2019 Analysis of Impediments to Fair Housing: Phase 1 Report

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housing: "The OHCD's website has continued to be successful in increasing awareness of housing rights and resources." In addition to the CAPER, the 2011 Analysis of Impediments notes, "Housing and social service professionals report that discrimination occurs more often, and may affect Micronesians more often than others but Micronesian immigrants are very unlikely to complain about mistreatment." 2011 Analysis of Impediments to Fair Housing, 2018 Action Plan of The Consolidated Plan (2015-2019) at Appendix E, page i. The agency's recognition of this discrimination is an important and critical step to ensuring compliance with fair housing laws. The agency submitted its Fair Housing Coordinator's Fair Housing Training, which included Marshallese translation on May 10, 2019. The agency's more up-to-date documents submitted did not detail how else it has addressed this discrimination. 2.4 Policy Accessibility The rest of this analysis focuses on how accessible and "user-friendly" the documents are for consumers. The reason for this approach is that if consumers do not have adequate and reasonable access to the forms and procedures, then the policies are rendered meaningless. Documents were reviewed to assess user-friendly brochures that utilize simple language and explanations, have relevant information about how to file complaints, and include other supports and resources (e.g., legal support agencies, language access info, etc.). The agency submitted some of its forms and notices regarding requests for reasonable accommodation. Overall, the forms were relatively simple and straightforward. However, they used legal language, which ensures compliance, but may be a barrier to access for certain members of the target population. For example, the Notice of Right to Reasonable Accommodation states If you have a disability and as a result of your disability you need: • A change in the rules or policies to give you an equal opportunity to take part in the Housing Choice Voucher (Section 8) program, or • A change in the way we communicate with you or give you information, you may ask for this kind of change, which is called a reasonable accommodation. If you can show that you have a disability and if your request is reasonable (does not pose "undue financial or administrative burden'), we will try to grant your request. Overall, the forms and notices are helpfully short and streamlined to increase usability, but can continue to improve through more accessible language for participants. OHCD may have produced other public -facing documents. The CAPER reported, "In addition, the County of Hawaii's OHCD partnered with the County of Hawaii's Aging and Disability Resource Center (ADRC) to provide Fair Housing brochures and information to their One Stop Resource Centers in Kona and Hilo .... To increase community outreach, the OHCD provided Fair Housing information for printing in the County of Hawaii's Silver Bulletin monthly newsletter which is distributed to about 3,500 senior citizens islandwide." CAPER at 26. The agency did not submit these brochures and other literature, and the reviewers are thus unable to determine their effectiveness in affirmatively furthering fair housing. Furthermore, the context 32