AGAINST PERSONS WITH DISABILITIES: GAINST PERSONS WITH DISABILITIES:

Barriers at Every Step riers at Every Step
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AGAINST PERSONS WITH DISABILITIES 

Barriers at Every Step 

Prepared for: 

Office of Policy Development and Research 

U.S. Department of Housing and Urban Development 

Prepared by: 

Margery Austin Turner 

Carla Herbig 

Deborah Kaye 

Julie Fenderson 

Diane Levy 

The Urban Institute 

Washington DC 

May 2005 
ACKNOWLEDGEMENTS 

This project could not have been successfully completed without the commitment and 

hard work of testers, testing coordinators, and local testing organizations in Chicago and 

Albuquerque. The authors therefore extend our appreciation and thanks to the directors and 

staff of Access Living Metropolitan Chicago, who participated in the design and implementation 

of both the exploratory and pilot phases of this study, and to Protection and Advocacy, Inc. of 

New Mexico, which participated in the exploratory phase. 

Sara Pratt served as an active contributor and adviser throughout the course of this 

project, contributing to the design of testing protocols, the development of training materials, 

and the review of test results and reports. She also authored a forthcoming guidebook of fair 

housing enforcement tools. 

A panel of expert advisors made valuable contributions to our understanding of the 

challenges facing disabled homeseekers and the potential of paired testing as a tool for better 

understanding these challenges. Panel members (and their organizational affiliations at the 

time of our January 2003 meeting) were Michael Allen, Bazelon Center for Mental Health Law; 

Julie Carter, Kennedy Foundation; Cathy Cloud, National Fair Housing Alliance; Katherine 

Copeland, Silver State Fair Housing Council; Don Eager, Donald Eager and Associates; Fred 

Frieberg, U.S. Department of Justice; Max Lapertosa, Access Living; Robert Liston, Montana 

Fair Housing; Joan Magagna, U.S. Department of Justice; Bonnie Milstein, Magar and Milstein; 

Susan Prokop, Paralyzed Veterans of America; Jeff Rosen, National Council on Disability; 

Susan Scovill, Housing Opportunities Made Equal of Richmond; and Jeanine Worden, U.S. 

Department of Justice. 

The authors also thank Urban Institute colleagues who contributed to the successful 

completion of this research. Specifically, David D’Orio developed the web-based data system 

used to enter and share testing information; Audrey Droesch assisted with the weekly process 

of creating representative samples of available rental housing units, which provided the starting 

point for every paired test; and Diane Hendricks helped produce all the test reporting forms and 

training materials. 

Finally, Todd Richardson from the U.S. Department of Housing and Urban 

Development’s Office of Policy Development and Research provided excellent guidance and 

oversight throughout this research effort. 

Despite the generous contributions from these individuals and organizations, any errors 

and omissions that may remain in this report are, of course, our own. All views expressed are 

those of the authors and should not be attributed to the Urban Institute, its trustees, or its 

funders. 
FOREWORD 

HUD's mission is to increase homeownership, support community development and increase 

access to affordable housing free from discrimination. The third leg of HUD’s mission, increasing 

access to affordable housing free from discrimination, led HUD to undertake a series of studies to 

measure and characterize the current level of discrimination in the United States. This report 

represents the last in the series of Housing Discrimination Study (HDS 2000) reports. The previous 

three reports were designed to determine the extent of housing discrimination based on race, color, or 

ethnicity that Americans may face today. This groundbreaking study, Discrimination Against Persons 

with Disabilities: Barriers at Every Step, measures the level of housing discrimination faced by 

persons with disabilities. 

This study developed and implemented new state-of-the-art paired testing procedures to measure 

discrimination faced by deaf persons and persons using wheelchairs when searching for housing to rent 

in the Chicago Metropolitan Area. The results are based on a sample of 200 paired tests. 

The research found the level of discrimination faced by both deaf persons and persons in 

wheelchairs to be extremely high, substantially greater than the levels of housing discrimination 

experienced by African Americans and Hispanics in the Chicago housing market. People who are deaf 

and use the TTY relay system to inquire about advertised rental units were refused service in one out 

of four calls. For wheelchair testers, one in every four disabled testers was told about fewer units than 

similarly qualified nondisabled testers. For both wheelchair users and deaf persons, they received far 

less information about the application process than did similarly qualified nondisabled testers. 

In addition to different treatment, this study also sought to measure to what extent landlords 

complied with the Fair Housing Act requirements of reasonable accommodation and reasonable 

modification for a person with a disability. One-in-six housing providers refused a request for a 

reasonable modification that the tester said they would pay for and 19 percent of those with on-site 

parking refused to make the reasonable accommodation of providing a designated accessible parking 

space for a wheelchair user. 

In support of HUD’s mission to increase access to housing free from discrimination, this report 

offers invaluable assistance by documenting some of the types of discriminatory practices persons with 

disabilities face. The findings will enable HUD to design and target education and outreach programs, 

as well as support HUD’s enforcement of the Fair Housing Act. 

 Alphonso Jackson 

 Secretary 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

TABLE OF CONTENTS 

1. INTRODUCTION AND SUMMARY .......................................................................................1
 

Study Purpose and Scope .............................................................................................1
 

Summary of Findings.....................................................................................................2
 

Organization of the Report ............................................................................................4
 

2. LESSONS FROM THE EXPLORATORY TESTING PHASE................................................5
 

Testing for Discrimination Against Persons with Mental Disabilities..............................5
 

Testing for Discrimination Against Persons Who are Deaf or Hard of Hearing .............8
 

Testing for Discrimination Against Persons Who are Blind or Visually Impaired.........10
 

Testing for Discrimination Against Persons with Mobility Impairments........................12
 

Adapting Testing Strategies to Different Market Segments.........................................13
 

3. PILOT DESIGN AND METHODOLOGY .............................................................................16
 

Sampling......................................................................................................................16
 

Field Implementation and Paired Testing Protocols ....................................................22
 

Using Paired Tests to Measure Discrimination............................................................28
 

4. DISCRIMINATION AGAINST HOMESEEKERS USING TTY SYSTEMS ..........................35
 

Unequal Access to Information....................................................................................35
 

Comparable Information About Available Units ...........................................................38
 

Less Information About the Application Process .........................................................39
 

Fewer Invitations for Follow-Up ...................................................................................40
 

Summary .....................................................................................................................40
 

5. DISCRIMINATION AGAINST HOMESEEKERS USING WHEELCHAIRS.........................42
 

Many Advertised Units Inaccessible ............................................................................42
 

Comparable Access to Housing Providers ..................................................................43
 

Less Information About Available Units .......................................................................45
 

Lower Fees..................................................................................................................46
 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Less Information About the Application Process .........................................................47
 

Comparable Provider-Initiated Follow-up ....................................................................48
 

Refusal of Reasonable Modification and Accommodation ..........................................48
 

Summary .....................................................................................................................51
 

6. SUMMARY AND IMPLICATIONS.......................................................................................53
 

Summary of Findings...................................................................................................53
 

Implications for Further Research ...............................................................................55
 

Implications for Policy and Practice .............................................................................57
 

ANNEXES: 

ANNEX A: Expert Panel ...................................................................................................59
 

ANNEX B: Test Authorization Form (TAF) and Advance Call Form ............................ 63 

Test Authorization Form ............................................................................................. 65 

Advance Call Form .................................................................................................... 67 

ANNEX C: TTY Testing Forms......................................................................................... 71 

TTY Test Assignment Form........................................................................................ 73 

TTY Test Instructions.................................................................................................. 75 

TTY Test Report Form................................................................................................ 81 

TTY Follow-Up Contact Form ..................................................................................... 89 

ANNEX D: Wheelchair Testing Forms ........................................................................... 91
 

Wheelchair Test Assignment Form............................................................................. 93 

 Wheelchair Test Instructions ......................................................................................97 

Wheelchair Test Report Form................................................................................... 105 

Wheelchair Tester-Initiated Follow-Up Contact Form ............................................... 117 

Wheelchair Follow-Up Contact Form ........................................................................ 119 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

1. INTRODUCTION AND SUMMARY 

Not enough is known about the prevalence of housing discrimination against persons 

with disabilities. Only slightly more than half of Americans know that it is illegal for landlords to 

refuse to make reasonable accommodation for persons with disabilities or to permit reasonable 

modification to a housing unit.1

 And although HUD data indicate that the volume of Fair 

Housing Act disability-related complaints is now comparable to complaints based on race, no 

rigorous estimates of housing discrimination against persons with disabilities are available.2 A 

few organizations have conducted tests for discrimination against persons with disabilities, but 

these testing efforts were not designed to provide statistically valid measures of the incidence 

and forms of discrimination market-wide.3 

Study Purpose and Scope 

The U.S. Department of Housing and Urban Development (HUD) contracted with the 

Urban Institute to advance the state-of-the-art in testing to measure discrimination against 

persons with disabilities, for both research and enforcement purposes. Because the population 

of persons with disabilities is diverse and the challenges for effectively measuring discrimination 

are substantial, this research effort was conducted in two phases. The first phase was 

exploratory; the Urban Institute developed and implemented a wide variety of testing 

approaches, targeted to different groups of persons with disabilities and different forms of 

housing market discrimination (other than discrimination through a failure to design and 

construct accessible housing, which is not encompassed in the scope of this study).4 This 

phase did not produce statistically representative measures of discrimination for any group, but 

1

 M. Abravanel and M. Cunningham (2002). How Much Do We Know: Public Awareness of the Nation’s Fair 

Housing Laws. Washington, D.C.: U.S. Department of Housing and Urban Development. 

2

 See National Council on Disability (November 6, 2001). Reconstructing Fair Housing. 

3

 Organizations that have conducted disability-related testing include Fair Housing Contact Service, Akron, 

Ohio; HOPE Fair Housing Center, Wheaton, Illinois; Metro Milwaukee Fair Housing Council, Milwaukee, Wisconsin; 

Housing Opportunities Made Equal, Richmond, Virginia; Austin Tenant's Council, Austin, Texas; Toledo Fair Housing 

Center, Toledo, Ohio; North Dakota Fair Housing Council, Bismarck, North Dakota; Protection and Advocacy, Inc, 

Albuquerque, New Mexico; Family Housing Advisory Services, Omaha, Nebraska; Access Living, Chicago, Illinois; 

Metro Fair Housing Services, Atlanta, Georgia; Project Sentinel, Palo Alto, California; Inland Fair Housing, Ontario, 

California; Housing Rights Center, Los Angeles, California; Fair Housing of Marin, San Rafael, California; Southern 

Arizona Fair Housing Center, Tucson, Arizona; Arkansas Fair Housing Council, Arkadelphia, Arkansas; Fair Housing 

Council of Southwest Michigan, Kalamazoo, Michigan; South Suburban Fair Housing Council, Philadelphia, 

Pennsylvania. 

4

 Exploratory testing was conducted during the spring and summer of 2003 in two metropolitan areas – 

Albuquerque, New Mexico and Chicago, Illinois. 

1 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

it did yield important lessons about what works and what does not, and how conventional testing 

methods can be adapted to effectively capture the kinds of discrimination that persons with 

disabilities experience when they search for rental housing. 

Based upon lessons from the exploratory phase, the second—pilot—phase was 

designed to produce rigorous, statistically representative estimates of the incidence of 

discrimination against selected groups of persons with disabilities in a single metropolitan rental 

market – Chicago, Illinois. Specifically, this phase focused on the treatment of deaf people who 

use the TTY system5

 to inquire about advertised rental housing, and on the treatment of 

persons in wheelchairs who visit rental properties in person to inquire about available units.6 

Summary of Findings 

Both groups of persons with I arrived at the property at 11:15. I was looking for disabilities who were studied in the the 701 buzzer to ring as I had been instructed in my 

pilot phase of this project encounter appointment call. A woman who I assume I spoke to 

significant levels of adverse yesterday to make an appointment opened the 

doorway halfway. She asked me if I was the one treatment when they search for who had an appointment. I told her yes. She very rental housing in the Chicago area, abruptly stated, "No wheelchairs here. You can't compared to comparable come in!" I attempted to ask if there was another 

nondisabled homeseekers. In fact, entrance that I could use to enter the building. She 

adverse treatment against persons muttered "you should have said something on the 

phone." She asked twice, "Can you walk?" I told with disabilities occurs even more her no. She repeated, "No wheelchairs here, no way often than adverse treatment of in!" She said, "Apartment's too small." I looked at African American or Hispanic her dumbfounded and replied, "OK!" 

renters in the Chicago-area Later that day, the nondisabled tester visited the housing market. same property. She was buzzed into the lobby of 

the building, which had an elevator, shown three People who are deaf and available apartments, and provided information use the TTY system to inquire about rents, security deposits, and fees. about advertised rental units in the 

Chicago Metropolitan Area are refused service in one out of four calls. Even when housing 

5

 Note that other people with hearing and communication disabilities may also rely on the TTY system, and 

that findings from this analysis would apply to them as well. 

6 The pilot phase testing was designed to measure the extent to which persons with disabilities experience 

adverse treatment when they search for housing in the Chicago area. The question of when differential treatment 

warrants prosecution and the related question of whether sufficient evidence is available to prevail in court can only 

be resolved on a case-by-case basis, which might also consider other indicators of treatment than those reported 

here. The tests used for this study were conducted for research purposes, not enforcement purposes. 

2 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

providers accept their calls, the TTY users receive significantly less information about the 

application process and fewer opportunities for follow-up contact than comparable hearing 

customers making telephone inquiries. 

People using wheelchairs who visit rental properties in the Chicago area7

 to inquire 

about advertised units are just as likely as nondisabled customers to meet with a housing 

provider. However, wheelchair users learn about fewer available units than nondisabled 

customers in more than one of every four visits and are denied the opportunity to inspect any 

units in three of ten visits. Wheelchair users also receive less information about the application 

process. On the other hand, they appear to be quoted lower fees than comparable nondisabled 

customers. 

In addition, persons with disabilities are frequently denied their requests for reasonable 

modification and reasonable accommodation8

 needed to make the available housing fully 

accessible to them. Almost one of every six housing providers who indicated that units were 

available refused to allow reasonable unit modifications needed by wheelchair users. And 19 

percent of those with on-site parking refused to make the reasonable accommodation of 

providing a designated accessible parking space for a wheelchair user. 

Discrimination is not the only obstacle that people with mobility impairments face in 

searching for rental housing. In the Chicago area, at least a third of advertised rental properties 

are simply not accessible for wheelchair users to even visit.9

 This study found that paired 

testing is a feasible and effective tool for detecting and measuring discrimination by rental 

housing providers against persons with disabilities. It can be used to capture both differential 

treatment discrimination and refusal to make reasonable accommodation or permit reasonable 

7

 Wheelchair tests were conducted in the City of Chicago and surrounding Cook County. 

8

 A reasonable modification, 42 U.S.C. § 3604(f)(3)(A), is a structural change made to the premises, while a 

reasonable accommodation, 42 U.S.C. § 3604(f)(3)(B), is a change, exception, or adjustment to a rule, policy, 

practice, or service. Both a reasonable modification and a reasonable accommodation may be necessary for a 

person with a disability to have an equal opportunity to use and enjoy a dwelling, including public and common use 

spaces. A request for a reasonable modification or reasonable accommodation may be made at any time during a 

tenancy. The Act makes it unlawful for a housing provider or homeowners’ association to refuse to allow a 

reasonable modification or reasonable accommodation when such a modification or accommodation may be 

necessary to afford persons with disabilities full enjoyment of the premises. To show that a requested modification 

may be necessary, there must be an identifiable relationship between the requested modification or accommodation 

and the individual’s disability. Further, the modification or accommodation must be “reasonable.” 

9 This study did not determine how many of these properties were covered by the design and construction 

requirements of the Fair Housing Act. 

3 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

modification, and the paired testing methodology can be adapted for a wide variety of disabilities 

and housing circumstances.10 

Persons with disabilities are effective testers. It is not necessary to have nondisabled 

testers pose as people with disabilities or as their proxies. Some testers with disabilities may 

require accommodation, including assistance in traveling to test sites or completing test 

reporting forms. In some cases, these accommodations can increase the costs of completing 

paired tests. 

Organization of the Report 

The remainder of this report begins by describing the project’s exploratory phase, and 

then focuses on findings from the pilot phase. 

Exploratory Phase. Chapter 2 describes the ten testing scenarios implemented in the 

exploratory phase, and briefly outlines key lessons from each, including challenges involved in 

targeting research tests to housing developed with Low-Income Housing Tax Credits and senior 

housing. 

Pilot Phase. Chapter 3 describes the two testing scenarios implemented in the pilot 

phase of this research effort, as well as methods for sampling and analysis. Chapters 4 and 5 

present findings from the project’s pilot phase, focusing first on discrimination against renters 

who are deaf attempting to use TTY services to inquire about available homes and apartments, 

and then on discrimination against renters who use wheelchairs when they visit rental properties 

in person. 

Chapter 6 provides a summary of findings from both phases of this research effort and 

their implications for both ongoing research and policy. Annex A provides a list of expert 

advisers to the Disability Discrimination Study; Annex B provides the forms used to authorize 

tests and make advance calls; and Annexes C and D provide all test reporting forms for 

telephone and in-person testing, respectively. 

10 Of course, paired testing may not be well-suited for detecting and measuring all forms of discriminatory 

treatment that may occur in a housing transaction, or all types of disabilities. 

4 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

2. LESSONS FROM THE EXPLORATORY TESTING PHASE 

Testing for discrimination against persons with disabilities is particularly challenging 

because different types of disabilities call for different testing strategies and because of the 

potential importance of capturing not only differential treatment but also denial of reasonable 

accommodation or reasonable modification. In the first phase of this study, the Urban Institute 

explored the feasibility and effectiveness of multiple testing strategies targeted to different 

categories of persons with disabilities and focusing on different aspects of housing 

discrimination. 

To help guide the development and design of these exploratory strategies, the Urban 

Institute convened a distinguished panel of expert advisors (see Annex A for a list of expert 

panel members). The panel met in Washington, D.C. for a day and a half at the outset of the 

project to discuss the challenges involved in testing for discrimination against persons with 

disabilities and to offer advice about possible testing strategies, what types of testing could be 

most effective, and how products from this study could be most useful to advocates and 

practitioners. 

This chapter summarizes the protocols that were implemented in the exploratory phase, 

and discusses lessons learned about feasibility and challenges from a research perspective. 

These protocols and their lessons for enforcement testing are discussed in greater detail in the 

forthcoming guidebook of enforcement tools. 

Testing for Discrimination Against Persons with Mental Disabilities 

During the first phase of this project, we implemented three testing scenarios for 

measuring discrimination against persons with mental disabilities. Two of these scenarios 

involved testers with mental illness or cognitive disabilities, while one relied upon nondisabled 

testers calling on behalf of homeseekers with disabilities.11 Some members of the expert 

advisory panel argued strongly against using nondisabled persons as proxies for persons with 

disabilities in any testing, on the principle that persons with disabilities are capable of 

participating effectively in research about the circumstances they face. Other members raised 

concerns, however, about the feasibility of recruiting sufficient numbers of testers with 

discernible developmental disabilities who could nonetheless pose effectively as homeseekers, 

and about the potentially damaging emotional impact that testing might have on persons with 

mental disabilities. Therefore, we used the exploratory phase of this project to experiment with 

11 A cognitive or developmental disability is indicated by below average intellectual functioning, combined 

with deficits in dealing with one or more activities of daily living. Mental illness is a psychiatric disorder that results in 

a disruption of a person's thinking, feelings, moods or ability to relate to others. 

5 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

both approaches to testing for discrimination against persons with mental illness or 

developmental or cognitive disabilities. 

Scenario: In-Person Testing with Persons with Mental Illness. The first scenario 

focused on differential treatment of individuals with mental illness seeking rental housing in the 

private market. One of the central challenges for this testing was how a tester would disclose 

the fact of his or her mental illness relatively early but in a credible way. The expert advisors 

generally agreed that most persons with mental illness would not disclose the fact, but that a 

scenario involving no recent rental history would provide a credible reason to do so. Therefore, 

in each of these tests, the tester with a disability visited a rental office in person, indicating that 

he or she had a mental illness, had just been released from a treatment facility, and therefore 

had no rental history or current landlord references. The nondisabled partner also indicated a 

lack of rental history for some credible reason, such as having just graduated from college or 

having been living abroad. 

Four tests of this type were completed. Our experience with these tests indicates that it 

is indeed feasible to conduct in-person testing for discrimination against mentally ill 

homeseekers, and that persons with 

mental illness can serve effectively as When a tester with a mental illness told the housing 

provider that he did not have a rental history, he was testers. However, it is challenging to told that he would be required to get a letter from the recruit mentally ill testers who can group home where he currently resides stating that handle the assignment, and some they would be responsible for paying the rent if the mentally ill testers may need extra tester failed to do so. The nondisabled tester, who 

support and assistance, including also presented himself as not having a rental history, 

assistance during the test. Specifically, was not told about such a requirement. (Test #0515) 

in some of the exploratory tests, the 

mentally ill tester was accompanied by an individual who posed as a friend and helped the 

tester remember basic information about his housing needs and questions to ask the rental 

agent. This approach proved to be credible and effective, but it significantly raises the cost of 

testing, and might not always be feasible for testing conducted for enforcement purposes.12 

Moreover, our experience indicates that testers with mental illness may be more effective 

testers if they conduct tests relatively infrequently, allowing them to recover from the stress 

associated with each test visit.13 Therefore, in order to conduct a large number of tests for 

12 This study shows that persons with disabilities are effective testers for testing that is designed for research 

(or measurement) purposes. When testing is intended for enforcement purposes, careful consideration should be 

given to whether a disabled or nondisabled tester will be able to reliably and credibly recall the test, sometimes years 

later, in an enforcement proceeding; withstand the scrutiny of litigation, including cross-examination in depositions 

and at trial; and whether the experience might undermine the tester's emotional and physical health. 

