reliability and Limitations

Each mode of testing is examined by different dimensions of 

discrimination. In cases for which the matched-pair sample 

size was sufficient, data were further cross-tabulated by (1) 

market size, (2) Olmstead status (that is, whether the pair was 

in a state with an Olmstead Plan or Olmstead-related litigation), 

(3) type of disability (MI or I/DD), (4) gender, and (5) race.33

E-mail Testing Findings

The analysis of the e-mail tests focused on the differences in 

the responses of housing providers to people with MD (MI and 

I/DD samples combined = protected class) compared with people without disabilities (control) across the following indicators 

on two different levels.

1. Level 1 (applicable to administered tests in which both 

testers sent an e-mail in inquiry; n = 359).

•	 Did each tester receive a response to his or her 

inquiry (favorable)?

2. Level 2 (applicable only to completed tests in which both 

testers received a response; n = 91).

•	 Were both testers told the advertised unit is available 

(favorable)?

•	 Were both testers invited to inspect the unit (favorable)?

•	 Was the unit available and, if not, were both testers 

given a reason for the unit not being available (favorable)?

•	 Were both testers advised to call the housing provider 

(favorable)?

•	 Were protected testers asked to provide additional 

information regarding their qualifications as an applicant (not favorable)?

•	 Were protected testers reminded about qualifications 

they must possess to rent the unit (not favorable)?

•	 Were protected testers encouraged to look at a different unit owned by the same landlord instead of the 

unit advertised (not favorable)?

The first step in the statistical analysis was to determine whether 

testers from the control group were more likely to receive a 

response to the initial inquiry than their matched protected 

testers. Figure 2 summarizes the number and distribution of 

e-mail responses versus nonresponses to the initial rental inquiries from testers both with and without MD. Of the 359 tests 

administered, only 91 tests (25 percent) resulted in responses 

to both testers in the pair, and, in 172 tests (48 percent), neither 

tester received a response. Thus, in 73 percent of the e-mail 

tests, the control and protected group received equal treatment.

Table 21 presents the results of this first level of analysis. As 

shown, people with MD (MI and I/DD combined) were significantly less likely to receive any response back to their rental 

inquiry via e-mail (17.55 percent of tests favored the control 

class compared with 9.19 percent that favored the protected 

class). The difference in these two percentages captures the net 

measure of preferential treatment given to the control testers 

Table 21. Differential Treatment in Response Received for Renters With MD (I/DD+MI) Found in E-mail Testing 

Test Dimension

Both 

Testers

(%)

Neither 

Tester

(%)

Control 

Tester

Only

(%)

Protected 

Tester

Only

(%)

Net 

Measure p-Value

Sample 

Size

(n)

Which tester(s) received a response to their e-mail? 25.35 47.91 17.55 9.19 8.36*** 0.0011 359

I/DD = intellectual or developmental disability. MD = mental disability. MI = mental illness.

*** Significant at the .01 level.

33 Throughout the Findings of Incidence of Discrimination section, in the event the sample size or matched-pair data available were not sufficient to yield conclusive 

statistical results, this limitation is documented and indicates the need for additional testing with larger sample sizes in the future.
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(8.36 percent).34 This positive net measure (8.36 percent) 

suggests that people with MD (MI and I/DD combined) were 

significantly less likely to receive a response back to their rental 

inquiry and that a greater percentage of people in the control 

group were favored. Moreover, the resulting p-value indicates 

that the difference in treatment between control and protected 

classes is significant.

A second level of analysis considers several dimensions of the 

response to the different testers, and thus only those tests in 

which both testers within a pair received a response (n = 91, 

or 25 percent of the administered tests) can be included in the 

analysis. Table 22 demonstrates that of the 91 tests in which 

both the control tester and the paired protected tester received 

a reply, protected testers identifying as having MD were less 

likely to be forwarded to a housing provider to make an appointment or to see the unit (7.69 percent favored the control 

class compared with 0.00 percent that favored the protected class).

As described in the Sampling Methods section, the protected 

tester identified himself or herself as an individual with either 

MI or I/DD. Figure 3 represents the response rates of the 183 

paired e-mail tests that were conducted by protected testers 

identifying as a person with MI.

Table 23 documents the results of the first level analysis to 

determine whether testers from the control group were more 

likely to receive a response to the initial inquiry than their 

matched protected tester. Of the 183 paired tests completed in 

which the protected testers revealed that they were people with 

MI (as opposed to I/DD), only 42 (22.95 percent) of the tests 

resulted in responses to both testers in the pair, and 93 (50.82 

percent) of the tests resulted in no response to either tester. 

Figure 3. Response Rates of E-mail Paired Tests for 

Protected Testers Identifying as a Person With MI

No response from provider

n = 93

Some response from provider

n = 90

Total MI tests conducted

n = 183

Control 

tester 

received a 

response 

n = 79

Only control 

tester 

received a 

response 

n = 37

Both

tester 

received a 

response 

n = 42

Only 

protected 

tester 

received a 

response 

n = 11

Protected 

tester 

received a 

response 

n = 53

MI = mental illness.

Thus, in 74 percent of the e-mail tests for which the tester 

revealed MI, the control and protected groups received similar 

treatment. If the responses were different within test pairs, 

however, control testers were favored at a rate of 20.22 percent 

compared with only 6.01 percent for the protected testers. The 

resulting net measure of 14.21 percent and p-value of 0.0001 

demonstrate that these differences are statistically significant.

Table 22. Summary of Differential Treatment of Renters With MD (I/DD+MI) Found in E-mail Testing 

Test Dimension

Both 

Testers

 (%)

Neither 

Tester

(%)

Control 

Tester

Only

(%)

Protected 

Tester

Only

(%)

Net 

Measure p-Value

Sample 

Size

(n)

Unit available 28.57 56.04 8.79 6.59 2.20 0.3953 91

Invited to inspect 72.94 11.76 7.06 8.24 – 1.18 0.5000 85a

Given reason for unit not available 28.57 53.85 8.79 8.79 0.00 0.5000 91

Contact housing provider 41.76 50.55 7.69 0.00 7.69*** 0.0078 91

Asked for additional qualification information 96.70 2.20 1.10 0.00 1.10 0.5000 91

Reminded about qualifications to rent 95.60 3.30 1.10 0.00 1.10 0.5000 91

Encouraged to look at different unit than one advertised 6.59 93.41 0.00 0.00 0.00 NA 91

I/DD = intellectual or developmental disability. MD = mental disability. MI = mental illness. NA = test statistics cannot be produced due to no 

observations in both discordant pairs.

*** Significant at the .01 level.

a

 The sample size of 85 is due to the lack of response data for one of the pairs involved for this particular test dimension. The set of pairs without 

comparable responses cannot be used in the analysis.

34 A positive net difference (control – protected net difference) means a greater percentage of people in the control class were favored, whereas a negative net difference would have meant a greater percentage of people in the protected class were favored. The p-value shows whether differences noted were significant and, if so, at 

what level.
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Table 23. Differential Treatment in Response Received for Renters With MI Found in E-mail Testing 

Test Dimension

Both 

Testers

(%)

Neither 

Tester

(%)

Control 

Tester

Only

(%)

Protected 

(MI) Tester

Only

(%)

Net 

Measure p-Value

Sample 

Size

(n)

Which tester(s) received a response to their e-mail? 22.95 50.82 20.22 6.01 14.21*** 0.0001 183

MI = mental illness.

*** Significant at the .01 level.

Because only 42 completed tests received responses from the 

housing provider to both the control and the protected (MI) 

testers, subsequent indicators of favorable or unfavorable treatment could be analyzed using only these 42 tests. The results 

summarized in Table 24 of the second level analysis show that 

people with MI, when compared with the control tester, were 

less likely to be referred to the housing provider to actually see 

the unit or to make an appointment to do so.

When these same analyses were conducted on the set of completed tests in which protected testers identified themselves as 

people with I/DD rather than people with MI, no significant 

differences were observed between the treatment of the 

protected and control testers. This finding suggests potentially 

different treatment of people by diagnosis or type of MD.

Differences in treatment were also noted based on other 

factors. Despite small sample sizes, notable trends were shown 

in the following areas.

•	 Size of market—In the very large markets, people with 

MD were less likely to receive a reply to their inquiries 

and less likely to be forwarded to a housing provider to set 

up an appointment to see the advertised unit than in other 

size markets. This lower level of response in Chicago and 

Washington, D.C., was noted particularly with respect to 

people with MI.

•	 Gender—Both men and women with MI were less likely 

to receive a reply to their inquiries relative to paired 

control testers, but unfavorable findings were higher in 

significance for men (significant at the .001 level for men 

compared with the .017 level for women). To the contrary, 

treatment differences based on gender were not found for 

testers identifying as having an I/DD.

•	 Current living situation (whether the person was living 

in a community or institutional setting before the 

rental request)—Overall, protected testers with MD were 

less likely to receive a reply to their e-mail inquiries than 

were control testers. Between the two different scenarios 

presented by the protected testers—either moving from 

an institutional setting (Olmstead) or moving from a family 

home or other community setting (non-Olmstead)—protected 

testers who indicated they were moving from an institutional 

setting were even less likely to receive a response to their 

request (significant at the .004 level for Olmstead versus the 

.090 level for non-Olmstead).

Reasonable Accommodation Requests 

via E-mail

Within the total pool of 359 attempted e-mail tests, 78 paired 

tests included a specific request from the protected tester for a 

reasonable accommodation (the control tester in the pair did 

not make a reasonable accommodation request). These reasonable accommodation requests, such as use of an assistance 

animal or the need for verbal reminders to pay rent at a certain 

time, were designed to relate directly to people with MD. Of 

the 78 housing providers who received e-mail inquiries that 

Table 24. Summary of Differential Treatment of Renters With MI Found in E-mail Testing 

Test Dimension

Both 

Testers

 (%)

Neither 

Tester

(%)

Control 

Tester

Only

(%)

Protected 

(MI) Tester

Only

(%)

Net 

Measure p-Value

Sample 

Size

(n)

Unit available 21.43 61.90 9.52 7.14 2.38 0.5000 42

Invited to inspect 70.00 5.00 12.50 12.50 0.00 0.5000 40

Given reason for unit not available 21.43 59.52 9.52 9.52 0.00 0.5000 42

Contact housing provider 45.24 45.24 9.52 0.00 9.52* 0.0625 42

Asked for additional qualification information 100.00 0.00 0.00 0.00 0.00 NA 42

Reminded about qualifications to rent 95.24 4.76 0.00 0.00 0.00 NA 42

Encouraged to look at different unit than one advertised 4.76 95.24 0.00 0.00 0.00 NA 42

MI = mental illness. NA = test statistics cannot be produced due to no observations in both discordant pairs.

* Significant at the .10 level.
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included a reasonable accommodation request, only 39 (50 

percent) sent e-mail responses back to the protected testers. Of 

those housing providers who did respond, roughly 15 percent 

were willing to grant the requested accommodation.

Table 25 summarizes the results of the tests requesting a 

reasonable accommodation. Only 6 of the 39 housing providers who responded (15.384 percent) responded favorably 

to the reasonable accommodation request.35 An additional 3 

housing providers (7.69 percent) responded to the request for 

a reasonable accommodation but in an unfavorable manner, 

either by stating that they were not willing to provide the 

requested accommodation or by giving a more ambiguous 

reply that left the impression that the request for a reasonable 

accommodation was not likely to be approved. The remaining 

30 responding housing providers simply did not address the 

request for a reasonable accommodation. These housing providers’ avoidance of addressing the reasonable accommodation 

request was considered to be unfavorable treatment.

Table 25. Summary of Reasonable Accommodation 

Requests by Testers With MD Found in E-mail Testing 

Type of 

Disability

Reasonable Accommodation Requests

Response 

Received

Willing To 

Provide (n)

Willing To 

Provide (%)

MI 21 3 14.29

I/DD 18 3 16.67

Total 39 6 15.384

I/DD = intellectual or developmental disability. MD = mental disability. 

MI = mental illness.

Overall, the vast majority of people with MD making an e-mail 

request for a reasonable accommodation (84.6 percent) were 

denied their request outright or were left, on their own, to 

determine how to pursue their request or to appeal a housing 

provider’s denial.

Additional qualitative analyses of e-mail replies to accommodation requests are provided in Appendix A, Qualitative Analyses 

and Findings on Overt and Subtle Discrimination Against 

People With Mental Disabilities by Different Testing Modes.

Telephone Testing Findings

This section summarizes findings from the telephone testing to 

measure discrimination against people with MD as they seek 

rental housing. Responses to tester inquiries were analyzed by 

assessing the following responses to testers.

•	 Were both testers told the advertised unit is available 

(favorable)?

•	 Were both testers invited to inspect the unit (favorable)?

•	 Was the unit available and, if not, were both testers given a 

reason for the unit not being available (favorable)?

•	 Were protected testers asked to provide additional 

information regarding their qualifications as an applicant 

(not favorable)?

•	 Were protected testers reminded about qualifications they 

must possess to rent the unit (not favorable)?

•	 Were protected testers encouraged to look at a different 

unit owned by the same landlord than the unit advertised 

(not favorable)?

Analyses focus on differences in treatment between people with 

MD (MI and I/DD) and control testers without disabilities. As 

shown in Table 26, no significant difference was identified with 

respect to whether potential renters with or without MD are told 

whether an advertised unit is available, although the trend suggests that people with MD are less likely to be told an advertised 

Table 26. Summary of Differential Treatment of Renters With MD Found in Telephone Testing

Test Dimension

Control

Tester Only

(%)

Protected 

Tester Only

(%)

Net

Measure p-Value Sample Size(n)

Unit available 6.59 4.94 1.65 0.1050 668

Invited to inspect 21.26 16.47 4.79** 0.0219 668

Given reason for unit not available 5.39 5.39 0.00 0.5000 668

NOT asked for additional qualification information 19.71 20.99 – 1.28 0.33085 629

NOT reminded about qualifications to rent 16.18 24.76 – 8.58 0.0004a 618

NOT encouraged to look at different unit than one advertised 7.78 4.79 2.99** 0.0188 668

MD = mental disability.

** Significant at the .05 level.

a

 The null hypothesis is not rejected as test statistics indicate significance in the other direction.

35 The testing demonstrated slightly higher levels of willingness to provide accommodations for people with I/DD (16.7 percent) versus people with MI (14.3 percent).
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unit is available than people without disabilities (p = .105). 

People with MD (both I/DD and MI), however, were treated 

significantly less favorably in two ways.

1. Protected testers were less likely to be invited to inspect an 

advertised unit.

2. Protected testers were more likely to be steered to a 

different unit than the one advertised, even when the 

advertised unit was available.

Additional instances of significant differences in treatment 

were found during telephone testing when the tests were analyzed based on the type of disability revealed by the protected 

tester. As shown in Table 27, when specifically looking at the 

sample of testers with MI (n = 357), testers with MI were—

•	 Significantly less likely to be told an advertised unit was 

available than the control tester.

