The Trainer

Complying with LEP Rules and Elevator Inspection Requirements

In this month's feature, we discussed how to comply with HUD's guidance on helping those with limited English proficiency (LEP) gain access to federally funded services and programs. Under guidance issued in 2007 and 2009, HUD requires housing entities to implement a plan that includes translating important materials and providing access to interpreters and outreach to persons with LEP.

Complying with LEP Rules and Elevator Inspection Requirements

In this month's feature, we discussed how to comply with HUD's guidance on helping those with limited English proficiency (LEP) gain access to federally funded services and programs. Under guidance issued in 2007 and 2009, HUD requires housing entities to implement a plan that includes translating important materials and providing access to interpreters and outreach to persons with LEP.

In our article on HUD's new requirements for elevator equipment inspections, we noted that beginning on Jan. 4, 2010, HUD has a new policy in regard to the responsibilities of REAC inspectors:

REAC inspectors will not enter or inspect enclosed rooms that house only elevator equipment. If the door to the room is not locked at the time of inspection, the REAC inspector will record a health and safety deficiency and will inspect the door.

If the room housing the elevator equipment contains other inspectable equipment, the room will be inspected. In addition, if the elevator equipment room provides the only access to another area, such as the roof or other common area, the room will be entered.

 

TRAINER'S QUIZ

INSTRUCTIONS: Each of the questions below has only one correct answer. On a separate sheet of paper, write down the number of each question, followed by the answer you have chosen—for example, (1) b, (2) a, and so on. The correct answers (with explanations) follow the quiz. Good luck!

QUESTION #1

Fill in the blank: Following the issuance of the final guidance in 2007 regarding access to assisted housing for persons with LEP, HUD determined that the only HUD-created document it considered vital is the _______________.

  1. basic financial disclosure document.

  2. zero-tolerance drug policy.

  3. lease.

QUESTION #2

Fill in the blank: After HUD issued guidelines on LEP in 2007, the agency was challenged in court by several organizations, including the _______________.

  1. National Multi-Housing Council and American Fair Housing Coalition

  2. American Fair Housing Coalition and National Apartment Association

  3. National Multi-Housing Council and National Apartment Association

QUESTION #3

It is against HUD policy to translate sections of a housing authority's Web site for persons with LEP. True or false?

  1. True.

  2. False.

QUESTION #4

Assisted housing managers should consider offering residents with LEP the assistance of interpreters as needed. True or false?

  1. True.

  2. False.

QUESTION #5

Fill in the blank: Prior to, or at the time of, a scheduled inspection, a site manager should make sure that elevator equipment is protected by _______________.

  1. permanent partitions, fencing, or screens

  2. temporary partitions, fencing, or screens

  3. a solid, impenetrable wall of concrete

QUESTION #6

If the REAC inspector does not have access to the elevator equipment room that contains other inseparable equipment or is an access route to other inspectable areas, the inspection will be ended. True or false?

  1. True.

  2. False.

QUESTION #7

Fill in the blank: At the time of inspection, the door to the elevator room should be _______________.

  1. left slightly ajar

  2. closed but with the key in the door

  3. locked

QUESTION #8

Fill in the blank: Through its certified inspectors, REAC conducts about _______________ physical inspections on HUD-owned, -insured, or -subsidized property annually.

  1. 10,000

  2. 20,000

  3. 30,000

 

ANSWERS & EXPLANATIONS

 

QUESTION #1

Correct answer: c

The lease is the only “vital” HUD-created document, the agency determined following concerns by the National Leased Housing Association and the American Association of Homes and Services for the Aging. That means that the lease is the only document that HUD expects housing providers to translate.

QUESTION #2

Correct answer: c

The two groups challenged HUD's final guidance, claiming that it was unlawfully vague and overly burdensome. A federal district court judge dismissed the suit, ruling that the guidance was “nonbinding.”

QUESTION #3

Correct answer: b

Housing providers are expected to consider translating other documents beside the lease to ensure meaningful access for persons with LEP. For example, the Cambridge Housing Authority is in the process of translating selected portions of its Web site into Spanish, Portuguese, and French/Haitian Creole to meet the needs of its greatest LEP populations.

QUESTION #4

Correct answer: a

HUD encourages site managers to reach out to the community and provide necessary assistance, such as using interpreters in person or through telephone services, as needed.

QUESTION #5

Correct answer: a

This is one of several steps that site managers can take if the inspector is to enter the elevator equipment room.

QUESTION #6

Correct answer: a

You must allow access to the REAC inspector, or the inspection will be terminated. In addition, the REAC inspector then would review the elevator certificates and inspect the operation of the elevators.

QUESTION #7

Correct answer: c

If the door is not locked at the time of inspection, the inspector will record a health and safety deficiency.

QUESTION #8

Correct answer: b

These inspections help to ensure that housing is decent, safe, sanitary, and in good repair.

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