13 Not all persons with mental illness will necessarily experience difficulty or stress serving as testers. 

6 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

research purposes, it would probably be necessary to extend the testing over a relatively long 

period, unless a very large pool of testers could be recruited. 

Scenario: In-Person Testing with Persons with Developmental or Cognitive 

Disabilities. The next scenario was similar to the first, but focused on differential treatment of 

individuals with developmental or cognitive disabilities. Again, the tester with a disability visited 

a rental office in person, indicating that he or she had been living in a group home and was 

looking to live on his or her own for the first time.14 The nondisabled tester would also indicate 

that he or she was looking for an apartment for the first time. Because of concerns about the 

ability of persons with developmental disabilities to complete test reporting forms, both testers 

were accompanied by a nondisabled person posing as a friend. This person did not ask or 

answer any questions of the rental agent, but was available to help the tester remember key 

questions to ask of the agent. 

Five tests of this type were conducted in the exploratory phase. Like the tests involving 

persons with mental illness, these tests confirm the feasibility of using the paired testing 

methodology to detect discrimination against homeseekers with cognitive disabilities, and the 

capability of disabled persons to act as 

Although both testers had appointments to meet with testers on their own behalf. As 

the housing provider, the nondisabled tester was anticipated, we found that testers with assisted immediately upon arrival to the office; the cognitive disabilities needed some disabled tester waited 40 minutes before someone 

assistance during the test in order to assisted her. (Test #0816) 

remember what they needed to ask of 

the rental agent. This approach proved to be credible to housing providers, and enabled 

persons with cognitive disabilities to be effective testers, but, as discussed earlier, it 

substantially raises the cost of testing, and might not always be feasible for testing for 

enforcement purposes.15 In order to conduct enough tests of this type to yield rigorous 

statistical estimates, it would probably be necessary to extend the testing over a fairly long 

period, in order to give testers with disabilities ample time and flexibility. 

14 In these tests, the individuals selected as testers were identifiable (based on appearance and speech) as 

cognitively disabled. 

15 This study shows that persons with disabilities are effective testers for testing that is designed for research 

(or measurement) purposes. When testing is intended for enforcement purposes, careful consideration should be 

given to whether a disabled or nondisabled tester will be able to reliably and credibly recall the test, sometimes years 

later, in an enforcement proceeding; withstand the scrutiny of litigation, including cross-examination in depositions 

and at trial; and whether the experience might undermine the tester's emotional and physical health. 

7 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Scenario: Telephone Testing Using Proxies for Persons with Developmental or 

Cognitive Disabilities. The third scenario for measuring discrimination against persons with 

mental disabilities also focused on differential treatment of homeseekers with developmental or 

cognitive disabilities. However, these tests were conducted by telephone instead of in person, 

and involved the use of nondisabled proxies representing disabled homeseekers. Specifically, a 

nondisabled person posing as the case-worker for a developmentally or cognitively disabled 

person would telephone a rental housing provider to inquire about housing availability for his or 

her client. In these tests, the nondisabled homeseeker was also represented by a family 

member calling on his or her behalf. For example, the caller might say “my brother will be 

moving here in a month, and I’m checking out possible apartments for him.” 

Five tests of this type were completed during the exploratory phase. These tests proved 

to be quite simple and inexpensive to In 2 out of 5 tests, the proxy for the disabled person conduct, and were credible to was told about fewer units then the proxy for the housing providers. This approach nondisabled person. In an additional test, the proxy represents a feasible strategy for for the disabled person was quoted a higher rent than 

addressing some of the challenges the proxy for the nondisabled person. (Test #s 0616, 

of working with testers who have 0722, 0706)

mental disabilities. However, it loses 

some of the narrative power of conventional paired testing, and because it does not rely upon 

persons with disabilities to act as testers on their own behalf, it may be objectionable to some 

advocacy organizations.16 

Testing for Discrimination Against Persons Who are Deaf or Hard of Hearing 

The exploratory phase of this project implemented two testing scenarios that focused on 

discrimination against homeseekers who were deaf or hard of hearing. 

Scenario: Telephone Testing with Persons Using TTY Services. The first scenario 

focused on differential treatment against persons who rely on TTY telephone services. 

Specifically, the deaf tester used a TTY telephone with a relay operator to call a rental agent to 

inquire about available units. The nondisabled tester made a comparable inquiry by telephone. 

Seven tests of this type were completed in the exploratory phase, indicating that this 

approach is feasible and credible. Tests can be completed quite quickly and cost-effectively, 

and can span a very wide geographic area because they do not require testers to travel around 

the metropolitan area to meet with housing providers in person. Moreover, TTY systems 

16 See the forthcoming Guidance for Practitioners on Testing for Disability Discrimination in Housing for a 

further discussion of the challenges involved in working with persons with developmental disabilities as testers. 

8 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

provide the deaf testers with a verbatim report on each telephone call, providing an independent 

narrative of what occurred. Finally, the exploratory testing indicated that some rental agents 

were uncomfortable with the TTY calling process or even unwilling to accept these calls, 

suggesting that this approach to testing may disclose very substantial barriers to housing search 

for individuals who are deaf or hard of hearing.17 

When a deaf tester called the housing provider using the TTY service, the call was answered by 

an answering machine. The relay operator left a message for the tester saying that he was 

interested in a two-bedroom apartment and asking the housing provider to call the tester back. 

The tester then asked the relay operator to call a second number that was listed in the 

advertisement. This time, the call was answered by a man. The tester typed, "good morning, my 

name is ________ and I am interested in the two-bedroom apartment. Is it available?" As he was 

typing this message, the relay operator was explaining to the housing provider that the call was 

being placed by a deaf person using a relay service. The housing provider then hung up. 

Because the relay operator wasn't sure if the housing provider had truly hung up or if the service 

had been disconnected, the tester asked her to call again and to explain that he is deaf and that 

he is calling about the apartment for rent. As the relay operator was typing this message to the 

housing provider, the housing provider said, "Hey, stop calling me, son of a bitch, will you?" and 

hung up again. (Test #1004) 

Scenario: In-Person Testing with Deaf Persons. The next testing scenario was 

designed to capture both differential treatment against homeseekers who were deaf or hard of 

hearing and refusal to make reasonable accommodation. A deaf tester who also had difficulty 

speaking understandably would visit a rental office in person to inquire about available housing. 

He or she used notes to communicate with the landlord or rental agent. Following the standard 

rental housing inquiries, the deaf tester asked whether the landlord would install flashing lights 

for the doorbell and alarm bells. If the landlord indicated that this accommodation would not be 

provided, the tester asked if he or she could pay for the installation of the flashing lights.18 The 

nondisabled tester also visited in person, simply making the standard rental housing inquiries. 

Six tests of this protocol were completed. We found this approach to be feasible and 

credible, providing an effective strategy for capturing both differential treatment of disabled 

17 It is important to note that, while some housing providers were unwilling to accept TTY calls, many others 

providers did provide full service to TTY users, indicating that the system is not excessively time consuming or 

burdensome. 

18 Courts have not definitively established whether the installation of flashing lights for doorbells and alarms 

should be classified as an accommodation (which the housing provider is required to provide) or a modification 

(which the housing provider must allow the tenant to provide). Therefore, on the advice of the expert advisors, our 

protocols call for the tester to ask first for the landlord to provide this service and then (if refused) to request 

permission to pay for it himself. 

9 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

homeseekers and refusal to make a reasonable accommodation. However, deaf testers had 

difficulty gaining access to buildings with intercom systems. In addition, the note-writing 

process proved to be time consuming The nondisabled tester was told that there were 10 

and awkward, both for housing providers two-bedroom and 15 one-bedroom units available. 

and testers. Some testers had difficulty She was taken to see three different models—a twowriting legible and understandable notes. bedroom, a one-bedroom, and a studio apartment. 

Even though she asked, the disabled tester was not An alternative approach that was not told specifically how many units were available and implemented in the exploratory phase, was shown only one of the model units. When she would be to send testers who are deaf or asked if there was anything else available, she was 

hard of hearing to meet with housing told that this was the only model they had to show 

providers accompanied by a sign her. (Test #1005) 

language interpreter. Although this would raise the cost of testing, it would eliminate differences 

in treatment that might be attributable to poor penmanship or the time-consuming nature of the 

note-writing process.19 Adding a sign language interpreter might add some additional 

complexities to a test, however, that need further exploration. 

Testing for Discrimination Against Persons Who are Blind or Visually Impaired 

Two in-person testing scenarios were implemented in the exploratory phase to capture 

discrimination against homeseekers who are blind or visually impaired. 

Scenario: In-Person Testing with Blind Persons Using Guide Dogs. The first 

scenario focused on differential treatment and refusal to make reasonable accommodation for 

persons using assistance animals. A tester who was blind and accompanied by a guide dog 

visited a rental office in person to inquire about available housing. If a unit was available, the 

tester requested an accommodation—waiver of the “no pets” policy or of any special fees or 

restrictions on the presence of the dog. When rental agents were unsure or ambiguous about 

policies regarding service animals, testers made repeated call-backs until they received a 

definitive answer regarding this accommodation. The nondisabled tester also visited in person, 

making the standard rental housing inquiries, without any mention of a pet. 

Eight tests were conducted using this protocol. This experience indicated that the 

approach is clearly feasible, and that it can effectively capture both differential treatment on the 

basis of disability and refusal to make a reasonable accommodation. However, this approach 

definitely requires follow-up inquiries to obtain a definitive answer about limitations or fees 

associated with the companion animal. Testers quite frequently received an uncertain or 

ambiguous response during their initial visits, and had to make repeated calls to get a final 

19 One advantage of the note-writing approach, however, is that it may generate a written record of 

discriminatory comments. 

10 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

answer. In addition, testers sometimes The blind tester was clearly recognizable as a blind had difficulty finding the front door, person—using both a cane and a guide dog. When 

using intercom or buzzer systems, and he arrived for an appointment with a housing 

gaining access to rental properties or provider, he was assisted by a stranger on the street 

management offices; as a to access the building, but was stood up by the 

housing provider. He returned to the office of the consequence they sometimes had to local testing organization and called the housing seek assistance from bystanders. provider to find out what happened. The housing 

Therefore, it might make sense to send provider told the tester that he had also been at the 

testers to their assignments with appointment site at the right time, but that because 

he saw that one of the men had a dog and dogs are someone who would provide not allowed, he did not answer the door. (Test transportation and will help them gain #0128) entrance, but who would not 

accompany them during the test. 

Scenario: In-Person Testing with Blind Persons but No Guide Dogs. The second 

scenario in this category also focused on both differential treatment and refusal to make 

reasonable accommodations, but eliminated the companion animal as a factor. Specifically, a 

tester who was blind or visually impaired visited a rental office in person to inquire about the 

availability of housing. At the end of the visit, he or she asked the agent to read the application 

form aloud so that he or she would know what information and documentation would be needed 

in order to complete an application. This approach was designed to test the willingness of rental 

agents to provide a reasonable accommodation immediately, as opposed to agreeing to provide 

one later.20 The nondisabled tester also visited in person, making the standard rental housing 

inquiries. 

Seven tests of this type were completed during the exploratory phase, proving it to be 

feasible and effective. As discussed above, testers who were blind sometimes had difficulty 

gaining access to rental offices. In A disabled tester who asked for the reasonable 

addition, some housing providers accommodation of having the housing provider read 

summarized or paraphrased the the application form was told, "no, you go home and 

application form rather than reading it fill out the application and call back." (Test #0525) 

verbatim, raising some question about 

what constitutes a reasonable accommodation in this regard. 

20 If written application forms were not used by a sampled housing provider, testers simply asked for a list of 

what information and documentation they would need to provide, and no data on reasonable accommodation were 

recorded. 

11 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Testing for Discrimination Against Persons with Mobility Impairments 

Testing for discrimination against persons with mobility impairments is more complex 

and challenging than one might at first think, because the accessibility of rental properties varies 

(depending in part upon structure type and when they were built), and because the kinds of 

modifications a disabled homeseeker might reasonably request depends upon the 

characteristics of the property and the unit. We implemented two exploratory testing scenarios 

designed to capture different forms of discrimination against persons with mobility impairments 

who are seeking housing in the rental market. 

Scenario: In-Person Testing with Persons Using Wheelchairs. The first scenario 

involved in-person testing by individuals using wheelchairs, in order to capture both differential 

treatment and refusal to permit reasonable unit modifications. These tests targeted rental 

housing available in the conventional, private market, some of which is accessible or could 

reasonably be made accessible, and some of which cannot reasonably be made accessible. 

HUD established at the outset that this project is not intended to test for compliance with 

accessible design and construction When a disabled tester asked if he could install a 

standards. Instead, its focus is on ramp into the unit, he was told by the housing 

discrimination against individual provider that if he were a current tenant and he had 

an accident that subsequently required a ramp, disabled homeseekers inquiring then they would be required to put one in, but about the availability of rental units otherwise he could not install a ramp. The tester and the reasonable accommodations was then told that he would have to be put on a

or modifications they need. waiting list for a more accessible unit. (Test #0931) 

Therefore, this testing scenario 

required the local testing coordinator to make a preliminary reconnaissance of each sampled 

property to determine whether the building was visitable or could reasonably be made 

accessible.21 If it was not, no test was conducted. For properties that appeared at this 

reconnaissance stage to be accessible, the nondisabled tester would visit first, making the 

standard rental housing inquiries, but also recording information about any modifications that 

might be needed to make the building or unit fully accessible. Based upon this information, the 

test coordinator determined what modification the tester with a disability should request in his or 

her visit. 

Seven tests of this type were conducted in the exploratory phase, establishing that it is 

feasible to test for both differential treatment and unwillingness to allow reasonable 

21 This reconnaissance focused on the visitability of the rental office and dwelling units, and used criteria 

consistent with the design and construction requirements of the Fair Housing Act in making the determination of 

whether the building was accessible. However, this study did not make any formal determination as to whether or not 

the building was covered under the design and construction requirements of the Fair Housing Act. 

12 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

modifications. However, nondisabled testers were not always able to accurately or consistently 

identify modification needs in their test visits. In some cases, this was because they were not 

shown the same unit as their nondisabled partners. Therefore, it may make more sense to 

develop a list of reasonable modifications in advance of the testing process, and train testers 

with disabilities to request the first relevant modification on the list, based on their assessment 

of the property and the unit. In addition, testers using wheelchairs sometimes had difficulty 

traveling around the metropolitan area to widely dispersed test locations. 

Scenario: Non-Paired Telephone Testing to Request a Reasonable 

Accommodation. The second testing scenario in this category focused on the willingness of 

rental housing providers to make reasonable parking accommodations for persons with mobility 

impairments. This scenario was non-paired, and therefore did not capture differential treatment. 

Instead, a disabled person telephoned a rental office to inquire about available units and 

indicated that, due to a mobility impairment, he or she would need a designated accessible 

parking space near the rental unit. Depending upon the outcome of this initial call, the tester 

would follow up with up to two additional phone calls as needed, trying to obtain a commitment 

on this accommodation. More specifically, testers made the additional phone contacts until they 

received an unambiguously positive or negative response to a three-part request: 1) can I have 

a parking space? 2) is the parking space reasonably close to my unit? and 3) will the parking 

space be designated for my exclusive 

When the tester with a physical disability called the use? 

housing provider to ask about a parking 

Seven tests of this type were accommodation, the housing provider said she had 

to check with the manager. However, she did say completed, establishing it as a very that "handicapped parking spaces were not inexpensive approach for assessing specifically designated to individual tenants and the willingness of housing providers to were available on a first-come first-served basis." 

make reasonable accommodations for She also told the tester that he could rent a covered 

persons with mobility impairments. In parking space for $15 per month in order to 

some cases, however, there was guarantee a designated parking space near the 

apartment. (Test #0518) ambiguity about whether the parking 

space would be officially designated as an “accessible” space, or whether it would simply be 

designated for the exclusive use of the resident. Moreover, because this approach is unpaired, 

it provides no information about differential treatment of persons with disabilities. However, in 

research tests, requests of this type regarding parking accommodation can be combined with 

the in-person, paired test scenario described above. 

Adapting Testing Strategies to Different Market Segments 

In previous research projects that have tested for discrimination in the private housing 

market, the Urban Institute has used a carefully designed sampling methodology to draw a 

13 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

representative sample of housing units or providers. Our standard methodology has been to 

define the universe from which the sample would be drawn, including or excluding particular 

categories of housing, to construct a listing of all units or providers in this universe, and then to 

draw a random sample so that every unit in the defined universe had a known chance of 

appearing in the sample. 

For most of the testing conducted during the exploratory phase of this project, the 

universe for testing was defined as housing units advertised as available for rent, excluding 

luxury rentals, publicly subsidized properties, and units restricted to elderly tenants.22 It included 

all other rental units (within specified geographic areas) advertised in one or more publicly 

available source. With these boundaries on the universe, representative samples were drawn 

from the classified advertisements of major metropolitan newspapers, community newspapers, 

and apartment and real estate guides. 

In addition, we experimented with adaptations to this sampling methodology to include 

two additional segments of the rental housing market—senior housing and properties 

subsidized under the Low-Income Housing Tax Credit (LIHTC) program. Specifically, we 

targeted wheelchair tests to senior rental housing developments, and a small number of the 

wheelchair, deaf, and blind protocols to LIHTC properties. Testing in both of these market 

segments proved feasible, but raised significant sampling issues from the perspective of largescale research testing. 

Scenario: In-Person Testing in Senior Housing. Elderly people make up roughly half 

of the mobility-impaired, blind/low vision, and deaf/hard-of-hearing populations. Targeting 

testing to elderly-only rental developments would make it possible to determine whether elderly 

disabled renters face discrimination when they apply to live in these developments, compared to 

the nondisabled elderly. Therefore, one exploratory testing strategy focused exclusively on 

elderly-only rental housing developments, and tested for differential treatment against 

homeseekers using wheelchairs. We anticipated that all elderly housing developments would 

be structurally accessible to persons with mobility impairments. An elderly tester using a 

wheelchair visited sampled developments in person to inquire about available housing. A 

nondisabled tester in the same age range also visited in person, making the same standard 

rental housing inquiries. 

22 Luxury units are typically excluded from paired testing studies both because they are atypical of the 

conventional housing market and because it may be difficult for testers to pose as sufficiently affluent to be credible, 

raising the risks of disclosure. Subsidized properties are generally excluded because they are likely to have waiting 

lists, complex application procedures, and specialized eligibility requirements. Properties restricted to elderly tenants 

are generally excluded because definitions of elderly may vary and because these properties may impose additional 

screening criteria, such as health assessments. 

14 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Two tests of this type were conducted in the exploratory phase. This approach is clearly 

feasible, but creating a sufficiently large sample of elderly-only rental housing developments 

proved to be a challenge from a research testing perspective. A sample of potential 

developments was drawn from an expansive Internet search of elderly housing sites, including: 

marketfinder.com, forrent.com, homestore.com, seniorresidences.com, and 

retirementhomes.com.23 Many rental developments targeted to seniors offer “assisted living” or 

“continuing care” services in conjunction with housing, and therefore require information about 

an applicant’s health care needs as well as housing needs. Testing for discrimination in these 

circumstances would require new approaches and protocols. However, it appears that a larger 

number of developments may offer housing for elderly homeowners, and may represent a 

feasible target for future testing for discrimination on the basis of disabilities. 

Scenario: Testing in Low-Income Housing Tax Credit Developments. Because a 

substantial proportion of persons with disabilities have low- to moderate-incomes, there is 

strong interest in testing rental properties that receive housing subsidies. Therefore, the 

exploratory phase of this project targeted a small number of tests to housing developed under 

the federal Low-Income Housing Tax Credit (LIHTC) program. Specifically, two tests for 

discrimination against blind persons (with guide dogs), two TTY tests, two in-person tests for 

discrimination against deaf persons, and four wheelchair tests were completed for LIHTC 

developments. Samples of potential developments were drawn from HUD’s LIHTC database 

and from listings provided by the New Mexico Mortgage Finance Authority and the Illinois 

Housing Development Authority. Testing protocols were modified slightly so that testers were 

not asking for units that were immediately available, but were inquiring about the length of the 

waiting list and what types of units might be available now or within the next three to six months. 

This experience indicates that, although testing LIHTC properties may well be feasible 

for enforcement or investigatory purposes, assembling a sufficiently large, reliable, and 

comprehensive sample of LIHTC properties to support rigorous research testing represents a 

significant challenge. Existing lists of LIHTC properties include many non-working telephone 

numbers. Advance calls to these properties sometimes indicated that managers did not know 

(or could not explain) what kind of subsidized housing they had or what eligibility requirements 

would apply. In addition, some properties do not accept in-person applications or inquiries and 

will not discuss availability until the application process has been completed and eligibility has 

been determined. 

23 Note that we did not include subsidized housing for seniors, which might have increased the pool of 

potential properties, but would have raised other issues regarding waiting lists and eligibility criteria. 

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Discrimination Against Persons With Disabilities: 

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3. PILOT DESIGN AND METHODOLOGY 

Although the paired testing methodology originated as a tool for fair housing 

enforcement, it has been adapted successfully for research purposes. In order to yield reliable 

measures of differential treatment in housing market transactions, paired testing must be 

applied to a representative sample of housing providers or available housing units in selected 

markets, and must adhere to highly standardized protocols. This Disability Discrimination Study 

(DDS) builds upon the experience from the Housing Discrimination Study 2000 (HDS2000) to 

enhance and extend the paired testing methodology, producing metropolitan-level estimates of 

discrimination against persons with disabilities for the Chicago region. This chapter describes 

the sampling procedures, testing protocols, and analysis techniques implemented in the second 

(pilot) phase of DDS. 