•	 Significantly less likely to be invited to inspect an advertised 

unit and significantly more likely to be forwarded to a 

different unit than the one advertised, even when the 

advertised unit was said to be available.36

•	 Significantly more likely to be asked to provide additional 

information about their qualifications.

•	 Significantly more likely to be sent ambiguous signs of 

rentals not being available.37

Analysis of the tests conducted for people with I/DD (n = 311), 

revealed a significant unfavorable difference in that people with 

I/DD were more likely to be forwarded to a different unit than 

the one advertised, even when the advertised unit was said to 

be available (Table 28). This finding suggests that people with 

I/DD are being steered toward a specific building, wing, or area 

within a property.

Table 27. Summary of Differential Treatment of Renters With MI Found in Telephone Testing

Test Dimension

Control

Tester Only

(%)

Protected (MI) 

Tester Only

(%)

Net

Measure p-Value Sample Size(n)

Unit available 7.56 4.48 3.08** 0.0467 357

Invited to inspect 19.61 14.01 5.60** 0.0339 357

Given reason for unit not available 5.60 5.04 0.56 0.3728 357

NOT asked for additional qualification information 22.87 17.68 5.19* 0.0702 328

NOT reminded about qualifications to rent 15.63 25.00 – 9.37 0.0043a 320

Sent ambiguous sign of availability 7.56 5.04 2.52* 0.0899 357

NOT encouraged to look at different unit than one advertised 7.28 4.20 3.08** 0.0429 357

MI = mental illness.

* Significant at the .10 level. ** Significant at the .05 level.

a

 The null hypothesis is not rejected as test statistics indicate significance in the other direction.

Table 28. Summary of Differential Treatment of Renters With I/DD Found in Telephone Testing

Test Dimension

Control

Tester Only

(%)

Protected (I/DD) 

Tester Only

(%)

Net

Measure p-Value Sample Size(n)

Unit available 5.47 5.47 0.00 0.5000 311

Invited to inspect 23.15 19.29 3.86 0.1481 311

Given reason for unit not available 5.14 5.79 – 0.65 0.3658 311

NOT asked for additional qualification information 16.28 24.58 – 8.30 0.0121 301

NOT reminded about qualifications to rent 16.78 24.50 – 7.72 0.0190 298

Sent ambiguous sign of availability 5.47 5.47 0.00 0.5000 311

NOT encouraged to look at different unit than one advertised 8.36 5.47 2.89* 0.0850 311

I/DD = intellectual or developmental disability.

* Significant at the .10 level.

36 This finding suggests that people with MI are being steered toward a different building or a specific wing or area within a building. 

37 See Appendix A: Qualitative Analyses and Findings on Overt and Subtle Discrimination Against People With Mental Disabilities by Different Testing Modes, for 

examples of this subtle discrimination.
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Telephone testing revealed that people with MI and I/DD 

were less likely to be reminded about qualifications or asked to 

provide additional information about their qualifications than 

people without disabilities.38 Further testing and qualitative 

debriefing of housing providers would be needed to determine 

whether this indicator is favorable or unfavorable.

The following differences by size of market, gender, and previous 

living status were also observed as trends in telephone testing.

•	 Size of market—People with both MI and I/DD were 

treated less favorably in large- and medium-sized markets, 

as compared with very large markets, in several areas, 

including (1) they were less likely to be told an advertised 

unit is available, (2) they were less likely to be invited to 

inspect that unit, and (3) they were encouraged more to 

look at a different unit than the one advertised.

•	 Gender—By contrast with e-mail findings, in telephone 

testing, women with MI were (1) less likely to be invited in 

to view the unit (22.70 percent of tests favored control-group 

women compared with 6.38 percent that favored women 

with MI; p = .0002), (2) less likely to be asked to provide 

additional information regarding their qualifications as an 

applicant (32.14 percent favored control-group women 

compared with 11.43 percent that favored women with 

MI; p = .0001), and (3) more likely to be encouraged 

to look at a different unit owned by the same landlord 

(14.18 percent favored control-group women compared 

with 7.09 percent that favored in women with MI; p = .034).

Men with MI were less likely to be asked about qualifications or any additional information than women with MI. 

Significant gender differences were not found for people 

with I/DD.

•	 Current living situation—Protected testers who indicated to the housing provider that they had been living in an 

institutional setting before renting (Olmstead) were (1) less 

likely to receive a reply to their inquiries, (2) less likely 

to be invited to inspect a unit, and (3) more encouraged 

to look at a different unit than the one advertised, when 

compared with the protected testers who reported to 

providers that they were living in a family home or 

community-based settings before renting (non-Olmstead).

Reasonable Accommodation Requests 

via Telephone

During telephone testing, if protected testers were invited to see 

a unit, a request for a reasonable accommodation was made. A 

total of 629 telephone tests included a request for a reasonable 

accommodation from the protected tester. Table 29 summarizes 

the results of the responses to these requests.

Table 29. Summary of Reasonable Accommodation 

Requests by Testers With MD Found in Telephone 

Testing 

Type of 

Disability

Reasonable Accommodation Requests

Response 

Received

Willing To 

Provide (n)

Willing To 

Provide (%)

MI 339 187 55.16

I/DD 290 185 63.79

Total 629 372 59.14

I/DD = intellectual or developmental disability. MD = mental disability. 

MI = mental illness.

By contrast with findings from the e-mail tests (in which only 

15.384 percent of housing providers expressed willingness 

to provide a reasonable accommodation when asked), 59.14 

percent of the housing providers who were asked to provide 

reasonable accommodations during telephone testing stated 

that they would be willing to make the accommodation or 

would view the request favorably given disclosure of the 

disability. This finding may indicate that housing providers 

are more likely to engage in a conversation and openly discuss 

accommodations on the telephone than in an e-mail. Telephone 

testing still showed a significant percentage of accommodation 

requests that were not accepted (40.86 percent), however. The 

remaining housing providers either stated outright that they 

were not willing to provide the accommodation or gave more 

ambiguous replies that more subtly pointed toward a negative 

decision.39 Thus, a large percentage of people with MD (40.86 

percent) were denied their request for a reasonable accommodation or left to figure out how to pursue that request on their 

own given negative input in response to their request.

In addition, reasonable accommodation response rates differed 

by type of disability (see Table 29), revealing that a higher 

percentage of housing providers were willing to provide 

38 This finding may suggest a favorable finding that housing providers know not to ask these types of questions, or it may suggest unfavorable treatment in that 

housing providers may be less likely to ask for any detailed rental information from applicants with MI and I/DD after having already shown less chance of inviting 

them to see or inspect a unit. 

39 For example, many housing providers or their agents stated that they did not think the owner would allow the requested accommodation or that it was unlikely 

the request would be considered, and they said that the applicant would need to find and call a representative at the housing provider to verify this information but 

did not give any contact information to do so.
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accommodations to people with I/DD (63.79 percent) than 

to people with MI (55.16 percent). Requests for a reasonable 

accommodation were also more likely to be considered and 

granted in large markets (65.7 percent) and medium markets 

(66.7 percent) than in very large markets (47.4 percent) or 

small markets (41.9 percent). This analysis again produced 

a higher acceptance rate for people with I/DD than with MI, 

regardless of market size.

Table 30 summarizes the varying levels of affirmative 

responses to requests for reasonable accommodations within 

different-sized markets tested. Given small sample sizes tested, 

particularly in smaller city markets, results are limited to showing only potential trends. This limit demonstrates the need for 

larger-scale testing to determine significant differences between 

metropolitan statistical areas based on market size.

Additional qualitative analyses of telephone responses to 

requests for reasonable accommodations are provided in 

Appendix A, Qualitative Analyses and Findings on Overt and 

Subtle Discrimination Against People With Mental Disabilities 

by Different Testing Modes.

Table 30. Summary of Reasonable Accommodation Request Responses by Specific Markets 

Type of 

Disability

Counts Willing To 

Accommodate

(%)

99% C.I. 95% C.I. 90% C.I.

Total 

Requested

Willing To 

Accommodate

Lower

(%)

Upper

(%)

Lower

(%)

Upper

(%)

Lower

(%)

Upper

(%)

Chicago-Joliet-Naperville, IL-IN-WI

MI 55 18 32.7 16.4 49.0 20.3 45.1 22.3 43.1

I/DD 46 21 45.7 26.7 64.6 31.3 60.0 33.6 57.7

MI+ I/DD 101 39 38.6 26.1 51.1 29.1 48.1 30.6 46.6

Washington-Arlington-Alexandria, DC-VA-MD-WV

MI 51 24 47.1 29.1 65.1 33.4 60.8 35.6 58.6

I/DD 42 29 69.0 50.7 87.4 55.1 83.0 57.3 80.8

MI+ I/DD 93 53 57.0 43.8 70.2 46.9 67.1 48.5 65.4

Nashville-Davidson--Murfreesboro--Franklin, TN

MI 53 35 66.0 49.3 82.8 53.3 78.8 55.3 76.7

I/DD 53 37 69.8 53.6 86.1 57.5 82.2 59.4 80.2

MI+ I/DD 106 72 67.9 56.2 79.6 59.0 76.8 60.5 75.4

Cincinnati-Middletown, OH-KY-IN

MI 75 48 64.0 49.7 78.3 53.1 74.9 54.9 73.1

I/DD 55 35 63.6 46.9 80.3 50.9 76.3 53.0 74.3

MI+ I/DD 130 83 63.8 53.0 74.7 55.6 72.1 56.9 70.8

Albuquerque, NM

MI 26 19 73.1 50.7 95.5 56.0 90.1 58.8 87.4

I/DD 23 18 78.3 56.1 100.0 61.4 95.1 64.1 92.4

MI+ I/DD 49 37 75.5 59.7 91.3 63.5 87.6 65.4 85.6

Fresno, CA

MI 27 17 63.0 39.0 86.9 44.7 81.2 47.7 78.2

I/DD 24 21 87.5 61.3 98.5 67.6 97.3 70.8 96.5

MI+ I/DD 51 38 74.5 58.8 90.2 62.5 86.5 64.5 84.5

Harrisburg-Carlisle, PA

MI 28 14 50.0 25.7 74.3 31.5 68.5 34.5 65.5

I/DD 25 14 56.0 30.4 81.6 36.5 75.5 39.7 72.3

MI+ I/DD 53 28 52.8 35.2 70.5 39.4 66.3 41.6 64.1

New Haven-Milford, CT

MI 10 6 60.0 19.1 92.3 26.2 87.8 30.4 85.0

I/DD 5 3 60.0 8.3 97.7 14.7 94.7 18.9 92.4

MI+ I/DD 15 9 60.0 27.4 92.6 35.2 84.8 39.2 80.8

Syracuse, NYa

MI 17 7 41.2 10.4 71.9 17.8 64.6 21.5 60.8

I/DD 14 6 42.9 8.8 76.9 16.9 68.8 21.1 64.6

MI+ I/DD 31 13 41.9 19.1 64.8 24.6 59.3 27.4 56.5

C.I. = confidence interval. I/DD = intellectual or developmental disability. MI = mental illness.

a

 Added after a potential detection issue was discovered in New Haven-Milford, CT.
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In-Person Testing Findings

This section summarizes findings from in-person testing to 

measure discrimination against people with and without MD 

as they seek rental housing. Key questions that form the basis 

for analysis include—

•	 Were both testers told the advertised unit is available 

(favorable)?

•	 Was the unit available and, if not, were both testers given 

a reason for the unit not being available (favorable)?

•	 Were protected testers asked to provide additional 

information regarding their qualifications as an applicant 

(not favorable)?

•	 Were protected testers reminded about qualifications they 

must possess to rent the unit (not favorable)?

•	 Were protected testers encouraged to look at a different 

unit owned by the same landlord than the unit advertised 

(not favorable)?

The first analysis focuses on differences between testers with 

MD (MI and I/DD samples combined) and testers without 

disabilities. As shown in Table 31, people with MD were significantly less likely than people without disabilities to be told 

that the advertised unit was available (5.94 percent favoring 

the control tester compared with 0.99 percent favoring the 

protected tester) and were less likely to be given a valid reason 

for why the unit was not available (3.96 percent favoring 

the control tester compared with 0.00 percent favoring the 

protected tester). No other significant differences in treatment 

were identified during the in-person testing.

The sample size varies if data were missing or not available for 

one of the matched pairs; only balanced matched-pair data 

were analyzed.

As in the other modes of testing, when additional characteristics 

of testers were considered in the analysis, evidence of differential treatment based on disability type, current living status, 

region, and gender were observed.

As shown in Table 32, people with MI were less likely to be 

told that an advertised unit is available (8 percent of tests 

favored the control group compared with 0 percent that favored 

the MI group) during in-person testing.

No significant differences in treatment were found between testers with I/DD and control testers without MD (see Table 33).

The following additional differences by gender, race, and living 

situation were also found to be significant in in-person testing.

•	 Gender—Women with MI were less likely to be told 

an advertised unit was available (11.43 percent of tests 

favored women without disabilities compared with 0 

percent that favored women with MI; p = .06) and more 

likely to be encouraged to look at a different unit than 

the one available (20 percent favored women without 

disabilities compared with 5.71 percent that favored in 

women with MI; p = .09) during the in-person testing. 

Table 31. Summary of Differential Treatment of Renters With MD Found in In-Person Testing

Test Dimension

Control

Tester Only

(%)

Protected 

Tester Only

(%)

Net

Measure p-Value Sample Size(n)

Unit available 5.94 0.99 4.95* 0.0625 101

Given reason for unit not available 3.96 0.00 3.96* 0.0625 101

NOT asked for additional qualification information 16.49 21.65 – 5.16 0.2055 97

NOT reminded about qualifications to rent 18.75 19.79 – 1.04 0.4347 96

NOT encouraged to look at different unit than one advertised 12.87 12.87 0.00 0.5000 101

MD = mental disability.

* Significant at the .10 level.

Table 32. Summary of Differential Treatment of Renters With MI Found in In-Person Testing

Test Dimension

Control

Tester Only

(%)

Protected (MI) 

Tester Only

(%)

Net

Measure p-Value Sample Size(n)

Unit available 8.00 0.00 8.00* 0.0625* 50

Given reason for unit not available 4.00 0.00 4.00 0.2500 50

NOT asked for additional qualification information 17.02 25.53 – 8.51 0.2517 47

NOT reminded about qualifications to rent 18.75 20.83 – 2.08 0.5000 48

NOT encouraged to look at different unit than one advertised 16.00 6.00 10.00 0.1133 50

MI = mental illness.

