1. UFAS, Why applicable?
Simply Put, “It’s the Law”
Section 504 of the Rehabilitation Act of 1973 of which the Uniform Federal Accessibility Standards (UFAS) are the implementing standards.

2. Why the Renewed Emphasis on UFAS
Concern for the plight of persons with disabilities? Not exactly
Astute Advocacy Groups Bringing Suit
Department of Justice Settlement Agreement

3. Review of the Rules
All multifamily properties that fit the definition of “federally assisted” constructed since the Act went into force were expected to comply with UFAS:
5% of units must meet accessibility standards for persons with physical disabilities
An additional 2% for persons with visual impairments
Applies to all new construction projects and projects that fit the definition of “substantially altered” (75% ratio of cost of repairs/as rehabbed replacement cost of the improvements)

4. Additional Compliance Requirements
Any project undergoing rehabilitation of all of the following:
Kitchens
Baths
Door jambs

5. Additional Compliance Requirements
Any project undergoing rehabilitation of all of the following:
Kitchens
Baths
Door jambs
Accessibility measures must be implemented to the extent financially/physically feasible (the feasibility test must be met). Even if it is determined that full compliance is not feasible based on the feasibility test, compliance of components to the extent possible must be implemented.

6. Repair Classification
Critical Repair that can be deferred based on an approved Corrective Action Plan (CAP)
Percentage of Units done up front
Balance of the units subject to the CAP
Goal is to minimize tenant displacement 2

7. CORRECTIVE ACTION PLANS
Identify each deficiency
Describe physical remedies
Estimate costs
Set specific schedule
Fastest possible
Not > 1 yr without HQ approval

8. Other Accessibility Compliance Requirements
Fair Housing Act (first occupancy after March 13, 1991)
The Americans with Disabilities Act (ADA) Implemented on July 26, 1990