Sufficient resources were available for this project to conduct large-scale testing for two 

of the scenarios from the exploratory phase. Based on findings from the exploratory testing, 

HUD staff determined that Stage 1 of the pilot phase should focus on persons who were deaf 

and used TTY systems to inquire about available rental housing throughout the Chicago 

metropolitan area. This approach was selected because of its low cost and evidence from the 

exploratory phase suggesting a very high level of differential treatment. HUD determined that 

Stage 2 of the pilot phase would focus on persons who had physical disabilities and used 

wheelchairs to visit advertised rental properties in the City of Chicago and surrounding Cook 

County. This approach was selected because housing providers could readily recognize that a 

tester had a disability, and because it was possible to establish clear protocols for requesting 

both reasonable modification and reasonable accommodation. Staff of Access Living of 

Metropolitan Chicago worked in partnership with the Urban Institute to design, plan, and 

conduct both phases of pilot testing. Approximately 100 paired tests were conducted for each 

disability type. 

Sampling 

Because the study goal was to observe and measure rental agent behavior, we needed 

a representative sample of rental agents, where an agent’s probability of selection reflects his or 

her share of available housing units. In addition, our sampling methodology needed to provide 

information about the housing being offered by each agent so that both members of a testing 

team could be assigned characteristics (such as household size and income) and preferences 

16 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

(such as housing type and location) that corresponded to housing that an agent actually had to 

offer.24 

The DDS paired testing methodology builds upon the testing methodology developed 

and implemented in the HDS2000. National paired testing studies conducted prior to HDS2000 

have all relied upon classified advertisements in major metropolitan newspapers to generate 

samples of rental and sales agents. The Housing Market Practices Study (HMPS, conducted in 

the late 1970s) drew a single sample of advertisements from the Sunday classified section of 

each metropolitan area’s primary newspaper. Tester teams were assigned characteristics and 

preferences consistent with the sampled housing units and visited the corresponding agents, 

inquiring generally about available housing. In the 1989 Housing Discrimination Study (HDS), 

this methodology was refined to involve weekly samples of available housing units, again drawn 

from the classified advertising sections of each metropolitan area’s major newspaper. This 

refinement allowed testers to begin each visit by inquiring about a particular housing unit, 

making the tests more credible and allowing both white and minority testers to send agents the 

same implicit signals about housing preferences. Phase I of HDS2000 replicated this approach, 

drawing weekly samples of advertisements from the Sunday classified section of each 

metropolitan area’s major newspaper.25 

However, relying solely upon metropolitan newspapers to represent the housing market 

as a whole has significant limitations and drawbacks. Therefore, Phase II of HDS2000 

developed procedures for drawing on multiple advertising sources in order to reflect more fully 

the universe of housing units available for rent in the sampled metropolitan areas. These 

procedures were applied again in Phase III. Since the primary goal of DDS was to measure the 

incidence of differential treatment in the Chicago Metropolitan rental market, DDS followed the 

same sampling procedures for rental tests as Phases II and III of HDS2000. 

In general, the weekly ad-sampling methodology offers several important benefits. It 

yields a representative sample of housing agents who use publicly available sources to 

advertise available units, where an agent’s probability of selection is proportionate to his or her 

share of all units advertised in this way. Because the advertising sources are readily available 

to those seeking rental housing, this sampling frame includes agents who can realistically be 

accessed by any homeseeker. In addition, the weekly sampling methodology provides a 

consistent and credible starting point for each test, tying the characteristics and preferences of 

testers to housing actually available from the sampled agent and sending consistent signals 

24 For a more detailed discussion of sampling principles, see chapter 2 of Research Design and Analysis 

Plan for Housing Discrimination Study 2000, The Urban Institute, March 2000. 

25 In addition, Phase I of HDS2000 experimented with alternative methods for identifying and sampling 

available units. 

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Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

from both members of a tester team. Finally, this methodology addresses one of the major 

ethical concerns about paired testing—that it imposes an unreasonable cost burden on housing 

agents, who have to spend time responding to testers’ inquiries, and potentially violates their 

expectations of privacy regarding these inquiries. By advertising in a widely available outlet, a 

housing agent is explicitly inviting inquiries from the general public. 

Four basic steps were required to produce the DDS ad samples: 

• Selecting a set of advertising sources that provided reasonably complete coverage 

for the metropolitan housing market; 

• Developing a schedule for rotating among sources on a weekly basis; 

• Establishing an efficient sampling protocol for each advertising source; and 

• Drawing weekly ad samples. 

Although the sampling process was basically the same for both test types, we had to make two 

changes for the wheelchair testing. First, due to the lack of public transportation for wheelchair 

users in the outer portions of the Chicago Metropolitan Area and the prohibitive costs 

associated with providing private transportation, the sample of advertisements used for 

wheelchair testing was limited to properties in the City of Chicago and Cook County. Second, 

the Chicago area rental housing stock, especially in the city itself, includes many older, walk-up 

apartment buildings. Some advertising sources included a large number of these older units, 

which were inaccessible to testers who use wheelchairs even to visit and, therefore, ineligible 

for our testing. Consequently, to ensure that each week’s sample included a sufficient number 

of eligible units, we adjusted the rotation schedule to include sources that featured newer rental 

properties in every week. 

Selecting advertising sources. We assembled an inventory of potential advertising 

sources for the Chicago Metropolitan Area. Drawing from media directories, the Internet, and 

local informants, we prepared a list of newspapers, Internet sites, and guides that area housing 

agents use to advertise rental units. Excluded from this inventory were foreign language 

sources, sources with very small circulation or ad volume, sources produced by a single rental 

company, sources requiring the user to specify housing preferences in order to obtain listings, 

and sources not readily available to the general public. Based upon this inventory, we selected 

a set of sources that provided reasonably complete coverage of rental advertisements for the 

metropolitan housing market as a whole. Two major metropolitan dailies were included among 

the selected sources. City and suburban community papers that provided a reasonable volume 

of advertisements for specific geographic sub-areas were included. No Internet sources were 

included because local informants indicated that they were not widely utilized and did not offer a 

significantly different (or larger) selection of advertisements than published sources. Finally, we 

18 
Major Metropolitan 

Discrimination Against Persons With Disabilities: 

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included free apartment guides that were available locally. Table 3-1 identifies the actual 

sources selected for the Chicago Metropolitan Area.26 

Table 3-1: Sources of Rental Housing Advertisements 

Newspapers 

Community Papers Rental Guides 

Chicago Tribune 

Chicago Sun Times 

Pioneer Press 

Chicago Reader 

Daily Southtown 

Daily Herald 

Apartment Guide 

Apartments for Rent 

Developing a rotational schedule. Once a reasonable set of advertising sources was 

selected for the Chicago Metropolitan Area, we developed a schedule for rotating among 

sources on a weekly basis. Our goals in developing this schedule were to minimize the overlap 

between sources that might be used in the same week, to sample on the most appropriate day 

of the week for each source, and to ensure an adequate number of advertisements from which 

to sample each week. The goal for the sampling schedule was to rotate the schedule equally 

among different source types and geographic areas. For example, a source that covered all or 

most of a metropolitan area (such as a major metropolitan newspaper) would be the only source 

utilized in a given week. However, several sources that targeted different geographic sub-areas 

might be combined in the same week. Finally, sources that were published monthly rather than 

daily or weekly, would generally be utilized during the weeks when they are first released.27 

During the wheelchair tests, the sampling schedule had to be adjusted because of a large 

portion of ineligible units. Since advertising sources often contain similar types of units (for 

example, small owner, older walk-up buildings, larger complexes), when we used the sources 

as they appeared in the original rotation, we ended up not having a large enough sample for 

26 Although the TTY tests included sites in the entire metropolitan area, and the wheelchair tests only 

included sites in Cook County, Illinois, we used the same sources for both types of test. We eliminated the sites that 

fell out of the Cook County Area during the sampling process for the wheelchair tests. 

27 During the TTY tests, we had to adjust this schedule slightly in order to get a large enough sample from 

our sources. 

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Discrimination Against Persons With Disabilities: 

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testing.28 We therefore adjusted the rotation, often adding a major metropolitan paper as a 

secondary source.29 Table 3-2 provides an illustrative example of a typical rotational schedule. 

Table 3-2: Rotating Across Sampling Sources 

WEEK TTY TESTS WHEELCHAIR TESTS 

1 Chicago Tribune Chicago Tribune 

2 Community newspaper and 

monthly apartment-seekers 

guide 

Community newspaper and 

monthly apartment-seekers 

guide 

3 Chicago Reader Chicago Reader, 

supplemented with Chicago 

Tribune 

4 Community newspaper and 

monthly apartment-seekers 

guide 

Community Newspaper, 

supplemented with Chicago 

Tribune 

5 Community newspaper and 

Chicago Sun Times 

Community newspaper and 

Chicago Sun Times 

Establishing sampling protocols. For each advertising source, we implemented a 

systematic sampling protocol, where we used randomly generated numbers to sample every 

“nth” ad in order to yield the target sample size. Not all advertised housing units were eligible for 

inclusion in our sample. Some types of ads were not suitable for our paired testing protocols. 

For example, subsidized rental housing units had to be excluded, because they impose income 

and other eligibility criteria for tenants. Additionally, during the wheelchair testing stage, we 

found that many advertised units were ineligible because the tester who used a wheelchair 

could not get into the building. DDS sampling protocols made a number of changes to the 

eligibility criteria used in Phase III of HDS2000. A list of ineligible housing types is provided on 

the Advance Call Form in Annex B: 

 Rental units in small (fewer than four units), owner-occupied buildings and singlefamily homes were excluded because they potentially would not be covered under 

the Fair Housing Act; 

28 See Chapter 5 for a description of the limited availability of accessible rental housing units. 

29 The secondary source was used when the original sample did not have enough eligible ads to complete 

the designated number of weekly tests. 

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Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

• Housing providers who had already been contacted, either through an advance call 

or actual testing, were excluded for detection reasons; and 

• Units located in buildings with a rental office that was not accessible to persons using 

a wheelchair were excluded. 

Drawing weekly samples. During both stages of testing, we drew ad samples on a 

weekly basis, applying the rotational schedule and sampling protocols outlined above. The 

weekly samples were two to three times larger than the target number of tests to be conducted 

in a given week, in part because some advertisements that appeared to be eligible for inclusion 

in the sample turned out to be ineligible when further information is gathered on site, and in part 

because some advertised housing units were no longer available by the time testers called to 

schedule a visit. To the greatest extent possible, we combined ad sources, so that the ad 

volume was roughly equal from week to week, making the sampling rates from each source 

approximately the same. 

Although specific sampling protocols varied by source of advertisements, the basic 

process consisted of the following six steps: 

• Prepare the sampling frame, removing pages that do not include any eligible ads; 

• Apply the sampling protocol developed for the site and ad source to randomly select 

the target number of advertisements; 

• Verify the eligibility of each advertisement as it is selected for inclusion in the sample; 

• Record all the information from the advertisement for transmission to the local testing 

organization; 

• Randomize the sequence of advertisements in the sample, so that the order in which 

ads are used to initiate tests does not correspond to the order in which they appear 

in the ad source or the order in which they were drawn into the sample; and 

• Transmit the sample to the local testing organization. 30 

The testing organization received one rental sample each week, though not always on the same 

day each week. If a sample proved to be insufficient for a particular site in a given week (i.e., 

included many ineligibles), additional sample units were drawn from the same advertising 

source and sent to the testing organization. 

30 As discussed further below, Phase II of HDS2000 developed a web-based data entry system for 

transmitting and managing data. Therefore, ad sampling information was entered into this system by Urban Institute 

staff and immediately became available to local testing coordinators on a secure web site. See the Test 

Authorization Form in Annex B. 

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Discrimination Against Persons With Disabilities: 

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Field Implementation and Paired Testing Protocols 

DDS implementation was managed by Urban Institute staff who subcontracted with 

Access Living, a local fair housing testing agency, whose staff were responsible for the day-today testing activities, directing testers and ensuring that tests were completed according to 

established procedures and protocols. A web-based data entry and data sharing system—the 

Central On-Line Database (CODE)—was used to transmit ad samples, assign tester 

characteristics, and record test results. This section describes the field guidelines and 

procedures implemented in DDS. Because the TTY tests were conducted over the telephone 

and the wheelchair tests were in-person, there were several differences in the protocols for the 

two test types. The following sections describe the testing protocols, and the differences in the 

protocols for the two test types. Figure 3-1 provides a graphic overview of the field 

implementation procedures for DDS. 

Preparing to Test. For each advertised housing unit selected for testing, Urban 

Institute staff prepared a Test Authorization Form (TAF), which was transmitted to the local 

testing organization via the CODE system. A unique control number identified each test, and 

the TAF specified the parameters of the test structure: 

• Testing Type – deaf by telephone or wheelchair in person; 

• Required Sequence – the randomly assigned order in which members of each tester 

team should make their test visits; 

• Rental Information – the type of housing (furnished or unfurnished); and 

• Ad Information – the information from the newspaper advertisement (name of paper, 

edition, location of ad), including ad copy. 

The local testing organization was required to use the TAFs received each week in the 

order of the control number. Advance calls were made on all TAFs, both to confirm the eligibility 

of the advertised units and to obtain information needed to make credible test assignments. 

Advance callers were instructed to obtain specific pieces of information about every advertised 

unit, such as the exact date of availability, rent price, number of bedrooms, and the address of 

22 
 

 

 

 

 

TESTERS CALL 

FOR 

APPOINTMENTS

PREPARE 

TESTS 

ASSIGNMENTS

 

 

Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Figure 3-1: Field Implementation Overview 

OVERVIEW OF FIELD IMPLEMENTATION PROCESS FOR DDS 

PREPARING TO TEST CONDUCTING THE TEST FOLLOWING THE TEST 

PREPARE & TRANSMIT 

TEST AUTHORIZATION 

FORMS 

SAMPLE 

HOUSING 

PROVIDERS 

CONDUCT 

ADVANCE CALLS 

& SITE 

RECONAISSANCE 

TESTERS 

CONDUCT 

TEST 

BRIEF TESTERS 

TESTERS COMPLETE 

REPORT FORMS TO 

DOCUMENT TEST 

EXPERIENCES 

DEBRIEF TESTERS 

ASSEMBLE AND 

TRANSMIT 

COMPLETED TEST 

FILE 

PARTICIPANTS IN 

FIELD 

IMPLEMENTATION 

STUDY 

URBAN 

INSTITUTE 

LOCAL TESTING 

ORGANIZATION 

PREPARE TEST 

ASSIGNMENTS 

TESTERS CALL FOR 

APPOINTMENT 

CONDUCT 

QUALITY 

REVIEW 

DATA READY 

FOR
 

CODING & ANALYSIS
 

23 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

the unit. If the advertised unit was no longer available, the advance caller inquired about other 

units that might be coming available. In order to facilitate the test visits, the advance caller also 

asked about office hours and whether or not an appointment was needed to view the housing or 

speak with a housing provider for in-person visits.31 

Wheelchair tests also required the local organization to conduct site reconnaissance in 

order to assess building accessibility. Specifically, after advance calls had been completed, 

staff drove by potential test sites to determine whether there were obvious insurmountable 

barriers to access for persons using wheelchairs. For example, properties where the building 

entrance or rental office was only accessible by stairs were deemed ineligible for testing. 

Personal, household and financial characteristics, along with a detailed set of 

instructions, were provided to each tester prior to conducting a test.32 Responsibility for 

developing tester characteristics was shared by the Urban Institute and the Access Living Test 

Coordinators. Test Coordinators developed the tester’s personal information, such as their 

current employer and current housing situation, sometimes using the tester’s real 

characteristics, if appropriate. Urban Institute staff provided extensive training to Test 

Coordinators on how to assign personal characteristics to testers (e.g., employers and 

occupations to avoid). Test Coordinators also determined other test characteristics, such as 

number of bedrooms to request, using information obtained during the advance phone call. 

Financial characteristics assigned to testers and housing requests to be made by testers were 

either assigned by the Test Coordinator or automatically assigned by the CODE system, based 

on the characteristics of the advertised housing unit to be tested: 

• minimum number of bedrooms acceptable for the household; 

• area or geographic preference; 

• reason for moving; 

• monthly and annual income; 

• length of time on the job; and 

• length of time at current residence. 

31 Advance callers were required to make at least five attempts to reach a housing provider (calling at 

different times of the day on different days) before a unit could be deemed ineligible. See Annex B for test 

authorization and advance call forms. 

32 For in-person tests, each tester was provided with only one test assignment at a time and was required to 

complete that test before receiving another test assignment. During TTY tests, testers were provided with more than 

one test assignment at a time. See Annexes C and D for all test assignment and reporting forms for the telephone 

and in-person tests, respectively. 

24 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Test Coordinators were required to meet with each tester, individually and in person, 

prior to a test being conducted. During this initial briefing, the Test Coordinator was responsible 

for reviewing the test assignment form with the tester and answering any questions about 

assigned characteristics; for providing the tester with the appropriate test forms and materials; 

and for reviewing procedures for conducting the test and completing the test report forms. In 

addition, testers were provided with a detailed set of instructions for every test assignment. 

These instructions specified the standard set of tasks testers were expected to accomplish 

during their test, including how to approach the test site, what questions to ask, and how to end 

the visit. Annexes C and D provide examples of the Test Assignment Forms, other forms, and 

detailed instructions provided to testers. 

Conducting the Test. During both stages of testing, testers were trained to inquire 

about the availability of the advertised housing unit that prompted their phone call or visit, similar 

units (same size and price) that might be available, and other units that might meet their 

housing needs. For in-person tests (involving persons using wheelchairs), testers also asked to 

inspect all available units, and the tester using a wheelchair asked for a unit modification and 

parking accommodation (if the development had on-site parking).33 If asked by the housing 

provider, testers provided information about their (assigned) household composition, financial 

characteristics, employment, and housing needs. Testers were trained not to express any 

preferences for particular amenities or geographic locations, and they did not submit formal 

applications, agree to credit checks, or make offers to rent available units. They also did not 

request application forms, leases, or other documents, but were to accept them if offered by the 

housing provider. In conjunction with these basic testing protocols, testers were also trained to 

be convincing in the role of an ordinary homeseeker, obtain as much information as possible 

from the housing provider about available housing, and take notes in order to remember key 

information about what occurred during the test and what information was provided by the 

housing provider. 

For the exploratory phase of DDS, deaf testers used a traditional TTY relay system to 

conduct their tests. During the pilot phone tests, however, testers were able to use Nextalk, a 

computer based relay operator phone system that was accessible to most testers at home and 

at the offices of the local testing organization. Both systems are routinely used by people with 

communication disabilities in order to make telephone calls. The deaf tester typed a message 

to the housing provider using a TTY (teletypewriter) or, in the case of Nextalk, a computer 

keyboard. A relay operator received the message as printed words on the TTY system. The 

operator then called the housing provider by phone, explaining the relay process, and reading 

33 The TTY test protocols did not include any request for reasonable accommodation because we concluded 

that it would not be credible to make such a request before a customer had even seen the rental property. 

25 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

the tester’s typed message (as the tester’s side of the conversation) to the housing provider. As 

the housing provider responded verbally, the operator typed the response back to the deaf 

tester. The deaf tester received the message and typed his or her response. A record of the 

conversation was generated automatically and incorporated into the test report form as a 

complete narrative of the call. The nondisabled tester made a comparable inquiry by telephone. 

For the in-person wheelchair tests, appointment calls were sometimes required before a 

tester could conduct the on-site visit. While the standard approach for most tests was for the 

tester to “drop in” rather than make an appointment, appointment calls were required when the 

sampled advertisement did not provide the location of the available housing, when the 

advertisement indicated that an appointment was required, or when the advance call indicated 

that an appointment was required. Testers were instructed to mention the advertised unit during 

this call, and were instructed to keep the call short in order not to exchange personal or financial 

information prior to the actual test. If an agent was reluctant to make an appointment with the 

tester, perhaps stating that there were regular office hours, the tester could specify with the 

agent what time he or she planned to arrive during those hours in lieu of an actual appointment. 

Reasonable Modification and Accommodation. At the end of an in-person visit, each 

tester with a disability was required to ask for a unit modification if he or she was told about an 

available housing unit.34 Specifically, we developed an ordered list of reasonable modifications 

in advance of the testing process and trained testers to request the first relevant modification on 

the list, based on an assessment of the property and the unit. All of the modifications included 

on the list were reasonable35 and testers were trained to tell housing providers that they would 

pay. These modifications included the following: 

1) Modify unit entry-way - widen the doorway, remove the threshold, install a ramp, or 

reverse swing of door; 

2) Modify the bathroom - widen doorway, remove cabinets under sink, or install grab 

bars around toilet; 

3) Modify switches - lower thermostat controls or light switches; and 

4) Modify door handles - change doorknobs to levers. 

34 In the pilot phase, the order of tester visits was randomized; in half the tests the disabled tester visited first 

while in the other half, the nondisabled tester visited first. 

35 There may be some circumstances in which widening a door involves a load bearing wall, and therefore 

may not be feasible. 

26 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

If a rental site had on-site parking, the tester with a disability also asked for an 

accommodation at the end of the visit. Specifically, testers were to ask if they could have an 

accessible parking space near the available unit or building entrance that could be designated 

for their exclusive use. The tester then recorded the comments made by the housing provider in 

response to this request. If the housing provider did not know the answer and had to ask 

someone else regarding the request for unit modification or parking accommodation, the tester 

was required to make one or more follow-up phone calls within a week in an effort to get a 

definitive answer. 

Following the Test. Following every test, each tester was required to complete a set of 

standardized reporting forms on the CODE system (provided in Annexes C and D).36 Test 

partners did not compare their experiences with one another or record any conclusions about 

differences in treatment; each simply recorded the details of the treatment he or she 

experienced as an individual homeseeker. The site visit report forms record observations made 

by the tester and information provided by the housing provider. In addition, some testers were 

required to complete a narrative of their test. The test narrative provided a detailed, 

chronological accounting of the test experience. Testers did not know prior to their conducting a 

test if a narrative would be required; this served both to ensure that testers were conducting all 

tests with equal attention to established protocols and procedures, including taking notes, and to 

ensure against fabrication of tests. For the telephone tests, deaf testers were not required to 

complete a narrative because a complete record of their conversation with the housing provider 

had already been generated through the TTY system. However, 50 percent of their nondisabled 

partners were required to complete a narrative (the selection of who had to complete a narrative 

was randomly generated through the test authorization process). Because the in-person testing 

was more complicated, all testers had to complete a test narrative. 

