DEMYSTIFYING THE

REHABILITATION ACT

What Faith-Based and Community Organizations

Need to Know About Using Federal Financial

Assistance to Serve People with Disabilities

Using Federal Financial

Assistance to Serve

People with Disabilities

IFyou represent a faith-based or

community-based organization that is

• Receiving financial assistance

from the United States

Department of Labor (USDOL)

(e.g., a grant, sub-award, contract,

in-kind assistance, etc.), or

• Planning to apply for financial

assistance from USDOL, or

• Partnering with an existing

USDOL-supported program,

THEN, the following 

information will help you better

understand how Section 504 of the

Rehabilitation Act of 1973 applies 

to your organization as you serve

people with disabilities.
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1As a faith-based organization, we are exempt from certain

parts of the Americans with Disabilities Act (ADA). However,

will any other Federal disability nondiscrimination laws apply

to us if we receive Federal financial assistance?

Yes. Section 504 of the Rehabilitation Act of 1973 (Section 504)

applies to organizations that receive Federal financial assistance,

including faith-based and community-based organizations.

Section 504 prohibits recipients of Federal financial assistance

from discriminating against an individual because of a disability,

and requires them to take certain positive actions to “level the

playing field” for people with disabilities. Keep in mind that

under the law, "financial assistance" includes more than simply

dollars and cents; it also includes non-monetary aid, such as

donations of items, services, or free or discounted use of government space or property.

This fact sheet provides information only about Section 504 of

the Rehabilitation Act of 1973, and the regulations that have

been published to implement it. Each Federal agency has its

own regulations implementing Section 504. The Department of

Labor’s Section 504 regulations can be found at:

http://www.access.gpo.gov/nara/cfr/waisidx_01/29cfr32_01.html.

Other disability-related laws may also apply to your organization,

such as Section 188 of the Workforce Investment Act (WIA). For

further information on the disability-related requirements of WIA

Section 188, you are encouraged to visit: 

http://www.dol.gov/oasam/programs/crc/section188.htm. 
2Our organization is very small. Will Section 504 of the

Rehabilitation Act apply to us?

Generally, yes. If, however, your organization has fewer than 15

employees on each day of the program year, and serves a total

of fewer than 15 people during a program year, your organization

may be exempt from the accessibility requirements that apply to

larger organizations. Those requirements are discussed in the

answer to question four (4). 

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3Does our organization need to change our program or

facilities before we apply for a Federal grant?

If your organization is applying for a Federal grant or certain other

types of Federal financial assistance, your application will need

to include a specific statement assuring that your program will

comply with disability nondiscrimination requirements if it

receives the assistance. However, you are not required to make

any changes until after you receive assistance. See the discussion of accessibility in the answer to the next question.

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4Our organization is interested in using Federal financial

assistance to mentor young people with disabilities, and

also in partnering with another Federally-supported program. We are concerned that our house of worship/facility has steps, but no ramp or elevator. Will our organization be required to make architectural changes for disability access, like installing a ramp or an elevator, widening

doors, and/or changing the restrooms and drinking fountains? What else do I need to know about making our

facility and programs accessible?

You are probably thinking of the Federal specifications for accessible facility design and construction (known as “architectural

accessibility” guidelines or standards). Complying with those

guidelines or standards is known as providing architectural

accessibility. Your place of worship or facility will be required to

meet or exceed the architectural accessibility standards only if it

was built, altered or renovated (or will be built, altered or renovated) after the date you first receive(d) Federal financial assistance.

If your organization does not plan to build a new facility, or to renovate or alter its present facilities, while you are receiving Federal

financial assistance, then the architectural accessibility requirements will not apply. Those requirements also will not apply to

you if your organization falls within the small-recipient exception

(see answer to question two (2).

Even though the architectural accessibility requirements may not

apply to your facility, you are still required to provide all of your

Federally-assisted programs and activities in such a way that,

viewed as a whole, they are accessible to people with disabilities.

