July 24, 2023

Submitted Electronically

Regulations Division
Office of General Counsel
U.S. Department of Housing and Urban Development
451 7th Street S.W.
Washington, DC 20410

Re: Docket No. FR-6257-A-01, RIN 2529-AB03 Nondiscrimination on the Basis of Disability:
Updates to HUD’s Section 504 Regulations

To whom it may concern:

Thank you for the opportunity to comment on the U.S. Department of Housing and Urban
Development’s (HUD’s) Section 504 regulations. Disability Rights Mississippi write to provide
comments that we hope will inform and support HUD’s proposed changes.

Disability Rights Mississippi (DRMS) is Mississippi’s designated Protection and Advocacy

(P&A) organization, authorized by federal law to advocate for the rights of people with all types
of disabilities, of all ages, throughout Mississippi (MS). The P&A system is a national network
of disability rights agencies providing legal representation and other advocacy services to people
with disabilities through extensive authority provided by Congress. As Mississippi’s P&A,
DRMS’s scope of work includes fair housing matters, including representation for people with
disabilities subjected to housing discrimination, education on housing rights, and advocacy for
people with disabilities who want to live integrated lives in our communities. DRMS is very well
versed in the housing needs and extreme lack of housing options facing people with disabilities
in MS.

Disability Rights Mississippi’s Comments on Selected Questions:

Question For Comment 1: The Department anticipates revising the definition of “individual
with disabilities” consistent with the ADA Amendments Act of 2008 and DOJ’s Title II
ADA regulations. The ADA Amendments Act of 2008 revised the definition of “individual
with disabilities” for the purposes of the ADA and made conforming amendments to
Section 504. In view of the ADA Amendments Act of 2008’s change to the definition of
disability, the Department is also considering whether the other definitions, currently
provided at 24 CFR 8.3 should be revised to clarify how the term “disability” is used in
connection with certain HUD programs, which have statutory authorizations to serve
specific populations. The Department seeks general comments on updating its definitions
contained at 24 CFR 8.3.

601-968-0600
5 Old River Place, Suite 101, Jackson, MS 39202
www.drms.ms
Response: Revising the definition of “individual with disabilities” to be consistent with the
ADA Amendments Act of 2008 and DOJ’s Title II regulations will help standardize the
definition and therefore DRMS supports such a revision. When revising the definition of
“disability” for the ADA Amendments Act of 2008, Congress made clear “that the term
‘disability’ shall be interpreted broadly” to ensure covered entities met their nondiscrimination
obligations. Revising the definition within 24 CFR 8.3 will similarly provide greater assurance
that entities covered under HUD’s Section 504 regulations will also meet their nondiscrimination
obligations. Antidiscrimination provisions are intended to serve a broad array of persons with
disabilities and revising the Department’s definition to be consistent with the ADA will ensure
the intentions of those antidiscrimination provisions are actualized. Standardizing the definition
will also eliminate potential confusion among housing providers that may be covered under both
HUD’s Section 504 regulations and requirements of the ADA.

Question for Comment 2: HUD’s Section 504 regulations at 24 CFR 8.4 contain general
prohibitions on discrimination and include examples of discriminatory application
processes, admissions policies, service provision, physical inaccessibility, eligibility, and site
selection that would either directly or indirectly result in discrimination against otherwise
qualified individuals with disabilities. 24 CFR 8.4(a) and (b).

a. To what extent are individuals with disabilities at serious risk of entering

institutional settings or being unable to transition from institutional or group
home settings, including skilled nursing facilities, correctional institutions and
inpatient rehabilitation for substance misuse, settings because they are unable to
find affordable, accessible, and integrated housing opportunities in community-
based settings? Please describe any challenges faced and solutions identified with
locating affordable, integrated, and accessible housing, including issues such as
ensuring housing is available when an individual is ready to transition from an
institutional setting, coordinating housing and services, identifying available
housing programs that individuals may be eligible for, the referral and/or
application process, the use of preferences, the operation of waitlists, insufficient
accessible and integrated housing opportunities, etc.

Response: In Mississippi, we see a trend of people resorting to nursing home placement due to
the lack of affordable wheelchair-accessible housing in the community of their choice. This
causes a severe lack of quality of life due to lack of community integration. Further, it is widely
known that home and community based services cost much less than nursing facilities, but only
if there is enough accessible and affordable housing available.

b. Are there specific examples of discrimination that individuals with mental health
or substance use disabilities have experienced, or other challenges faced by such
individuals, in securing affordable housing, such as rental policies eligibility or
exclusion criteria, that meets disability-related needs that HUD should consider
addressing in its Section 504 regulations?