After completing each test, testers were instructed to contact their Test Coordinator in 

order to arrange for an in-person debriefing. At the debriefing, the Test Coordinator was 

responsible for collecting all of the completed test forms, as well as any notes or other materials 

obtained by the tester; reviewing the forms to make sure they were filled out completely; and 

discussing any concerns the tester may have had about the test or any deviations they may 

have made from the test assignment or instructions. Some visits to rental agencies resulted in 

follow-up contact, initiated either by the housing provider or the tester. Provider-initiated 

36 As in the Housing Discrimination Study, DDS used the CODE system to generate and send TAFs to the 

local testing organization. The web-based CODE system also provided an efficient way for Test Coordinators to 

develop tester assignments and for all project staff to monitor testing activities. Among the advantages of web-based 

data entry, the CODE system performed basic checks for data completeness and consistency as the data were 

entered, and made test reports immediately available for quality control review by the local testing organization and 

Urban Institute project staff. 

27 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

contacts were monitored systematically and recorded through a voicemail account set up for 

each tester. All follow-up contacts (including mail as well as telephone calls, and follow-up 

initiated by testers to obtain answers regarding reasonable modifications or parking 

accommodations) were recorded on a Follow-Up Contact Form, which documented when the 

follow-up was received, who initiated it, and the nature of the follow-up. 

Using Paired Tests to Measure Discrimination 

Data from a sample of standardized and consistent paired tests can be combined and 

analyzed to measure the incidence and forms of discrimination in urban housing markets. The 

remainder of this chapter describes the statistical techniques used to analyze data from DDS 

testing. Specifically, we discuss basic measures of adverse treatment, the challenge of 

distinguishing systematic discrimination from random differences in treatment, rental treatment 

indicators, and tests of statistical significance. 

Gross and Net Measures. A paired test can result in any one of three basic outcomes 

for each measure of treatment: 1) the nondisabled tester is favored over the tester with a 

disability; 2) the tester with a disability is favored over the nondisabled tester; or 3) both testers 

receive the same treatment. The simplest measure of adverse treatment is the share of all tests 

in which the nondisabled tester is favored over the tester with a disability. This gross incidence 

approach provides very simple and understandable indicators of how often people without 

disabilities are treated more favorably than equally qualified people with disabilities. However, 

there are a few instances in which testers with disabilities receive better treatment than their 

nondisabled partners. Therefore, we report both the gross incidence of nondisabled-favored 

treatment and the gross incidence of disabled-favored treatment. 

Although these simple gross measures are straightforward and easily understandable, 

they may overstate the frequency of systematic discrimination.37 Specifically, adverse treatment 

may occur during a test not only because of differences in disability status, but also because of 

random differences between the circumstances of their visits to the rental housing providers. 

For example, in the time between two testers’ visits, an apartment might have been rented, the 

agent may have been distracted by personal matters and forgotten about an available unit, or 

one member of a tester pair might meet with an agent who is unaware of some available units. 

37 We use the term “systematic discrimination” to mean differences in treatment that are attributable to a 

customer’s disability status, rather than to any other differences in tester characteristics or test circumstances. This 

term is not the same as “intentional” discrimination, nor is it intended to mean that these differences would 

necessarily be ruled as violations of federal fair housing law. 

28 
Discrimination Against Persons With Disabilities: 

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Gross measures of nondisabled-favored and disabled-favored treatment include some random 

factors and therefore provide upper-bound estimates of systematic discrimination.38 

One strategy for estimating systematic discrimination (that is, to remove the cases where 

non-discriminatory random events are responsible for differences in treatment) is to subtract the 

incidence of disabled-favored treatment from the incidence of nondisabled-favored treatment to 

produce a net measure. This approach essentially assumes that all cases of disabled-favored 

treatment are attributable to random factors—that systematic discrimination never favors 

persons with disabilities—and that random nondisabled-favored treatment occurs just as 

frequently as random disabled-favored treatment. Based on these assumptions, the net 

measure subtracts differences due to random factors from the total incidence of nondisabledfavored treatment. 

However, it seems unlikely that all nondisabled-favored treatment is the result of random 

factors; sometimes persons with disabilities may be systematically favored on the basis of their 

disability. For example, a landlord might think that a young person with a disability may not 

socialize as much as a young nondisabled person and, therefore, might be a quieter tenant. 

The net measure subtracts not only random differences, but also some systematic differences, 

and therefore probably understates the frequency of systematic discrimination. Thus, net 

measures provide lower-bound estimates of systematic discrimination, and they reflect the 

extent to which the differential treatment that occurs (some systematically and some randomly) 

is more likely to favor nondisabled people over people with disabilities. 

In the analysis presented here, gross incidence measures are reported for both 

nondisabled-favored and disabled-favored treatment. When these two gross measures are 

significantly different from one another, we conclude that a systematic pattern of differential 

treatment based on disability status has occurred. If, on the other hand, the incidence of 

disabled-favored treatment is essentially the same as the incidence of nondisabled-favored 

treatment, we cannot conclude that these differences are systematically based on disability 

status. Because our sample sizes are relatively small, and our data might not be normally 

distributed, conventional tests of statistical significance could fail to detect differences in 

treatment that are actually significant. Therefore, we use the Sign Test to determine whether 

the incidence of nondisabled favored treatment is significantly different from the incidence of 

disabled-favored treatment.39 

38 Note that it is conceivable that random factors might reduce the observed incidence of nondisabledfavored or disabled-favored treatment, so that the gross-incidence measure is technically not an absolute upperbound estimate for systematic discrimination. 

39 See Heckman, James J. and Peter Siegelman. 1993. “The Urban Institute Audit Studies: Their Methods 

and Findings” in Clear and Convincing Evidence: Testing for Discrimination in America (Fix, Michael, and Raymond J. 

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Discrimination Against Persons With Disabilities: 

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It is important to note that even when no statistical pattern of disability-based differential 

treatment is observed, individual cases of discrimination may occur. Specifically, even if the 

gross incidence of nondisabled-favored treatment is statistically insignificant, this does not mean 

that discrimination never occurred, but only that the number of cases was too small to draw any 

conclusions about systematic patterns across the sample as a whole. Similarly, for variables 

where gross measures of nondisabled-favored and disabled-favored are essentially equal, there 

may in fact be instances of disability-based discrimination, even though the overall pattern does 

not favor one group systematically. Finally, even when treatment on a single indicator appears 

to favor either the disabled or nondisabled tester, this does not necessarily mean that the entire 

test favors the tester. A qualitative review of the entire test file might be needed to assess the 

overall outcome across multiple measures. 

Treatment Indicators. A visit with a housing provider is a complex transaction and may 

include many forms of favorable or unfavorable treatment. This report presents results for a 

series of individual treatment indicators that reflect important aspects of the housing transaction. 

Many, but not all of these indicators are common to both TTY and wheelchair tests. In selecting 

indicators for analysis, we have focused on forms of treatment that can be unambiguously 

measured, and appear to have real potential to affect the outcomes of the housing search. 

Ultimately, other analysts may choose to focus on additional or alternative treatment indicators. 

However, the indicators presented here provide a comprehensive overview of the treatment that 

testers received during their contact with rental agents. 

Indicators of adverse treatment in rental housing tests address five critical aspects of the 

interaction between a renter seeking information and a landlord or rental agent. The first aspect 

addresses whether or not the tester was able to speak to a landlord or rental agent: 

• Were you able to speak with a housing provider to discuss housing options? 

The second aspect uses a group of indicators that measure the extent to which the tester with 

the disability and the tester without a disability received comparable information in response to 

their inquiries about the availability of the advertised housing unit and other similar units that 

would meet their needs: 

• Was the advertised housing unit (or a unit with the same number of bedrooms) 

available? 

• Were other units available? 

• How many units were available? 

Struyk eds.). Washington, DC: The Urban Institute Press; and Ramsey, Fred L. and Daniel Schafer. 1997. The 

Statistical Sleuth: A Course in Methods of Data Analysis. Belmont, CA: Wadsworth Publishing Company. 

30 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

For in-person tests, testers not only inquired about the availability of housing units, but they also 

asked to inspect units that were available for rent. These treatment measures focus on whether 

the tester in the wheelchair and the nondisabled tester were able to inspect the advertised 

housing unit and/or other available units: 

• Were you able to inspect a unit (if any were available)? 

• How many units were inspected? 

The third aspect explores potential differences in the costs quoted to each tester of the test pair 

for comparable housing: 

• How much was the rent for available units?40 

• How large a security deposit was required? 

• Was an application fee required?41 

Testers not only inquired about the availability of housing units, but they also attempted to gain 

information about the rental process. Therefore, the fourth aspect focuses on whether the test 

partners were provided with similar information about the rental process: 

• Did the housing provider invite the tester to pick up an application or offer to send 

one to the tester (phone tests), or invite the tester to complete an application on site 

or give the tester one to take home (in-person tests)? 

• Did the housing provider say that a credit check was part of the application process? 

• Did the housing provider say that a criminal background check was part of the 

application process? 

• Did the housing provider request information about income, source of income, or 

occupation? 

In general, testers who receive more information (including information about required credit 

checks or criminal background checks) are considered to be favored, because the housing 

provider has given them more details about what will be required to obtain housing. 

40 If a tester was given information for more than one unit at a site, we averaged the rent amounts, security 

deposit, and application fee quoted by the housing agent. For research purposes, any difference in dollar amount 

between the nondisabled and disabled testers for any of these financial items was counted as a difference in 

treatment. 

41 Requiring an application fee from one tester but not the other is viewed as unfavorable treatment because 

it raises the cost of housing search. 

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Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

The fifth aspect assesses the extent to which agents encouraged or helped the tester with a 

disability and the nondisabled tester to complete the rental transaction: 

• Did the agent make follow-up contact? 

• Did the agent invite the tester to come into the rental office and to view the available 

unit? 

• Did the agent offer to send the tester an application? 

• Were arrangements made for future contact? 

Finally, for the in-person (wheelchair) tests, several indicators explore whether the tester with a 

disability could make required unit modifications or would be granted a parking accommodation: 

• What was the agent’s response to the request for unit modification? 

• What was the agent’s response to the request for parking accommodation? 

• What conditions were placed on the unit modification or parking accommodation, if 

granted? 

Because these questions were not raised by the nondisabled tester, these indicators are not 

used to measure differential treatment. They are simply used to reflect the percent of tests in 

which a modification or accommodation was denied. 

Summary Indicators. In addition to presenting results for the individual differential 

treatment indicators discussed above, this report combines indicators to create composite 

measures for categories of treatment (such as housing availability or information about the 

application process) as well as for the transaction as a whole.42 The first type of composite 

classifies tests as nondisabled-favored if the nondisabled tester received favorable treatment on 

one or more individual items, while the tester with a disability received no favorable treatment. 

Tests are classified as “neutral” if one tester was favored on some individual treatment items 

and his or her partner was favored on even one item. This approach has the advantage that it 

identifies tests where one partner was unambiguously favored over the other. But it may 

incorrectly classify tests as neutral when one tester received favorable treatment on several 

items, while his or her partner was favored on only one. This approach also classified tests as 

neutral if one tester was favored on the most important item while his or her partner was favored 

42 Note that indicators relating to reasonable modifications and accommodations are not included in these 

composite measures of differential treatment. And again, it is important to emphasize the difference between 

methods used for the statistical analysis of paired testing results and methods used to assemble or assess evidence 

of unlawful conduct in an individual case. No pre-determined set of decision criteria can substitute for case-by-case 

judgments about test results. 

32 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

on items of lesser significance. Therefore, it may understate the overall incidence of differential 

treatment across indicators, but nonetheless provides useful measures of the consistency of 

adverse treatment. 

In addition to the consistency approach, hierarchical composites were constructed by 

considering the relative importance of individual treatment measures to determine whether one 

tester was favored over the other. For each category of treatment measures (and for the overall 

test experience), a hierarchy of importance was established independent of analysis of the test 

results. For example, if a nondisabled tester found out about more available units than the 

tester with a disability, then the nondisabled tester was deemed to be favored overall, even if 

the tester with a disability was favored on less important items. Table 3-3 presents the 

hierarchy of treatment measures for both the TTY and the wheelchair tests. 

Table 3-3: Construction of Hierarchical Composites* 

TTY Tests Rank 

Able to speak to provider 1 

Advertised or similar unit available 2 

Number of available units 3 

Rent 4 

Security deposit 5 

Application fee 6 

Application offered to tester 7 

Informed about credit check 8 

Informed about background check 9 

Asked for income information 10 

Encouraged to call back 11 

Invited to visit 12 

Wheelchair Tests Rank 

Able to speak to provider 1 

Advertised or similar unit available 2 

Number of available units 3 

Ability to inspect units 4 

Number of units inspected 5 

Rent 6 

Security deposit 7 

Application fee 8 

Told application needed 9 

Application offered to tester 10 

Informed about credit check 11 

Informed about background check 12 

Asked for income information 13 

 Wait time 14 

*Grey shading shows differences in the hierarchical measures used for TTY tests and wheelchair tests. 

In the chapters that follow, two overall estimates of discrimination are highlighted. The 

first is a lower-bound estimate of systematic discrimination, based on the hierarchical composite 

measure. Because the hierarchical composite reflects both systematic discrimination and 

33 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

random differences in treatment, we subtract the overall incidence of disabled-favored treatment 

from the incidence of nondisabled-favored treatment to create a net, lower-bound estimate of 

overall discrimination. In addition to this lower-bound estimate, we report the overall incidence 

of consistent nondisabled-favored treatment – the share of tests in which the nondisabled tester 

was consistently favored over the tester with a disability (and the disabled tester was never 

favored). This represents out “best estimate” of the overall level of discrimination against 

persons with disabilities. 

34 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

4. DISCRIMINATION AGAINST HOMESEEKERS USING TTY SYSTEMS 

The Disability Discrimination Study provides the first rigorous estimates of discrimination 

against deaf people who use TTY systems to inquire about the availability of advertised rental 

housing.43 A total of 101 paired tests were completed during the winter of 2004, in which testers 

who were deaf used the TTY system with relay operators to inquire about available rental 

housing in the Chicago metropolitan areas, while nondisabled testers made comparable 

telephone inquiries. 

Paired testing demonstrates that deaf people frequently experience discrimination by 

rental housing providers, many of whom refuse to accept TTY calls or provide less information 

about advertised rental units than they provide to hearing customers making telephone 

inquiries. In cases where both hearing and deaf testers were able to gain access to a housing 

provider and obtain information about an advertised unit, the deaf tester was often treated as a 

less-serious customer and received fewer opportunities for follow-up contact.44 

Unequal Access to Information 

Deaf testers seeking rental housing were significantly less likely to be able to speak to a 

housing provider than were their hearing counterparts. In one of every four tests, only the 

hearing tester was able to speak to a housing provider regarding available units (compared to 

two percent of tests in which only the deaf tester was able to speak to the rental housing 

provider). Housing providers denied access to deaf testers in several ways, including simply 

hanging up, refusing requests for information, or questioning the veracity of the call or caller. 

Table 4-1: Unequal Access to Information 

INFORMATION ACCESS Hearing 

Favored Deaf Favored Net Measure 

Access to Information (N=101) 25.7% 2.0% 23.8%** 

For net estimates, * indicates statistical significance at the 90% confidence level, 

while ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

43 For purposes of this study, we use the term “deaf” to refer to persons with hearing or communication 

disabilities. 

44 Opportunity for follow-up contact includes any action or statement made by the housing provider 

suggesting follow-up with the possible renter. These actions include the housing provider saying he or she would call 

the tester back to follow-up with the initial phone conversation, inviting the tester to call him or her back, sending an 

application to the tester, or inviting the tester to see the rental unit in person. 

35 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

i 

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Both testers called on Tuesday morning and spoke w th the same person. The non-disabled 

tester ca ed f rst and the tester w th the d sab lity called an hour and 15 m nutes later. Their 

narrat ves are reported here, edited only for grammar and to remove any dent fying information. 

Non-disabled Tester. On 2/24 04 at 9:25 am I called PHONE NUMBER and John from 

NAME] Realtors answered the phone. I told him I was interested in the 1 bedroom apartment 

advert f he would have any available by 3/15/04. He said he had several available. He 

asked what my price range was and I told him my max budget was $1,350. I proceeded to ask 

him what the info was on these units. Very quick y he went through the fol owing. He said he 

had units for $975-985, $1,075, $1,175, and $1,250. I then asked him to clar fy these rents and 

clearly tell me how many units I had to choose from. He did by telling me he had units ranging 

from $975-985, a un t at $1,075, a unit at $1,175 and $1,250. I then proceeded to ask him what 

nd of fees were invo ved and he said a $50 application fee and a $250 non-refundable admin. 

fee only f you are approved. In other words f you are denied you get that money back. Both 

fees are at application. I asked him his lease terms and he said 1 year typical terms. He said 

the building was a courtyard building and has three different f oor plans. I then pushed for more 

info and asked for the exact locat ons of the available units and he said ADDRESS] has the 

$975-985, $1,075 and $1,175 rents vacant and the $1,250 rent is at ADDRESS] vacant. I 

asked h m to further clarify the $250 non-refundable fee and he said that s all that is asked 

because a lot of people are sav ng for their real estate purchase or downpayment. I thanked 

him for his t me and told him I am calling around and I appreciated his t me and he said no 

problem and the call ended at 9:31am. 

Deaf Tester. The disabled tester’s narrative is the verbatim report automatically generated by 

the TTY system. 

relay operator: Irc ca 1683f ur caller id w ll send) GA [go ahead 

tester: Hello pls block caller id and pls d al [PHONE NUMBER pls GA 

relay operator: ur caller id blocked PHONE NUMBER] nging 1 ... 

tester: Relay, are we having trouble w th communicat on? GA 

relay operator: The person calling you is either deaf or hard of hearing. They w 

typing their conversat on, which w be read to you. When you hear the 

phrase, “go ahead,” p ease respond directly to the caller. The operator 

will type everyth ng that is heard back to the caller. One moment for your

 call to beg n. GA 

tester: Hello my name is Laura and I’m calling to inquire about the ad in the 

Chicago Reader for the one bedroom apartment on ADDRESS]. Is that 

still availab e and what is your name? GA 

Realtor: My name is [NAME] and that’s not the correct address. It’s ADDRESS} 

and the apt is availab e for immediate occupancy. Our off ce is located at 

ADDRESS] so she needs to come by the off ce and we’re open unt 7 in 

the evening ton ght, Wednesday and Thursday night ‘till 5:30 on Friday 

night. 11 to 4 on Sat and Sun. So umm she can come by and we can 

walk over to the property which is only a b ock or 2 away and we’l 

happy to show it to her and if she has any other quest ons I w ve her 

the fax number and we will... xxx m Our fax number is as follows 

FAX NUMBER and this completes my call and I can’t stay on the phone 

any longer. I am in a meeting f any other quest ons contact me by fax 

person hung up). 

irc 1683f ga or sk 

tester: Thank you sk 

36 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Some housing providers simply hung up on the deaf testers. Testers using TTY 

technology were required to confirm with the relay operator that the housing provider had heard 

the entire explanation of how a TTY call works before a test could be considered a “hang up.” 

In a number of instances, deaf testers had to make several attempts to call a housing provider 

before the relay operator was even able to complete the explanation. Even after the call was 

explained, some housing providers gave no specific reason for not wanting to speak to the deaf 

tester, or they provided a seemingly irrelevant response from someone who had available 

housing to rent. Examples include: 

“No, I don’t want to speak with them.” 

“No, we don’t need that.” 

“I can’t do this right now. This is a business.” 

“I don’t want to talk to anyone I don’t know.” 

After the relay operator’s second attempt to explain the TTY call, one housing provider said, 

“Hello, I don’t speak English.” However, the non-deaf tester was able to get complete 

information when he called the same number.45 In all of the tests involving a hang up, the deaf 

tester was never able to speak to the housing provider at all. 

Other housing providers gave reasons for refusing to provide any information to deaf 

testers. In some cases, providers informed the relay operator that the tester had to call back at 

another time or had to find information about the housing some other way, such as via fax or the 

Internet. Some deaf testers were also told they must come into the office in order to get 

information. (In the two instances where a hearing tester was refused information, he was 

never told to find information elsewhere nor was he required to come in person to the housing 

site; he was only asked to call back later.) Examples of comments made to deaf testers by 

housing providers refusing to provide information include the following: 

“I don’t want to accept this call. That person can e-mail me.” 

“If she has any other questions, I will give her the fax number.” 

“You need to come to see the place and we’ll talk after that...Get all your information 

together and come and see the apartment.” 

“She needs to come by the office...She can come by and we can walk over to the 

property which is only a block or two away.” 

45 It could not be discerned if both testers spoke to the same housing provider, because the tests were 

conducted by phone and the deaf tester was not able to get far enough into the conversation to ask for the provider’s 

name. 

37 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Several housing providers also refused to give all or some information about the available 

housing to deaf testers by challenging the seriousness or veracity of the call. 

“How did you get my number anyway?” 

“I don’t understand why they are contacting me.” 

“Are you being serious? Are you looking for an apartment? I don’t have time for this. I 

will notify the phone company.” 

When a rental housing provider refuses to take a call from a potential customer or 

refuses to provide any information about available housing, he effectively denies access to any 

units he may have available. Many homeseekers gather initial information about available 

rental options over the telephone. For a deaf person who communicates primarily through sign 

language, the ability to obtain information over the telephone is especially important. The 

decision by rental housing providers not to accept TTY calls essentially “slams the door” on deaf 

homeseekers, making it impossible for them to conduct their housing search independently. 

Also, the fact that some housing providers did accept TTY calls and provided complete 

information to deaf testers confirms that it is feasible to use the technology in a way that 

provides equal treatment to deaf homeseekers. 