* Significant at the .10 level.
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Table 33. Summary of Differential Treatment of Renters With I/DD Found in In-Person Testing

Test Dimension

% Tester Favored

Control

Tester Only

(%)

Protected (MI) 

Tester Only

(%)

Net

Measure p-Value Sample Size(n)

Unit available 3.92 1.96 1.96 0.5000 51

Given reason for unit not available 3.92 0.00 3.92 NA 51

NOT asked for additional qualification information 16.00 18.00 – 2.00 0.5000 50

NOT reminded about qualifications to rent 18.75 18.75 0.00 0.5000 48

NOT encouraged to look at different unit than one advertised 9.80 19.61 – 9.81 0.1509 51

I/DD = intellectual or developmental disability. NA = test statistics cannot be produced due to no observations in control, protected, or both groups.

Such observations were not made for men (for additional 

qualitative analyses of the content of these responses, see 

appendix A).

•	 Race—Although sample sizes and matched-pair data were 

too small to be conclusive to analyze most differences, 

African-Americans with MI were less likely to be told 

an advertised unit was available (9.76 percent favored 

African-Americans without disabilities compared with 

0.00 percent that favored African-Americans with MI; 

p = .06) than African-American control testers.

•	 Current living situation—Testers with MI who identified 

as living in a nursing home or institution before renting 

(Olmstead group) were less likely to be told an advertised 

unit was available (13.33 percent favored people without 

disabilities compared with 0.00 percent that favored people with MI living in nursing homes; p = .06) and trending 

toward more likely to be encouraged to look at a different 

unit (23.33 percent favored people without disabilities 

compared with 6.67 percent that favored people with MI 

living in nursing homes; p = .09). No significant findings 

were observed in test results for applicants with I/DD who 

identified as living in large group homes versus with family 

before renting.

In addition to the analysis of these quantitative findings, all 

qualitative field notes and examples from in-person testing 

were analyzed for additional overt and subtle indications of 

discrimination. An innovative mixed-methods approach was 

used for analyzing these qualitative data, which yielded rich 

descriptive findings on additional areas of potential discrimination that were not measured in the quantitative analyses. These 

qualitative methods and findings are summarized separately in 

appendix A, Qualitative Analyses and Findings on Overt and 

Subtle Discrimination Against People With Mental Disabilities 

by Different Testing Modes.
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Findings From the Evaluation of Different Testing Modes

Two primary objectives of this study were to (1) develop 

and implement different testing methods and approaches for 

measuring housing discrimination on the basis of MD and 

(2) evaluate the strengths and weaknesses of each approach, 

to establish a set of protocols for conducting paired testing 

to measure the degree to which people with MD experience 

discrimination in the search for rental housing. This section 

of the report evaluates the three testing methods implemented 

over the course of this research effort, focusing on the unique 

aspects of implementing paired testing with, and on behalf of, 

people with MD.

DDS 2005 explored the development of methodologies to test 

for housing discrimination on the basis of MD and served as 

a starting point for developing the research approach for this 

study. The final report from DDS 2005 provided the study team 

with a set of considerations when employing people with MD 

as testers and also provided some insights on how to reveal 

disability and how to construct parallel stories for paired testing. 

This information was supplemented with a review of current 

research on testing, insights from focus groups that included 

people with MD, and guidance from the study’s expert panel to 

develop the testing protocols implemented in this project.

People With Disabilities As Testers: Is 

It Feasible?

HUD, the study team, the expert panel, and focus groups 

strongly supported the participation of people with MD 

throughout the project, both as advisors and as testers. 

Although the recommendations of DDS 2005 indicated such 

an approach was feasible for in-person testing, the report also 

noted the potential difficulty of recruiting a sufficient number 

of testers with MD and the concern that the effectiveness of the 

testers might decline if too many tests were conducted within 

a given time period. With these concerns in mind, people with 

MD were engaged early in the planning process to help design 

the testing protocols and to participate in the testing process. 

The study team sought to balance the equally important 

practical need to produce credible results in a reasonably short 

period of time with the need to contain costs. This balance 

imposed practical limitations on methodologies, but it also 

supported the consideration of different approaches, both for 

the benefit of the testers with MD and for the efficient execution 

of the study.

The final research design included pilot testing that employed 

people with and without MD as testers. People with MD 

served exclusively as protected testers for the in-person testing, 

completing each test accompanied by a companion without 

MD, who was another trained tester posing as friend helping 

in the search process. This testing design was based on the 

recommendation of the expert panel, was confirmed by focus 

groups that included people with MD as a reasonable strategy,40

and replicated the approach of the 2005 DDS.

The conclusion reached by the study team, as discussed 

subsequently, was that producing reliable fair housing test 

results while working with individuals with MD—both MI and 

I/DD—is feasible.

Tester Profile: How Do You Isolate 

and Reveal Disability?

A key challenge to conducting matched-pair testing for housing 

discrimination on the basis of MD is ensuring that the tester 

can convincingly and unambiguously reveal the presence of 

MD to a housing provider. Based on a review of the literature, 

findings from focus groups, and discussions with the expert 

panel, the following recommendations were made regarding (1) 

the severity of a tester’s disability, (2) the disclosure-and-reveal 

sequence, and (3) the profile of the tester.

Severity of Disability

After reviewing existing research on testing with this population, and keeping in the spirit of the goals of the Fair Housing 

Act and the Americans with Disabilities Act, the study team 

determined not to restrict the type or severity of MD for testers, 

other than being confident that the person with MD was able 

to complete the assigned test. To make this determination, a 

40 Focus groups noted that people with MD who brought along another person for support when searching for housing reported feeling safer and more comfortable 

in the housing search process. Focus group respondents also noted that even when a companion was present, people with MD still experienced potential 

discrimination by landlords. The expert panel, which also included people with MD, agreed that this approach would likely yield good data by having two people 

to observe and record each test. The concern that the presence of a companion might affect or bias a test was discussed with the expert panel, and it was ultimately 

determined that the effect of a companion accompanying the protected tester would likely be minimal.
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verification process was used that was equivalent to seeking 

informed consent when enrolling a research subject. For 

this project, tester candidates were required to be their own 

guardian and be capable of giving the equivalent of informed 

consent, recognizing that this restriction would likely reduce 

the pool of potential MI and I/DD testers. The research team 

then ensured that the candidate understood what was expected 

of him or her and could repeat the requirements back to 

research team member. The ultimate goal was to ensure that 

all testers were able to fully execute the test, including the 

reporting requirements after the test, not only at the time of 

recruitment but also on the day of each scheduled test. To 

this end, the recruitment, interview, and training process was 

critical for successful testing involving people with MD.

Revealing Disability

Several challenges were identified as being inherent in testing 

for housing discrimination on the basis of MD.

•	 Unlike other housing discrimination research studies, 

which have focused on externally recognizable characteristics, such as race and ethnicity, most MD is not visible or 

immediately recognizable (Corrigan and Penn, 1999) and 

therefore must be revealed during testing.

•	 Although many people with MD in the real world may 

be reluctant or unwilling to reveal their disability, for the 

purpose of these tests, the MD must be clearly, credibly, 

and consistently disclosed to the housing provider or agent.

•	 Many people with MD have multiple or co-occurring 

mental or physical disabilities; however, the testing design 

can focus on only the single issue of the presence of MD.

•	 Although people with MD may disproportionately have 

low incomes, profiles for both control and protected 

testers had to depict them as income qualified for the 

units they were seeking in order to avoid introducing 

another variable into the tests.

Recognizing that the necessarily narrow design of the testing 

implemented for the purposes of this research effort does not 

represent the multiple and complex factors that affect the 

typical experience of many people with MD during the housing 

search process, different strategies were developed across the 

three test modes to isolate the variable of interest in this project.

Because data are limited on testing for housing discrimination 

against people with MD, the study team turned to recent 

research on discrimination during the search for employment 

for additional guidance for its disclosure strategies. Revealing 

disability41 during a job interview has parallels to the housing 

search process; that is, some individuals may reveal the presence of a disability right at the start of the housing search process, and others may hide their disability and continue to do so 

after moving into a unit. The timing of disclosure of disability 

during matched-pair testing was studied by Dalgin and Bellini 

(2008)using a tester profile that contained a 9-month gap in 

employment. In that study, the control testers with no disability 

offered that they were taking care of their mother who had a 

serious illness during that time. The testers with disabilities 

disclosed that they had been ill and needed to take some time 

off to deal with their own health concerns. Disclosure of the 

specific nature of the health concern (that is, disability) then 

occurred later when voluntarily shared by the candidate either 

in a short or long response (that is, more or less detail). This 

study determined that extensive information on disability does 

not change the outcome, because no difference was evident in 

response to the shorter version of disclosure. This approach 

assured that the employer knew the applicant had MD early in 

the interview process and then later received some additional 

information about that disability.

The DDS 2005 exploratory testing grappled with how the 

protected tester could reveal the presence of a disability to a 

housing provider. For this project, it was generally agreed that, 

although most people in this group would not typically disclose 

their disability outright to a housing provider, it would be 

credible to do so if the each tester disclosed while explaining 

why they had no recent rental history. As a result, in all tests, 

protected testers disclosed that their lack of rental history was 

due to being in a mental health treatment facility (for people 

with MI) or in a group home (for people with I/DD). Paired 

control testers disclosed that they had either been a student 

living in a dorm, had lived with family, or had lived abroad.

41 MacDonald-Wilson, et al. (2011:192) defined disclosure as “revealing information about one’s diagnostic label, mental health condition, or psychiatric disability” 

and identify seven different types or reasons for disclosure.

1. Full disclosure—no one excluded from knowing.

2. Selective disclosure—to people whom the person trusts.

3. Strategically timed—after building trust over time; may or may not be full disclosure.

4. Targeted—condition of employment. 

5. Nondisclosure—hide it from all.

6. Inadvertent—reveal instead of being “found out.”

7. Forced—something came up that required it (e.g., hospitalization).
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Another approach to revealing disability in testing is with a 

request for a reasonable accommodation. Common accommodations requested can include assistance animals, variance of the 

rent due date to accommodate the date of receipt of disabilityrelated income, request for a live-in aid, waiver of minimum 

income or credit requirements, acceptance of rent from a 

third-party payer, or agreement to communicate through a 

case worker or family member.42 Kaye (2012: 16) suggested 

that “disclosure of a PD [psychiatric disability] through a 

written accommodation request accompanying an application 

can cause a housing applicant to be negatively stereotyped as 

less capable than an applicant without a PD, despite similar 

qualifications” and can increase likelihood of discrimination.

Establishing a Suitable Profile

A key concern in this project was to make the testing situation 

as realistic as possible. This goal meant that the tester profiles 

were required to align with the reality experienced by people 

with MD but also to not trigger suspicion by the housing 

provider or generate bias. The following was recommended.

•	 Type of disability—The specific type of disability was not 

stated during a test. Instead, protected testers gave the 

broad category of having either MI or I/DD and then revealed 

more about functional aspects of the disability during the 

interview (telephone or in-person) or in the e-mail.

•	 Visible characteristics—Race, gender, and age of test 

pairs were driven by actual tester demographics but were 

matched across pairs for all test types.

•	 Income—The income of each tester was established by 

the study team and was in the range needed to afford the 

unit being sought. Furthermore, testers did not claim SSDI or 

any other disability-related income, nor did they indicate 

that they were using a Housing Choice Voucher or any other 

form of housing assistance. This condition was to eliminate 

any potential bias based on source of income, which is a 

protected class in some jurisdictions but not others. 

•	 Employment—It was agreed that testers should be 

working to eliminate concerns that unemployment might 

be a source of bias for some housing providers. Being 

employed, however, does not ensure sufficient income to 

afford many apartments (using the “30 percent of income” 

rule), therefore, control and protected testers’ profiles were 

designed to include employment that realistically paid 

enough to cover the rent at the property being tested.

Using the testing protocols described in previous sections, protected class testers were trained to reveal their disability in such 

a way that it was unambiguous and could not be discredited 

even if the protected tester did not “manifest symptoms.” The 

approach taken in this study was, thus, full disclosure of MD in 

all test modes by the individual acknowledging the presence of 

a disability (1) directly (for example, “I have a mental disability”) 

and (2) indirectly (for example, rental history). In some cases, 

disability was also revealed by asking for a reasonable accommodation; however, such a request was made only after the first 

two disclosure methods were completed and all information 

required for the test to be considered complete was attained. 

In all cases, the functional aspects of disability, rather than the 

type of disability, were provided when disclosing any details.

Tester profiles were matched for consistency between the 

protected tester and control tester. Similar backgrounds were 

used to establish a similarity in rental history. The guidance for 

testers with disabilities during in-person testing and proxies 

during the telephone testing, and the exact language used in 

e-mail testing, are presented subsequently.

E-mail Testing: Strengths and Weaknesses

E-mail testing is important given the growing use of this medium for communication in the rental housing search process. As 

a testing mode, it has several strengths when focusing on individuals with disabilities. It also has some limitations, including 

the inability to interpret a nonresponse from a housing provider 

and the effect such a nonresponse has on the overall set of 

paired test results. One strategy for addressing this concern is 

to enlarge the sample, or to oversample. This approach, too, can 

also have drawbacks, however, especially in smaller markets 

where increasing the sample size can also increase the risk of 

test detection.

A key strength of e-mail testing is the elimination of potential 

fatigue among testers, which was a particular concern raised in 

the discussion of working with people with MD as testers. With 

the e-mail as the “tester,” this mode also reduces human error 

in reporting because it provides verbatim statements on both 

sides of the transaction—each member of the tester pair and 

the housing provider. This design allows for the message and 

initial contact of the tester to be controlled, including when and 

how the disability is revealed, thus ensuring consistency across 

42 Kaye (2012: 31) suggested an additional reasonable accommodation request to reveal a PD by having “two applicants requesting that they can break lease with no 

penalty, but one is asking in case of psychiatric hospitalization and the other is asking in case of military deployment.”
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all tests, which in turn can produce reliable and unambiguous 

quantitative measures to determine if clear patterns of discrimination exist against people with MD.

E-mail testing also provides data that allow for a more systematic 

and specific analysis to find evidence of subtle discrimination. 

Since passage of the FHA, researchers involved in paired 

testing studies have observed that it is rare to find a “smoking 

gun” of proof (Hanson, Hawley, and Taylor, 2011). E-mail 

testing provides written data directly from a housing provider 

that can then be used to more accurately assess the subtle nature 

and extent of discrimination (Hanson, Hawley, and Taylor, 

2011; HDLP, 2012).

Subtle discrimination may be used to discourage someone in 

a protected class from pursuing a particular housing option. 

It can also include more favorable treatment of the protected 

class. For example, recent testing in Vermont involving in-person 

testing of people with disabilities, including MD, found that 

27 percent of the control testers were positively favored, but 

neither protected nor control testers experienced outright discrimination.43 The e-mail data produced for this project were 

coded and analyzed using qualitative methods, which found 

evidence of (1) subtle discrimination against the protected 

tester and (2) more overt differences in treatment that could 

be categorized as discrimination (Hanson, Hawley, and Taylor 

(2011). See Appendix A, Qualitative Analyses and Findings on 

Overt and Subtle Discrimination Against People With Mental 

Disabilities by Different Testing Modes for a more extensive 

discussion of this topic.