Page 2 of 12
Response: Persons who have previously been incarcerated also face significant difficulty
obtaining housing, especially because many housing applications have a question that asks about
a tenant’s criminal history. Individuals with disabilities who have been incarcerated face the
double barrier of a lack of accessible housing and housing providers that impose “blanket bans”
without taking into consideration mitigating factors, such as the specific type of criminal activity,
the possible mitigating factors of a disability and the passage of time. Then you add on the
requirement to provide an application fee and the financial burden to apply to multiple places
while being denied housing because of their criminal background becomes an insurmountable
financial hurdle.

Additionally, People with mental health or substance use disabilities face strong stigma when it
comes to the housing market. That stigma often presents itself via policies that are otherwise
neutral; however, they still have a discriminatory effect on persons with mental health or
substance use disabilities. For instance, rental history and credit checks can often present
impossible obstacles for these individuals because they may be likely to have a history of
unstable housing, evictions, or poor credit due to financial struggles associated with their
conditions. These kinds of lookback policies, without guidance as to how far the “lookback”
period is or how to further evaluate a person’s individual history, often result in screening out
individuals with substance use and mental health disabilities from housing opportunities.

Many housing providers have abstinence only policies. Such policies are often based on a fear of
relapsing. However, abstinence only policies do not align with current medical knowledge,
which supports the use of Medications for Opioid Use Disorder (MOUDs) or Medications for
Addiction Treatment (MATs) to assist individuals remain in recovery as opposed to an
“abstinence only” approach.

c. Are there specific examples of discrimination that individuals with intellectual,

cognitive, or developmental disabilities have experienced, or other challenges
faced by such individuals, in securing affordable housing that meets the
disability-related needs that HUD should consider addressing in its Section 504
regulations?

Response: First and foremost, the inclusion of plain language options in all housing
advertisements and instructions on how to apply should be used. The process to apply is
confusing enough and additional efforts should be taken to explain the process in plain language.

Persons with intellectual, cognitive, or developmental disabilities often need assistance from
someone else, such as a trusted friend or family member, to apply for housing. If a landlord sees
that an applicant needs assistance in applying for housing, they may be less likely to rent to the
applicant based on discriminatory desires to not rent to individuals with disabilities, or due to
unfounded fears that the individual will not be a good tenant or will need assistance beyond what
the housing provider wants to approve.

Page 3 of 12
 d. Are there specific examples of discrimination that individuals with physical
disabilities have experienced, or other challenges faced by such individuals, in
securing affordable housing that meets the disability-related needs that HUD
should consider addressing in its Section 504 regulations?

Response: The greatest obstacle individuals with mobility disabilities face in housing is the
simple lack of accessible housing, particularly accessible, affordable housing. In Mississippi,
fully wheel-chair accessible rental units are either unavailable, unaffordable, or both. What few
are available are in segregated communities for seniors or “disability only” housing. Though
persons with mobility disabilities may make reasonable modifications that make previously
inaccessible units accessible to their disability related needs, such modifications take time and
financial resources from the renter. An additional concern is the location of the unit, particularly
among individuals who rely on public transportation or paratransit to go to work, attend
appointments, or run errands.

Question for Comment 4: Section 504 requires that newly constructed housing and non-
housing facilities be designed and constructed to be readily accessible to and usable by
persons with disabilities. HUD’s existing Section 504 regulations require that in new
construction multifamily housing projects, currently a minimum of five (5) percent of the
total dwelling units in each multifamily housing project (or at least one unit, whichever is
greater) must be made accessible for persons with mobility impairments. An additional two
(2) percent of the total units (or at least one unit, whichever is greater) must be made
accessible for persons with hearing or vision impairments. In circumstances where greater
need is demonstrated, HUD may prescribe higher percentages or numbers. 24 CFR 8.20
through 8.22. Physical accessibility requirements also apply to any alterations of housing
and non-housing facilities. 24 CFR 8.21. Additionally, recipients must operate each housing
and non-housing-related program and activity receiving federal financial assistance so the
program or activity, when viewed in its entirety, is readily accessible to and usable by
individuals with disabilities. 24 CFR 8.20, 8.21, and 8.24. This may require alterations to
comply with program accessibility obligations in older facilities that were built before
HUD’s Section 504 regulations became effective. This
may also require alterations in addition to and separate from meeting the affirmative
physical accessibility requirements described above.

