Fair Housing Planning Considerations for Individuals with Disabilities

Affirmatively Furthering Fair Housing (AFFH)

What is AFFH?

Affirmatively Furthering Fair Housing (AFFH): Under the Fair Housing Act (FHA) of 1968, recipients of HUD 

funds must “affirmatively further the policies and purposes” of the FHA. Disability is connected to the AFFH 

mandate through the 1988 FHA amendments.

Who Can Impact Fair Housing Planning?

• Disability stakeholders

• Recipients of federal funds

• Individuals with disabilities

• Advocacy groups who fight for disability rights

• ACL’s Disability Network

Sample Fair Housing Questions You Can Ask

• Who lacks access to opportunity in our community?

• How can we address inequity among protected class groups?

• How do we promote integration and reduce segregation?

• How can we transform racially or ethnically concentrated areas of poverty (R/ECAPs) into areas of 

opportunity?

• How can we tie the identified fair housing impediments to goals in our Consolidated Plan or Public 

Housing Authority Plan?

• What are the best ways to include protected characteristic 

groups like individuals with disabilities?

The Deep Dive - Areas of Disability Analysis

• Look for identifiable actions, omissions, or decisions that 

restrict or affect availability of housing choices based on FHA 

protected characteristics — in this case disability

• Seek additional information from other disability stakeholders

• Assemble demographic & opportunity maps to understand your 

community better

Obligations of AFFH

Take Meaningful 

Actions

AFFH

Foster Inclusive 

Communities

Overcome 

Patterns of 

Segregation

Eliminate 

Barriers that 

Restrict Access 

to Opportunities

Disability Stakeholders in Fair Housing Planning

• Individuals with disabilities 

continue to face impediments 

to fair housing choice, as 

evidence by 61.7% of fair 

housing complaints in 2019 

were based on disability & 

failure to make reasonable 

accommodations

• Community engagement with experts informs 

robust fair housing planning 

• Individuals with disabilities can serve in a key 

role supplementing HUD-provided data 

• 31% of COVID-19 deaths in 

June 2021 were older adults, 

individuals with disabilities, 

and their care givers in 

congregate care settings

• Supports Olmstead

obligations 

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Fair Housing Planning Considerations for Individuals with Disabilities

Affirmatively Furthering Fair Housing (AFFH)

Who Can Help with Outside Research, Input, and Planning?

Disability stakeholders can play a key role in the fair housing process to improve outcomes for individuals with disabilities. Input from local stakeholders 

strengthens fair housing planning. Local data and reports contribute to HUD mapping tools and state and national information.

Some examples of disability stakeholders: 

Benefits of Community Participation

• State and local disability departments and 

commissions

• Local & state non-profit and government 

administrative fair housing agencies

• Private non-profit agencies that service individuals 

with disabilities

• Advocacy organizations who promote disability 

rights

• Disabled users of government services

• Policy makers who focus on disability legislation

• Public & private housing industry organizations

• Tenant or resident organizations or advocates

• Community-based organizations representing 

individuals with disabilities

• Faith-based organizations

• Organizations relevant to opportunity (ex: schools, 

environmental justice)

• State & local universities

• Resident advisory boards of the public housing 

authorities

• Centers for Independent Living

• Protection and Advocacy Agencies

• Councils on Developmental Disabilities

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Bridges the gap between current 

local needs and decisions about 

where and how to invest public 

dollars judiciously.

Will help program participants develop 

an awareness of disparities that limit 

fair housing choice in a particular 

region and will integrate valuable 

local knowledge to help local officials 

understand why those disparities 

exist, and how to overcome them.

Community members and 

stakeholders engaged at the 

beginning of the development 

process will take ownership of 

the outcomes, and this gives fair 

housing planning legitimacy and 

longevity.

Improve data collection and data 

sharing to better understand the 

needs of individuals with disabilities 

to ensure equal access and equal 

housing opportunities.

Informed 

Decision 

Making

Building 

Trust & 

Relationships

Ownership & 

Support

Better 

Information

Benefits of 

Community 

Engagement
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Fair Housing Planning Considerations for Individuals with Disabilities

Affirmatively Furthering Fair Housing (AFFH)

Effective Communication for Accessible Community Engagement

Remote Hearings and Community Meetings Accessibility Considerations

• Websites, emails, and digital notifications are accessible for persons with 

vision, hearing, and other disabilities.

• Ensure the availability of auxiliary aids such as audio description, captioning, 

sign language and other types of interpreters.

• The platform used to host the remote hearing or meeting offers sufficient 

functionality to ensure effective communication. Platform accessibility is 

assessed in advance of the hearing or meeting. 

• Keyboard accessibility, accessible documents, screen reader support, and 

transcripts.

Examples of Auxiliary Aids and Services 

• American Sign Language (ASL) interpreters

• Computer-Assisted Real Time Transcription (CART)

• Assistive listening devices (when requested by individuals who are deaf or hard 

of hearing)

• All written materials in accessible formats for persons who are blind or have 

low vision

• An accessible website so text, images, buttons, and forms are accessible to 

blind, low vision, deaf, and hard of hearing individuals 

The Legal Obligations for Recipients of HUD funding

• Section 504 of the Rehabilitation Act

• Americans with Disabilities Act

• Take proactive steps to ensure effective communication with recipients prior to 

engagement

Resources

• AFFH Website: hud.gov/affh

• HUD’s Data & Mapping Tool (AFFH-T): https://egis.hud.gov/affht

• HUD’s AFFH Webpage: hud.gov/AFFH

• AFFH Rule Guidebook

• Fair Housing Planning Guides: Vol. 1 and Vol. 2

• Technical Assistance and General Inquiries: AFFH@hud.gov

• GSA 508 Compliance

• HUD’s Effective Communication Webpage: FHEO Effective Communication

• DOJ’s Web Access Guidance: Web Guidance

• ACL Website: ACL

• ACL’s Disability Network: ACL Network

Now You’re Ready to Invite People to the Fair Housing Planning Table

How YOU Can Get Involved in Community Participation

• Meetings and/or public forums involving both disability and AFFH 

stakeholders

• Community outreach

• Focus groups for individuals with disabilities living within a 

jurisdiction/region/state

• Housing/neighborhood surveys to learn about accessibility and 

access to opportunity

• Local or regional collaborations that focus on neighborhood access 

to opportunity for individuals with disabilities such as access to 

transit, education, and grocery stores

• Consultation with disability stakeholders

These stakeholders 

could be from ACL’s 

disability network 

such as: Centers for 

Independent Living, 

Protection & Advocacy 

Agencies, & Councils 

on Developmental 

Disabilities

What to Discuss:

Accessible digital communications

Access to housing for seniors & 

individuals with mobility limitation

Integrating priorities regarding access to 

housing & housing services for seniors and 

adults with disabilities

Developing a pedestrian network 

that works for all from a universal 

design perspective

Local disability data & 

data analysis