This analysis also highlighted issues relating to the timing of 

e-mails in testing, and particularly when the initial housing 

inquiry e-mail was received and responded to. In this testing, it 

could only be assumed from the e-mail time stamp that the order in 

which an e-mail response was received by the testing team was 

also the order in which it was read by the housing provider.

Although a new frontier in testing, this project confirms that 

e-mail testing research can generate reliable results that, based 

on statistical analysis of quantitative data, can be used to determine discrimination. These same data can be coded for both 

quantitative and qualitative analysis to look systematically for 

evidence of subtle forms of discrimination, which may be of use 

in future testing efforts. Table 34 summarizes the pros and cons 

of the e-mail method of testing.

Table 34. Pros and Cons of E-mail Testing 

Pros Cons

Cost effective for a large number of tests. Captures only first point-of-contact step of housing search process.

Automated system generates predetermined script. No live interaction with housing provider.

Logistically straightforward. Many larger housing providers use canned, scripted replies regardless 

of initial request—unclear whether provider is responding to the 

disability component. 

Test administrators, but no testers—eliminates tester fatigue and error. Potential for low response rate requires larger sample size. 

Less time consuming than other modes (e-mail is the data so no report 

forms or debriefing required).

Data are limited to the e-mail returned.

Provides exact language used by housing provider for analysis. Difficult to interpret nonresponses.

Telephone Testing: Strengths and 

Weaknesses

The number of telephone tests that were completed, 

including those tests that included a request for a reasonable 

accommodation, exceeded the goals for this test mode. This 

result demonstrates that telephone testing can produce a high 

volume of tests for analysis in a relatively short period of time 

and can be used successfully to produce useful data.

The telephone mode of testing also has its limitations, however, including—

•	 Testers have no face-to-face interaction with housing 

providers, so interpreting responses to questions is based 

solely on what people say over a telephone, which may be 

different than if the conversation occurred in person. 

•	 Compared with e-mail testing, telephone testing produces 

detailed field notes to use in subsequent analysis. Although 

a positive, it is also a negative because it requires additional 

time for testers to produce their reports.

•	 The particular test design here, which used proxies, is not 

the equivalent of actually speaking with a person with MI 

or I/DD. The results, although valid and useful, may not be 

as socially valid as using a person with MD to do the testing.

43 Housing Discrimination Law Project of Vermont Legal Aid (2012).
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Based on the successful use of testers with MD for in-person 

testing as part of this project, the study team believes that it 

would be feasible to conduct telephone testing that employs 

people with MD to serve as protected testers, making calls and 

requesting information about the apartment for themselves, 

assuming that a strong commitment to training and oversight 

is in place. As noted previously, the social validity of this testing 

is likely to increase if people with disabilities are used in the 

testing process to make telephone calls.

Table 35 summarizes the observed pros and cons of telephone 

testing. As with e-mail testing, most of the issues are not unique 

to testing for discrimination against people with MD.

Table 35. Pros and Cons of Telephone Testing 

Pros Cons

Live interaction w/housing provider. No face-to-face interaction.

Use of proxy without a disability as friend or family member to conduct 

test allows for more flexibility in recruiting, training, and scheduling 

testers. 

Not the equivalent of actually speaking to people with MI or I/DD.

Can be conducted from anywhere in the United States (one centralized 

location or group of remote locations).

Requires being in a location with sufficient MD community to recruit 

from if using population to test.

Testers have script in front of them during test and record results in real 

time.

Although detailed field notes a positive, they require time for testers 

to produce, unlike e-mail, for which returned e-mail response alone is 

used.

I/DD = intellectual or developmental disability. MD = mental disability. MI = mental illness.

In-Person Testing: Strengths and 

Weaknesses As Evaluated by Testers 

With MD and Companion Testers

In-person testing is a labor-intensive process for any protected 

class, given the recruitment and retention strategies needed to 

ensure that the required number of paired tests is executed. In 

this study, one significant concern was that people with MD 

would require more time between tests to reduce potential for 

fatigue, and that therefore completing the planned number 

of tests within a reasonable timeframe would necessitate the 

recruitment of a larger number of testers, which can have significant cost implications. In addition, the use of a companion 

tester raised concerns regarding both increased costs and a 

possible delay in testing as a result of having to coordinate 

multiple schedules for each test.

The initial literature review and focus groups, input from the 

expert panel, and a small set of in-person pretests served as 

preparatory steps to working with in-person testers with MI 

and I/DD. These efforts were designed to provide key insight 

into housing discrimination experienced by this population 

and ideas for how to involve community members as in-person 

fair housing testers, including the recruitment, selection, and 

training of testers and the data collection process.

The in-person testing had a smaller sample size and a longer 

execution time, and it was conducted in only two, very large 

housing markets. To evaluate the inclusion and active participation of people with MD as testers, four focus groups with 

key participants and stakeholders were conducted, including 

(1) project leaders, (2) testers with I/DD, (3) testers with MI, 

and (4) companion testers.

Additional earlier focus groups, primarily consisting of testers, 

were held in the weeks immediately after the completion of 

in-person testing and data collection so participants could reflect 

on their testing experiences. The detailed approach and results 

of the focus groups, which includes quotes from participants, 

can be found in one of the short papers associated with this 

project, Accessible & Participatory Methods for Involving People 

with Mental Disabilities In Housing Discrimination Testing.

Strategies for Tester Recruitment, Selection, 

Retention, and Matching

Test coordinators from the two participating fair housing testing 

organizations broadly recruited potential testers by contacting 

a variety of community groups and organizations with which 

people with MI and I/DD had active contact, such as programs 

that provide housing or community living services. Because 

of widespread employment disparities among this population, 

some people with MI and I/DD were found to be more available 

to work as testers; however, the availability of testers who were 

currently unemployed may also have restricted the recruitment 

of testers with full-time jobs or busy schedules.

Test coordinators also implemented extended interactions with 

potential testers to allow for the evaluation of the “fit” between 

the tester and the testing responsibilities involved (that is, 
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discerning if the candidate could complete the essential job 

duties). During these interactions, test coordinators provided 

potential testers a candid and thorough description of the 

project and their expected role, including an emphasis on 

the responsibilities of being a tester versus other roles in the 

project, assessing how the potential tester understood his or 

her role, and the potential tester’s comfort with pretending to 

be searching for an apartment and disclosing their disability 

during the housing search process. All these issues were 

proactively addressed during the initial tester training. For 

some, initial training helped test coordinators make a final 

determination about a potential tester’s involvement in the 

actual in-person tests.

In addition, the study team learned how best to deliver training to potential testers with MD, by simplifying and limiting 

background information and lecture and instead focusing on 

short practice exercises, open discussion of any questions, and 

other modifications that enable testers to gain comfort carrying 

out a test and working with a companion tester.

Test coordinators also noted that they needed to allocate 

significant time to the recruitment process, needing initially 

to recruit about three times the number of testers needed. For 

example, in some cases, most notably among potential testers 

with I/DD, availability and reliability were issues (for example, 

getting training scheduled, not showing up for scheduled 

training, the availability of reliable transportation, and the 

need to navigate a new transportation route without support). 

Finding available testers was especially difficult given the need 

to coordinate I/DD testers with companion testers for initial 

training, practice testing, and each in-person test.

Despite these challenges, test coordinators from the two 

participating testing organizations were able to recruit the 

required number of testers due to their extensive contacts and 

continual networking with community groups and people with 

disabilities. These established connections with community 

groups and people with disabilities were essential to this effort 

and would be difficult for organizations not familiar with and 

embedded within disability communities to replicate. The use 

of these community-based testing organizations was a critical 

component of the project and a key to success in actively 

supporting people with MD during the in-person testing effort.

Test coordinators also noted that it was important to identify 

people who would be good companion testers, and they noted 

that ensuring a strong rapport between a tester with disabilities 

and his or her companion tester was key to the protected 

testers’ comfort and to the quality and efficiency of testing. Test 

coordinators also noted that it was especially important that 

they consult with both the protected tester and the companion 

independently, and early in the partnership, to ensure that the 

pair was a good match. This assessment of the match began 

during the initial training, when the team purposively built in 

many opportunities for pairs to get to know each other and 

become comfortable with each other during practice tests. Test 

coordinators and testers agreed that a tester’s choice of his or 

her companion was very important to the comfort and fidelity 

of the tester and data collection and agreed that pairs should be 

rematched if one of the members was not comfortable. 

Preparing and Supporting Testers: Initial 

Training

Project leaders worked to design tester training to effectively 

engage testers with both MI and I/DD and to actively support 

their learning. For both groups, training materials deemphasized complicated text, reduced the number of ideas presented 

at one time, and incorporated graphics, photos, and images 

to illustrate more abstract points such as civil rights. The 

trainings also included opportunities to observe testing skits 

performed by test coordinators and project staff first, and then 

for testing pairs to actively engage in several different testing 

scenarios by role-plays (moving from working in pairs with an 

assigned project staff to role-playing in front of the whole group 

and getting feedback thereafter), and they included frequent 

breaks to take in information learned. Basing their approach 

on initial insights from stakeholder focus groups and expert 

panel meetings conducted at the start of the project, project 

leaders delivered the training differently for each group to 

maximize their learning. For example, testers with I/DD had the 

information broken into smaller units followed immediately by 

opportunities to practice a small skill first and then build up 

to practicing a full test and then onto an actual practice test in 

the field, and testers with MI received initial information in one 

sitting and then practiced different scenarios.

Testers reported that these experiences—particularly the opportunity to practice and receive individualized feedback—helped 

them learn their responsibilities and feel prepared for their role. 

Some testers noted that when the time between training and testing 

in the field was significant, it was beneficial to have opportunities to brush up on their skills and review the testing protocol. 

Project leaders observed that ensuring that the training had a 

good deal of time devoted to hands on learning was essential.

Preparing and Supporting Testers: 

Ongoing Support During In-Person Testing

The in-person paired testing was also designed to support 

testers during data collection in ways that testers and companion testers found helpful. Project leaders provided scripts and 
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checklists to help testers remember the personal information 

they would need to provide during testing. They also provided 

reminders via e-mail, telephone, or both (cell phone communications were used frequently before, during, and after testing) 

and were readily available to respond to questions and assist 

with unanticipated problems.

Many project leaders and testers agreed that being able to debrief 

with test coordinators immediately after each test (either by 

telephone or in person) was very helpful. The testing protocols 

required debriefing within 48 hours of the actual test and, in 

many cases, testers completed debriefing immediately after the 

test or within 24 hours. For some testers, being able to complete 

the forms at the testing coordination agency allowed them 

access to onsite computers and to test coordinators in case any 

questions arose. These factors were reported to have helped 

the testers submit completed forms quickly and accurately.

Whether for training or data collection, project leaders thought 

it was important to ask testers what they needed assistance 

with (for example, writing, reading, or a quiet room to 

complete forms in) and to be flexible in responding to testers’ 

emergent needs. Many noted that the level of support needed 

decreased over time as testers increased their skills and level 

of comfort. Although some testers initially felt nervous, they 

reported becoming increasingly comfortable as they gained 

experience. Thus, it was important to support a key group of 

testers so they could do many tests and feel comfortable in 

doing so, rather than trying to have a large pool of testers who 

completed only one or two tests each.

Preparing and Supporting Testers: Use of 

Companion Testers As Ongoing Supports

Companion testers also provided support to protected testers 

during data collection. For example, when testers forgot to ask 

a question of a landlord, “got off track,” or “froze,” companion 

testers were able to naturally prompt the tester or provide a 

response. Companion testers also reassured testers and helped 

them feel less nervous during data collection or when in a new 

area of their community. Companion testers were also able to 

provide assistance by taking notes, organizing and remembering information, helping out when unanticipated situations 

arose, and in some cases with transportation.

Many testers with MD and companion testers thought that 

the presence of the companion testers may have helped the 

protected tester feel less stressed, because immediate support 

was available. It was also noted that protected testers and 

their companion testers complemented one another during 

data collection by offering different ideas and that working as 

a pair made the experience more enjoyable. Protected testers 

and companion testers noted that the support provided by 

companion testers during data collection may have also added 

credibility to the disclosure of a disability by testers. On the 

other hand, some companion testers wondered whether their 

presence tempered potential opportunities for differential 

treatment by landlords.

Most thought that companion testers were most effective when 

they saw their relationship with the tester as a partnership; 

that is, when companions understood that they were there to 

support testers, not to be testers. To achieve this understanding, 

companion testers needed to be flexible to their paired tester’s 

needs and preferences. The dynamic of successful relationships 

was evident when testers and companion testers had discussed 

and agreed on each individual’s role and responsibility, had 

good communication before and after data collection, and both 

contributed to the completion and approval of reporting forms. 

Mentoring, training, and role-playing may be required to help 

companion testers excel in these supporting roles. The need 

for training on how to be a good companion tester may have 

been particularly relevant for companion testers who had been 

testers in other fair housing testing situations. Although their 

previous experience provided great knowledge and insight, they 

also had to transition to playing a supporting role, rather than 

the primary role, during a test.

When directly asked whether companion testers were needed, 

the study team agreed that most testers with I/DD would need 

a companion tester to complete data collection. The study team 

also believes, however, that most testers with MI, and perhaps 

some testers with I/DD, could initially benefit from a companion but could potentially conduct testing on their own as they 

gained experience.

Documenting Differential Treatment and 

the Role of the Companion Tester

Some protected testers reported that they thought they 

experienced negative treatment by housing providers or agents 

and that the companion tester helped to document and handle 

that treatment. For example, one tester was asked repeatedly 

whether he had a criminal background, what his income was, 

and whether he could afford the unit. Another thought the 

housing provider was suggesting she may not be intelligent 

enough to live in the building, and another was told that the 

landlord would “pray for her.” Others reported landlords acting 

distracted (talking on the telephone or looking at their watch), 

being abrupt in interactions, refusing to provide an application 

(likely because an application had been received earlier in the 
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day), or simply “giving attitude.” Companion testers had the 

sense that testers appreciated having someone with them to 

witness and validate this treatment.

Recommendations for Expanded Testing 

in the Future

Although they understood the scientific value of the current 

testing approach and its focus on one specific disability group, 

many testers stated that they wished the project could be 

broadened to better reflect the actual experiences of individuals 

with MD, especially because many people with MD experience 

more than one functional limitation. For example, some 

people with I/DD also were anticipating some future physical 

accessibility issues and wanted to be able to document those as 

well. They also thought it would be illuminating to study the 

qualities of accessible housing, particularly what that means 

and looks like for people with MD.