a. To what extent does the lack of accessible units and other facilities in assisted
housing discourage applications from eligible persons with a disability? To what
extent is the lack of accessibility a barrier to the participation in various HUD-
assisted housing programs by persons with a disability? What challenges do
households face in finding available affordable and accessible housing in their
respective communities? What factors or sources of data should HUD and its
recipients use to determine the level of need for accessible housing?

Page 4 of 12
Response: In Mississippi, 17% of our population have a serious difficult walking or climbing
stairs. Section 504 only requires 5% of properties to be accessible. That leaves 13% of our
population without access to housing. This forces them to try to resort to trying to retro-fit
existing properties at a great expense that usually ends up not meeting their needs. The number
of units required to be accessible should really be increased to 20%.

b. Is there information that HUD should consider to clarify, strengthen, and encourage
compliance by recipients’ with program accessibility obligations?

Response: A lot of the housing options in Mississippi are old and require retrofitting. However,
there are many issues with this because many of the homes have narrow doorways—often load
bearing and cannot be replaced—, bathrooms are small, kitchens are narrow and steps require
long access ramps. These major renovations are costly.

Question for Comment 5: Tenant-based housing choice vouchers (HCV) and other tenant-
based rental assistance programs are crucial to enable individuals with disabilities to
secure affordable, accessible, and integrated housing opportunities of their choice. HUD’s
regulation at 24 CFR 8.28 provides examples of specific safeguards to ensure individuals
with disabilities have access to these programs.

a. What challenges exist in using an HCV or other tenant-based rental assistance in

the private rental market to secure a unit that meets a household’s disability-related
needs? For example, is the process for households with members with disabilities to
seek an extension of the search term due to the lack of accessible housing effective or
is the process for seeking exception rent under the exception payments standard for
accessible housing units effective, and/or what other difficulties exist for individuals
with disabilities in securing a suitable unit? Do households with members with
disabilities encounter issues using HCVs or other tenant-based rental assistance due
to the need for live-in caregivers? Is there information that HUD should consider on
various methods or approaches that have proven effective in helping individuals
with disabilities access these types of programs in order to provide equal access?

Response: Persons with disabilities seeking to use an HCV face two major hurdles: first, they
must find a landlord to accept their HCV; second, they must find a unit that is accessible to their
disability-related needs. Many apartment listings typically do not provide any information about
accessible features or may not accurately describe whether a unit is accessible. So, voucher
holders who need accessible units need time to contact the housing provider to ask questions to
determine whether some available units clearly would not meet their needs. Voucher holders
who need accessible units then need visit the units that potentially would be accessible. Those
visits must be of the exact unit they would be renting and not just a model or “comparable” or
“similar” unit to be sure it would be accessible to them because small differences in dimensions
can make a difference in access and usability. Some people with mobility disabilities also use
mobility devices that may be larger or have larger turning circles than a typical wheelchair, so
actual use of their individual mobility device in the actual unit they seek to rent is critical in
determining whether the unit would be accessible to them.

Page 5 of 12
Voucher holders with disabilities, particularly mobility disabilities, will routinely need a longer
search term to locate an accessible unit. Housing authorities should consider automatically
granting longer search terms for voucher holders with mobility disabilities and should freely
grant extensions.

Voucher holders with other disabilities that may have other disability related needs for certain
features may similarly need additional time and housing authorities should freely grant
extensions if voucher holders with disabilities are unable to find a unit that meets their needs.

In the past, we have heard of some housing authorities that flatly refused to grant extensions for
voucher search terms. Other housing authorities would only grudgingly extend search terms if
advocates contacted the housing authority on behalf of voucher holders with disabilities. That
seems to happen less often in recent years but remains a concern.

Voucher holders, particularly those with mobility disabilities, often need units in buildings with
elevators and those buildings in most markets tend to be newer and thus have higher rents.

