ADA Compliance Guidelines for Hotels

ADA Compliance for Hotels

Top ADA Priorities

Hotel owners and operators face ADA exposure when a guest with a disability can’t use the hotel the same way other guests can. Most hotel ADA problems come from two sources: access on the property during a normal stay, and access through reservations and digital booking before the guest arrives.

1. Access on the Property

Guests file ADA complaints when a hotel prevents them from reaching and using a room or guest areas on the same terms as other guests. Hotels also create ADA exposure when accessible routes get blocked during daily operations or when accessibility features remain out of service beyond short repair periods.

2. Reservations and Digital Booking

ADA booking disputes arise when a hotel’s online listing does not give enough detail for a guest to choose the right accessible room type before they arrive. Accessible room pages should tell a guest what accessibility features the room has, with enough detail to decide whether that room meets the guest’s access needs before booking. Third-party booking sites can also cause disputes when their room descriptions don’t accurately reflect the accessibility features of a room.

Coverage and Control Across the Property

Coverage Maps

Hotels need a clear way to track which areas of the property create ADA exposure. A “coverage map” is a one-page checklist, not a drawing of the property, that names the guest-facing areas and access paths that require consistent attention. The checklist should name the guest-facing areas the hotel has to keep accessible and the access paths guests use to reach them, starting with the path from arrival to check-in and the path to the accessible guestroom. It should also include public restrooms in lobby areas and any amenities the hotel sells as part of the stay, like a pool area or fitness center.

Control Maps

A “control map” assigns a specific person or team to each item on the coverage map, and that person should have authority to approve the work and confirm the issue is corrected. For example, event layouts can block the path to check-in or elevators, so the checklist item should go to the manager who controls event setups, not someone who can only report the problem.

Physical Controls That Drive the Most Complaints

Arrival Paths and Interior Routes

Guests with mobility limitations need a continuous, unobstructed path from arrival to check-in and then to the accessible guestroom. Hotels block that path when staff park housekeeping carts in hallways, stage supplies near elevators, rearrange lobby furniture for events, or place temporary signs that pinch the route.

Hotels should use the following controls to keep the route usable throughout the day:

• Keep the path from accessible parking or designated drop-off area to the hotel entrance clear during operating hours.

• Keep the lobby path to the front desk and elevators clear during peak check-in and peak checkout hours.

• Keep the path from elevators to accessible guestrooms clear at all time, including tight turns and pinch points.

• Schedule routine walk-throughs so staff identify obstructed arrival paths and interior routes before guests do.

Doors and Door Hardware

Guests with limited hand strength need doors that open without tight gripping or twisting, and wheelchair users need doorways that stay passable without scraping or getting stuck. Door hardware becomes a barrier when it requires twisting or strong grip.

Hotels should use the following controls to keep doors usable:

• Check door operation at accessible entrances and along access paths used to reach accessible guestrooms.

• Prioritize repairs for doors that drag, stick, or fail to latch, since those issues can make a doorway unusable.

• Replace door hardware that requires twisting or strong grip when it prevents independent use.

• Include door checks in routine maintenance so problems get caught before guests report them.

Accessible Bathrooms

Accessible bathrooms need to work for guests who use wheelchairs or walkers, and for guests who have limited balance or strength. Bathroom complaints usually tie back to two issues: the layout doesn’t leave usable space where a guest needs it, or grab bars aren’t solid enough to hold body weight or aren’t installed where a person can actually use them.

Hotels should use the following controls to keep accessible bathrooms usable:

• Check the clear space a guest needs to move into position at the toilet and in the bathing area, then correct layouts that block access.

• Check grab bars for firmness and placement in the toilet area and bathing area, then fix any bar a guest can’t rely on for support.

• Confirm the bathing setup allows safe entry and use without improvised workarounds.

• Confirm faucets and shower controls work without tight gripping or twisting.

Pool Access Features

Pool access can create ADA compliance issues for hotels when a guest can’t use the pool during posted hours because the access equipment isn’t available for use or staff can’t operate it. Hotels that have a lift on deck can still face ADA problems when the lift isn’t ready for immediate use when the guest asks.

Hotels should use the following controls for pool access:

• Check pool access equipment before the pool opens so it is ready during pool hours.

• Keep pool access equipment available for immediate use when a guest requests access.

• Train multiple staff members to operate the equipment so access does not depend on one employee being on duty.

• Log any outage through a work order and record the return-to-service date.

Planning Renovations Without Creating ADA Problems

Why Renovations Create New ADA Problems

Renovations can create ADA issues when the project changes how guests reach or use a space and the hotel doesn’t catch the impact until construction is underway. Once walls go up and fixtures get set, accessibility problems become harder to correct, so hotels should confirm accessibility impacts before the project starts.

Hotels should review renovation scope for changes like lobby remodels that tighten circulation and reduce usable paths to the front desk or elevators, or limit access to nearby public restrooms. Guestroom renovations deserve the same review, since furniture placement changes can block the usable path to the bed or bathroom. Restroom upgrades can also reduce usable space when fixture placement shifts, and amenity upgrades can leave an access barrier in place even though the hotel promotes the space.