In considering the expansion of matched-pair testing to 

study housing discrimination on the basis of MD to a larger 

geographic scale, project leaders, testers, and companions had 

many recommendations. For example, project leaders—

•	 Thought that having an experienced, centralized oversight 

team would be important to ensuring that the data 

collection protocols are being administered similarly 

across sites (including for training), to facilitate ongoing 

communications among sites, and to provide ongoing 

support and accommodations, as needed.

•	 Confirmed the importance of some strategies that were 

used in this project, such as the need for housing organizations to partner closely with organizations run by people 

with disabilities within testing regions to succeed in this 

work.

•	 Stressed the importance of allowing adequate time for 

the recruitment, training, and ongoing support of testers 

with MD, with some suggesting the initial recruitment of 

approximately three times as many testers as originally 

needed.

•	 Believed that holding training in places that are familiar 

to potential testers, such as at disability and community 

organizations, could help attract testers with MD because 

they are more likely to trust these sites.

•	 Emphasized that, in preparing testers and companion 

testers for data collection, the research team and companion testers should not make assumptions about what 

testers can and cannot do.

•	 Agreed that experienced testers with I/DD and MI, and 

companion testers, might be well-equipped to train future 

testers, and their role as peer mentors and trainers should 

be considered in future studies.

•	 Emphasized the value of building in time for mentoring 

and one-on-one training.

Testers with MI and I/DD and their companion testers also 

made valuable suggestions, including—

•	 Agreeing on the benefits of making sure that everyone has 

an opportunity to role-play and complete a practice test 

with feedback.

•	 Noting that having all testers engage in more than one 

practice test might be advantageous.

•	 Suggesting that, although each person is unique, trainings 

should include some general information about MI and I/DD 

at the start of tester interaction that, in a respectful way, 

acknowledges the considerable heterogeneity of people 

with MD. 

•	 Recommending that they receive a checklist detailing 

everything they should do before a test (including practical 

information, such as use the restroom). 

•	 Expressing a desire that they do tests in areas where their 

personal characteristics match those of the local community and in areas that “feel safe.” 

•	 Noting that it would be helpful to attempt to make sure 

that apartment-viewing appointments were with leasing 

agents and not with maintenance personnel.

•	 Suggesting that they should also be involved in making 

calls to arrange apartment-viewing appointments, because 

some profile information is requested at that point of contact.

•	 Raising the issue of how to ensure that testers receive 

support for any emotional reactions they may have during 

data collection. 

•	 Encouraging testers and companion testers to return to the 

testing coordination agency after each test to debrief and 

complete reporting forms, and after testing would also be 

a potential time to support them emotionally, give them 

additional resources if needed, or both.

•	 Urging that test assignment and report forms be as clear as 

possible so that testers and companions would have fewer 

questions for test coordinators.

•	 Raising the possibility of alternative payment options 

so that those who receive disability benefits could more 

fully participate without having their subsidized disability 

income being at risk.
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Finally, several testers suggested that all testers should have the 

chance to reflect and debrief at the end of the project, similar 

to what was done in debriefing focus groups with a small 

sample of testers and staff in this study. Testers expressed 

that the focus groups enabled them to validate their feelings, 

revisit their experiences and make sense of them, reconnect 

with other testers and companion testers, and validate their 

contributions and role in the overall project.

The pros and cons of in-person testing are summarized in Table 36. 

In-person testing yields richer data than the other modes, but it 

costs more and takes more time to complete the tests. Although 

that is true for any protected class, the pros and cons are amplified when using people with disabilities as testers. Depending 

on the objective, the added time and costs associated need to be 

weighed against the data produced.

Table 36. Pros and Cons of In-Person Testing

Pros Cons

Face-to-face interaction with a housing provider captures richest, most 

realistic interaction information, including verbal and nonverbal responses.

Logistically complex; scheduling of two testers and companion for 

protected tester to conduct tests and debrief.

Test reaches deeper into rental transaction. Tester recruitment, training, support, and retention are challenging.

Involves people with MI and I/DD in conducting research, which increases 

social validity of findings.

Potential for tester fatigue and emotional reactions need to be considered in training and debriefing support. 

Use of companion without disability provides additional attention to 

detailed observations and field notes for improved rigor of analysis of 

findings. 

Requires longer time in the field for testing to coordinate tests.

Upfront screening and training reduces attrition, and people with MD 

were found to be effective testers.

Requires more preparation, time, and resources, especially collaboration 

and involvement of disability and community organizations that understand how to provide accommodations to testers with MI and I/DD.

I/DD = intellectual or developmental disability. MD = mental disability. MI = mental illness.
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Summary, Conclusions, and Recommendations

The pilot testing effort documented in this report represents 

the largest and most comprehensive effort to date to validate 

methods of testing for housing discrimination against people 

with mental disabilities. The pilot testing also represents the 

first time that people with MI and I/DD have been enlisted to 

serve as in-person testers in a housing discrimination study of 

this size and therefore contributes significantly to the knowledge about disability-related housing discrimination and the 

design of research methodologies that are accessible, inclusive, 

and participatory to people with MI and I/DD.

The testing conducted in this study documented significant 

levels of adverse differential treatment toward individuals with 

MD when compared with the treatment of a control group of 

individuals who did not have MD. Such adverse differential 

treatment included observations that individuals with MI or I/

DD were—

•	 Less likely to receive a response to their inquiry (17.55 percent 

of tests favored the control group of people without disabilities compared with 9.19 percent that favored people 

with MI and I/DD in e-mail testing).

•	 Less likely to be told an advertised unit was available (5.94 

percent favored people without disabilities compared with 

0.99 percent that favored people with MI and I/DD in 

in-person testing).

•	 Less likely to be invited to contact the housing provider to see 

the unit (7.69 percent favored people without disabilities 

compared with 0.00 percent that favored people with MI 

and I/DD in e-mail testing).

•	 Less likely to be invited to inspect the unit (21.26 percent 

favored people without disabilities compared with 16.47 

percent that favored people with MI and I/DD in telephone 

testing). 

•	 More likely to be encouraged to look at a different unit than the 

one advertised, a potential indicator of steering people with 

MI and I/DD toward specific buildings or areas within 

rental complexes, resulting in segregated living patterns.

Rates of adverse treatment also varied between disability types, 

with higher rates of adverse treatment noted for individuals 

with MI than for individuals with I/DD. This finding may indicate 

that individuals with MI face more negative stereotypes and 

stigma from housing providers and their agents.44 This study, 

however, was not large enough to yield conclusive evidence 

about what motivation might be underlying the observed differential treatment between people with MI as compared with 

people with I/DD, nor was the study designed to examine differential discrimination based on type of MD. Future larger-scale 

research should explore these questions and might include 

additional focus groups with housing providers to discuss study 

findings and to seek housing providers’ reactions and responses 

to the results of fair housing testing.

In both e-mail and telephone testing, a significant percentage 

of individuals with MI and I/DD also experienced adverse treatment with respect to requests for a reasonable accommodation. 

The reasonable accommodations requested were identified as 

specific to the protected tester’s functional needs. The willingness of a housing provider to grant a request for a reasonable 

accommodation varied by mode of testing, with requests for 

a reasonable accommodation made by telephone receiving 

significantly more favorable responses than requests made by 

e-mail.45 This finding may reflect the fact that housing providers 

were able to have a more personal or indepth conversation with 

the tester with MD via telephone, resulting in more favorable 

responses to these requests. On the contrary, in e-mail testing, 

replies were often more formal and very limited in scope. These 

experiences may advise the use of telephone over e-mail testing 

in future large-scale discrimination testing.

Negative responses to testers’ requests for a reasonable accommodation ranged from outright denials to more subtle barriers, 

such as indications that the individual with MD would be 

responsible for actively seeking out and appealing the denial 

of their request with higher-level managers whose name and 

contact information were then not provided.46 These findings 

on responses to requests for reasonable accommodations 

further add to potential discrimination against people with 

44 This observation was supported in the qualitative data obtained from focus groups of people with MI that were conducted both before and after the testing to 

reflect on their experiences.

45 In-person testing protocols did not include a request by the protected tester for a reasonable accommodation.

46 In addition, testing results varied by rental market, with the rate of granting a reasonable accommodation request lowest in Chicago-Joliet-Naperville, IL-IN-WI 

(38.6 percent) and highest in Albuquerque, NM (75.5 percent).
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MD, and it is recommended that reasonable accommodation 

requests be included in in-person testing in the future, using 

a test design similar to that used in telephone testing in this 

project, wherein requests for a reasonable accommodation are 

not made unless the tester is invited to inspect the unit.

This study also yielded significant findings on how to implement fully inclusive fair housing testing employing people with 

MD. All three modes of testing that were carried out (e-mail, 

telephone, and in person) showed promise for bringing testing 

for housing discrimination on the basis of MD to a national 

scale. Each produced a different form of testing data that not 

only yielded evidence of discrimination but also provided 

insights on opportunities for future testing.

Because online housing searches and e-mail communications 

with housing providers during these searches is anticipated 

to increase, efforts to use e-mail testing in this project should 

inform future e-mail testing. Observations include—

•	 E-mail testing is a relatively cost-effective method of 

tracking changes over time in discrimination in initial 

contacts people with MD have with housing providers 

(that is, trying to get in the door).

•	 Longitudinal data showing a change in the rates of differential treatment of people with MD could be efficiently 

collected by subsequent e-mail testing of the same sample 

of housing providers.

•	 E-mail could also be useful for monitoring how housing 

providers are responding to reasonable accommodation 

requests, if a followup e-mail is added to further interact 

on the reasonable accommodation request. This technique 

could also ensure that the housing provider is responding 

directly to the request as opposed to sending a scripted or 

form reply.

The in-person testing in this study that specifically involved 

testers with MD demonstrates that people with MI and I/DD 

can serve as effective testers when the proper training and 

supports are provided.

As the first large-scale in-person testing that had people with 

MD as testers, this project demonstrated the importance of 

disability-focused and directed training. The entire process of 

engagement with testers, from recruitment to training, testing, 

and debriefing, was grounded in constant feedback from 

the people with MD and members of the expert panel. The 

evidence from the in-person testing in this project suggests 

strongly that both populations can also conduct telephone 

testing if the same approach to training and debriefing is used. 

This project demonstrates that the training and use of disability 

rights organizations to coordinate and debrief testers is a highly 

effective design for testing focused on disability and was a 

critical component of the successful completion of in-person 

testing in the given timeframe in this study.

The use of companion testers, although adding cost and 

coordinating time, resulted in several important benefits to the 

project, including—

•	 Providing valuable cognitive and emotional assistance to 

testers with MD before, during, and after each test.

•	 Providing a natural way to reveal the MD via a friend in 

conversation while viewing a unit.

•	 Providing a means to confirm what had been heard and to 

clarify what was observed during each test, thus providing 

richer data and field note observations. 

•	 For testers who used public transit, companions often 

(although they were not expected to) provided transit 

assistance or went along on public transportation with the 

tester with MD, ensuring that both testers would get to 

appointments in a timely fashion.

Findings from this project, although important in documenting 

how housing discrimination may occur against people with 

MI and I/DD as they seek rental housing, are limited given the 

small sample sizes, particularly when attempting analyses on 

variations of treatment between subcategories of paired tests, 

such as gender, race, type of disability, and geography. Future 

research, done on a larger scale, could examine other important 

issues, for example—

•	 Are people with different types of MD, or different requests 

for other types of reasonable accommodations, met with 

less favorable responses or more discrimination? 

•	 How do factors such as age, gender, race, and previous 

living status contribute to or interact with MD to affect 

rental housing access? 

•	 How does income or economic status interact with MD to 

affect housing access and choice?

•	 How does the use of rent subsidies (for example, Housing 

Choice Vouchers) and other government-supported 

sources of income for housing affect housing access and 

choice for people with MD?

Finally, efforts to find protocols to study and test for housing 

discrimination after initial contact with a housing provider (for 

example, application results, before move in, after move in, 

changes in response to requests for reasonable accommodations 

over time, and criteria for lease termination) should continue.
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Based on the results of the study, the authors make the following recommendations.

•	 A broad-based education initiative should be created to educate housing providers, including owners and landlords 

and their agents, about fair housing rights and obligations 

and about appropriate policies and practices when dealing 

with individuals with MI, I/DD, and other MD.

•	 Public and private housing, disability, and civil rights 

organizations should redouble efforts to engage and educate 

the community of people with MI, I/DD, and other MD about 

their rights under federal, state, and local antidiscrimination laws, how to recognize potential discrimination, and 

what actions to take when faced with discrimination.

•	 Additional research is necessary to better understand the 

scope and severity of the discriminatory barriers encountered by individuals with MI and I/DD as they seek, 

obtain, and retain accessible rental housing.

•	 Individuals with MI and I/DD can and should be an integral 

part of future housing research and testing, housing discrimination education initiatives, and efforts to strengthen 

housing policy to promote equal housing opportunity.

In addition, protected and companion testers involved in the 

in-person testing for this project offered the following summary 

recommendations for including people with MD in future 

housing discrimination research.

Project Leadership and Design

•	 Project leadership is deeply important to people with 

MD. Having test coordinator sites embedded within local 

disability and housing rights organizations was especially 

valuable in supporting testers with disabilities.

•	 Testing sites and all project members should actively foster 

commitment to, and belief in, the inclusion of people with 

MD at all stages of research projects.

•	 An inclusive project should foster coleadership, in which 

the research team and the protected community colead 

and collaborate to design and conduct discrimination 

research with a goal of bringing housing discrimination 

experts together with people with personal experience 

with disability to fully and accurately understand the 

actual experiences people have when seeking housing.

•	 Future testing should use experienced testers with MD 

(such as those from this project) and their experiences in 

protocol development and training as peer trainers and 

mentors in a train-the-trainer model.

Recruitment and Selection of Testers

•	 Reinforce responsibilities and expectations of participation 

with potential testers to encourage increased reliability and 

validity of findings.

•	 Provide sufficient time, resources, and expertise to recruit, 

select, and support team members with MD.

•	 Have a sustained selection process for testers and companion testers that allows for time to build relationships and 

develop a fit between test pairs.

•	 Involve experienced testers with MD in tester recruitment 

and selection as they also have key contacts and networks 

throughout protected communities.

Training and Data Collection

•	 Be proactive and flexible in accommodating team members 

with MD in training and data collection, including specific 

attention to strategies to make participation more accessible and inclusive to this community.

•	 Have a choice and range of supports and accommodations 

available to testers, and match emotional support to 

individual needs, adjusting the supports as needed as 

testers gain experience.

•	 Provide testers with choice throughout the process, 

including a choice of whether to stay with a companion 

tester or to choose another that is a better fit.

•	 Ensure that all testers have time to role-play, practice, and 

receive individualized feedback during trainings.

•	 Train companion testers to provide positive, effective support 

to testers with MD in a respectful, person-directed way.

•	 Assess the value of companion testers—between the added 

credibility and validity added to the capture of testing data 

versus the potentially unanticipated effect that their presence may actually decrease or buffer differential treatment.