This process is known as providing program or programmatic

accessibility. Rather than meeting a specific set of guidelines or

standards (as with architectural accessibility), providing programmatic accessibility allows you to take a common-sense

approach. For example, if the part of your house of worship or

facility where you planned to provide a Federally-assisted program is not accessible to people with disabilities, you can provide programmatic accessibility in one or more of the following

ways: (1) providing additional sessions of the same program in a

portion of your house of worship or facility that is accessible; (2)

moving the entire program to an accessible facility; (3) renovating the inaccessible part of the house of worship or facility; or (4)

any other method that will enable you to provide a fully-accessible program. Whatever method you choose, you must make the

program accessible within 60 days of the date on which your

organization first receives Federal financial assistance.
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Other examples of possible ways to provide program accessibility, depending on the individual circumstances of your organization and the Federally-supported programs it offers, include

redesign of equipment; assignment of aides to help customers or

employees; and visits to clients at home, among many other possibilities. The method you use to provide programmatic accessibility is up to you. In deciding what method to use, remember

that Section 504 requires you to offer programs and activities to

persons with disabilities in the most integrated setting appropriate for the needs of those persons. 

If you are required to make all or part of your house of worship or

other facility architecturally accessible, the law allows you six (6)

months to develop a transition plan for making the required

changes. Those changes must be completed as quickly as possible, but not later than three (3) years after you first receive

Federal financial assistance.

The Federal architectural accessibility standards are available

from the U.S. Access Board at the following Web page:

http://www.access-board.gov/gs.htm, or by calling the Access

Board’s toll-free phone number:

• (800) 872-2253 (Voice) • (800) 993-2822 (TTY)

Please note that if your facility must comply with accessibility

standards, and your state or local accessibility standards are

more stringent than the Federal standards, you should use the

more stringent standard(s). 
5Our organization conducts some of its programs in office

space donated by a local business. This space is not accessible to people with disabilities. Are we exempt from accessibility requirements because we do not own or rent the

space?

No.Your organization is not exempt from the accessibility requirements simply because the space it uses is donated (i.e., neither

rented nor owned). 

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6Our organization serves people with a wide range of disabilities, such as people who are blind, deaf, and/or have

learning disabilities or mental retardation. Where can I go

to get information about providing accommodations for

such individuals?

The Job Accommodation Network (JAN) is a good place to start.

JAN is a free information and referral service (funded through the

USDOL Office of Disability Employment Policy) that provides

information about, and individual suggestions for, accommodations for people with disabilities in various contexts (not just the

context of employment). JAN also provides information about

the Americans with Disabilities Act and other disability-related

legislation, and resources for technical assistance, funding, education, and services related to the employment of people with

disabilities. 

http://www.jan.wvu.edu

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7Our organization has a school bus and a van that we use to

bring participants to our program. What do we do about

transporting people who have mobility impairments (e.g.,

people who use wheelchairs, canes, walkers, etc.)?

If providing transportation is part of your organization’s program,

you must extend that service to participants with disabilities in

the most integrated manner possible (i.e., participants with disabilities should be riding together with participants without disabilities to the greatest extent that is appropriate to the needs of

the participants with disabilities).

Although your organization is not necessarily required to make all

its vans and buses accessible, please be aware that carrying an

individual with a disability into and out of a van or bus is not an

acceptable means of providing access to transportation. Your

organization should consider obtaining at least one van or bus

that meets accessibility requirements, or providing an alternative

means of transportation for program participants who have disabilities. Your organization may be able to accomplish these

goals through partnerships with other organizations, such as

senior citizen organizations or public transportation providers. In

addition, your organization may be able to take advantage of

Federal programs that can help pay for accessible vans or buses,

such as the U.S. Department of Transportation’s 5310 Program.

http://www.fta.dot.gov/grant_programs/specific_grant_programs/elderly_disabilities/4230_7954_ENG_HTML.htm

The following Web sites may serve as helpful resources for information about transportation for persons with disabilities:

• United We Ride (a Federally-sponsored Web site)

http://www.unitedweride.gov

• Project Action

http://projectaction.easterseals.com/site/PageServer?pagename 

=ESPA_homepage
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8What national resources are available to help our organization work with youth/adults with disabilities?