Voucher holders with disabilities commonly are not aware of or are not informed about the
availability of exception payment standards. Housing Authorities need to provide clear and
understandable information (in alternative formats) to voucher holders about the availability of
exception rents. Housing authorities also need to simplify the process for applying for and
approving exception rents when there is a disability need for the exception rent to obtain a unit
that meets the disability needs of a voucher holder with a disability.

b. Please provide details about the availability of affordable accessible units in

different areas of the United States (e.g., urban areas, suburban areas, and rural
areas, including geographically isolated and remote areas) in the private rental
market and any proven strategies that encourage landlords to participate in the
tenant-based HCV program.

Response: In Mississippi, we have found many housing providers are reluctant to accept tenacy-
based HCVs due to how hard it is to get through the administrative red tape. There is a surplus of
paperwork and oversight required with this program. If this process could be more streamlined
and more trainings/education done on the process, this would be helpful. It may also be helpful
to provide any kind of incentive to convince other providers to accept HCVs.

Question for Comment 8: As the Federal agency with primary responsibility for
administering the Nation’s federally assisted housing programs, the Department has a
unique role in considering how residential and connected spaces (e.g., spaces for laundry,
mail, telecommunications, office, maintenance, parking, recreation, service, and
community functions) must be made accessible. HUD is looking at the accessibility and
usability of spaces and elements within one’s own home and connected spaces that will
impact daily living, which is different than considering accessibility in places of public
accommodation or other settings. HUD is considering how the development of various
enhanced accessibility features can be incorporated or incentivized into the design and

Page 6 of 12
construction of affordable housing developments. Advances in the types of accessibility
features can assist individuals with various types of disabilities obtain, remain in, and
receive the full benefits of their housing. For example, for individuals with mobility
disabilities, such features may include: power operated or other keyless proximity-based
entry at entrances and exits from buildings and passageways through the building; light
weight or low resistance doors; detachable shower-heads; smart, remotely adjustable
thermostats; adjustable shelves in closets and storage; full extension pull-out drawers,
shelves, and racks; roll-in showers; avoiding swinging interior doors within individual
accessible dwelling units; faucets with touch or motion sense water controls; and reinforced
ceilings to accommodate a track and harness system. For individuals who are blind or have
low vision, examples of such features may include: audible elevator indicators; innovative
entry systems that do not solely rely on an individual’s ability to see in order to gain access;
controls with audio feedback as opposed to or in addition to touch screens; and enhanced
lighting. For individuals who are deaf or hard of hearing, examples of such features may
include: innovative entry systems that do not solely rely on an individual’s ability to hear in
order to gain access; doorbells with light alerts; activated close captioning on televisions
located in public areas; and video phones or other video connections for communications.

In addition, specific accessibility features assist individuals to remain in their homes and to
age in place, such as vertical and angled grab bars to get up and down from toilets and for
stepping in and out of bathing fixtures. Examples to assist individuals who are blind or
have low vision include contrasting surfaces, enhanced lighting, tactically discernible
controls, and elimination of tripping hazards. Examples to assist individuals who are deaf
or hard of hearing include innovative entry systems, doorbells with light alerts, and
emergency alarms for fire and carbon monoxide leaks that can accommodate personal
notification devices.

a. What barriers do individuals with disabilities face in public and common use areas
of housing and non-housing facilities (e.g., building entrances, building entry
systems, recreation and fitness facilities, mail and package rooms, coworking
facilities, parking structures, laundry rooms)? What accessibility features or
advanced technology can help overcome these barriers?

Response: Technology has greatly advanced for common appliances since the last issuance of
HUD 504 regulations. For example, many appliances use touch screens and electronic menus
now. These appliances are inaccessible for blind and low vision users who cannot interact with
the touch screen. Similarly, tenants with dexterity and mobility disabilities cannot independently
interact with the machines. To enable tenants with disabilities to independently interact with such
machines, the machines need to be designed with text to speech technology and voice input
technology.

For instance, technology exists that allows blind users to interact with a touch screen. Software
can be installed that reads aloud what is seen on the screen when the people touch that part of the
screen. The blind individual can then use a series of finger swipes to move throughout menus.
Similarly, software can be used to enable a person with a physical disability to talk directly to the

Page 7 of 12
appliance. The voice activated technology can then listen to the voice of the user and perform the
requested task.