Comparable Information About Available Units 

When both deaf and hearing testers gained access to a rental housing provider, neither 

tester was systematically favored with respect to information about available units. For the large 

majority of tests, units were available to both testers, and the housing provider told both about 

the same number of units.46 In addition, in tests where at least one unit was available to each 

tester, the housing provider quoted similar rental amounts, application fees, and security 

deposits to each tester.47 

46 In addition to asking about available rental housing units with the same number of bedrooms listed on the 

test assignment, testers were trained to inquire about available units with a greater number of bedrooms than 

assigned. Few units of this type were available, however, and thus were not included in the results. 

47 Because testing was completed over the telephone, specific unit numbers were not available. In addition, 

many providers advertised multiple units, making it impossible to designate a single unit as the advertised unit. The 

rent amount, security deposit, and application fees are, therefore, averages for all of the available units for which the 

housing provider provided information. 

38 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Table 4-2: Comparable Information About Available Units 

UNIT AVAILABILITY Hearing 

Favored Deaf Favored Net Measure 

Rental Unit Available (N=73) 

Number of Units Available (N=73) 

Rent Amount (N=65) 

Security Deposit (N=66) 

Application Fee (N=66) 

Overall Treatment (N=73) 

1.4% 1.4% 0.0% 

20.6% 26.0% -5.5% 

15.4% 26.2% -10.8% 

15.2% 21.2% -6.0% 

4.5% 13.6% -9.1% 

21.8% 26.7% -5.0% 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** 

indicates significance at the 95% level (using a two-tailed test). Gross estimates are by 

definition statistically significant. 

Less Information About the Application Process 

Although they received comparable information about available units, deaf testers 

frequently were not given as much information and encouragement about the application 

process as their hearing partners. The DDS testing protocols required both testers to ask about 

application procedures, but many housing providers provided the deaf testers with less 

information. Specifically, prerequisites for renting a house or apartment often include a 

completed application form, credit report, and criminal background check. 

Housing providers were significantly less likely to offer the deaf tester an application or 

to inform him or her that a credit check would be required. In three of every ten tests, the 

housing provider either invited the hearing tester to pick up an application or offered to mail the 

application, but did not make the same offer to the deaf tester (compared to 7.3 percent of tests 

where the housing provider favored the deaf tester). In three of every ten tests, the hearing 

tester was told that a credit check was necessary prior to renting an available unit, while the 

deaf tester was not given any information regarding a credit check requirement (again 

compared to 7.3 percent of tests where the deaf tester was given more information). 

39 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Table 4-3: Less Information About the Application Process 

INFORMATION ABOUT 

APPLICATION PROCESS 

Hearing 

Favored Deaf Favored Net Measure 

Application Offer (N=69) 

Credit Check (N=69) 

Criminal Background Check (N=69) 

Income Information (N=69) 

Overall Treatment (N=69) 

30.4% 7.3% 23.2%** 

31.9% 7.3% 24.6%** 

4.4% 2.9% 1.5% 

2.9% 10.1% -7.3% 

33.7% 10.9% 22.8%** 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** 

indicates significance at the 95% level (using a two-tailed test). Gross estimates are by 

definition statistically significant. 

Overall, deaf testers received less-favorable treatment than their nondisabled partners 

across all of these application indicators in three of every ten tests (and were favored in only 

about one of ten tests). As a result, the net estimate of discrimination for this category of 

treatment is statistically significant at 22.8 percent. 

Fewer Invitations for Follow-Up 

Deaf testers also experienced significant adverse treatment with respect to invitations for 

follow-up contact. More than one third of the housing providers invited only the hearing testers 

to call back if they were interested in a unit and to visit the properties to look at units or to fill out 

an application (compared to 8.7 percent of tests in which the tester with a disability was 

favored). 

Overall, deaf testers received less-favorable treatment than their nondisabled test 

partners across these follow-up indicators in three of every ten tests (and were favored in only 

11 percent). As a result, the net estimate of discrimination for this category of treatment is 

statistically significant at 19.8 percent (see Table 4-4). 

Summary 

Testing for discrimination against deaf persons who use TTY systems to inquire about 

advertised rental housing in the Chicago Metropolitan Area reveals significant levels of adverse 

treatment (see Table 4-5). Specifically, in one of every four calls, housing providers refused to 

40 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Table 4-4: Fewer Invitations for Follow-Up 

FOLLOW-UP Hearing 

Favored Deaf Favored Net Measure 

Call Back (N=69) 

Visit Invitation (N=69) 

Overall Treatment (N=69) 

20.3% 8.7% 11.6% 

34.8% 8.7% 26.1%** 

30.7% 10.9% 19.8%** 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** 

indicates significance at the 95% level (using a two-tailed test). Gross estimates are by 

definition statistically significant. 

communicate with deaf testers, while accepting and responding to conventional telephone 

inquiries. When deaf testers were able to communicate with a housing provider, they received 

comparable information about available units, but less information about the application process 

than their nondisabled partners. Deaf testers also experienced significant adverse treatment 

with respect to invitations for follow-up. Overall, deaf testers received less favorable treatment 

than their nondisabled partners in six of every ten tests conducted (and were favored in about 

one third). The lower-bound (net hierarchical) estimate of discrimination against deaf persons 

using TTY systems is statistically significant at 26.7 percent. In addition, deaf testers 

experienced consistently adverse treatment relative to their hearing partners in almost half of all 

tests. 

Table 4-5: Summary Measures of Consistent Adverse Treatment 

SUMMARY MEASURES Hearing 

Favored Deaf Favored Net Measure 

Access to Information (N=101) 

Unit Availability and Cost (N=73) 

Application Process (N=69) 

Follow-Up (N=69) 

25.7% 2.0% 23.8%** 

21.8% 26.7% -5.0% 

33.7% 10.9% 22.8%** 

30.7% 10.9% 19.8%** 

Hierarchical Composite (N=101) 

Consistency Composite (N=101) 

61.4% 34.7% 26.7%** 

49.5% 9.9% 39.6%** 

For net estimates, * indicates statistical significance at the 90% confidence level, 

while ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

41 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

5. DISCRIMINATION AGAINST HOMESEEKERS USING WHEELCHAIRS 

The Disability Discrimination Study provides the first rigorous estimates of discrimination 

against people who use wheelchairs and visit rental housing providers in person to inquire about 

the availability of units. A total of 99 paired tests were completed during the spring and summer 

of 2004, in which testers who had physical disabilities and used wheelchairs visited advertised 

rental properties in person. 

It is far more difficult for a person using a wheelchair to find rental housing in the 

Chicago area than for a nondisabled person. More than a third of rental homes and apartments 

that are advertised in the City of Chicago and surrounding Cook County are in buildings that are 

inaccessible for wheelchair users even to visit. When persons using wheelchairs visit properties 

that are accessible (or could reasonably be made accessible), they can meet with and speak to 

rental housing providers as frequently as nondisabled persons, but they are often told about and 

shown fewer units, receive less information about available units, and are treated as less 

serious rental customers. Finally, 16 percent of rental housing providers who indicated that they 

had units available for the wheelchair user refused to make or allow for reasonable unit 

modifications, and about 19 percent of those who had on-site parking refused to make the 

reasonable accommodation of providing a designated accessible parking space. 

Many Advertised Units Inaccessible 

Many advertised properties were inaccessible to wheelchair users. We eliminated 

advertisements at the sampling stage if there was any indication the property or the unit would 

be inaccessible. Then, after the advance call but prior to assigning testers to a particular unit, 

project staff drove by the advertised property to assess whether or not it would be accessible to 

people using wheelchairs. Using our drive-by approach, we found that roughly 36 percent of the 

sampled ads were ineligible for testing because the properties appeared to be inaccessible for 

people in wheelchairs to even visit. In other words, at best, a person who uses a wheelchair is 

limited to only about two-thirds of the Chicago area rental housing market from the outset.48 

48 As discussed earlier, this study did not attempt to determine whether sampled rental properties were 

covered by the design and construction requirements of the Fair Housing Act. Moreover, properties that appeared to 

be accessible based upon the reconnaissance process could have had interior barriers that would make them 

inaccessible for persons using wheelchairs. 

42 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Table 5-1: Many Advertised Units Inaccessible 

 Testing Week 

Percent Deemed 

Inaccessible after 

Drive-by 

Week 1 35.9% 

Week 2 34.7% 

Week 3 11.1% 

Week 4 35.7% 

Week 5 12.3% 

Week 6 40.0% 

Week 7 40.0% 

Week 8 35.0% 

 Testing Week 

Percent Deemed 

Inaccessible after 

Drive-by 

Week 9 50.5% 

Week 10 31.6% 

Week 11 58.0% 

Week 12 44.4% 

Week 13 48.4% 

Week 14 60.0% 

Week 15 47.8% 

TOTAL 36.0% 

Comparable Access to Housing Providers 

Neither the nondisabled nor testers with disabilities were systematically favored with 

respect to access to housing providers. For a large majority of tests, both testers were able to 

speak to a rental housing provider close to his or her scheduled appointment time. 

Table 5-2: Comparable Access to Housing Providers 

ACCESS TO INFORMATION Nondisabled 

Favored 

Wheelchair 

User Favored Net Measure 

Able to Speak to Rental Housing 

Provider (N=99) 

Wait time (N=92) 

Overall Treatment (N=99) 

6.1% 1.0% 5.1% 

13.0% 10.9% 2.1% 

18.2% 11.1% 7.1% 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** 

indicates significance at the 95% level (using a two-tailed test). Gross estimates are by 

definition statistically significant. 

43 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

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Both testers dropped in without an appointment at the apartment complex on a Friday w thin two 

and a ha f hours of one another. The disabled tester went f rst at 11:00 am; his v sit lasted 6 

nutes. The non-disabled tester followed at 1:00 pm his v sit lasted 20 m nutes. The 

narratives are reported here, edited only for grammar and to remove any dentify nformation. 

Non-disabled Tester. I arr ved at ADDRESS] at 1:00 PM for a drop-in v I was greeted in 

the lobby by the doorman, who called up to the rental off ce and then took my name and sent 

me up to the 2nd f oor office. I was immediately greeted by NAME], who asked me to fill out a 

tor's card, wh ch asked for my name and phone number, but not my occupation...and the 

size apartment I sought and rent range. After NAME] looked over my card, she began to 

collect some brochure mater als for me, f oor plans, price sheets. 

She asked me to follow her, after she got some apt. keys, and we proceeded up the elevator to 

the 8th f oor, where we v ewed apt. #816. This apartment is a two bedroom un t, w th two full 

bathrooms and a very nice v ew. It has an up-to-date k tchen and the apt. has been painted and 

the carpets cleaned. [NAME] explained that the rent on th s unit is $1485 mo. She pointed out 

that all units had a lease length that is negot able, but there is a special w th a one-year lease, 

for 2-months free park ng, which is normally $210/mo. She went on to add that there is no 

secur ty deposit for the rental un ts however, there's a one t me non-refundable move- n fee of 

$375 and an application fee of $50 for a credit check. She said that there was an identica 

apartment on the 18th f oor 1816) that was also avai e in my t meframe, however, the rent 

for the higher f oor, was $1530/mo. NAME] casually asked me where I worked and I told her 

that I worked r ght down Illinois St. at NAME OF COMPANY]. She showed me by the pool, 

tness center, cyber cafe, laundry facilities and the lobby and ta ked about the amenit n the 

building, including storage lockers and a b ke room. I asked what was inc n the rent, and 

she sa d that water and e ectr c are pa d by the tenants, as we as cable and phone. All the 

appliances are e ectric. 

When we got back to the off ce, [NAME] put together all the paperwork for me, and gave me a 

promotional bag to put it all into, along w th her business card. She asked me if I liked the 

apartment, and "could I have her take it off the market for me today?" I said that I had ust 

started looking, but I thought they were very nice. She said that she could g ve me an 

application to fill out f I decide that I'd like to move in there. I said, “sure, I can take that w th 

me." NAME] shook my hand and said, "thank you for com ng by, f you have any quest ons, be 

sure to g ve me a call." I said, "thank you, I w ." We said goodbye, and I got back to my car at 

1:20 PM. 

Disabled Tester. I arr ved at [NAME OF COMPLEX at 10:26 am. The door attendant asked 

how cou d he help me. I said I was looking for a 2 bedroom. He asked f I had an appointment. 

I told him no. He sa d that was unusual or strange at a low voice. He said he would call 

upstairs to see f they could show the apartments. When he was speak ng to someone upstairs 

- I could not hear what he was say ng. When he got off the phone he told me that the rep had 

two other appointments to show and he wou d not be available. I told him I could wait. He said 

no, he was told to g ve me packet and business card and f I had any quest ons the information 

wou d be provided in the packet. As he handed me the packet he showed me the website 

address. He said, “Is that ok w th you?” I said “Not really.” He said nothing. I stated that the ad 

didn't say an appointment was necessary. He came around the desk, gave me the packet, and 

escorted me to the door. I got in the cab and left. 

44 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Less Information About Available Units 

Wheelchair users experienced significant levels of adverse treatment with respect to 

housing availability. In five percent of tests, the rental housing provider told the nondisabled 

tester that a unit was available while telling the tester with a disability that no units were 

available (compared to no tests in which the tester with a disability was favored). 

After telling testers with disabilities that no units were available, some providers 

suggested that they look elsewhere for housing: 

“He told me to go down the street and look for places that have rentals available. 

He told me, ‘You can find lots of rentals down busy streets.” 

“I was told that nothing was available, but to see about an apartment locator 

service so I wouldn’t have to go around so much.” 

“The housing provider later stated, ‘You would be better off buying my house. It 

would be more accessible to you.’ “ 

Even when both testers were told that a rental unit was available, wheelchair users were not 

always told about as many units as comparable nondisabled testers. Specifically, in more than 

one in four tests, the nondisabled tester was told about more units than the tester who used a 

wheelchair (compared to nine percent of tests where the wheelchair user was favored). 

Table 5-3: Less Information About Available Units 

UNIT AVAILABILITY 

Nondisabled 

Favored 

Wheelchair 

User Favored Net Measure 

Rental Unit Available (N=88) 

Number of Units Available49 (N=78) 

Ability to Inspect Unit (N=78) 

Number of Units Inspected (N=78) 

Overall Treatment (N=88) 

4.5% 0.0% 4.5% 

26.9% 9.0% 17.9%** 

37.2% 6.4% 30.8%** 

11.5% 1.3% 10.2%** 

35.4% 7.1% 28.3%** 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** 

indicates significance at the 95% level (using a two-tailed test). Gross estimates are by 

definition statistically significant. 

49 This and all remaining individual treatment indicators were constructed for the 78 tests in which both 

testers were able to speak to a housing provider and both were told about at least one unit in the same size category. 

45 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Wheelchair users also received less-favorable treatment than comparable nondisabled 

testers with respect to unit inspections. In almost four of every ten tests where both testers 

were told that a rental unit was available, only the nondisabled tester was able to inspect a unit 

(compared to 6 percent of tests in which the tester with a disability was favored). And in 12 

percent of tests, the nondisabled tester was able to inspect more units than the comparable 

tester with a disability (compared to only 1 percent in which the tester with a disability was able 

to inspect more). 

Overall, wheelchair users received less-favorable treatment than their nondisabled 

counterparts with respect to unit availability and inspections in more than a third of tests 

(compared to only 7.1 percent of tests in which wheelchair users were favored). Thus, the net 

estimate of discrimination for this category of treatment is statistically significant at 28.3 percent. 

Lower Fees 

In contrast to inspection opportunity findings, housing providers quoted lower security 

deposit amounts and lower application fees to testers who used a wheelchair. Although testers 

with disabilities were also more likely to be quoted lower rent amounts, this difference was not 

statistically significant. Wheelchair users were quoted lower security deposit fees in 27 percent 

of tests, while nondisabled testers were quoted lower fees in only 14 percent of tests. In 17 

percent of tests, the wheelchair user was quoted a lower application fee (compared to six 

percent of tests where the nondisabled tester was quoted a lower application fee). Overall, 

wheelchair users were quoted higher costs than their nondisabled counterparts in 21.2 percent 

of tests (compared to 31.3 percent in which wheelchair users were quoted lower costs). The net 

estimate of discrimination for this category of treatment is not statistically significant. 

Table 5-4: Lower Fees 

FEES Nondisabled 

Favored 

Wheelchair 

User Favored Net Measure 

Rent Amount (N=78) 

Security Deposit (N=78) 

Application Fee (N=78) 

Overall Treatment (N=78) 

24.4% 25.6% -1.2% 

14.1% 26.9% -12.8%* 

6.4% 16.6% -10.2%* 

21.2% 31.3% -10.1% 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** 

indicates significance at the 95% level (using a two-tailed test). Gross estimates are by 

definition statistically significant. 

46 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Although these data indicate that testers who use wheelchairs were favored with respect 

to rental amounts and fees, this analysis is approximate. Testers often were unable to obtain 

exact unit numbers for each available unit (or for the advertised unit). The analysis was, 

therefore, based on the mean quoted fee for all units available to a tester. Because more units 

were made available to nondisabled testers, the mean fee might include units that may be more 

expensive and possibly of better quality than the units available to the testers using a 

wheelchair. 

Less Information About the Application Process 

Testers using wheelchairs also experienced unfavorable treatment with respect to 

information about the application process. Compared to the nondisabled testers, testers using 

wheelchairs were far less likely to be informed of requirements for renting a unit, such as 

submitting a completed application, having a credit check run, or providing information on their 

source of income. In addition, housing providers were more likely to offer the nondisabled tester 

an application to begin the rental process. Overall, wheelchair users received less information 

than their nondisabled partners in 44.4 percent of tests (compared to only 14.1 percent percent 

in which wheelchair users received more information). Thus, the net estimate of discrimination 

for this category of treatment is statistically significant at 30.3 percent. 

Table 5-5: Less Information About the Application Process 

INFORMATION ABOUT 

APPLICATION PROCESS 

Nondisabled 

Favored 

Wheelchair 

User Favored Net Measure 

Application Needed to Rent (N=78) 

Application Offered to Tester (N=78) 

Credit Check (N=78) 

Criminal Background Check (N=78) 

Income Information (N=78) 

Overall Treatment (N=78) 

19.2% 0.0% 19.2%** 

21.8% 10.3% 11.5%* 

26.9% 3.8% 23.1%** 

5.1% 5.1% 0.0% 

24.4% 10.3% 14.1%** 

44.4% 14.1% 30.3%** 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** 

indicates significance at the 95% level (using a two-tailed test). Gross estimates are by 

definition statistically significant. 

47 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Although all testers were assigned to pose as being employed full-time, some housing 

providers assumed that the tester with a disability was receiving some sort of subsidy that would 

either pay for rent or finance the unit modification: 

“We do not provide subsidized housing.” 

“We do not take Section 8. [after asking the tester repeatedly if he has Section 

8]” 

“So would the Chicago Housing Authority pay for that? [after the tester requests 

a unit modification]” 

Comparable Provider-Initiated Follow-up 

Follow-up contact by housing providers, such as phone calls to ask if prospective 

tenants are still interested in a unit or to thank them for their interest, is rare in rental housing 

transactions. And because they are so rare, any such contact might be seen as favorable 

treatment of a prospective renter in the form of increased service and encouragement on the 

part of the housing provider. Only 17 of the DDS wheelchair tests involved follow-up contact 

initiated by the housing provider. As discussed further below, five of these tests involved the 

housing provider responding to the request for a unit modification or parking accommodation 

without further inquiry regarding the tester’s continued interest in renting the unit. In these 

cases, the housing provider did not contact the nondisabled tester. 

Therefore, our analysis of provider-initiated follow-up is limited to 12 tests, which is not 

sufficient to provide statistical results. In four of these tests, both testers received follow-up 

contact, either by phone or by mail. In these contacts, the housing provider wanted to know if 

the tester was still interested in renting a unit or wanted to provide information about other units 

that had come available since the tester’s initial visit. In one test, both testers were sent thank 

you cards in the mail. In the eight remaining tests, only one tester in the pair received follow-up 

contact from the housing provider. In two of these cases, only the tester with a disability 

received follow-up; and in six, only the nondisabled tester received follow-up. Two of the tests 

in which only the nondisabled tester received follow-up were cases in which the tester with a 

disability was told during the site visit that no units were available. 

Refusal of Reasonable Modification and Accommodation 

When the testers using wheelchairs were able to inspect any available units, they asked 

the housing provider if they would be permitted to make a reasonable modification that would 

48 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

make the unit more accessible for them.50 As discussed in Chapter 3, all of the requested 

modifications were limited to a single unit, and all were reasonable in scope. Testers assured 

the housing providers that they would pay for the modification and pay to have the unit returned 

to its original condition at the end of their occupancy. About one of every six housing providers 

(16 percent) refused to allow some or all of the modification that was requested. Slightly more 

than half of housing providers agreed outright to allow the modification. The remaining 30 

percent of tests generated an inconclusive response. Specifically, 14 percent of the providers 

agreed to the request but indicated that some conditions or limitations would apply. For 

example, one tester was told that the apartment was still being shown to prospective tenants, 

but that if nobody else leased it, the landlord would allow the modification. Finally, 16 percent of 

providers indicated that they had to check with someone else. 

Figure 5-1: Refusal of Reasonable Modification 

16% 

16% 

14% 

54% 

Mod fication Permitted i

Refusal for Some or All of 

Modif cat i ion 

Had to Check with Someone 

Else 

Conditi ons or Lim tat i ions 

Imposed 

For properties with on-site parking (56 tests), testers also asked whether an accessible 

parking space could be made available and designated for their exclusive use. Two of every 

ten housing providers (19 percent) refused to make this reasonable accommodation for 

50 Using the hierarchy of modifications described in chapter 3, testers requested the first relevant 

modification from the list. A modification was identified for every test in which the tester with a disability was able to 

inspect a unit – a total of 80 tests. 

