ADA Best Practices Tool Kit for State and Local Governments

E. Effective Communication

From the moment people begin to arrive at a shelter, good communication between staff, volunteers, and residents is essential. Many shelter residents and volunteers might have communication-related disabilities, including those who are deaf or hard of hearing and those who are blind or who have low vision. People with mental retardation or psychiatric disabilities might also have communication difficulties in certain circumstances, such as registering, filling out applications for benefits, or trying to understand what benefits and services are available.

Under the ADA, shelter operators must provide “effective communication” to people with disabilities unless doing so would result in a fundamental alteration or would impose undue financial and administrative burdens.¹¹ Shelters that are part of a state or local government sheltering program must give “primary consideration” to the type of auxiliary aid or service preferred by the person with a disability;¹² they must defer to that choice unless another equally effective method of communication is available or the preferred method would impose an undue financial and administrative burden or fundamental alteration.¹³ This requirement applies even if a third party operates the shelter under an arrangement with the state or local government.

Advance planning is critical to ensuring effective communication during an emergency. Without such planning, it may be difficult or impossible to locate auxiliary aids and services and have them ready for use at the shelter. Advance planning will also alleviate the expense and burdens associated with providing auxiliary aids.

• Provide alternate format materials for people who are blind or who have low vision. People who are blind or have low vision may request documents and brochures in alternate formats (Braille, large print, or audio recording). Generally, shelter supplies should include alternate format versions of documents that are routinely made available to shelter residents. Having alternate formats available for distribution during an emergency requires advance planning. 
  
  When documents are prepared on the spot and alternate formats cannot be prepared in advance or produced as needed, shelter operators are still required to provide effective communication through alternate means.¹⁴ Often, the most effective solution in an emergency is to provide a person to read printed documents and, where applicable, someone to help fill out forms. People who serve as readers or provide assistance filling out forms must be “qualified” – in the context of an emergency shelter, this means being capable of and willing to read materials and complete forms as instructed by the person with a disability. 

• Ensure that audible information is made accessible to people who are deaf or hard of hearing. In emergency shelters, most information is conveyed through oral announcements. Shelter operators must ensure that people who are deaf or hard of hearing have access to this information in a timely and accurate manner. In some circumstances, qualified sign language or oral interpreters may be required by the ADA. In others, posting messages and announcements in written format on a centrally located bulletin board, or writing notes back and forth with residents who are deaf or hard of hearing, may suffice.
  
  The type of auxiliary aid or service required in a specific situation depends on several factors, including the length, complexity, and importance of the communication and the person’s language skills and history. For example, handwritten notes will not communicate information effectively to a person who cannot read. Similarly, providing a sign language interpreter will not be effective for a person who is hard of hearing and does not understand sign language. If it becomes an undue financial and administrative burden to obtain qualified sign language or oral interpreters at a shelter, then the ADA does not require them. However, advance planning can significantly reduce the costs and administrative burdens of making interpreters available.

• Provide a TTY for the use of people who are deaf or hard of hearing. Many people in shelters use telephones to apply for disaster relief benefits, arrange for transitional housing, and speak to family and friends. People who can use standard voice telephones typically make use of shelter telephones or cellular phones for this purpose. But without access to a teletypewriter (TTY), people who are deaf or hard of hearing and those who have speech disabilities are unable to communicate with others over the telephone.