•	 Design all materials, illustrations, role-plays, and videos 

in all training and data collection instructions and forms 

using clear, concise, and plain language.

•	 Use technology to enable people with MD to take on 

increasingly independent roles in testing, such as the use 

of voice-operated smartphones or tablets during data 

collection and reporting.

•	 Discuss in initial trainings the attitudes that may be 

encountered during tests and how to capture attitudes and 

treatment in more detail in reporting.
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Appendix A: Qualitative Analyses and Findings on Overt 

and Subtle Discrimination Against People With Mental 

Disabilities by Different Testing Modes

The purpose of this additional indepth qualitative study was 

to provide detailed qualitative analyses of the overt and subtle 

discrimination experienced by people with mental disability 

(MD)—that is, people with mental illness (MI) and people with 

intellectual or developmental disability (I/DD)—as gathered 

from multiple sources including e-mail, telephone, and in-person 

testing, field notes, and tester debriefing reports. The following 

research questions were used to guide the qualitative analyses.

•	 Is there evidence of subtle discrimination on the basis of 

mental disability in the e-mail, telephone, and in-person 

tests conducted during this study, and what does it look like?

•	 Is there evidence of overt discrimination on the basis of 

mental disability in the telephone and in-person tests 

conducted during this study, and what does it look like?

Qualitative Analysis Methodology

The structure and process for the analyses was guided by 

Ahmed and Hammarstedt (2008), who examined subtle 

discrimination on the basis of sexual orientation in the rental 

housing market using e-mail testing, and by Hanson, Hawley, 

and Taylor (2011), who proposed a methodology for qualitatively analyzing e-mail contents for subtle discrimination. As 

in these previous studies, this study used matched-pair tests in 

that each pair was matched in key demographics (for example, 

age, gender, and race or ethnicity) except for MD status, with 

one tester having an identified MD and one tester not having MD.

The tester with MD (protected tester) specifically disclosed 

having either MI or I/DD. This reveal occurred in multiple 

ways: (1) disclosing having lived in a psychiatric facility or 

nursing home for the past year, (2) directly identifying himself 

or herself as a person with I/DD or MI, and (3) requesting a reasonable accommodation (that is, using an assistance animal or 

requesting a verbal rental payment reminder). The other tester 

in the pair (control tester) did not identify as having a disability 

and instead identified as someone who recently graduated from 

college or who had been living with his or her parents to show 

a matched previous rental history. Both testers in a pair were 

also given matching profiles that included similar income and 

job histories, at a level adequate to pay for a one-bedroom rental unit in that market, and other similar personal demographics 

other than disability status.

E-mail Testing

As reflected in the larger discrimination study, 359 e-mail pairs 

were sent out, including 176 pairs with testers with I/DD and 

183 pairs with testers with MI. Out of those 359, 187 pairs 

received at least one response from an agent or landlord. To 

qualitatively compare the e-mails in this particular phase of 

the study, we selected only e-mail pairs that both received 

responses (n = 91 pairs). Of those 91 pairs, 9 were not codable 

for the following reasons: (1) different agent responded, (2) agent 

noticed the testing and test was not used, or (3) lack of qualitative data to code. Therefore, 82 pairs were codable, including 

45 pairs with a tester with I/DD and 37 pairs with a tester with 

MI. Out of the 82 e-mail pairs, 25 e-mail tests also included a 

reasonable accommodation request that could be analyzed (see 

Figure A-1).

Figure A-1. E-mail Testing Responses

E-mail pairs sent out 

(n = 359)

E-mail pairs with 

at least 

one response 

(n = 187)

E-mail pairs with 

responses to both 

(n = 91)

E-mail pairs 

not codable

(n = 9)

E-mail pairs

 coded

(n = 82)

I/DD testers 

(n = 45)

MI testers

(n = 37)

With RA request

(n = 10)

With RA request

(n = 15)

I/DD = intellectual or developmental disability. MI = mental illness. RA = reasonable accommodation.
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Telephone and In-Person Testing

A total of 668 pairs participated in telephone tests of randomly selected available apartment ads across nine different 

metropolitan statistical areas (MSAs). In-person testing 

involved a visit to view the apartment by 101 pairs in the 

Chicago-Joliet-Naperville, IL-IN-WI, and the Washington-Arlington-Alexandria, DC-VA-MD-WV MSAs, 83 of which had 

valid qualitative data to additionally code. See Table A-1.

Table A-1. Samples of Telephone and In-Person 

Testing 

Type Sample Type of Disability Total

I/DD MI

Telephone Valid pairs 300 352 652

Missinga 11 5 16

Total 311 357 668

In person Valid pairs 48 35 83

Missinga 3 15 18

Total 51 50 101

I/DD = intellectual or developmental disability. MI = mental illness.

a

 Qualitative data were not available to code.

Data Analysis

A mixed-methods approach was used to analyze data, beginning 

with qualitative analyses, followed by quantitative frequency 

counts and analyses of summary themes, to answer the research questions and fully understand discrimination practiced 

by housing providers. Each type of testing used different data 

analysis methods, as described in the following section.

E-mail Testing Only: Quantitative 

Coding of Keywords Indicating Subtle 

Discrimination

The housing discrimination study by Hanson, Hawley, and Taylor (2011) provided significant guidance for the interpretation 

of the results of e-mail testing, especially because e-mail testing 

yields an explicit and defined text-based inquiry and response 

that can be analyzed verbatim.

Hanson, Hawley, and Taylor describe several dimensions of 

coding favorable and unfavorable treatment in landlord-tenant 

correspondence. They describe favorable treatment as including 

examples “if landlords describe the unit in a positive way, if 

they mentioned other available units, if they invited further 

contact, and if they used generally friendly language” (Hanson, 

Hawley, and Taylor, 2011: 281) and unfavorable treatment as 

asking the tenant for more information about their employment 

or background or also as using more discouraging language, 

such as emphasizing additional fees and building rules. In 

addition to the keyword list Hanson, Hawley, and Taylor created, the analysis here added more unfavorable and favorable 

treatment dimensions specific to MD (for example, asking for 

further disability-related information or disclosure) that were 

identified after a round of pilot coding.

Using the subtle discrimination keywords listed in Table A-2, two 

members of the study team coded the frequency of positive and 

negative languages used in e-mails. These counts were compared between the protected and control groups and divided 

into four categories: (1) present in neither, (2) present in both, 

(3) control group only, and (4) protected group only. Evidence 

of subtle discrimination was coded if positive language was 

shown more frequently in the control tester only or if negative 

language was more frequently present in the protected tester only.
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Table A-2. Subtle Discrimination Indicator Keyword Groups

Category Keywords

Positive language categories

Positive descriptive New Clean Quiet Nice Good Beautifula Othera

(for example, 

wonderful)

View unit Tour

Show

Stop

Come

Visit

Meet

See

View

Look

Appointmenta Othera

Tour time offered Specific time Range of time

Prompts Quick 

Hurry 

Fast

Todaya 

Tomorrowa

Call Application Look forward toa Other (for example, Let me 

know, questions)

Greetings Hi 

Hello 

Hey

Dear Good morning/

afternoon

Othersa

Polite Thank you 

Thanks

Sincerely Regards 

Best

Please Love toa 

Happy toa

Othera

Other units Second Several Other

Negative language categories

Fees Application fee Deposit fee $ Fee starting Othera (for example,., pet policy, move-in fee)

Employment Employment Employer Income Paystub Credit Othera

(for example, source of rent)

Background Criminal Background Verification

Verify

Othera

Discouraging Already rented No longer Not available Best wishesa Good lucka Othera

History Rental history Eviction Othera

Negative descriptive Old Needs work Othera

Disabilitya Disability 

Handicap 

Diagnosis

Medication 

Hospitalization

Treatment 

Treated

Accommodation Service dog Other (for example, mentally 

competent, caregiver)

a

 Indicates keywords that were added in this study.

Qualitative Interpretation and Grounded 

Theory Analysis: E-mail, Telephone, and 

In-Person Testing

Because additional qualitative data were available and new, 

given the focus on testers with MD in this study, a grounded 

theory qualitative approach was used to generate a framework 

to analyze and code both overt discrimination (as defined 

within the Fair Housing Act) and more subtle, potential 

discrimination. After coding the keywords, the two coders 

also qualitatively described their overall impression of each 

pair of e-mails, concerning subtle or overt discrimination (or 

both) against one tester. Each decision was associated with a 

description of evidence for subtle or overt discrimination or 

no subtle or overt discrimination, as identified by coders. If 

consensus on the discrimination status could not be reached 

between the two coders, a third, blinded member coded the 

e-mail to resolve the difference. By constant comparison of 

these qualitative data, the findings were aggregated into themes. 

These themes then were used as criteria for determining subtle 

or overt discrimination.

Converting Qualitative Findings to 

Summary Frequency Counts: E-mail, 

Telephone, and In-Person Testing

Qualitative data were assigned a quantitative descriptive 

frequency count—if subtle, overt, or no discrimination was 

indicated—an assessment of whether the response showed 

or did not show an openness for further communication with 

the landlord. All quantitative data were entered into an SPSS 

17.0. Descriptive analysis and cross-tabulation analysis were 

conducted to examine the frequency and proportion of different 

categories indicating subtle discrimination. McNemar’s Test 

was used to analyze the difference in treatment between the 

control and protected groups (McNemar, 1947), with a p-value 

of less than .05 used to indicate significantly different treatment 

between control and protected testers.
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Results

E-mail Testing

Quantitative Analysis of Keywords Related to 

Subtle Discrimination

Quantitative analysis of keywords for positive and negative 

language shows significantly different treatment in several 

areas. The control group was more frequently given a specific 

or range of time to view an available housing unit or to meet 

the landlord (p < .05) when compared with protected testers 

with MD. E-mail responses to testers with MD showed a 

significantly higher use of discouraging words (p < .05). A 

trend also emerged of using positive language more often with 

control group only and negative language more often with 

the protected group only; however, the difference was not 

statistically significant in some cases. See Table A-3.

As shown in Table A-4, an analysis of positive and negative 

language used in e-mail responses showed that 34.1 percent 

of landlords practiced favorable treatment to people without 

disabilities by using at least one of the seven positive language 

categories. A total of 17.0 percent of landlords practiced 

unfavorable treatment to people with MD by using at least 

one of the seven negative language categories. Combined, 37 

e-mails (45.1 percent) showed at least one category of subtle 

discrimination present.

Qualitative Themes and Descriptive Frequency 

Counts on Subtle Discrimination

During e-mail testing, seven themes emerged related to subtle 

discrimination against the protected testers with MD. These 

themes were (1) more encouraging to control tester or more 

discouraging to protected tester; (2) more friendly, informal, 

or personalized with control tester or more formal or less 

personalized with protected tester; (3) more urgency, priority, 

or prompting of further action for control tester to view the 

unit; (4) agent made him or herself more available to control 

tester; (5) agent requested more effort or information from 

protected tester before moving forward; (6) agent (potentially 

inadvertently) discriminated against protected tester by asking 

about disability or discussing disability in a discouraging way; 

and (7) agent did not agree to or acknowledge reasonable 

accommodation requests related to MD. Each of the seven 

themes that emerged from the data is outlined in the following 

sections, followed by examples from field notes that epitomize 

Table A-3. Response Difference in E-mail Content 

Response Present in Neither Present in Both Control Group Only Protected Group Only McNemar p-Value

Positive language

Positive descriptive 45 (77.6%) 8 (13.8%) 2 (3.4%) 3 (5.2%) 1.000

View unit 14 (24.1%) 31 (53.4%) 8 (13.8%) 5 (8.6%) 0.581

Tour time offered 26 (44.8%) 18 (31.0%) 12 (20.7%) 2 (3.4%) 0.013*

Prompts 14 (24.1%) 37 (63.8%) 3 (5.2%) 4 (6.9%) 0.227

Greeting 12 (20.7%) 34 (58.6%) 7 (12.1%) 5 (8.6%) 0.774

Polite 8 (13.8%) 44 (75.9%) 4 (6.9%) 2 (3.4%) 0.687

Other units 56 (96.6%) 1 (1.7%) 0 (0.0%) 1 (1.7%) 1.000

Negative language

Disability 52 (89.7%) 1 (1.7%) 0 (0.0%) 5 (8.6%) 0.063

Discouraging 49 (84.5%) 3 (5.2%) 0 (0.0%) 6 (10.3%) 0.031*

Background 57 (98.3%) 0 (0.0%) 0 (0.0%) 1 (1.7%) NA

Employment 54 (93.1%) 3 (5.2%) 0 (0.0%) 1 (1.7%) 1.000

Fees 47 (81.0%) 5 (8.6%) 2 (3.4%) 4 (6.9%) 0.687

Negative descriptive 58 (100.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%) NA

History 58 (100.0%) 0 (0.0%) 0 (0.0%) 0 (0.0%) NA

NA = not applicable.

Notes: n = 58 pairs. p-value < 0.05 indicates significantly different treatment between the two groups. Identical e-mail replies (n = 24) were not 

coded with this criterion. n = 9 did not have qualitative data available to code.

Table A-4. Subtle Discrimination Responses in Multiple Categories 

Response Number of Categories

0 1 2 3 4 5

Positive language to control class only 54 (65.9%) 21 (25.6%) 6 (7.3%) — 1 (1.2%) —

Negative language to protected class only 68 (83.0%) 11 (13.4%) 2 (2.4%) 1 (1.2%) — —

Negative and positive language against protected class only 45 (54.9%) 26 (31.7%) 8 (9.8%) 2 (2.4%) — 1 (1.2%)

Notes: n = 82 pairs. n = 9 did not have qualitative data available to code.
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it. In many cases, quotations were taken directly from landlord 

responses. In some cases, the researcher’s analysis is summarized given the data supporting subtle discrimination, such as 

in the form of tone throughout or timing of the e-mail.

Theme 1: More encouraging to control tester or more 

discouraging to protected tester.

Researcher analysis: “Agent used more encouraging 

language with Control tester (C) (‘your future home,’ 

‘your new home’). Agent included list of amenities and 

photos of rental community with C [control tester] but 

not PC [protected tester]. C received two emails, while 

PC got one. The additional email C received had more 

information with the range of rates for 1BR and 2BR and 

included an easy link to schedule a visit.” (12885)

Theme 2: More friendly, informal, or personalized with 

control tester or more formal or less personalized with 

protected tester.

Researcher analysis: “Both were invited for a visit. However, the agent introduced herself (‘my name is Wendy 

the property manager’), asked for a contact number, 

and showed more willingness (e.g., ‘I look forward to 

working with you in the very near future in obtaining an 

apartment!’) to assist C and not to Protected Tester (P).” 

(12959)

Theme 3: More urgency, priority, or prompting of further 

action for control tester to view the unit.

Researcher analysis: “P [protected tester] emailed agent 

first, but agent responded to C first and C was given an 

earlier time slot to visit.” (9668)

Researcher analysis: “No invitation to contact the landlord 

for P, while C was given the landlord’s phone number.” 

