The new provisions will have a tremendous impact on requirements affecting guest rooms with communication features, including alarms, visual-notification devices for telephone calls, door knocks or bells, telephones with volume control, and specified outlet locations for the use of text telephones. Hoteliers will have
to contend with proposed requirements that are significantly more stringent than what was previously acceptable. For example, in accordance with the current law, a new hotel with 310 to 400 rooms requires that at least eight guest rooms incorporate the above listed communications elements, while the new standards 
require that 20 rooms maintain these features.

As it pertains to small hotels, the law offers no leniency. Currently, the law states that hotels with 76 to 100 rooms require four rooms to incorporate communications features; the updated law will ask that nine rooms are in compliance. Additionally, the proposed dispersion of accessible rooms will broaden in scope to include views and bathroom hot tubs/spas in addition to the considerations for room size, type, cost, and amenities.

Hoteliers must also address another critical component of the proposed modification to regulations that outlines reservation policies designed to offer further protection for the disabled community. The DOJ is considering amending the law to add provisions that will ensure that guests are provided with specifics 
relevant to accessible accommodations, including not only a detailed description of the accessible guest room, but specifics on accessibility features. These additional requirements include hotel chains that utilize centralized reservations systems, stipulating that the remote reservations employee must have detailed 
information available relevant to the specific hotel location’s guest room and accessible features. The DOJ wants to ensure that disabled patrons are fully apprised as to the facility’s ability to serve the needs of the customer. The proposed changes will also require that the hotel staff share the company’s policy relevant to the guarantee of accessible room reservations. Also, under the proposed guidelines, the hotel company’s “hold and release” policy must be updated to reflect the company’s position on releasing accessible guest rooms to the general public prior to the hotel selling out.