By Aaron Olsen

Hotel managers that have the responsibility for training employees who take room reservations should pay particular attention to the new regulations announced by the Department of Justice implementing Title II and III of the Americans with Disabilities Act (ADA).  While many of the new regulations address design features to make premises more accessible, the new Department of Justice regulations also provide specific requirements that hotels must follow when reserving rooms.  Hotels will need to properly train their employees and ensure that their electronic reservation systems comply with these new regulations.

As part of the regulations announced on September 15, 2010 by the Department of Justice, hotels must:

  •  Modify their policies, practices, or procedures to ensure that individuals with disabilities can make reservations for accessible guest rooms during the same hours and in the same manner as individuals who do not need accessible rooms.
  • Identify and describe accessible features in the hotels and guest rooms offered through their reservations service in enough detail to reasonably permit individuals with disabilities to assess independently whether a given hotel or guest room meets his or her accessibility needs.
  • Ensure that accessible guest rooms are held for use by individuals with disabilities until all other guest rooms of that type have been rented and the accessible room requested is the only remaining room of that type; and,
  • Prevent accessible guest rooms from being double booked.

As a practical matter, this will require many hotel operators to revise their electronic reservations systems and to train employees who take reservations so that they understand the features of accessible rooms.  In light of the substantial changes that some hotel operators will need to make to their reservations systems, these regulations will not go into effect until March 15, 2012.  The majority of the other ADA regulations announced on September 15, 2010 go into effect on March 15, 2011.

Fact Sheets published by the Department of Justice highlighting the new regulations can be found here and here.