49 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

wheelchair users, while 44 percent of providers agreed to make it. The remaining 37 percent of 

tests concluded with an ambiguous response. Specifically, 7 percent of providers agreed to 

make the modification but imposed conditions or limitations, and three of ten indicated that they 

had to check with someone else. 

In five tests, housing providers called testers back regarding the request for unit 

modification or parking accommodation. For three of these tests, the housing provider said that 

the modification or accommodation could be made; on one, the request was denied, and on the 

last, the housing provider still did not know whether the request could be honored. Testers 

initiated follow-up calls regarding modifications or accommodations in 11 tests.51 In one test, the 

housing provider said he still did not know if the parking accommodation could be made, but 

called the tester back immediately to inform her that, in fact, it could. In five tests, the housing 

provider said the unit modification or parking accommodation simply could not be made, and in 

five other tests, the housing provider said he still did not know if the modification or 

accommodation could be made. 

Figure 5-2: Refusal of Reasonable Accommodation 

7% 

30% 44% 

Agreed to 

Accommodation 

Denied Accommodation 

Had to Check with 

Someone E se l

Conditi ons or Lim tat i ions 

Imposed 

19% 

51 Disabled testers were instructed to conduct follow-up phone calls if they were not given a definite 

response to their request for unit modification or parking accommodation. Unfortunately, not all testers conducted 

follow-up calls on all required tests; Urban Institute staff identified seven such tests. 

50 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

In two cases where the housing provider agreed that the requested unit modification 

would be allowed, we have evidence to suggest that this request would not really be honored. 

Specifically, although the tester with a disability was told that the unit modification could be 

made, the housing provider told the nondisabled partner that the modification would not be 

allowed. For example, in one of these tests, the tester with a disability reported: “I told him that 

I used a wheelchair and I would need to widen the bathroom door. He told me he would tell 

Omar the janitor to make the door wider.” The nondisabled tester visited later the same day and 

reported: “He pointed out the bathroom door and said someone had asked to modify the width 

of the door but that was not possible, it would change the structure of the building. He said they 

would not fit in the bathroom because of their wheels.” 

Summary 

Testing for discrimination against persons using wheelchairs to search for rental housing 

in the City of Chicago and surrounding Cook County reveals significant levels of adverse 

treatment. Specifically, more than a third of advertised rental homes and apartments are in 

buildings that are inaccessible for wheelchair users to even visit. As illustrated in Table 5-6, 

when persons using wheelchairs visit properties they are systematically told about and shown 

fewer units than comparable nondisabled homeseekers. In addition, persons using wheelchairs 

receive less information about available units and less information about the application process 

Table 5-6: Summary Measures of Consistent Adverse Treatment 

Information about Application 

Process 

Nondisabled 

Favored 

Wheelchair 

User Favored Net Measure 

Access to Information (N=99) 

Unit Availability & Inspection (N=88) 

Unit Costs (N=78) 

Application Process (N=78) 

18.2% 11.1% 7.1% 

35.4% 7.1% 28.3%** 

21.2% 31.3% -10.1% 

44.4% 14.1% 30.3%** 

Hierarchical Composite (N=99) 

Consistency Composite (N=99) 

59.6% 29.3% 30.3%** 

32.3% 9.1% 23.2%** 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** 

indicates significance at the 95% level (using a two-tailed test). Gross estimates are by 

definition statistically significant. 

51 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

than their nondisabled counterparts. Overall, wheelchair users experience unfavorable 

treatment in almost six of ten visits to advertised rental properties (but were favored over their 

nondisabled counterparts in only three of ten visits). The lower-bound (net hierarchical) 

estimate of discrimination against wheelchair users is statistically significant at 30.3 percent. In 

addition, wheelchair users experienced consistently adverse treatment relative to their 

nondisabled partners in 32.3 percent of visits. 

Because the wheelchair users who served as testers for this study had differing degrees 

of disability, we tested the hypothesis that persons who appear most severely disabled may 

experience more discrimination.52 Indeed, we found that wheelchair users whose severity of 

disability was classified as “high” were more likely to experience unfavorable treatment relative 

to their nondisabled partners than were wheelchair users whose severity of disability was 

classified as “low” or “moderate.” However, due to the small sample sizes, these differences 

are not statistically significant. 

In addition to differential treatment, almost one in six rental housing providers who 

indicated that they had units available for the wheelchair user refused to allow for reasonable 

unit modification. Almost one in five of those who had on-site parking refused to make the 

reasonable accommodation of providing a designated accessible parking space. 

52 Each tester who used a wheelchair was classified according to apparent severity of disability into one of 

three categories – low, moderate, and high. Forty-eight tests were conducted by testers whose severity of disability 

was classified as low or moderate, and 51 were conducted by testers whose severity of disability was classified as 

high. 

52 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

6. SUMMARY AND IMPLICATIONS 

The Disability Discrimination Study was designed to advance the state of the art in the 

use of paired testing to measure discrimination against persons with disabilities for both 

research and enforcement purposes. Because the population of persons with disabilities is 

diverse and the challenges for effectively measuring discrimination are substantial, this research 

effort was conducted in two phases. The first phase was exploratory; the Urban Institute 

developed and implemented a wide variety of testing approaches targeted to different groups of 

persons with disabilities and different forms of housing market discrimination. The second— 

pilot—phase of the study produced rigorous statistically representative estimates of the 

incidence of discrimination against two groups of persons with disabilities in the Chicago 

Metropolitan Area. Specifically, this phase focused on the treatment of deaf people who used 

the TTY system to inquire about advertised rental housing, and on the treatment of persons in 

wheelchairs who visited rental properties in person to inquire about available units. This chapter 

briefly summarizes findings from both phases of this research effort and discusses their 

implications for ongoing research and policy. 

Summary of Findings 

The study found paired testing to be a feasible and effective tool for detecting and 

measuring discrimination by rental housing providers against persons with disabilities. It can be 

used to capture both differential treatment discrimination and refusal to make reasonable 

accommodation or permit reasonable modification, and the paired research testing methodology 

can be adapted for a wide variety of disabilities and housing circumstances.53 Moreover, 

persons with disabilities are effective testers. Generally, it is not necessary to have nondisabled 

testers pose as people with disabilities or as their proxies. However, some testers with 

disabilities may require accommodation in the testing practice itself, including assistance in 

traveling to test sites or completing test reporting forms. In some cases, these accommodations 

can increase the costs of completing paired tests. 

Both groups of persons with disabilities who were studied in the pilot phase of this 

project encountered significant levels of adverse treatment when they inquired about advertised 

rental housing in the Chicago area, compared to comparable nondisabled homeseekers. 

People who were deaf and used the TTY system to inquire about advertised rental units in the 

Chicago Metropolitan Area were refused service in one out of four calls. Even when housing 

providers accepted their calls, the TTY users received significantly less information about the 

53 Of course, paired testing may not be well-suited for detecting and measuring all forms of discriminatory 

treatment that may occur in a housing transaction, or all types of disabilities. 

53 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

application process and fewer opportunities for follow-up contact than comparable hearing 

customers making telephone inquiries. Overall, testers who were deaf and used the TTY 

system experienced consistently adverse treatment in 49.5 percent of their calls, and our lowerbound (net) estimate of the incidence of discrimination is 26.7 percent. 

People using wheelchairs who visited rental properties in the Chicago Metropolitan Area 

to inquire about advertised units were just as likely as nondisabled customers to meet with a 

housing provider. However, in more than a quarter of all visits they were told about fewer 

available housing units, and in three of ten visits they were denied the opportunity to inspect any 

units. Moreover, wheelchair users received less information about the application process. 

However, they appear to have been quoted lower fees than comparable nondisabled 

customers. Overall, testers using wheelchairs who visited advertised rental properties in person 

experienced consistent adverse treatment in 32.3 percent of their visits, and our lower-bound 

(net) estimate of the incidence of discrimination is 30.3 percent. 

The most recent study of housing discrimination based on race and ethnicity included 

the Chicago Metropolitan Area and provides estimates of the incidence of adverse treatment 

experienced by African American and Hispanic renters there.54 Although the testing protocols 

differed, we can compare the incidence of adverse treatment against African Americans and 

Hispanics to our new estimates of adverse treatment against wheelchair users for selected 

treatment measures. These comparisons indicate that persons with disabilities face more 

frequent adverse treatment in the Chicago area rental market than African Americans or 

Hispanics. In particular, persons who are deaf and use the TTY system were unable to obtain 

any information from rental housing providers in 26 percent of their inquiries, while minorities 

were always able to obtain at least some information and service. In addition, persons using 

wheelchairs who visited rental housing providers in person were approximately as likely as 

African Americans or Hispanics to be denied information about available units, but substantially 

more likely to be denied opportunities to inspect units. Not only were testers with disabilities 

more likely to experience unfavorable treatment (relative to their nondisabled partners) than 

blacks or Hispanics, they were much less likely to be favored. As a consequence, the net 

measures of systematic discrimination against persons with disabilities are generally higher than 

the net measures of discrimination on the basis of race and ethnicity. 

54 Turner, Margery Austin, Stephen L. Ross, George C. Galster, and John Yinger. 2002. Discrimination in 

Metropolitan Housing Markets: Phase I Annex. Washington, D.C.: U.S. Department of Housing and Urban 

Development. 

54 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Table 6-1: More Adverse Treatment Against Persons 

with Disabilities Than Against Blacks and Hispanics55 

Treatment Measures 

In-Person Wheelchair Tests In-Person Black/White Tests In-Person Hispanic/Non-Hispanic White 

nondisabled 

favored 

disabled 

favored 

net 

measure 

white 

favored 

black 

favored 

net 

measure 

non-Hisp 

white fav 

Hispanic 

favored 

net 

measure 

Advertised unit available? 

Number of units available 

Able to Inspect units? 

Number of units inspected 

4.5% 0.0% 4.5% 

26.9% 9.0% 17.9% ** 

37.2% 6.4% 30.8% ** 

11.5% 1.3% 10.2% ** 

6.2% 3.1% 3.1% 

21.5% 18.5% 3.1% 

6.2% 4.6% 1.5% 

12.3% 13.8% -1.5% 

10.8% 7.7% 3.1% 

26.2% 13.8% 12.3% 

7.7% 10.8% -3.1% 

16.9% 16.9% 0.0% 

For net estimates, * indicates statistical significance at the 90% confidence level, while ** indicates significance at the 95% level 

(using a two-tailed test). Gross estimates are by definition statistically significant. 

In addition, persons with disabilities are frequently denied their requests for reasonable 

modification and reasonable accommodation needed to make the available housing fully 

accessible for them. Almost one of every six housing providers who indicated that units were 

available refused to allow reasonable unit modification needed by wheelchair users. Similarly, 

one of every five of those with on-site parking refused to make the reasonable accommodation 

of providing a designated accessible parking space for a wheelchair user. 

Discrimination is not the only obstacle that people with mobility impairment face in 

searching for rental housing. Although the tests conducted as part of this study were not 

intended to measure the extent of compliance with the design and construction requirements of 

the Fair Housing Act, they did highlight the substantial challenges persons with disabilities face. 

For example, in the Chicago area, at least a third of advertised rental properties are apparently 

not accessible for wheelchair users even to visit, severely limiting their housing options. 

Implications for Further Research 

The two pilot testing efforts conducted as part of this study clearly establish the feasibility 

and effectiveness of paired testing as a research tool for measuring the extent and forms of 

discrimination against persons with disabilities. Additional testing studies can and should be 

conducted – extending the methodology to more types of disabilities, more segments of the 

housing market, and more metropolitan areas. 

More specifically, based on the experience gained from this study, both telephone 

testing for discrimination against persons who are deaf and use TTY systems and in-person 

testing for discrimination against persons using wheelchairs could be conducted for a nationally 

representative sample of housing markets. The primary challenge involved in conducting a 

national study would be the identification and recruitment of testing organizations with sufficient 

55 Tests for discrimination on the basis of race and ethnicity were conducted in-person, and therefore, 

measures of adverse treatment are not directly comparable to the tests of discrimination against deaf persons using 

the TTY system. 

55 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

capacity to recruit disabled testers, provide the necessary accommodations for these testers to 

work effectively, and manage a large volume of high quality tests. 

In addition, pilot testing studies (of roughly 100 tests each) could be conducted in 

selected metropolitan rental markets to produce rigorous estimates of discrimination against 

persons who are blind (with or without guide dogs), against persons who are deaf and visit 

rental properties in person (with or without a sign language interpreter), and against persons 

with mental illness or with cognitive or developmental disabilities (with or without a companion). 

All of these testing strategies are feasible and have the potential to identify patterns of 

discrimination facing persons with disabilities. However, as discussed in Chapter 2, extra time 

and resources will be necessary to implement them effectively. 

The experience from this study also suggests that testing for discrimination against 

persons with disabilities could effectively be extended to the sales market as well as the rental 

market. We also recommend further exploratory work focusing on housing for the elderly, 

including homeowner communities and assisted living and continuing care facilities. However, 

testing in these types of facilities—which provide both housing and health care—raises 

additional issues about testers’ assigned characteristics and about application procedures. 

One of the issues raised by the expert panel of advisors to this study was whether it 

would be feasible to produce pooled estimates of discrimination against persons with different 

types of disabilities, rather than separate estimates for each disability type. To the extent that 

tests focus on differential treatment rather than reasonable modification and accommodation, 

pooled estimates may be feasible. For example, in the exploratory phase of this study, out of a 

total of 48 paired tests, 25 (or 52 percent) documented treatment that favored the nondisabled 

tester over the tester with a disability, while only 1 (or 2 percent) documented treatment that 

favored the tester with a disability. 

Pooling tests in this way has the advantage of providing information that is relevant to 

more persons with disabilities for the same total number of tests. However, pooling across 

types of disabilities poses disadvantages as well. First, we do not believe that pooled results 

can be generated on questions about whether housing providers allow reasonable modification 

or provide reasonable accommodation, because the modification and accommodation requests 

differ significantly across types of disabilities. Second, conducting tests across different types of 

disability is likely to be more costly and time-consuming than conducting the same number of 

tests of a single type of disability, because of the complexities of recruitment, training, and 

accommodation. 

56 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

Implications for Policy and Practice 

The high levels of adverse treatment documented in this study call for heightened public 

education and enforcement. As a first step, results from the pilot phase should be used in a 

public education campaign to inform housing providers (and other businesses) about the 

operation of TTY systems and about their importance as a communication tool for persons who 

are deaf. Refusing to conduct business with a TTY caller effectively slams the door on a 

customer who is deaf or who has some other communication-related disability. Similarly, results 

from this study showing a high incidence of adverse treatment against testers using 

wheelchairs, the refusal of some housing providers to allow reasonable unit modification or 

provide reasonable parking accommodation should be used to educate housing providers about 

their obligations under the federal Fair Housing Act. 

 Paired testing is not only feasible and effective as a research tool, but also as a tool for 

detection and enforcement. Based upon the experience gained in both the exploratory and pilot 

phases of this project, HUD should encourage local fair housing and disability rights 

organizations to conduct more paired testing for discrimination against persons with disabilities. 

Most local disability testing efforts to date have focused exclusively on issues of reasonable 

accommodation or reasonable modification. However, the DDS shows that it is possible to 

conduct paired tests of differential treatment against persons with disabilities, and that inquiries 

about reasonable modification or accommodation can effectively be appended to rigorous 

paired research tests without undermining the validity of comparisons to the treatment of 

nondisabled testers. 

57 
Discrimination Against Persons With Disabilities: 

Barriers At Every Step 

58 
ANNEX A 

Expert Panel 

59
 
 60
 
Measuring Discrimination Against People with Disabilities 

Expert Panel Meeting 

January 13 and 14, 2003 

Panel Members 

Michael Allen 

Bazelon Center for Mental Health Law 

Washington DC 

Julie Carter 

Kennedy Foundation Fellow 

Takoma Park, MD. 

Cathy Cloud 

Vice President 

National Fair Housing Alliance 

Washington, DC 

Katherine Copeland 

Executive Director 

Silver State Fair Housing Council 

Reno, Nevada 

Don Eager 

Donald Eager and Associates 

Lancaster, Ohio 

Fred Freiberg 

US Department of Justice 

Housing and Civil Enforcement 

Washington, DC 

Max Lapertosa 

Access Living 

Chicago, IL 

Robert Liston 

Director 

Montana Fair Housing 

Missoula, Montana 

Joan Magagna 

US Department of Justice 

Housing and Civil Enforcement 

Washington, DC 

Bonnie Milstein 

Magar and Milstein 

San Francisco, California 

Susan Prokop 

Associate Advocacy Director 

Paralyzed Veterans of America 

Washington, DC 

Jeff Rosen 

General Counsel 

National Council on Disability 

Washington, DC 

Susan Scovill 

Housing Opportunities Made Equal (HOME) 

of Richmond 

Richmond, Virginia 

Jeanine Worden 

US Department of Justice 

Housing and Civil Enforcement 

Washington, DC 

HUD Staff 

Linda Cruciani - OGC 

Assistant General Counsel 

Fair Housing Enforcement Division 

Barbara Elkin - OGC 

Attorney Advisor 

Fair Housing Compliance Division 

Harry Carey - OGC 

Associate General Counsel 

Office of Fair Housing 

Dale Rhines 

Program Analyst 

Office of Enforcement 

David Enzel - FHEO 

DAS For Enforcement and Programs 

Beth Frank - FHEO 

Deputy Director 

Office of Enforcement 

61
 
Kevin Neary - PDR 

Director, Program Evaluation Division 

Richardson, Todd - PDR 

GTR, Program Monitoring and Research 

Division 

Milton Turner - FHEO 

Director, Compliance and Disability Rights 

Division 

Urban Institute Staff/Consultants 

Margery Turner 

Project Director 

Metropolitan Housing and Communities 

Policy Center 

Julie Fenderson 

Metropolitan Housing and Communities 

Policy Center 

Carla Herbig 

Consultant 

Deborah Kaye 

Metropolitan Housing and Communities 

Policy Center 

Diane Levy 

Metropolitan Housing and Communities 

Policy Center 

Sara K. Pratt 

Consultant 

Kimberlee Ross 

Metropolitan Housing and Communities 

Policy Center 

62 
ANNEX B 

Test Authorization Form (TAF) 

and 

Advance Call Form 

63
 
 64
 
 

DDS TAF Data Entry Form - Rental Tests 

SITECODE: 

WEEK: 

CONTROL: 

UI Internal Test Site DDS 

0 

XX-02-0005-D 

Go 

TRANTYPE Transaction Type Rental 

SITECODE SITE UI Internal Test Site DDS 

WEEK Week 0 

AD_NO Ad Number ***** 

CONTROL CONTROL # XX-02-0005-D 

ISSUEDTE Date of Issuance (mm/dd/yy) 01/01/01 

ORGNAME Organization UI Internal Test Site DDS 

SAMPNAME Sampler Code 

TESTTYPE Testing Type 2 

SEQUENCE Required Sequence Disabled/Non Disabled 

NARRATIV Narrative Required Yes 

UNITYPE Unit Type -1 

SRCETYPE Source Type 

ADDATE Date the Ad appeared (mm/dd/yy) 

SRCENAME Source Name -1 

EDITION Edition (if applicable) 

GEOG Location of Ad (Page, Column, Etc) 

TH01 

ADTEXT Text of Ad 

TH02 

EDITNAME Editor Name 

RELEASE Release this test? Yes 

Enter a Advance Call 
66
 
Disability Discrimination Study 

ADVANCE CALL FORM 

Complete one form for each call attempted 

CONTROL # ___ ___ – ___ ___ – ___ ___ ___ ___ – D Person making call: 

Phone Number(s): (_____) ; (_____) 

Day of Week: Date: __ __/ __ __/ __ __ Time: __ __:__ __ AM PM 

1. Were you able to obtain housing information during this call? 

Yes (skip to Q2) No (go to Q1a) 

1a. If No, why not? 

Left Message on Voicemail, Answering Machine, or Paper 

Left Message with Person who did not have information 

 Told to Call Back Later 

Wrong Number 

No Answer 

 Telephone Number No Longer in Service 

Other (Specify): 

(SKIP to Question 7) 

2. Housing Information (enter one type of unit [i.e., bedroom size] per line): 

Address of Unit # of 

Bdrms 

# of 

Units 

Price Date 

Available* 

__ __/ __ __ 

Advertised Unit? 

a. Yes No Not Sure 

b. Yes No Not Sure 

c. Yes No Not Sure 

d. Yes No Not Sure 

e. Yes No Not Sure 

67 
3. If this is a multi-unit building, does it have 4 or fewer units? Yes No 

3a. If Yes, does the owner live in the building? Yes No 

4. What are the office hours (include weekend and evening hours where available)? 

For In-Person Tests 

5. Is it possible to drop in to speak with a housing provider about the available housing? 

Yes (you may drop in) No (you must have an appointment) 

5a. Verify the address to be visited: 

6. With whom did you speak? 

7. Is this the final advance call? Yes No 

7a. If Yes, based on the results of the advance call, is the housing ineligible for any reason? 