Along with the various types of technology to increase accessibility, simple accommodations can
be implemented to make appliances accessible. Washers and dryers can be labeled with tactile
and large print labels to allow blind and low vision users to engage with the appliances
independently. The same thing can be done with any other self-service machines or devices
provided in a housing complex. [I was thinking of delivery package lockers that I have seen in a
large apartment building with a centralized electronic keypad like Amazon lockers.

Along the same lines, many types of housing are now using electronic key fob technology to
choose a floor in an elevator or unlock an apartment door. Such technology can be more
accessible since bringing an electronic key fob to a reader can be easier and more usable for a
tenant with a dexterity disability than using a traditional key. However, electronic key fob
readers can be difficult to find for someone who is blind or low vision. Consequently, the
addition of things like tactile identifying marks and large or bright colors should be included.

Many housing units also include gyms for tenants to use. The accessibility of the gym equipment
must be ensured. Similar to other devices discussed previously, touch screens and other panels
are often inaccessible for blind or low vision tenants. Housing units should be required to
purchase equipment that is accessible, if possible, for all tenants. Similarly, the structure of some
exercise equipment makes their use by persons with physical disabilities impossible. Again,
housing providers must be required to seek out the most accessible exercise equipment.

b. What accessibility features or advanced technology should the Department be aware

of that improve accessibility in designated accessible units for individuals with
mobility disabilities?

Response: Roll-in showers are an important accessibility feature that are absent from most
apartments, including those that are designated as accessible. Although not all physical disabled
people need or prefer roll-in showers, they are a necessity for some individuals. Increasing the
number of roll-in showers would increase housing options for many people. Smart features, such
as thermostats and lights would also be beneficial

c. What accessibility features or advanced technology should the Department be aware

of that improve accessibility in designated accessible units for individuals with
vision and hearing disabilities?

Response: Various devices and appliances, such as alarms, washers and dryers, and ovens would
be more useful to Deaf and Blind tenants if they had both visual and auditory signals.

d. Given the increasing aging population, the Department is considering its role in
providing affordable housing opportunities to this population and how to enable
households to remain in their housing. Are there specific accessibility features that
can help individuals to age in place?

Page 8 of 12
Response: The same types of accessibility features used for other types of disabilities would be
useful for elderly tenants or homeowners. They would benefit from having things like grab bars
in bathrooms, space that is adequate for mobility aids such as wheelchairs and walkers,
apartments located on the first floor, and apartments and common areas in locations that are
convenient to get to.

Elderly people who own homes would benefit from agencies that can provide resources about
home modifications, such as vendors who can provide the modifications, and information about
applying for grants to assist in paying for modifications.

e. There are alternative accessibility provisions in accessibility standards that address

the more limited reach ranges and need for lower seat heights and dining surfaces
for children with disabilities that are different than accessibility features configured
for adult use. The Department is interested in any comments related to dimensions
for children

f. To what extent does the failure to maintain accessible features, including elevators
and lifts, limit individuals with disabilities access to affordable housing?

Response: It is preferable to have accessible units on the first floor to avoid the need for an
elevator. However, a unit on a different floor would be acceptable if there was a guarantee that
the elevator would work properly. Many disabled individuals would not consider a unit that
required the use of an elevator because of the risk that the elevator would be out of order when
the individual needed to use it. Requiring landlords to regularly monitor elevators to ensure that
they are functioning properly may alleviate some concerns about living on a different floor.

Additionally, many apartment buildings do not have elevators. This means that disabled
individuals may be limited to the first floor, which restricts the ability to interact with neighbors,
which goes to the issue of integrated living mentioned earlier. Requiring elevators in multilevel
buildings would benefit disabled individuals who wish to interact with others.

Question for Comment 10: A reasonable accommodation is a change, exception, or

adjustment to a rule, policy, practice, or service that may be necessary for a person with
disabilities to have an equal opportunity to use and enjoy a dwelling, including public and
common use spaces, or to participate in a HUD-assisted program or activity. For purposes
of Section 504, this also includes recipients providing structural changes to a unit or public
or common use area when they may be needed as a reasonable accommodation. Generally,
the failure to provide reasonable accommodation is a form of discrimination under Section
504. HUD anticipates further addressing the concept of what constitutes a reasonable
accommodation in its Section 504 regulations. HUD is aware that it may be useful to its

Page 9 of 12
recipients to understand the broad array of the types of accommodations that may be
useful to individuals with different types of disabilities, such as individuals who are blind or
have low vision, individuals who are deaf or hard of hearing, individuals with intellectual,
cognitive, or developmental disabilities, individuals with mental health disabilities or
substance use disabilities, and individuals with mobility disabilities. The Department is
interested in comments on these issues.