Planning Steps Before Work Starts

Before signing a construction contract, hotels should list every area the renovation will touch and every place where the work could reduce ADA accessibility. The hotel’s project lead should walk those locations and take photos and measurements at the points most likely to cause access problems during the renovation and after it is complete.

Before construction begins and before reopening once construction is complete, hotels should:

1. Build an accessibility map for the project. Mark the affected areas on the plans, then mark the same locations on site so the GC and trades know where ADA compliance issues are most likely to show up first.

2. Set a temporary access plan before work starts. Identify the accessible route guests will use while work blocks normal paths, then post clear signage and update the plan as phases change.

3. Require two accessibility checkpoints in the schedule. Hold a walkthrough after framing and another walkthrough before finishes get installed in any area that affects an accessible route or an accessible room.

4. Test access before reopening. Walk the accessible route through the renovated areas and correct any barrier found before reopening.

Online Booking Controls for Accessible Rooms

Why Online Booking Creates ADA Problems

Online booking disputes happen when an “accessible” room type appears in the booking flow without enough detail for a guest to decide whether the room type meets the guest’s access needs. Title III rules require hotels to identify and describe accessible features with enough detail for independent assessment, and the requirement still applies when a third party takes the reservation.

Online booking disputes also happen when the hotel accepts a reservation for an accessible room type and later can’t deliver it at check-in because reservation controls left the room type in general inventory and assignment rules reassigned it before arrival. Title III addresses that risk through rules that require hotels to protect accessible room types after booking and deliver the reserved room type at arrival.

Controls That Reduce Booking Disputes

Title III focuses on two control areas: what the hotel publishes about accessible room types and how the hotel’s booking systems protect accessible inventory after booking.

Listing controls determine whether a guest can choose the right accessible room type from what the hotel publishes online, including on third-party sites.

1. Publish accessible information by room type, not a generic “ADA room,” so the guest knows what the hotel will assign.

2. Describe accessible features with enough detail for a decision before purchase, since the rule requires detail that supports independent assessment.

3. Push the hotel’s room-type accessibility details to third-party booking sites that sell the hotel’s inventory, since the rule reaches third-party reservations.

4. Update descriptions after any renovation that changes layout or features, since the booking promise needs to match the finished room type.

Inventory controls determine whether the hotel can deliver the reserved accessible room type at arrival after the booking is made.

1. Allow accessible room types to be reserved through the booking channels offered to other guests and during normal booking hours.

2. Hold accessible room types for guests who need them until comparable non-accessible room types are no longer available.

3. Remove the reserved accessible room type from availability so another guest can’t book it.

4. Deliver the reserved accessible room type at arrival, rather than switching the guest into a different room type.

Keeping ADA Compliance on Track

A workable ADA compliance routine catches access problems before a guest reports them. Staff should check the same high-risk areas on a set schedule and record every fix in a work order or vendor ticket, along with a completion date.

Hotels should run the following routine controls on a schedule:

• Review accessible routes at set times, including before peak arrivals and before large events, then remove any obstruction before guests reach it.

• Review accessible room types and accessible bathroom setups by room number on a rotating basis, then fix layout issues and hardware failures through work orders.

• Review online accessible room listings and third-party listings on a set schedule, then update descriptions when renovations or room changes alter features.

• Review pool access readiness during pool hours, then document downtime and repairs through work orders.

What to Do When a Complaint or Demand Letter Arrives

The first response to a complaint or demand letter should focus on evidence preservation and fast correction of the issue. Most disputes turn on what the listing said, what room type was reserved, what room type the hotel assigned, and what the property did after the issue was reported.

Hotels should take the following steps as soon as it is feasible:

• Capture screenshots of the booking flow and the accessible room listing for the room type at issue, including any third-party listing the guest used.

• Pull reservation records and room assignment history for the stay so the hotel can show what room type was reserved and what room type the property assigned.

• Pull work orders and maintenance logs for the feature involved, then document any repair work completed after the complaint.

• Correct the issue that triggered the complaint, then update listings and internal procedures so the same failure doesn’t repeat at the next check-in.

When to Contact an ADA Attorney

Hotel owners and operators should contact an ADA defense attorney when a demand letter arrives, since the response should rely on facts the hotel can prove with its records. A strong response ties back to what the hotel’s website or booking engine said about the accessible room type, what the guest reserved, what room type the front desk assigned at check-in, and what the property did after the guest raised the issue. Hotel owners and operators should also contact an attorney when the same access complaint keeps coming back after staff made repairs, since repeat complaints usually point to a process gap, meaning a recurring breakdown in how the hotel conducts access assessments.

Work With Conn Maciel Carey LLP

Conn Maciel Carey LLP works with hotel owners and operators on ADA compliance issues tied to online booking and on-property access. The firm reviews reservation practices and accessible-room descriptions, then advises on responses to ADA complaints and demand letters.

Contact Conn Maciel Carey LLP’s national labor and employment group at (202) 715-6244 to discuss an ADA review for your property or portfolio.