The DisabilityInfo.gov Web site, supported by USDOL and other

Federal departments and agencies, provides a wealth of annotated links to resources, services and information for and about

people with disabilities that is available throughout the Federal

government or from Federally assisted programs. Topics include

choice and self-determination, civil rights and protections, disability statistics, education, emergency preparedness, employment, health, housing, income support, parenting, recreation and

travel, technology, transition, and transportation.

http://www.disabilityinfo.gov

Disability Program Navigators (DPNs), located in USDOL’s OneStop Career Centers, help job seekers with disabilities “navigate”

the complex challenges of seeking employment. Through joint

funding from USDOL and the Social Security Administration

(SSA), the DPN initiative hires One-Stop staff to identify

resources, establish linkages and partnerships with other public

and private agencies serving adults and youth with disabilities,

and provide technical assistance and training to assist the OneStop Career Center staff in serving job seekers with disabilities. 

http://www.doleta.gov/disability. 

The Employer Assistance and Recruiting Network (EARN) is a national toll-free telephone and electronic information referral service

designed to assist employers in locating and recruiting qualified

workers with disabilities. EARN, a service of the USDOL Office of

Disability Employment Policy, can also provide technical assistance on general disability employment-related issues, such as

the business case for hiring people with disabilities.

Phone: 1-866-EARN NOW (327-6669) (voice/TTY)

http://www.earnworks.com

The Job Accommodation Network (JAN) is a free information and

referral service (funded through the USDOL Office of Disability

Employment Policy) that provides information about, and individual suggestions for, accommodations for people with disabilities

in various contexts (not just the context of employment). JAN

also provides information about the Americans with Disabilities

Act and other disability-related legislation, and resources for

technical assistance, funding, education, and services related to

the employment of people with disabilities. In addition, JAN analyzes trends and statistical data related to the technical assistance it provides.

http://www.jan.wvu.edu
The National Center on Secondary Education and Transition (NCSET)

is funded by the U.S. Department of Education’s Office of Special

Education Programs. NCSET describes its mission as coordinating national resources, offering technical assistance, and disseminating information related to secondary education and transition for youth with disabilities in order to create opportunities

for these youth to achieve successful futures.

http://www.ncset.org 

The National Center on Workforce and Disability/Adult (NCWD), funded by the USDOL Office of Disability Employment Policy,

describes its mission as “provid[ing] training, technical assistance, policy analysis, and information to improve access for all

in the workforce development system.”

http://www.onestops.info 

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The National Collaborative on Workforce and Disability/Youth

(NCWD/Y), funded by the USDOL Office of Disability Employment

Policy, describes its mission as working with state and local

workforce development systems to ensure youth with disabilities

are provided full access to high quality services in integrated settings in order to maximize their opportunities for employment

and independent living. 

http://www.ncwd-youth.info

The National Dissemination Center for Children with Disabilities

(NICHCY) is a national information center, funded by the United

States Department of Education’s Office of Special Education

Programs, which provides information on disabilities and disability-related issues. NICHCY’s special focus is children and youth

(birth to age 22).

http://www.nichcy.org

The National Mental Health Association (NMHA) is a national nonprofit organization that describes itself as “addressing all aspects

of mental health and mental illness.” Its Web site includes

resources for public education, training and technical assistance.

http://www.nmha.org

The National Mental Health Information Center, a service of the

Substance Abuse and Mental Health Services Administration

(SAMHSA) at the U.S. Department of Health and Human

Services, is the primary information resource for Federal mental

health programs. The Information Center provides general information about a range of mental health-related topics, news, topical publications, and a telephone information center.

Phone: 1-800-789-2647 (voice)

866-889-2647 (TDD)

http://www.mentalhealth.org

The National Technical Assistance Center for State Mental Health

Planning (NTAC) describes itself as providing “focused, state-ofthe-art technical assistance and consultation to state mental

health agencies, state mental health planning and advisory councils,

consumers, and families to help ensure that the best practices

and most up-to-date knowledge in mental health and related

fields are translated into action at the state and local levels.” 

http://www.nasmhpd.org/ntac.cfm

The National Youth Employment Coalition (NYEC) describes itself as

“a non-partisan network improving the effectiveness of organizations that seek to help youth become productive citizens.”