Yes No 

7b. If Yes, please specifiy the reason(s) for ineligibility: 

 Housing provider could not be reached after repeated attempts 

 Telephone number was no longer in service 

 Telephone number was incorrect

 No housing available

 Only housing available has 3 or more bedrooms 

 Small owner (4 units or fewer) 

 Single-Family Home

 Mobile Home 

 Seasonal/temporary/vacation/short-term 

 Outside of target area 

 Exceeds rent limit for target area 

 Share situation 

Sublet 

 Apartment locator service 

For-Fee Service 

 Public/Section 8 housing/LIHTC development 

 Housing for older persons 

68 
 Other (specify): 

8. Comments: 

69 
70
 
ANNEX C 

TTY Testing Forms 

71
 
72
 
DDS Test Assignment Form - Rental (Telephone) 

TEST SITE 

PPNAME 1 

2 

3 

4 -1 

12 

13 

provider 

ADATEV DATE OF CALL (mm/dd/yy) 

ATIMEV TIME OF CALL (_ _:_ _) 

ATIMEVM A.M. P.M. for TIME OF CALL 

header9 

Name of Test site (if known) ***** 

header11 Site Address (if known) 

PADDRS street ***** 

PPHN2 Second Number: (000)000-0000 ***** 

header20 SOURCE OF INFORMATION ON TEST SITE 

SRCENAME Advertisement: Name of source 

Minimum number of bedrooms for 

household 

Type of unit 

Date Housing is Needed (mm/dd/yy) 01/01/01 

PHMPRI Price of housing ***** 

PHHCOMP Household Composition Single Adult 

APRIR Price Range [Tester may consider units for 

LESS than this range as well] 1100 to 1300 

APREFER Area Preference (IMPORTANT: DO NOT CITE A NEIGHBORHOOD 

PREFERENCE) 

AAREAP If you are pressed by the agent, you may 

state that you are looking in 

header33 Remember: You are open to any areas recommended by the housing 

header1 Telephone (TTY) Rental Assignment 

SITECODE SITE UI Internal Test Site DDS 

CONTROL 0 CONTROL # XX-01-0002-D 

SEQUENCE Tester sequence 2 

DISID DISABILITY ID Disabled 

TESTERID 0 TESTER ID NUMBER (No Tester Assigned) 

ATSTTYPE 0 TYPE OF TEST rental 

AAPPTYPE 0 TYPE OF APPROACH -1 

PCITY 2 city ***** 

PSTATE 2 state 

ZIP 00000 

***** 

PZIP 2 ***** 

Head171 Telephone number(s) of test site: 

PPHN1 3 First Number (000)000-0000 ***** 

ADDATE 5 Advertisement: Date of Publication 

(mm/dd/yy) 

6 

PBEDS 7 1 

PMINBED 7a 1 

PHMTYPR 8 

PHNEED 

-1 

9 

10 

11 

ADTEXT Advertisement: text of ad 

header24 TYPE OF HOUSING TO BE REQUESTED 

Number of Bedrooms to be requested 

AMOVERR 14 Reason for Moving 
ASSIGNED CHARACTERISTICS 

15 Tester Name: 

Tester Address 

16 

16 

17 

18 -1 

18 -1 

18 -1 

Gross 

Annual 

19 

19 

AOCC1 20 Tester current occupation 

20 

20 

20 

20 -1 

Type of current housing: Rent 

21 

21 -1 

21 

22 

Yes 

AHEAD55 Other places visited: Just started looking 

header36 

TFNAME 

header38 

TFADD1 Tester Address 

TFADD2 Tester Address (city/state/zip) 

TVPHONE Voice Mail Number Assigned to Tester 

(000)000-0000 

header42 Information on Persons in Household 

ARACE1 Tester's race 

TSEX Tester's gender 

AAGE1 Tester's age 

TH01 Household 

Income Income 

AINCMON1 Tester 4925 59100 

AINCMONT Total for Household 4925 59100 

TH02 

header73 Employment Information 

AEMP1 Name of tester's current employer 

AEAD11 First line of tester's employer's address 

AEAD12 Second line of tester's employer's address 

AELNG1 Length of employment at current job 

AHEAD21 Credit standing: Excellent, no late payments 

header13 CURRENT HOUSING SITUATION 

AHEAD31 

ARENTNOW Amount of Current Rent 1190 

ALGNCUR Years at Current Residence 

ALEASETP Type of Rental Agreement at Current 

Residence 

AHEAD61 History of rent payment at current residence: Always on time. 

AHEAD62 Other characteristics: Non-smoking, No pets 

AOTHINFO Other Test Information 

RELEASE Test Released 

THE INFORMATION ON THIS PAGE IS CONFIDENTIAL, IF YOU PRINT THIS PAGE OUT, PLEASE DO 

NOT SHARE IT WITH ANYONE OUTSIDE THE DDS PROJECT. 
Disability Discrimination Study – Pilot Phase 

TEST INSTRUCTIONS 

Scenario: Communication Disability

 Telephone 

 Differential Treatment 

A. Conducting the Test 

There are some tasks that all DDS testers are expected to 

complete on every test of a housing provider. These tasks are 

detailed below and will always be attached to the Test Assignment 

Form. 

• Review and refer to your test assignment 

You should review your test assignment thoroughly and keep it with 

you during your telephone call so that you can refer to it if 

necessary. The housing provider may ask you questions about 

your personal situation or financial circumstances, and you will 

need to be prepared to answer them. 

• Call the housing provider in response to the advertised 

housing. Be persistent when trying to reach the housing 

provider 

The disabled tester will call the housing provider using a TTY/TDD 

machine and a relay operator. The non-disabled tester will call the 

housing provider directly. 

You will be required to make five (5) attempts to reach a housing 

provider within 24 hours. You should call at different times of the 

day. Never leave a message on an answering machine or with a 

person who cannot discuss the housing with you. If you cannot 

reach the housing provider within 24 hours, notify your Test 

Coordinator. 

75 
• Take Notes 

It is essential that testers take good notes during the telephone 

call. You will need these notes in order to complete the test report 

forms and narrative after your test has been completed. 

• Inquire about the available rental housing 

You should confirm the availability of rental housing options when 

you call the housing provider. There is an order or sequence that 

you should follow in asking about available rental housing. 

Step 1 

Always inquire about the availability of any 

rental housing that has the same number of 

bedrooms as you are assigned. If it is 

available, express interest in it. Remember, 

the housing must be within your assigned price 

range and available when you need it. 

Step 2 

If no housing is available with the number 

of bedrooms assigned, inquire about any 

other rental housing that might meet your 

needs. Remember, the rental housing must be 

in your assigned price range and available 

when you need it, according to your 

assignment. 

If, at any point during the test, a housing provider offers or recommends 

that you consider a home or apartment, you should express interest in it, 

provided that the rental housing is (1) within your price range and (2) 

available for when you need it. 

• Obtain information about the available rental housing 

Testers must express interest in and obtain detailed information 

about homes or apartments that are suggested by a housing 

provider during the phone test. Whenever testers are informed 

about rental housing that meets their needs (i.e., bedroom size, 

price range and date of availability), it is vital that certain 

information is obtained about each home or apartment suggested, 

including the following: 

76 
/ Exact Address (and floor the unit is located on) 

/ Number of Bedrooms 

/ Rent Price 

/ Security Deposit 

/ Other Fees (if any) 

/ Length of Lease 

/ Date of Availability 

Testers may have to ask for some of the information listed above if 

it is not volunteered by the housing provider. 

Also, testers will inquire about the application process and if any 

fee is required. Testers should also make note of the purpose and 

amount of any other fees and if those fees would need to be paid at 

the time of application. 

Remember, testers will never complete a rental application or 

formally apply for any rental unit. It is reasonable, however, for a 

prospective renter to inquire about any application fees that might 

be required prior to deciding whether to apply for available rental 

housing. 

If the housing provider asks if you would like an application mailed 

to you, be agreeable and provide your address. However, if the 

housing provider wants to make an appointment with you to come 

in to complete an application or view units, say that you are just 

beginning your housing search and are not interested in doing this 

at the present time. 

IF YOU ARE TOLD ABOUT A WAITING LIST, please follow 

these simple instructions: 

/ Ask how many people are on the waiting list. 

/ Ask how long it might take to be offered a unit. 

77 
/ Do not ask or agree to put your name on any waiting lists. 

• Obtain the name of the housing provider 

If the housing provider has not volunteered his or her name by the 

end of your call, please ask for it. 

• Allow the housing provider to suggest any follow-up contact 

Every call that a tester makes to a rental housing provider will come 

to an end. Testers should not initiate, suggest or offer to make any 

arrangements for future contact with the housing provider. As a 

tester, you may thank a housing provider for his or her assistance, 

but you must refrain from suggesting that you will get back to the 

housing provider or that the housing provider should contact you. 

Please permit the housing provider to suggest any follow-up 

contact. 

Following are some examples to illustrate how a test might unfold and how 

you should inquire about housing availability. These examples should NOT be 

viewed as “scripts” for how you should make your calls, but should serve as a 

guide on how to conduct the test while adhering strictly to the DDS protocols. 

78 
Advertised Housing: st that rents for $1300. 

Tester Assignment: th . Rent limit is $1325. 

Is it still available? 

th? 

th

th 

light. 

Tester: 

Tester: 

Felipe. 

Ok. 

EXAMPLE 1 

2-bedroom apartment available June 1 

2 bedroom apartment needed by June 15 

Housing Provider: Hello, Saguaro Apartments. 

Tester: Hi, I’m calling about the 2-bedroom apartment for rent. 

Housing Provider: No, I just rented that one. 

Tester: Do you have any other apartments that would be available by June 15 

Housing Provider: There is a 2-bedroom unit that should be available by the 15 . It rents for $1400. 

And then I will also have a 1-bedroom as well. That will rent for $1275. 

Tester: I’d be interested in the 1- bedroom then. Can you tell me about the unit? 

Housing Provider: It’s on the 4 floor of the building. The rooms are a nice size and there is plenty of 

The kitchen was updated a couple of years ago. There is laundry on the 

ground level of the building and an exercise room. 

Do you require a security deposit or any fees for applying? 

Housing Provider: The deposit is one month’s rent, but there aren’t any other fees. We do ask for 

 references though. 

Tester: And the apartment is available as of June 15th, right? How long is the lease? 

Housing Provider: It’s a one year lease usually. Yes, the apartment could be rented for June 15th. 

Thanks for the information. I’m calling about a few places I’ve seen advertised. 

What is your name, by the way? 

Housing Provider: Well, if you want to take a look at it, just stop by. 

Tester: Thanks again. 

79 
Advertised Housing: st that rents for $1300. 

Tester Assignment: th . Rent limit is $1325. 

. 

Is it still available? 

ial on 

Sorry. 

Tester: 

EXAMPLE 2 

2-bedroom apartment available June 1 

2-bedroom apartment needed by June 15 

Disabled tester places call over a TTY/TTD machine via a relay operator 

Housing Provider: Hello, Saguaro Apartments. 

Tester: Hi, I’m calling about the 2-bedroom apartment for rent. 

Housing Provider: What kind of call is this? 

Tester: I’m calling through a relay operator because I can’t speak to you directly. 

Housing Provider: I’m sorry. I’m not set up to take such a call. 

Tester: The relay operator can help us communicate. You don’t need anything spec
 

your end to take the call. 

Housing Provider: I’m just swamped right now and can’t take the time. 

Can you tell me if the 2-bedroom apartment is still available? 

Housing Provider: No, it’s been rented. (hangs up phone) 

80 
Disability Discrimination Study 

TEST REPORT FORM - TELEPHONE CALL 

CONTROL # ___ ___ – ___ ___ – ___ ___ ___ ___ – D TESTER ID #: __ __ – __ __ __ 

1. Name of Test Site (if known): 

Phone Number(s): (_____) ; (_____) 

2. Address (if provided):

 (number) (street) 

(city) (state) (zip code) 

3. Date and Time of Call 

Date (month/day/year): _____/_____/_____ Day of week: 

Time: __ __:__ __ AM PM 

4. Time call began: __ __:__ __ AM PM 

Time call ended: __ __:__ __ AM PM 

5. This is call attempt number (circle): 1 2 3 4 5 

6. Was this call attempted using TTY/TDD- Relay Operator? Yes No 

7. Were you able to speak with a housing provider to discuss housing options? 

Yes 

No 

7a. If No, why not? 

 Told to call back later 

Wrong number 

 Housing provider hung up 

No answer 

 Telephone number no longer in service 

 Housing provider would not discuss housing

 Other (specify): 

(NOTE: IF NO, STOP HERE; DO NOT COMPLETE REST OF THE FORM) 

81 
8. Name of person with whom you spoke: 

9. When you asked about the availability for the type of rental housing that you were assigned 

(e.g., one bedroom), what were you told? [check only ONE box] 

 The rental housing is available when I need it

 The rental housing is NOT available when I need it 

 The housing provider did not know whether the rental housing was available 

Something else (specify): 

9a. How many units of this type were you told about? Units 

10. What were you told about any "other" rental housing ("other" rental housing has a different 

number of bedrooms than assigned, is within your price range, and is available when you 

need it)? [check only ONE box] 

 Other rental housing is available when I need it 

 Other rental housing is NOT available when I need it 

 The housing provider did not know whether other rental housing was available 

Something else (specify): 

10a. How many other units were you told about? Units 

11. How many TOTAL rental housing units did the housing provider tell you were available? 

(Add units from 9a and 10a) Units 

12. Did the housing provider tell you that an application form of some kind must be completed 

before renting a unit? 

Yes 

No 

12a. Did the housing provider invite you to come in and pick up an application or offer to send you 

one? 

Yes 

No 

12b. Did the housing provider tell you that a credit check was part of the application process? 

Yes 

No 

82 
12c. Did the housing provider tell you that a co-signer would be needed as part of the application 

process?

 Yes 

No 

12d. Did the housing provider tell you that a criminal background check was part of the application 

process?

 Yes 

No 

13. Did the housing provider request information about your income, source of income or 

occupation?

 Yes 

No 

If yes, please record what the housing provider said? 

14. Did the housing provider make any remarks about disability or persons with disabilities? 

Yes 

No 

14a. If Yes, please record what the housing provider said: 

15. Did the housing provider make any remarks about accessibility or units that were 

 "handicapped" accessible? 

Yes 

No 

15a. If Yes, please record what the housing provider said: 

83 
16. Did the housing provider make any remarks about race/ethnicity, religion, or families with 

children? 

Yes 

No 

16a. If Yes, please record what the housing provider said: 

17. Where you referred to the following during your call? 

 Assisted living 

 Nursing home 

Group home 

 Low income housing 

Other

 None 

18. What arrangements were made regarding future contact between you and the housing 

provider [check all that apply]? 

 The housing provider said that he/she would call you back 

 The housing provider invited you to call him/her back 

 The housing provider invited you to come in to inspect units/pick up application 

 Future arrangements were not made 

Other (specify): 

19. When was this report completed? 

Date (month/day/year): _____/_____/_____ Day of week: 

Time: __ __:__ __ AM PM 

Did you receive assistance in completing form? Yes No 

If Yes, who assisted you? 

(print) 

84 
Disability Discrimination Study 

AVAILABLE RENTAL UNIT FORM (Telephone Call) 

CONTROL # ___ ___ – ___ ___ – ___ ___ ___ ___ – D TESTER ID #: __ __ – __ __ __ 

1. Address: 

(number) (street) (unit #) 

(city) (state) (zip code) 

2. Type of building: 

 Multi-unit building with 5 or more units (apartments, condos, etc.) 

 Single family home 

Mobile home 

 Something else (e.g., apartment building with 4 or fewer units) 

Basic Information 

3. Is this the advertised unit? Yes No Not Sure 

4. Date available: / / 

5. How much is the rent? $ / month 

6. Number of bedrooms: 

7. How many floors in the building? 

8. Unit is on what floor? 

9. What did the housing provider tell you about the unit's accessibility? 

 Unit is "handicapped" accessible 

 Unit is not "handicapped" accessible 

 Unit accessibility was not discussed 

10. Length of lease? (check all that apply) 

Month-to-month One-year 

Three-month Two-year 

 Six-month Other (specify): 

85 
11. FEES (e.g., pet fee, parking, cleaning, etc.) 

Name/Purpose Amount When Paid? 

Application $ At Application 

After Move in 

At Application 

After Move in 

Security Deposit $ 

$ At Application 

After Move in 

$ At Application 

After Move in 

$ At Application 

After Move in 

$ At Application 

After Move in 

11a. Did the housing provider say that any of the above fees were negotiable? 

Yes No 

11b. If yes, what did the housing provider say? 

How Often? 

One-time

 Monthly 

One-time

 Monthly 

One-time

 Monthly 

One-time

 Monthly 

One-time

 Monthly 

One-time

 Monthly 

86 
Waiting List 

12. Were you told that there was a waiting list for this unit? Yes No 

12a. If Yes, how many people were you told were on the list? 

12b. If Yes, how long would it take to be offered a unit? 

12c. If Yes, did the housing provider offer to place your name on the list? Yes No 

Financial Incentives / Specials 

13. Did the housing provider inform you that you might be able to take advantage of any financial 

incentives or specials if you decided to apply for and/or rent this unit? 

Yes No 

13a. If Yes, what were you told? 

No 

Date form completed: ___ ___ / ___ ___ / ___ ___ 

Did you receive assistance in completing form? Yes 

Person completing form:

 (print) 

87 
88
 
Disability Discrimination Study

FOLLOW-UP CONTACT FORM 

• COMPLETE ONE FORM FOR EACH CONTACT 

• DO NOT USE THIS FORM FOR APPOINTMENT CALLS 

• TESTER: NOTIFY TEST COORDINATOR OF ANY CONTACT AND FORWARD MATERIALS RECEIVED 

CONTROL # ___ ___ – ___ ___ – ___ ___ ___ ___ – D TESTER ID #: __ __ – __ __ __ 

1. Date and time of contact: 

 Day of the week: 

Date: ___ ___/ ___ ___/ ___ ___ 

Time: ____:____ AM PM 

2. Type of Contact: 

 Telephone call to tester at home 

 Telephone message left at tester's home 

 Voice Mail message retrieved by Test Coordinator 

Postal mail 

E-mail 

Other (specify): 

3. Name of person making contact: 

4. Name of agency (if given): 

5. What was the stated purpose of the contact? (check all that apply) 

 Housing provider wanted to see if tester is still interested in renting 

 Housing provider wanted to let tester know about more available units

 Housing provider wanted to get more information from tester 

 Housing provider wanted to provide information about accommodation/ 

modification 

 Housing provider wanted to thank tester 

Other (specify): 

6. Describe any materials received: 

 89 
90
 
ANNEX D 

Wheelchair Testing Forms 

91
 
 92
 
DDS Test Assignment Form - Rental (In-Person) 

AAPPTYPE 0 TYPE OF APPROACH 

TEST SITE 

PPNAME 1 

2 

Drop-In 

ADATEV DATE OF VISIT (mm/dd/yy) 

ATIMEV TIME OF VISIT (_ _:_ _) 

ATIMEVM A.M. P.M. for TIME OF VISIT 

header9 

Name of Test site (if known) ***** 

header11 Site Address (if known) 

PADDRS street ***** 

header1 In-Person Disability Rental Assignment 

SITECODE SITE UI Internal Test Site DDS 

CONTROL 0 CONTROL # XX-02-0002-D 

SEQUENCE Tester sequence 1 

DISID DISABILITY ID Non Disabled 

TESTERID 0 TESTER ID NUMBER (No Tester Assigned) 

ATSTTYPE 0 TYPE OF TEST rental 

PCITY 2 city ***** 

PSTATE 2 state 

ZIP 00000 

***** 

PZIP 2 ***** 

Head171 Telephone number(s) of test site: 

PPHN1 3 First Number (000)000-0000 ***** 

3 

4 Third source 

PPHN2 Second Number: (000)000-0000 ***** 

header20 SOURCE OF INFORMATION ON TEST SITE 

SRCENAME Advertisement: Name of source 

Minimum number of bedrooms for 0 household 

Type of unit Unfurnished 

Date Housing is Needed (mm/dd/yy) 04/15/04 

5 

6 

PBEDS 7 1 

PMINBED 7a 

PHMTYPR 8 

PHNEED 9 

ADDATE Advertisement: Date of Publication 

(mm/dd/yy) 

ADTEXT Advertisement: text of ad 

Gatewood Apartments. Studio-

$645, 1BR-$750. Covered 

parking available. Cable included! 

Rent special 1/2 off 1st month 

rent. Call 1-800-555-7676. 

header24 TYPE OF HOUSING TO BE REQUESTED 

Number of Bedrooms to be requested 

PHMPRI 10 Price of housing ***** 

PHHCOMP 11 Household Composition Single Adult 

APRIR 12 Maximum Rent Price 800 

HEADMOD Unit Modification (For Disabled Testers Only) 

If you are a disabled tester, ask the housing provider for one of the 

UNITMOD2 following:

-Modify entry 
-Modify bathroom 

14 

15 

ASSIGNED CHARACTERISTICS 

16 Tester Name: 

Tester Address 

17 

17 

17 

18 -1 

18 -1 

18 -1 

18 

is: 

Gross 

Monthly 

Gross 

Annual 

18 

18 

AOCC1 19 Tester current occupation 

19 

19 

19 

19 

Type of current housing: Rent 

21 760 

21 

-Modify switches 

-Change doorknobs to levers 

HEADACC2 If on-site parking is available, please ask for a parking accommodation. 

(For Disabled Testers Only) 

APREFER Area Preference (IMPORTANT: DO NOT CITE A NEIGHBORHOOD 

PREFERENCE) 

AAREAP If you are pressed by the agent, you may 

state that you are looking in 

header33 Remember: You are always open to considering any areas 

recommended by the agent. 

AMOVERR Reason for Moving 

AHEAD55 Other places visited: Just started looking 

header36 

TFNAME 

header38 

TFADD1 Tester Address 

TFADD2 Tester Address (city/state/zip) 

TVPHONE Voice Mail Number Assigned to Tester 

(000)000-0000 

header42 Information on Persons in Household 

ARACE1 Tester's race 

TSEX Tester's gender 

AAGE1 Tester's age 

DISCAUS 

(For Disabled Testers Only) If asked, 

please state that your cause of disability 

TH01 Household 

Income Income Income 

AINCMON1 Tester 3100 37200 

AINCMONT Total for Household 3100 37200 

THXX 

header73 Employment Information 

AEMP1 Name of tester's current employer 

AEAD11 First line of tester's employer's address 

AEAD12 Second line of tester's employer's address 

AELNG1 Length of employment at current job 

AHEAD21 Credit standing: Excellent, no late payments 

header13 CURRENT HOUSING SITUATION 

AHEAD31 

ARENTNOW Amount of Current Rent 

ALGNCUR Years at Current Residence 3 years 
22 

Yes 

ALEASETP Type of Rental Agreement at Current 

Residence Lease 

AHEAD61 History of rent payment at current residence: Always on time 

AHEAD62 Other characteristics: Non-smoking, No pets 

RELEASE Test Released 

THE INFORMATION ON THIS PAGE IS CONFIDENTIAL, IF YOU PRINT THIS PAGE OUT, PLEASE DO 

NOT SHARE IT WITH ANYONE OUTSIDE THE DDS PROJECT. 
96
 
Disability Discrimination Study – Pilot Phase 

TEST INSTRUCTIONS 

Scenario: Wheelchair User 

In-Person 

 Differential Treatment

 Unit Modification/Parking Accommodation 

A. Conducting the Test 

In DDS, there are only two approaches that testers will make when conducting 

in-person tests: 

• A tester will drop in to visit a housing provider in response to an 

advertisement or listing for available housing;

 or 

• A tester will arrive for an appointment that was arranged by 

telephone with the housing provider in response to an advertisement 

or listing for available housing. 

