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Section 504 Grievance Procedure

Colorado Department of Local Affairs - Division of Housing

Policy Statement

Colorado Department of Local Affairs - Division of Housing (PHA) is committed to ensuring that no qualified individual with a disability shall, solely on the basis of disability, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance, as required by Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794), and its implementing regulations at 24 CFR Part 8.

This Grievance Policy provides a prompt and equitable means for resolving complaints alleging discrimination on the basis of disability in PHA's programs, services, or activities.

I. Definitions

  • Complainant: Any individual with a disability who believes they have been subjected to discrimination by the PHA on the basis of disability. This includes applicants, residents, and participants in PHA programs.
  • PHA: Colorado Department of Local Affairs - Division of Housing.
  • Section 504 Coordinator: The individual/individuals designated by the PHA to coordinate its efforts to comply with Section 504.
  • Grievance: A formal complaint alleging discrimination on the basis of disability.

II. Section 504 Coordinator

The PHA has designated the following individual as its Section 504 Coordinator:

Name: Katherine Helgerson Title: Director, Office of Rental Assistance; 504 Coordinator Address: 1313 Sherman St, Room #320  Denver, CO 80203 Phone: 303-864-7852/Option 9 Email: DOLA_DOH_Section504@state.co.us TTY/TDD: 303-864-7758

The Section 504 Coordinator is responsible for:

  • Receiving and investigating grievances.
  • Ensuring compliance with this policy.
  • Providing information about Section 504 and this grievance procedure.
  • Facilitating reasonable accommodations.
  • Providing training to department and division staff on Section 504 requirements and the grievance procedure.

III. Grievance Procedure

A. Informal Resolution

Complainants are encouraged, but not required, to attempt to resolve concerns informally before filing a formal grievance. Concerns can be discussed directly with the PHA staff member involved or with the Section 504 Coordinator. Informal resolution attempts do not extend the time limits for filing a formal grievance.

B. Filing a Formal Grievance

  • Who Can File: Any individual with a disability who believes they have been discriminated against by the PHA on the basis of disability.
  • Time Limit: A formal grievance must be filed in writing within 60 calendar days of the date of the alleged discriminatory act or the date the Complainant became aware of the alleged discriminatory act.
  • How to File: Grievances must be submitted in writing to the Section 504 Coordinator using the designated complaint form. If needed, the Section 504 Coordinator (or their designee) is available to help file the grievance. The grievance should include:
    • Complainant's name, address, and contact information.
    • A description of the alleged discriminatory act, including dates, times, and locations.
    • The name(s) of the individual(s) alleged to have committed the discriminatory act, if known.
    • The specific program, service, or activity involved.
    • The desired resolution or remedy.
    • Any supporting documentation.
    • The Complainant's signature.
  • Assistance with Filing: If a Complainant requires assistance in formulating a written grievance due to a disability, the Section 504 Coordinator will provide reasonable assistance.

C. Investigation

  1. Acknowledgement: Upon receipt of a formal grievance, the Section 504 Coordinator will send a written acknowledgment to the Complainant within 10 business days. The acknowledgment will confirm receipt of the grievance and provide an estimated timeline for investigation and resolution.
  2. Review and Investigation: The Section 504 Coordinator will conduct a thorough, impartial, and prompt investigation. This may include:
    • Interviewing the Complainant.
    • Interviewing PHA staff members or other individuals involved.
    • Reviewing relevant documents, policies, and procedures.
    • Gathering any other pertinent information.
  3. Confidentiality: All information related to the grievance will be treated with confidentiality to the extent possible, consistent with the need to conduct a thorough investigation and comply with legal requirements.

D. Resolution and Notification

  1. Proposed Resolution: Within 120 calendar days of receiving the formal grievance (or a mutually agreed-upon extension), the Section 504 Coordinator will issue a written decision to the Complainant. The decision will include:
    • A summary of the investigation findings.
    • A determination as to whether discrimination occurred.
    • If discrimination is found, a description of the proposed resolution or corrective action to address the discrimination and prevent its recurrence.
  2. Complainant's Response: The Complainant will have 10 calendar days from the receipt of the proposed resolution to accept or reject it. If the Complainant accepts the resolution, the PHA will implement the agreed-upon actions.
  3. Appeal Process: If the Complainant is not satisfied with the proposed resolution, or if the PHA determines that no discrimination occurred, the Complainant may appeal the decision.

IV. Appeal Process

  1. How to Appeal: An appeal must be submitted in writing to the PHA’s Deputy Director within 15 calendar days of the Complainant's receipt of the Section 504 Coordinator's decision. The appeal should state the reasons for dissatisfaction with the decision and provide any additional relevant information.
  2. Review of Appeal: The PHA’s Deputy Director will review the original grievance, the Section 504 Coordinator's decision, and the Complainant's appeal. They may conduct further interviews or gather additional information as deemed necessary.
  3. Final Decision: Within 30 calendar days of receiving the appeal, the PHA’s Deputy Director will issue a final written decision to the Complainant. This decision will be the final administrative decision of the PHA.

V. Retaliation Prohibited

The PHA prohibits retaliation against any individual who files a grievance, participates in an investigation, or exercises their rights under Section 504. Any individual who believes they have been subjected to retaliation should immediately contact the Section 504 Coordinator.

VI. External Remedies

This grievance procedure does not preclude a Complainant from pursuing other remedies available under federal, state, or local law. A Complainant may file a complaint with:

VII. Record Keeping

The Section 504 Coordinator will maintain records of all grievances filed, including the complaint, investigation findings, decisions, and any corrective actions taken. These records will be kept for a minimum of 3 years or as required by applicable regulations.

VIII. Policy Review

This policy will be reviewed periodically, at least every 2 years, to ensure its effectiveness and compliance with current laws and regulations.

Adopted by: Colorado Department of Local Affairs - Division of Housing

Last Revised: August 29, 2025

This form should be used to report problems or issues with this website. Questions pertaining to a program or service provided by DOH should be addressed to contact information located on the specific program pages.

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