Response: The legal requirement that HUD-funded programs provide reasonable

accommodations for people with disabilities is fundamental to ensuring equal access to those
programs. Reasonable accommodation policies are the key to the proverbial door to housing,
ensuring people with disabilities can access and participate in HUD programs, services, and
activities.

Currently, many housing providers include occupancy limits. However, if a tenant has a
significant disability that requires a 24 hour live-in personal care attendant, an accommodation to
the policy is necessary. The tenant should not be penalized for having a live-in aid in the
dwelling place. A number of P&A agencies have received numerous calls on this occurrence.
HUD needs to make clear going forward that the above situation is considered a reasonable
accommodation.

Question for Comment 11: HUD undertakes two types of investigations under its Section
504 regulations – complaint-based investigations and compliance reviews. Any person, or
their authorized representative, who believes that they have been subjected to
discrimination by a recipient of HUD financial assistance may file a Section 504 complaint
with HUD. Similarly, persons may file a complaint with HUD on behalf of specific classes
of individuals who have been subjected to discrimination by a recipient.

HUD may conduct periodic compliance reviews of recipients that include a review,
including an on-site review of recipients’ policies, practices, and procedures, to determine
whether recipients are complying with HUD’s Section 504 regulations. Recipients are also
subject to program compliance reviews and monitoring procedures by HUD in its oversight
of program requirements designed to further compliance with HUD’s Section 504
regulations. 24 CFR 8.56. Are there any clarifications or changes HUD should consider in
procedures for initiating and conducting investigations and/or enforcement mechanisms
with respect to individual complaints or compliance reviews?

Response: The Department should consider revamping the complaint process. Particularly, the
Department should consider retaining more complaints for investigation rather than referring so
many to the local Fair Housing Assistance Programs. Although complainants are free to pursue
these complaints by filing a private lawsuit, this population of people does not have money to
hire legal counsel.

Page 10 of 12
Question for Comment 13: The Department recognizes that individuals with disabilities who
are also members of other protected class groups (e.g., race, color, national origin, sex
(including sexual orientation and gender identity), familial status, religion, age, etc.) may
be uniquely impacted by revisions to HUD’s Section 504 regulations and is interested in
receiving public comment on unique considerations related to intersectionality.

a. Are there unique barriers or other forms of discrimination in housing or HUD

assisted programs against individuals with disabilities who are also members of
other specific protected class groups?

Response: Domestic violence can subsequently cause mental trauma and victims will meet the
definition of disability. These victims may find it difficult to secure housing where they feel safe
from a past abuser. However, sometimes being able to relocate out of their jurisdiction may pose
difficulties. Many times in order to do this, they are forced to pay for more expensive housing
just to stay safe from abuse.

Additionally, often times there is an overlap between people of color who have severe mental
disabilities with behaviors that could be mistaken for acts of crime instead of need for mental
health assistance. When criminal behavior is alleged, often times the housing provider evicts the
tenant and any rental assistance is terminated.

b. In particular, is there information that HUD should consider regarding how

disability discrimination affects persons of color, LGBTQ+ persons, families with
children, older adults, and individuals with limited English proficiency who also
require appropriate auxiliary aids and services necessary to ensure effective
communication?

Response: Trauma associated with negative experiences such as discrimination of being a part
of a protected class can establish a disability or exacerbate an existing disability. It is not
uncommon for members of a protected class to develop or trigger a disability on account of the
trauma from discrimination and/or exacerbate the disability they already have.

Additionally, ethnic minorities who do not speak English and also have an intellectual disability
are likely to have a far more difficult time reading through applications and other documentation
when trying to procure a place to live. As a result, when making websites more accessible, such
as including plain language documents, additional steps including instructions in other
commonly spoken languages should be considered.

We hope that the provided information assists the Department in its revisions of its Section 504
regulations. If you have any questions regarding these comments, please contact Katherine
Henderson, Legal director of Disability Rights MS at 601-968-0600 or khenderson@drms.ms.
Thank you very much for considering our views.

Page 11 of 12
Sincerely,

Katherine W. Henderson

Katherine Henderson
Legal Director
Disability Rights Mississippi

Page 12 of 12