NYEC’s activities include a project on youth with disabilities. 

http://www.nyec.org

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The National Youth Leadership Network (NYLN) describes its mission

as advancing the next generation of disability leaders by promoting leadership development, education, employment, independent

living, and health and wellness among youth leaders with disabilities in all aspects of society at national, state, and local levels.

http://www.nyln.org

The PACER Center, funded by the United States Department of

Education’s Office of Special Education Programs, aims to

expand opportunities for, and enhance the quality of life of, children and young adults with disabilities and their families, based

on the concept of parents helping parents.

http://www.pacer.org
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PEPNet, created and managed by the National Youth Employment

Coalition (NYEC), is a system and an information source, based

on practice and research, for identifying and promoting what

works in youth employment and development for all youth,

including youth with disabilities. Specifically, PEPNet works to

improve programming and capacity in the youth

employment/development field, inform public policy, and

increase support for effective youth programming.

http://nyec.modernsignal.net/page.cfm?pageID=110 

Project ACTION (Accessible Community Transportation in Our Nation),

funded by the U.S. Department of Transportation’s Federal

Transportation Administration (FTA) and administered by the

National Easter Seal Society, is a national research and demonstration program established to improve access to transportation

for people with disabilities and assist transit providers in implementing the ADA.

http://www.projectaction.org

Public/Private Ventures (P/PV) is a research, public policy, and program development organization. P/PV describes its mission as

improving the effectiveness of social policies, programs, and

community initiatives, especially as they affect youth and young

adults, including those with disabilities.

http://www.ppv.org

USDOL’s CareerOneStop Web site offers a suite of national Web sites

that help businesses, job seekers, students, and workforce professionals find employment and career resources. 

http://www.careeronestop.org

The above list of resources is not meant to be exhaustive. Any

listing of non-governmental resources should not be construed

as an endorsement of the entities, their services, or products by

the Office of Disability Employment Policy or the U.S.

Department of Labor. 
9Who can our organization contact for additional information related to our legal obligations under Section 504, the

with Disabilities Act, and other federal disability statutes? 

The Civil Rights Center (CRC) at the U.S. Department of Labor

enforces and administers Federal laws prohibiting discrimination

in programs and activities receiving Federal financial assistance

from DOL or through the One-Stop system. CRC conducts compliance reviews, investigates discrimination complaints, and provides compliance assistance and training. CRC staff members

are available to answer your questions about the disability

nondiscrimination laws that apply to your organization because

of its status as a recipient of Federal financial assistance. You

are encouraged to submit your questions via e-mail at the

address below.

U.S. Department of Labor

Room N-4123

200 Constitution Avenue, NW

Washington, DC 20210

(202) 693-6500 (voice)

(202) 693-6515 (TTY/TDD)

(800) 877-8339 (Federal Relay Service)

CivilRightsCenter@dol.gov

http://www.dol.gov/oasam/programs/crc/crcwelcome.htm

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The ADA Home Page, a U.S. Department of Justice Web site with

links to information on ADA requirements, technical assistance

publications, design standards and enforcement.

http://www.usdoj.gov/crt/ada/adahom1.htm

The Office of Disability Employment Policy (ODEP), a Federal agency

at the U.S. Department of Labor, provides leadership to increase

employment opportunities for adults and youth with disabilities. 

U.S. Department of Labor

Room S-1303

200 Constitution Ave., NW

Washington, DC 20210

Ph: (202) 693-7880

TTY: (202) 693-7881

Fax: (202) 693-7888

http://www.dol.gov/odep

The Center for Faith-Based and Community Initiatives (CFBCI) at the

U.S. Department of Labor seeks to empower faith-based and

community organizations (FBCOs) as they help their neighbors

prepare for, enter and thrive in the workforce.

U.S. Department of Labor

Room S-2235

200 Constitution Avenue, NW

Washington, DC 20210

(202) 693-6450

(800) 877-8339 (Federal Relay Service)

http://www.dol.gov/cfbci

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Employer Resources

Productivity Tools & Strategies 

when Hiring, Accommodating & Retaining

Employees

Job Accommodation Network

www.jan.wvu.edu

800.526.7234 — V/TTY

Recruiting, Hiring & Business 

Case Resources

Employer Assistance & Recruiting Network (EARN)

www.earnworks.com

866.EARN.NOW (866.327.6669) — V/TTY

Publications, Fact Sheets, 

Interview & Hiring Tips

Office of Disability Employment Policy

U.S. Department of Labor

www.dol.gov/odep

202.693.7880

877.899.5627 — TTY

The statements expressed herein do not necessarily reflect the position or policy

of the U.S. Department of Labor. Nor does mention of 

tradenames, commerical products, or organizations imply 

the endorsement by the U.S. Department of Labor.