The approach to be made by a tester will be determined by the Test Coordinator 

and specified on the Test Assignment Form. 

There are some tasks that all DDS testers are expected to complete on every 

test of a housing provider. These tasks are detailed below and will always be 

attached to the Test Assignment Form. 

• Review your test assignment 

You should review your test assignment thoroughly and make sure you 

have memorized your characteristics. The housing provider may ask you 

questions about your personal situation or financial circumstances, and 

you will need to be prepared to answer them. 

• Take Notes 

It is essential that testers take good notes during the test. It is perfectly 

natural for prospective renters to jot down information about the terms and 

conditions of renting available homes and apartments during their search 

for housing. You will need these notes in order to fill out the Test Report 

Forms after your test has been completed. 

97 
• Inquire about available rental housing 

Even if you have an appointment for your test, you should still confirm the 

availability of rental housing options when you arrive for your visit. There 

is an order or sequence that you should follow in asking about available 

rental housing: 

Step 1 

Always inquire about the availability of any rental housing 

that has the same number of bedrooms as you are assigned. 

If it is available, express interest in it. Remember, the 

housing must not be over your maximum rent amount and 

available when you need it. 

Step 2 

If no housing is available with the number of bedrooms 

assigned, inquire about any other rental housing that might 

meet your needs, according to your assignment. It must (1) 

have at least the minimum number of bedrooms; (2) not be 

over your maximum rent amount; and (3) be available when 

you need it. 

If, at any point during the test, a housing provider offers or recommends 

that you consider a home or apartment, you should express interest in it, 

provided that the rental housing meets your needs according to your 

assignment. 

• Obtain information about the available rental housing 

Testers must express interest in and obtain detailed information about 

apartments that are suggested by a housing provider during a test. 

Whenever testers are informed about rental housing that meets their 

needs (i.e., bedroom size, price limit and date of availability), it is vital that 

certain information is obtained about each apartment suggested, including 

the following: 

/ Exact Address (including unit #) 

/ Number of Bedrooms 

/ Rent Amount 

/ Security Deposit 

/ Other Fees (if any) 

/ Length of Lease 

98 
/ Date of Availability 

/ Application Process 

Testers may have to ask for some of the information listed above if not 

volunteered by the housing provider. 

When testers inquire about the application process, they will ask if any 

fee is required. Testers should also make note of the purpose and amount 

of any other fees and if those fees would need to be paid at the time of 

application. Remember, testers will never ask for or complete a rental 

application or formally apply for any rental unit. 

If the housing provider offers you a rental application, you should agree to 

take one with you and let the housing provider know that you will complete 

it if you decide later that you want to apply. 

• Ask to inspect any available units 

After you are told about all units that are available that meet your needs, 

you will then ask to inspect them. You are to try to inspect ALL units that 

you are told are available. You should also be open to inspecting model 

units and units that are similar to the ones that are actually available (such 

as the manager’s unit). 

• Be prepared to show your driver’s license or other ID 

The housing provider might request to hold your driver’s license or other 

ID or a copy of it for security purposes prior to showing you rental units. 

Be agreeable to this request. If the housing provider makes a copy of 

your license, make sure to get it back at the end of your visit. 

• Ask for a Unit Modification (Disabled Testers Only) 

If a unit is available and you are able to inspect it, you will ask if you can 

make a unit modification. You should try to wait until AFTER you have 

been told about all available units before making this request. 

Please follow the order listed below to determine which type of unit 

modification you should request. You may ask for more than one 

modification for a specific type, as indicated.
 

Modification Type 1: Modify unit entry way (you may ask for more 

than one of the following: widen doorway, remove threshold, install 

ramp, reverse swing of door) 

99 
Modification Type 2: Modify bathroom (you may ask for more than 

one of the following: widen doorway, remove cabinets under sink, 

install grab bars around toilet) 

Modification Type 3: Modify switches (you should ask for only one of 

the following: lower thermostat controls, lower light switches) 

Modification Type 4: Modify door handles (change doorknobs to 

levers) 

If you are unable to inspect an available unit [e.g., tenants still living there, 

housing provider can’t find the key, etc.], you should ask if you can install 

a grab bar around the toilet area. 

• Ask for a Parking Accommodation (Disabled Testers Only) 

If a unit is available and the test site has on-site parking, you will ask if a 

“handicapped-accessible” parking space can be made available near the 

unit or building entrance. If the housing provider says that another type of 

parking space could be made available to you, ask if the space can be 

made “handicapped accessible.” 

• If you are told about a Waiting List, please follow these instructions: 

/ Ask how many people are on the waiting list. 

/ Ask how long it might take to be offered a unit. 

/ Do not ask to or agree to put your name on any waiting lists. 

• Obtain the name of the housing provider 

If the housing provider has not volunteered his or her name by the end of 

your visit, please ask for it. 

• Allow the housing provider to suggest any follow-up contact 

At the conclusion of your test visit, you should NOT initiate, suggest or 

offer to make any arrangements for future contact with the housing 

provider. You should simply thank the housing provider for his or her time 

and assistance, but you MUST NOT suggest any kind of follow-up, such 

as “I will call you when I decide.” Please let the housing provider suggest 

any follow-up contact. 

• Conduct tester-initiated follow-up, if instructed 

Testers who receive an inconclusive or vague answer to their request for 

unit modification will be assigned to initiate a follow-up call to the housing 

100 
EXAMPLE 1 

Advertised Housing: 1-bedroom apartments from $480. 

Test Assignment: st . Price limit is $520. 

Tester: 

available? 

Housing Provider: 

Tester: 

Housing Provider: We will have 

Tester: 

st . 

Housing Provider: 

Tester: It looks nice.

Housing Provider: 

Tester: Sounds good. 

i

Housing Provider: 

Tester: That would be fine. 

provider. The Test Coordinator will let you know when such a call should 

be made. 

You will make three (3) attempts to make a follow-up call. You will ask to 

speak to the same housing provider with whom you spoke during your test 

visit. You will remind the housing provider who you are and what your 

request was (e.g., widen doorway, install a grab bar, lower light switches, 

etc.) 

Following are some examples to illustrate how a test might unfold and how you should 

inquire about housing availability, inspection, unit modification, and parking 

accommodation. These examples should NOT be viewed as “scripts” for how you 

should conduct your visit, but should serve as a guide to conducting the test while 

adhering strictly to the DDS protocols. 

 1-bedroom needed by July 1 

Hi, I’m here about the 1-bedroom apartment that was advertised. Is it still 

No, I’m sorry, it’s just been rented. 

Oh, that’s too bad. Would you have anything else available? 

Well, we do have a 2-bedroom, but that’s going for $520. 

another 1-bedroom August 1st. Would you like to see that one? 

I think I would be interested in the 2-bedroom. I really do need to find a 

 place by July 1 Would I be able to see that unit right now? 

Sure, it’s vacant now. (They enter the unit.) See, we’ve just painted the 

whole place and put in new tiling in the bathroom and kitchen. 

 What kind of lease is there? 

It’s a year lease for the first year and then month-to-month after that. The 

security deposit is one month’s rent. 

What would I need to do to apply if I were interested in this 

 un t? 

You would need to fill out an application and there is a $25 credit check fee 

for each person in the household. 

Oh, you know, I would need a grab bar around the 

toilet area. Would I be able to put one in? 

101 
EXAMPLE 2 

Advertised Housing: 1-bedroom apartments from $480. (Building does not have on-site 

parking.) 

Test Assignment: st . Price limit is $520. 

Tester: 

available? 

Housing Provider: 

Tester: st? 

Housing Provider: 

Tester: 

Housing Provider: 

notice. 

Tester: Oh, I see. 

Housing Provider: rd

Tester: And what kind of lease is required? 

Housing Provider: 

Housing Provider: 

Tester: 

Housing Provider: 

Tester: 

Housing Provider: 

Tester: 

Housing Provider: Uh, Joe. Yeah, okay. 

Tester: 

Well, I don’t know. I would have to talk to the owner. 

Okay, maybe you could find out for me. Oh and also, would I be able to 

get a parking space? I would need it to be handicapped-accessible and 

 close to the building entrance. 

All the units come with an assigned parking space. 

Could the space be made accessible for my van and marked as 

 handicapped? 

No, I’m sorry we couldn’t do that. 

Oh, okay, thanks...I’m sorry, what was your name again? 

Thanks, Joe. 

 1-bedroom needed by July 1 

Hi, I’m here about the 1-bedroom apartment that was advertised. Is it still 

No, sorry, it’s already been rented. 

Well, would you have anything else available July 1 

That’s the only 1-bedroom we had. I have a 2-bedroom available, but that 

 is going for $500. 

Well, that’s in my price range. Would I be able to take a look at it today? 

Uh, well, the tenants are still in there and I would need to give them 24-hour 

Well, could you tell me about it then? 

Well, what do you want to know? It’s a 2-bedroom on the 3 floor, the rent 

is $500, and the security deposit is the same. 

It’s a one-year lease, no exceptions. 

102 
Tester: That sounds fine. 

Housing Provider: 

Tester: 

think I coul 

Housing Provider: 

Tester: Okay, then. 

Housing Provider: Joe. 

Tester: 

What would I need to do to if I wanted to apply? 

You would need to fill out an application and there is a $25 credit check fee 

for each person in the household. Anything else? 

Well, yes, actually. If there isn’t already a grab bar around the toilet, do you 

d be put one in if I decided to rent the place? 

No, that wouldn’t be possible. You know, we can’t have tenants just putting 

in anything they wanted. That would just be crazy. 

 Thanks very much for your time, I’m sorry what did you say 

 your name was again. 

Thanks, a lot, Joe. 

103 
104 
Disability Discrimination Study 

TEST REPORT FORM (In-person) 

CONTROL # ___ ___ – ___ ___ – ___ ___ ___ ___ – D TESTER ID #: __ __ – __ __ __ 

1. Name of Test Site (if available): 

2. Address: 

(number) (street) 

(city) (state) (zip code) 

3. Type of Visit: Drop-In Appointment 

4. Date and Time of Site Visit: 

Date (month/day/year): _____/_____/_____ Day of week: 

Assigned Time (if applicable): __ __:__ __ AM PM 

Appointment Time (if applicable): __ __:__ __ AM PM 

5. Time visit began: __ __:__ __ AM PM 

Time visit ended: __ __:__ __ AM PM 

6. Information on the primary person with whom you had contact during your visit: 

Name: 

Position: 

Approximate Age: Race/ethnicity: 

Gender: M F 

Discernable disability: Yes No 

If Yes, please specify: 

7. Were you able to meet with a housing provider to discuss housing options? 

Yes 

No 

7a. If No, why not? 

(NOTE: IF NO, STOP HERE; DO NOT COMPLETE REST OF THE FORM) 

105 
8. If you had an appointment, how many minutes did you wait to meet with someone (i.e. 

between the time you were greeted by someone when you entered and the time you met 

with the housing provider? 

minutes 

9. When you asked about the availability for the type of rental housing that you were assigned 

(e.g., one bedroom), what were you told? [check only ONE box] 

 The rental housing is available when I need it

 The rental housing is NOT available when I need it 

 The housing provider did not know whether the rental housing was available 

Something else (specify): 

9a. How many units of this type were you told about? Units 

10. What were you told about any "other" rental housing ("other" rental housing has a different 

number of bedrooms than assigned, is within your price range, and is available when you 

need it)? [check only ONE box] 

 Other rental housing is available when I need it 

 Other rental housing is NOT available when I need it 

 The housing provider did not know whether other rental housing was available 

Something else (specify): 

10a. How many other units were you told about? Units 

11. How many TOTAL rental housing units did the housing provider tell you were available? 

(Add units from 9a and 10a) Units 

12. Did the housing provider tell you that an application form of some kind must be completed 

before renting a unit? 

Yes 

No 

12a. Did the housing provider ask you to complete an application during your visit or give you an 

application to take with you? 

Yes 

No 

106 
12b. Did the housing provider tell you that a credit check was part of the application process? 

Yes 

No 

12c. Did the housing provider tell you that you would need a co-signer as part of the 

 application process?

 Yes 

No 

12d. Did the housing provider tell you that a criminal background check was part of the application 

process?

 Yes 

No 

13. Did the housing provider request information about your income, source of income or 

occupation?

 Yes 

No 

If yes, please record what the housing provider said? 

14. Were you referred to the following during your visit? 

 Assisted living 

 Nursing home 

Group home 

 Low income housing 

Other:

 None 

15. Did the housing provider make any remarks about disability or persons with disabilities? 

Yes 

No 

107 
15a. If Yes, please record what the housing provider said: 

16. Did the housing provider make any remarks about accessibility or units that were 

 "handicapped" accessible? 

Yes 

No 

16a. If Yes, please record what the housing provider said: 

17. Did the housing provider make any remarks about race/ethnicity, religion, or families with 

children? 

Yes 

No 

17a. If Yes, please record what the housing provider said: 

18. Did the housing provider provide you with any of the following items THAT YOU DID NOT 

 ASK FOR? 

Business card 

Brochure 

 Floor plan 

 Listing of available units 

 Lease/Rental Agreement 

Gift 

Other (specify): 

108 
19. What arrangements were made regarding future contact between you and the housing 

provider [check all that apply]? 

 The housing provider said that he/she would contact you 

 The housing provider invited you to call him/her 

 Future arrangements were not made 

Other (specify):
 

20. When was this report completed? 

Date (month/day/year): _____/_____/_____ Day of week: 

Time: __ __:__ __ AM PM 

Did you receive assistance in completing form? Yes No 

If Yes, who assisted you? 

(print) 

109 
_________________________________________________________ 

_________________________________________________________ 

_________________________________________________________ 

UNIT MODIFICATION (for disabled testers only) 

Q1. Which modification did you ask to make? (Check one category) 

 Modify entry (check all that apply) 

__ Install ramp 

__ Widen doorway 

__ Remove threshold 

__ Reverse swing of door 

 Modify bathroom (check all that apply) 

__ Widen doorway 

__ Remove cabinets under sink 

__ Install grab bars around toilet 

 Modify switches (check one) 

__ Lower thermostat controls 

__ Lower light switches 

 Change doorknobs to levers 

Q2. When you asked the housing provider if you could make the unit modification, what 

were you told? 

 The housing provider said that I could make the unit modification myself 

and pay for it (answer Q3). 

 The housing provider would make the unit modification, but I would have 

to pay for it (answer Q3). 

 The housing provider would make the unit modification at no cost to me 

(answer Q3). 

 The housing provider agreed to make some of the modifications and not 

others. Please explain:______________________________________ 

 The housing provider would not allow me to make the unit modification. 

 The housing provider had to check with someone else to see if the unit 

modification could be made. 

110 
_________________________________________________________________ 

_________________________________________________________________ 

_________________________________________________________________ 

 The housing provider had to check to see how much the unit modification 

costs. 

 The housing provider did not know if the unit modification could be made, 

and did not offer to find out. 

 Something else:_____________________________________________ 

Q3. Did the housing provider tell you that any conditions would be imposed if the unit 

modification were to be made (e.g., insurance, licensed contractor, waiver of 

liability, return to original state, extra deposit)? 

 Yes 

 No 

Q3a. If Yes, please describe? ______________________________________________ 

111
 
__________________________________________________________ 

__________________________________________________________ 

__________________________________________________________ 

________________________________________________________________ 

________________________________________________________________ 

________________________________________________________________ 

PARKING ACCOMMODATION (for disabled testers only) 

Q1. When you asked the housing provider if a “handicapped-accessible” parking 

space could be made available near an available unit / the building entrance, 

what were you told? 

 A “handicapped-accessible” parking space could be made available near 

an available unit / the building entrance (answer Q2). 

 A “handicapped-accessible” parking space could be made available, but 

not near an available unit / the building entrance (answer Q2). 

 A “handicapped-accessible” parking space could NOT be made available. 

 There is no “handicapped-accessible” parking. 

 The housing provider had to check with someone else to see if a 

“handicapped-accessible” parking space could be made available. 

 The housing provider had to check to see how much the “handicappedaccessible” parking space costs. 

 The housing provider did not know if a “handicapped-accessible” parking 

space could be made available, and did not offer to find out. 

 Something else: _____________________________________________ 

Q2. Did the housing provider tell you that any conditions would be imposed if the parking 

accommodation were to be made (e.g., additional cost). 

 Yes 

 No 

Q2a. If Yes, please describe? ______________________________________________ 

112
 
Disability Discrimination Study 

AVAILABLE RENTAL UNIT FORM 

In-Person Visit 

CONTROL # ___ ___ – ___ ___ – ___ ___ ___ ___ – D TESTER ID #: __ __ – __ __ __ 

1. Address: 

(number) (street) (unit #) 

(city) (state) (zip code) 

2. Type of building: 

 Multi-unit building with 5 or more units (apartments, condos, etc.) 

 Single family home 

Mobile home 

 Something else (e.g., apartment building with 4 or fewer units) 

Basic Information 

3. Is this the advertised unit? Yes No Not Sure 

4. What did you inspect? 

Available unit 

 Other unit similar to the available unit (e.g., model, manager's unit, recently rented unit) 

Nothing 

5. Date available: / / 

6. How much is the rent? $ / month 

7. Number of bedrooms: 

8. How many floors in the building? 

9. Which floor is the unit on? 

10. What did the housing provider tell you about the unit's accessibility? 

 Unit is "handicapped" accessible 

 Unit is not "handicapped" accessible 

 Unit accessibility was not discussed 

113 
11. Length of lease? (check all that apply) 

Month-to-month One-year 

Three-month Two-year 

 Six-month Other (specify): 

12. FEES (e.g., pet fee, parking, cleaning, etc.) 

Name/Purpose Amount When Paid? How Often? 

Application $ At Application One-time

 After Move in Monthly 

At Application One-time

 After Move in 

Security Deposit $ 

Monthly 

$ At Application One-time

 After Move in Monthly 

$ At Application One-time

 After Move in Monthly 

$ At Application One-time

 After Move in Monthly 

$ At Application One-time

 After Move in Monthly 

12a. Did the housing provider say that any of the above fees were negotiable? 

Yes No 

12b. If yes, what did the housing provider say? 

114 
Waiting List 

13. Were you told that there was a waiting list for this unit? Yes No 

13a. If Yes, how many people were you told were on the list? 

13b. If Yes, how long would it take to be offered a unit? 

13c. If Yes, did the housing provider offer to place your name on the list? Yes No 

Financial Incentives / Specials 

14. Did the housing provider inform you that you might be able to take advantage of any financial 

incentives or specials if you decided to apply for and/or rent this unit? 

Yes No 

14a. If Yes, what were you told? 

No 

Date form completed: ___ ___ / ___ ___ / ___ ___ 

Did you receive assistance in completing form? Yes 

Person completing form:

 (print) 

115 
116 
Disability Discrimination Study 

TESTER-INITIATED FOLLOW-UP FORM 

CONTROL # ___ ___ – ___ ___ – ___ ___ ___ ___ – D TESTER ID #: __ __ – __ __ __ 

1. Phone number called: (_____) -

2. Date and time of contact: 

 Day of the week: 

Date: ___ ___/ ___ ___/ ___ ___ 

Time: ____:____ AM PM 

3. This is call attempt number (circle): 1 2 3 

4. Was the follow-up call completed? 

Yes (go to Q5) 

No (check one box below) 

 Left message on voice mail, pager, etc. 

 Left message with person 

 Told to call back later 

No answer 

 Telephone number no longer in service 

Other (specify): 

5. When you asked the housing provider if you could make the unit modification, what were you 

told? 

The housing provider said that I could make the unit modification myself and pay 

for it. 

The housing provider would make the unit modification, but I would have to pay 

for it. 

The housing provider would make the unit modification at no cost to me. 

 The housing provider would not allow me to make the unit modification. 

The housing provider still did not know if I could make the unit modification. 

 The housing provider said the unit was no longer available. 

Something else: 

117 
6. Comments made by the housing provider: 

118 
Disability Discrimination Study

FOLLOW-UP CONTACT FORM 

• COMPLETE ONE FORM FOR EACH CONTACT 

• DO NOT USE THIS FORM FOR APPOINTMENT CALLS 

• TESTER: NOTIFY TEST COORDINATOR OF ANY CONTACT AND FORWARD MATERIALS RECEIVED 

CONTROL # ___ ___ – ___ ___ – ___ ___ ___ ___ – D TESTER ID #: __ __ – __ __ __ 

1. Date and time of contact: 

 Day of the week: 

Date: ___ ___/ ___ ___/ ___ ___ 

Time: ____:____ AM PM 

2. Type of Contact: 

 Telephone call to tester at home 

 Telephone message left at tester's home 

 Voice Mail message retrieved by Test Coordinator 

Postal mail 

E-mail 

Other (specify): 

3. Name of person making contact: 

4. Name of agency (if given): 

5. What was the stated purpose of the contact? (check all that apply) 

 Housing provider wanted to see if tester is still interested in renting 

 Housing provider wanted to let tester know about more available units

 Housing provider wanted to get more information from tester 

 Housing provider wanted to provide information about accommodation/ 

modification 

 Housing provider wanted to thank tester 

Other (specify): 

6. Describe any materials received: 

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HUD USER 

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