(12877)

Theme 4: Agent made him or herself more available to 

control tester.

Researcher analysis: “Landlord made himself only 

available during the working day to PC, but offered more 

availability to C.” (11565)

To protected tester: “I can meet you at the building daily 

10am-2pm. The unit is currently occupied till June 1.” 

To control tester: “I’m by the building every day, 9am3:00pm. What’s a good day/time for you?” (12140)

Theme 5: Agent requested more effort or information from 

protected tester before moving forward.

Researcher analysis: “PC asked the agent to suggest available 

hours, but the agent did not give PC these hours; instead, 

she told PC to call (extra step/effort that PC now needs to 

take).” (12133)

Researcher analysis: “Agent offered tour to C immediately, 

but for PC the invite was conditional (‘Please introduce 

yourself a little bit more before make an appointment’). The 

landlord asked several questions about the tester’s request 

for an assistance animal accommodation, income, and move 

in date and how many people would be renting.” (11914)

Theme 6: Agent (potentially inadvertently) discriminated 

against protected tester by asking about disability or 

discussing disability in a discouraging way.

Researcher analysis: “Very subtle discrimination. Agent 

seems to be trying to be helpful with the parking situation, 

but says ‘do you still want to see it?’ as if this may have 

deterred PC. Never actually says to PC that unit is still 

available, but does to C.” (12491)

Researcher analysis: “Well-meaning agent, but asks questions 

about disability and mentions needing to qualify based on 

the application to PC but not to C. The agent is polite to 

PC (offers to give reminder calls for rent, says would love 

to have as part of community, etc.), but still mentions the 

need for a formal application for PC but not C.” (12946)

Theme 7: Agent did not agree to or acknowledge reasonable 

accommodation requests related to MD.

Researcher analysis: “PC asked about having an assistance 

dog as reasonable accommodation, but the agent responded with the building’s pet policy and that certain breeds 

are not allowed in the building regardless of the disability 

accommodation request.” (13249)

Researcher analysis: “Agent did not acknowledge the tester’s reasonable accommodation request. PC email request: 

‘...My dog is my assistance animal and I want to make sure 

she can stay with me in this apartment.’ No response from 

landlord to this request.” (12719)

Using these themes, each e-mail pair was coded as containing 

subtle discrimination or not (see Table A-5). This analysis 

showed that about 42.7 percent of the protected testers experienced some type of subtle discrimination against them, whereas 

only 2.4 percent of the control group did.
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Table A-5. Subtle Discrimination in E-mail Testing 

Subtle Discrimination Against 

the Protected Class

Count 

(Percentage)

Yes 35 (42.7%)

No 41 (50.0%)

Unclear 6 (7.3%)

Subtle discrimination against the control group 2 (2.4%)

Notes: n = 82 pairs. n = 9 did not have qualitative data available to code.

Quantitative Analysis of Reasonable 

Accommodation Requests

Of the 82 paired e-mail tests, 25 protected testers included a 

reasonable accommodation request in their initial inquiry (that 

is, asking for either a rent reminder or to have an assistance 

animal in the apartment). Of those inquiries, 23 e-mail pairs 

could be coded, of which the housing provider did not respond to or acknowledge the request in 16 cases and approved 

the request in 3 instances. In the remaining 4 instances, the 

landlord did not agree to the request. In other words, they 

responded negatively, such as “dogs are not allowed,” or 

inappropriately, such as asking about the size of the assistance 

animal before deciding whether they would accept the request. 

Both of these examples represent discriminatory practices. A 

subanalysis was conducted to explore which disability group 

or which type of reasonable accommodations were more or 

less likely to receive negative responses. See Table A-6.

Quantitative Analysis of the Status of Further 

Communication

The status and overall tone of further communication with the 

landlord was also coded to examine whether they left an open 

door (positive to view unit) or a closed door (negative to view 

unit). Although findings show that that the protected group 

had slightly more closed-door episodes, significantly different 

treatment was not shown between the two groups in e-mail 

testing (Table A-7).

Table A-7. Open Door/Closed Door in E-mail Testing

Response Control

Group

Protected 

Group

McNemar’s 

p-Value

Open door 53 (91.4%) 50 (86.2%) 0.223 Closed door 2 (3.4%) 4 (6.9%)

Unclear 3 (5.2%) 4 (6.9%) —

Notes: n = 58 pairs. Identical e-mail replies (n = 24) were not coded 

with this criterion. n = 9 did not have qualitative data to code.

Telephone Testing Findings

Qualitative Themes With Quantitative Analysis of 

Subtle Discrimination

During telephone testing, six themes emerged related to subtle 

discrimination against the protected tester. These themes were 

(1) more urgency, priority, or prompting of further action 

for control tester to view the unit; (2) more encouraging to 

control tester or more discouraging to protected tester; (3) more 

friendly, informal, or personalized with control tester or more 

formal or less personalized with protected tester; (4) agent requested more effort or information from protected tester before 

moving forward; (5) agent made him or herself more available 

to control tester; and (6) agent (potentially inadvertently) 

discriminated against protected tester by asking about disability 

or discussing disability in a discouraging way. The themes that 

emerged are summarized in the following section, followed by 

examples and quotations that epitomize them.

Unlike e-mail testing, telephone testing did not yield rental 

agent quotations. Instead, quotations represent field note 

excerpts or the tester’s own words describing the interaction 

with the agent.

Table A-6. Housing Provider Responses to RA Requests in E-mail Testing 

Group Type of RA Request Number of RA Requests Responses Total

Positive Negative None

I/DD Rent reminder 3 0 1 2 3

Assistance animal 7 2 2 3 7

MI Rent reminder 8 1 0 7 8

Assistance animal 5 0 1 4 5

Totals 23 3 4 16 23

I/DD = intellectual or developmental disability. MI = mental illness. RA = reasonable accommodation.

Notes: n = 23 pairs. n = 2 did not have qualitative data to code.
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Theme 1: More urgency, priority, or prompting of further 

action for control tester to view the unit.

•	 Subtheme A: More prompting or urgency for control 

tester to view the unit, complete an application, or follow 

up.

Quotation (to protected tester): “[The agent said] I do not 

give any information over the phone. Good bye.”

Quotation (to control tester): “The agent said would you 

like to come in today and see the apartment?”

Researcher analysis: “No information about apartment was 

given to PC, while C was given several details and invited 

to view the unit.” (16484)

•	 Subtheme B: Agent shows priority to control tester by 

requesting more information from him or her during the call.

Researcher analysis: “Agent asked for C’s last name, phone 

number and email address to contact them, but did not 

ask PC for this.” (12420)

Theme 2: More encouraging to control tester or more 

discouraging to protected tester.

•	 Subtheme A: More units or lease options offered to 

control tester.

Researcher analysis: “C offered more apartment options 

(with rents ranging between $980 and $1040) and different lengths of leases (3-13 months). PC offered one only 

($1010) and length of lease wasn’t discussed.” (12420)

•	 Subtheme B: More positive information given about the 

unit, community, or rental process to control tester or 

more negative information given to protected tester.

Quotation (to protected tester): “Deborah [landlord] also 

explained that Susan [renter] would need to make 3x the 

rent and have a credit score of 650 or better.”

Researcher analysis: “Agent mentioned income/credit 

requirement to PC tester only.” (12437)

Researcher analysis: “Agent told C about six amenities and 

did not tell PC about any. Also, PC was told the application process would take 7-10 days, while C was told it 

would only take 3-5 business days.” (16235)

Theme 3: More friendly, informal, or personalized with 

control tester or more formal or less personalized with 

protected tester.

Quotation (to control tester): “I asked if I would just 

come in and see the place and if I like it, I can rent it. He 

laughed and said, ‘if we like each other, then you can rent 

it. It’s not just about you.’ I said fair enough. ... He asked 

if I was moving with someone else. I said no. He said that’s 

beautiful.”

Researcher analysis: “Agent was friendlier/joking with control tester and did not say anything like this to protected 

class tester. Also, agent cut off protected class tester when 

they were trying to justify their need for a reasonable 

accommodation.” (12115)

Theme 4: Agent requested more effort or information from 

protected tester before moving forward.

Quotation (to protected tester): “[Agent said tester’s 

granddaughter with a developmental disability must call 

to set up an appointment] “if she is really interested in an 

apartment.”

Researcher analysis: “The agent would not accept the protected class tester calling for her granddaughter. Instead, 

they required that the granddaughter call to set up the 

appointment herself, which requires extra effort and may 

not be possible for PC to do by self.” (15058)

Researcher analysis: “Agent asked for two pay stubs and/

or proof of income from the protected class tester but not 

from the control tester.” (6696)

Theme 5: Agent made him or herself more available to 

control tester.

Quotation (to control tester): “He said that he is available 

today until 6pm and tomorrow from 9am-5pm to show me 

the unit if I was interested. ... He said I could give him a 

call on his line; he said the number is different than what I 

called. He gave me his personal line.”

Researcher analysis: “The control tester was told about the 

agent’s availability and office hours, whereas the protected 

class tester was not. Also, the control tester was given the 

agent’s personal/direct line, whereas the protected class 

tester was not.” (11955)

Theme 6: Agent (potentially inadvertently) discriminated 

against protected tester by asking about disability or 

discussing disability in a discouraging way.

•	 Subtheme A: Agent questions protected tester’s competence.

Quotation (to protected tester): “[The agent] was concerned 

that Susan (PC tester) would not be able to care for herself 

and may leave on the gas. I assured her that the counselors 

would not allow her to go on her own if they felt she would 

endanger herself.” (12250)
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Quotation (to protected tester): “Is Denise (PC tester) able 

to care for the dog independently and clean up behind the 

animal?” (10980)

Quotation (to protected tester): [The protected tester 

asked for a rent reminder as a reasonable accommodation. 

The agent] “said he was willing to do that but he would 

hold me [family member calling] responsible. I explained 

that this would be her responsibility; she would just need 

the reminder when it was close to the time. He said that I 

told him that Denise had a ‘problem’ and she was autistic. 

He said that if he gave her the apt he would be willing to 

do what I asked. However, because she had a ‘problem’ 

ultimately I would have to be responsible because he 

couldn’t babysit her up there in that apt.” (12115)

•	 Subtheme B: Agent makes other assumptions about 

protected tester due to their disability.

Quotation (to protected tester): [Immediately after disability 

disclosure], “the agent asked if she [the tester’s sister with 

a developmental disability was on Section 8 or SSI.” (16593)

Quotation (to protected tester): “[The agent said], ‘you 

mentioned your brother needs to stay calm.’ She said ‘he 

isn’t violent?’ I said ‘no he isn’t.’ She said ‘we are going to 

do a credit/criminal background.’ [Agent] said ‘he doesn’t 

have anything on his record?’ I said, ‘no not a thing.’”

Researcher analysis: “The agent appears to be linking 

mental illness to violence and a criminal record, therefore 

insisting on the need for a background check. This appears 

to be evidence of stigma and stereotyping.” (11927)

Basing their analysis on these themes, coders summarized 

whether subtle discrimination was present (Table A-8). 

The results revealed that 63 percent of the protected testers 

experienced subtle discrimination, with a higher percentage 

(65.7 percent) among testers with I/DD.

Table A-8. Subtle Discrimination in Telephone Testing

Disability Yes No Unclear Total n

I/DD 197 (65.7%) 83 (27.7%) 13 (4.3%) 293

MI 214 (60.8%) 126 (35.8%) 9 (2.6%) 349

Totals 411 (63.0%) 209 (32.1%) 22 (3.4%) 642

I/DD = intellectual or developmental disability. MI = mental illness.

Notes: n = 642 pairs. 10 pairs were not coded because disability was 

not disclosed during testing. 16 pairs did not have qualitative data to 

code.

Qualitative Themes With Quantitative Analysis: 

Overt Discrimination

Three themes emerged related to overt discrimination that 

would be covered explicitly under the FHA. These themes were 

(1) only the protected tester received a negative response about 

availability of the unit, (2) fees or rent rates quoted were higher 

for only the protected testers, (3) the agent made overt comments related to disability, and (4) the agent denied reasonable 

accommodation requests.

Theme 1: Only the protected tester received a negative 

response about the availability of the unit.

Researcher’s analysis: “Initially said unit available then 

changed the answer after disability disclosure, saying “‘call 

back next week.’” (15339)

Researcher’s analysis: “To PC, agent said that ‘the apartment 

would be rented by the end of the week’ because they have 

enough applicants whereas to C, the one bedroom was available and information was given on how to view.” (12698)

Theme 2: Fees or rent rates quoted were higher for only the 

protected testers.

Researcher’s analysis: “PC tester was told rent for apartment 

was $1,325. Control tester was told and got from ad that 

rent was $1,005 for the same apartment.” (12165)

Researcher’s analysis: “Agent required 1 month security 

deposit from PC tester, none for C.” (6728)

Researcher’s analysis: “Security deposit for Protected Class 

tester is $99 to one month’s rent ($1005), for Control 

tester is $99 to $300.” (7528)

Theme 3: The agent made overt comments related to disability.

Quotation: [To a question about the process for application], “I have no process, I’m pretty busy I have no more 

time to talk” and “if she needs rent reminder she needs to 

stay in the group home and I have no more time to talk to 

you. Good bye.” (14442)

Quotation: “We need to keep the crazies out” regarding 

criminal and credit background check. (14532)

Quotation: “Do you think that she should consider renting 

an apartment if someone needs to remind her to pay the 

rent?” (15342)

Quotation: “She said no, we are not the type of property 

that deals with people with, mental cases. I don’t really 

know how to say it, but yeah, mental cases.” (11619)
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Theme 4: The agent denied reasonable accommodation 

requests.

•	 Subtheme A: Agent denies the request directly and 

unequivocally.

Quotation: “Absolutely No! That’s up to the family to 

handle if you want her to rent an apartment here.” (8768)

Quotation: “She told me they don’t allow pets under any 

circumstances.” (13433)

•	 Subtheme B: Agents not knowing the legal rights of 

people with disabilities and needing to ask their managers 

or consult with others (for example, homeowners’ 

association) to provide the testers with the answer.

Quotation: Agent said, “she is not sure about the rent reminder but she would inquire with the main office about 

it and would get back to me.” (12462)

Researcher analysis: “Landlord was unsure about assistance animal and stated that he ‘needs to ask the home 

owner’s association.’” (14472)

•	 Subtheme C: Verbal rent reminder request not accepted, 

but alternative methods (for example, e-mail reminder, 

written reminder, auto payment plan) offered.

Quotation: “When asked about the rent reminder I was 

informed that they only provide a five day written notice 

for those who are in jeopardy of being late.” (12108)

•	 Subtheme D: Assistance animal request was often denied 

based on general no pet policy or weight or size policy, or 

accepted but with additional pet fee charges.

Quotation: Agent said “she is sorry but no pets are allowed. I said my brother has his doctor’s documentation. 

She said she is sorry but they have a no pet policy.” 

(12968)

Quotation: “I asked if the fees could be waived and she 

[agent] explained that they could not be waived because 

they would have to do it for everyone.” (13345)

Researcher analysis: Agent said that “pet over 25lbs is usually not allowed but it would be ok with documentation. 

However, pet fee cannot be waived.” (21474)

•	 Subtheme E: Agent not acknowledging the need of an 

assistance animal for a person with MD.

Quotation: “Support animal is not permissible unless the 

resident was blind.” (10985)

Overt discrimination was determined based on these themes, 

with results showing that approximately 57 percent of the 

protected testers experienced overt discrimination (see Table 

A-9). No significant difference was found by type of MD (MI or 

I/DD).

Table A-10 summarizes differences in responses between type 

of requests and between different disability testers.

Table A-9. Overt Discrimination in Telephone Testing

Disability Yes No Unclear Total n

I/DD 168 (57.3%) 122 (41.6%) 3 (1.0%) 293

MI 202 (57.9%) 141 (40.1%) 6 (1.4%) 349

Totals 370 (57.6%) 263 (41.0%) 9 (1.4%) 642

I/DD = intellectual or developmental disability. MI = mental illness.

Notes: n = 642 pairs. 10 pairs were not coded because disability was 

not disclosed during testing. 16 pairs did not have qualitative data 

available to code.

Table A-10. Housing Provider Responses to RA 

Requests in Telephone Testing 

Group Type of RA 

Request

Number of 

RA Requests

Responses

Positive Negative

I/DD Rent reminder 147 79 (53.7%) 68 (46.3%)

Service animal 131 70 (53.4%) 61 (46.6%)

MI Rent reminder 182 76 (41.8%) 106 (58.2%)

Service animal 155 90 (58.1%) 65 (41.9%)

Totals 615 315 (51.2%) 300 (48.8%)

I/DD = intellectual or developmental disability. MI = mental illness. RA = 

reasonable accommodation.

Notes: n = 615 pairs. 37 protected testers were not included in the 

analysis because they did not request RA during their testing.

Quantitative Analysis of Status of Further 

Communication

Coding of the status of further communication with the landlord revealed that the protected testers experienced significantly 

more closed-door or negative communications, whereas control 

testers experienced more open-door, positive communications. 

Table A-11 summarizes the disposition of closed-door versus 

open-door responses among the control group testers and 

protected class testers.

Table A-11. Open Door/Closed Door in Telephone 

Testing

Response Control

Group

Protected 

Group

McNemar’s 

p-Value

Open door 571 (88%) 311 (47.7%) 0.000 Closed door 46 (6.4%) 205 (31.4%)

Unclear 35 (5.4%) 136 (20.9%) —

Note: n = 652 pairs.
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In-Person Testing Findings

Qualitative Themes With Quantitative Analysis: 

Subtle Discrimination

During in-person testing, six themes emerged related to subtle 

discrimination against the protected tester. These themes were 

(1) more urgency, priority, or prompting of further action for 

control tester to submit an application, follow up, or continue 

the rental process; (2) more encouraging to control tester or 

more discouraging to protected tester; (3) more friendly, informal, or personalized with control tester or more formal or less 

personalized with protected tester; (4) agent requested more 

effort or information from protected tester before moving forward; (5) agent made him or herself more available to control 

tester; and (6) agent (potentially inadvertently) discriminated 

against protected tester by asking about disability or discussing 

disability in a discouraging way.

The themes and accompanying subthemes that emerged from 

the data are outlined in the following list and are followed by 

quotations that epitomize them. Similar to telephone testing 

data, in-person testing data were taken from tester field notes 

that testers wrote on completion of the test. The quotations 

that follow each theme are field note excerpts, or the tester’s 

own words describing the interaction with the agent. Researcher analyses are interpretations or summaries of the tester field 

note excerpts.

Theme 1: More urgency, priority, or prompting of further 

action for control tester to submit an application, follow 

up, or continue the rental process.

•	 Subtheme A: More prompting or urgency for control 

tester to continue the rental process.

Researcher analysis: “The agent told the control tester to 

please give him a call when they make the decision, that 

they won’t find a better unit, and that the unit may go fast. 

The agent did not say these things to the protected class 

tester.” (16213)

•	 Subtheme B: Agent shows priority to control tester by 

requesting more contact information from them.

Researcher analysis: “The control tester was asked to provide 

their ID, phone number, and email before the tour while 

the protected class tester was only asked to provide their 

ID. This is evidence of being more interested in following 

up with or giving priority to the control tester.” (14056)

Theme 2: More encouraging to control tester or more discouraging to protected tester.

•	 Subtheme A: More units or amenities shown, more options 

offered, or both to control tester.

Researcher analysis: “The control tester’s tour included two 

apartments, the business center, mailroom, and gym area 

while the protected class tester’s tour only included one 

apartment. Second, the protected class tester was offered 

one apartment while the control tester was offered three 

apartments.” (14082)

•	 Subtheme B: More positive information given about the 

unit, community, or rental process to control tester or more 

negative information given to protected tester.

Researcher analysis: “The control tester was given notes on 

floor plans and the protected class tester received verbal 

information only. Also, the control tester was told about more 

amenities (parking, business center, dry cleaning service, 

package receiving service, storage facilities, security deposit, 

close to everything including grocery store), while the 

protected class tester was told about fewer amenities (close 

to metro, gym) and was also given extra discouraging information (that utilities are not included in the rent).” (14082)

Researcher analysis: “The protected class tester was told 

about more income/fee requirements. Additionally, they 

were told that the application process would take 4-7 days, 

while the control tester was told it would take only 3-4 days. 

Finally, the agent told the protected class tester that there 

was crime in the building/on the property and did not say 

this to the control tester.” (13939)

Theme 3: More friendly, informal, or personalized with 

control tester or more formal or less personalized with 

protected tester.

Quotation (to control tester): “[The agent] introduced me to 

[another staff member] and said that her name was ‘Shirley.’ 

... We returned to the Leasing Office and Shirley asked me 

if I had seen anything that I liked. I said that I had. Lindsay 

mentioned to her that I was looking for my first apartment.”

Researcher analysis: “The agent introduced the control tester 

to another staff member and initiated conversation between 

them, which is evidence of being friendly and personalized 

with this tester. The agent did not introduce the protected 

class tester to any other staff members. Also, the agent 

offered the control tester several decorating tips on what to 

do with the space and pointed out the track lighting, which 

she did not do with the protected class tester, thus showing 

friendliness and personalization once again.” (14082)
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Theme 4: Agent requested more effort or information from 

protected tester before moving forward.

Researcher analysis: “The agent told the protected class 

tester that no flyers were available and asked the tester to 

check the website for them. Conversely, when meeting 

with the control tester, ‘went over to a file and retrieved 

a flyer which listed information about the apartments, 

including their features, rental rates, fees, and what was 

needed to apply.’” (14619)

Theme 5: Agent made himself or herself more available to 

control tester.

Researcher analysis: “The agent opened the unit door 

and left the protected class testers to look around the 

(smelly, uncleaned) unit by themselves. The control tester 

was accompanied by the agent when viewing the unit. 

Additionally, the agent provided the control tester with 

her name, phone number, and office hours, but only 

provided the protected class testers with her name and 

phone number but no office hours.” (14619)

Theme 6: Agent (potentially inadvertently) discriminated 

against protected tester by asking about disability or 

discussing disability in a discouraging way.

•	 Subtheme A: Agent questions protected tester’s competence.

Researcher analysis: “The agent addressed the protected 

class companion tester when asking/answering questions, 

rather than speaking with the tester with a disability, who 

was the one actually seeking to rent the unit.” (15082)

•	 Subtheme B: Agent makes other assumptions about 

protected tester due to their disability.

Researcher analysis: “The agent mentioned Section 8 housing 

to the protected testers, who replied by saying they were 

actually looking for market rental housing, not Section 8 

housing. Even after the testers made this clarification, the 

agent still mentioned Section 8 housing a second time.” 

(13783)

Based on these themes, subtle discrimination was coded (Table 

A-12). In all, 45 protected testers (54.2 percent) experienced 

Table A-12. Subtle Discrimination in In-Person Testing

Disability Yes No Unclear Total

I/DD 23 (47.9%) 24 (50.1%) 1 (2.0%) 48

MI 22 (62.9%) 13 (37.1%) 0 (0.0%) 35

Totals 45 (54.2%) 37 (44.6%) 1 (1.2%) 83

I/DD = intellectual or developmental disability. MI = mental illness.

Notes: n = 83 pairs. 18 pairs did not have qualitative data to code.

subtle discrimination during their visit to the apartment, with 

a higher percentage of subtle discrimination (62.9 percent) 

experienced by testers with MI.

Qualitative Themes With Quantitative Analysis: 

Overt Discrimination

In in-person testing, similar themes to those in telephone testing 

emerged related to overt discrimination; however, reasonable 

accommodation requests were not done during the in-person 

testing.

Theme 1: Only the protected tester received a negative 

response about the availability of the unit.

Researcher analysis: “Units were not available for PC to 

view. The agent went to make copies of PC’s ID before 

showing the units, talked to another staff for 3-4 mins, and 

came back out saying that contractors are working in both 

units thus units so not available for viewing. No further 

invite was offered to come back to see the units after the 

work is done. C was able to view units.” (14284)

Theme 2: Fees or rent rates quoted were higher for only the 

protected testers.

Researcher analysis: “To C agent said that there is no security 

deposit and now they do non-refundable move-in fee 

of $200. PC was told that there is a one month security 

deposit ($1005).” (14283)

Theme 3: The agent made overt comments related to disability.

Researcher analysis: “Agent inquired about nature and 

severity of disability. Agent asked what kind of disability 

PC has.” (16521)

Table A-13 shows the analysis of occasions of overt discrimination. Far less overt discrimination occurred in the in-person 

testing than in the telephone testing. Out of 83 testers, 11 protected testers (13.3 percent) experienced overt discrimination. 

The discrimination rate was higher with testers with MI.

Table A-13. Overt Discrimination in In-Person Testing

Disability Yes No Unclear Total

I/DD 4 (2.1%) 43 (89.6%) 1 (2.1%) 48 (100%)

MI 7 (20.0%) 28 (80.0%) 0 (0.0%) 35 (100%)

Totals 11 (13.3%) 71 (85.5%) 1 (1.2%) 83 (100%)

Notes: n = 83 pairs. 18 pairs did not have qualitative data to code.
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Quantitative Analysis of Status of Further 

Communication

Coding of the status of further communication with the 

landlord shows that the protected group had slightly more 

occasions when further communication was closed, but the 

differences were not significant (Table A-14).

Table A-14. Open Door/Closed Door in In-Person 

Testing

Response

Count (Percent)

Control

Group

Protected 

Group

McNemar’s 

p-Value

Open door 81 (97.6%) 78 (94.0%) 0.250 Closed door 2 (2.4%) 5 (6.0%)

Notes: n = 83 pairs. 18 pairs did not have qualitative data to code.

Discussion and Conclusions

This mixed-methods approach to qualitatively analyzing data, 

followed by summarizing findings quantitatively to examine 

differences between people with and without MD in market 

rental searches, produces new and significant findings that 

further document specific examples and frequencies of both 

subtle and overt housing discrimination against people with MI 

and I/DD. These findings, including implications for education 

and training of housing providers on the FHA and specifically 

on reasonable accommodations based on MD within rental 

housing, are summarized in this section.

Telephone Testing

•	 Some agents specifically cited the FHA but misinterpreted 

it. They said that they follow the FHA and, therefore, they 

cannot give anyone special treatment—they need to treat 

everyone the same. This finding seems to show progress in 

that they are aware of the FHA and are trying to follow it, 

but more education about disability reasonable accommodations is needed.

•	 A trend that emerged was that, with some protected testers 

with I/DD, the agent appeared excited about renting the 

unit to the tester and would cite positive safety amenities 

of the unit and building (for example, gated community) 

but would later ask for extra eligibility requirements, 

fees, or verification. This practice seems to show intent to 

initially appear fair, encouraging, and open to the tester 

but to later subtly discriminate by making it more difficult 

for protected testers to rent.

•	 Some agents did not know about their ability to approve 

a reasonable accommodation and had to ask a manager 

before providing the protected tester with an answer. In a 

few cases, however, the agents asked the manager while on 

the call and then approved the reasonable accommodation 

request. This finding shows that, although many agents 

are still not trained in fair housing requirements, some are 

making the effort to ensure they are giving the prospective 

tenant the correct answer. Also, the managers in these 

cases are knowledgeable about the FHA and reasonable 

accommodations, which demonstrates the positive effect 

the law has had in recent years.

•	 For protected testers who asked for an assistance animal 

reasonable accommodation, some agents would ask 

questions related to the building’s pet policy. For example, 

some agents asked the breed or size of the animal, and, 

although the agents ended up approving the reasonable 

accommodation request because the tester’s animal fit 

the pet policy parameters, this request would likely have 

been denied if the tester had a different assistance animal 

that did not fit general requirements. This practice shows 

potential discriminatory behavior, but it did not play out 

in these particular cases due to the tester’s scenario rather 

than the agent’s decision or behavior.

Both Telephone and In-Person Testing

•	 Protected testers were often told that an application fee 

would be charged for each adult applicant, whereas control 

testers were told about this extra fee less often. Even when 

protected testers clarified that only the person with a 

disability would be applying for and renting the unit, some 

agents still felt the need to reiterate this additional fee.

Differences Detected

•	 Overt discrimination practice was found to be much more 

likely in telephone testing (57 percent) than in in-person 

testing (13 percent). One potential explanation of the 

lower overt discrimination rate in in-person testing is 

that, in in-person testing, the testers had already made an 

appointment in advance and knew the unit was ready to 

be viewed. In telephone testing, however, many protected 

testers were told that units were not available compared 

with control testers who were given information about 

available units. Open door/closed door analysis supports 

that a significant difference in unit availability exists 

between control and protected testers.

•	 Subtle discrimination occurred to more than one-half of 

the protected testers in both telephone (63 percent) and 

in-person testing (54 percent). During in-person testing, 
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agents could not overtly discriminate because the testers 

were already there to view the unit, but the agents still 

practiced subtle discrimination with the intention of 

discouraging the protected tester from taking the next step 

or as a result of asking about MD.

•	 During in-person testing, testers with MI showed higher 

discrimination rates than testers with I/DD in both subtle 

and overt discrimination, whereas during telephone testing 

discrimination rates against testers with MI and I/DD 

were similar. Given the fact that the in-person tests were 

conducted by persons with MI and I/DD, as opposed to 

the telephone tests, which were conducted by proxies, this 

observation adds weight to the notion that persons with 

MI experience higher rates of housing discrimination when 

compared with persons with I/DD.
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