Exhibit · GIRMA, GMA, and Gallagher Bassett · Sent
Adjuster, then supervisor, then the chief executive of the association that runs GIRMA. Certified mail. Eleven exhibits. The answer came from a lawyer, two weeks late.
What it is
A certified-mail and email notice to Larry Hanson, CEO and Executive Director of the Georgia Municipal Association, as administrator of GIRMA, sent April 14, 2026 with eleven exhibits. It escalates the five unanswered requests to the principal level and challenges the April 1 determination. The legal sections are outside this record; the documented failure list (section III) and the five asks (section V) are transcribed.
Why it matters
This is the letter the May 1 Westbury letter answers: “I have been asked to respond to your letter to Larry Hanson dated April 14, 2026.” Everything GIRMA’s lawyer said on May 1 is a response to what is on this page.
What it shows
“No ADA Coordinator has been identified. No grievance procedure has been provided. No accommodation has been offered or implemented.” Five asks, ten business days. The ten days ran out on April 28. The reply came May 1.
What it does not show
A reply from Mr. Hanson. The reply came from outside counsel and is its own exhibit.
Transcript, sections III and V (verbatim, redacted where marked)
Date: April 14, 2026 (certified mail, return receipt requested, and email)
From: me
To: Larry Hanson, CEO and Executive Director, Georgia Municipal Association, 201 Pryor Street SW, Atlanta, GA 30303
Cc: [GMA Deputy Executive Director]; Robert Angotta, Supervisor, Gallagher Bassett; [two Gallagher Bassett staff members]; Belinda Boscoe, Gallagher Bassett; GIRMA Claims; GIRMA NetClaim; GIRMA Helpline
Subject: Formal Title II ADA Compliance Notice and Challenge to Claim Determination Sufficiency; GIRMA Claim No. [redacted]; Written Response Required Within Ten Business Days of Receipt
Attachments: Eleven exhibits: the February 13 claim notice; the April 1 determination letter; the March 13, March 16, April 2, April 6, and April 12 communications; [one exhibit redacted]; the June 5, 2025 certificate of coverage; coverage agreement pages; the seven automated claim reports
Mr. Hanson,
This letter is directed to you as CEO and Executive Director of the Georgia Municipal Association in your capacity as administrator of the Georgia Interlocal Risk Management Agency (GIRMA). It is being delivered by certified mail and email simultaneously. It addresses two independent failures in the handling of the above-referenced claim: (1) GIRMA’s ongoing failure to comply with Title II of the Americans with Disabilities Act, 42 U.S.C. § 12132, and (2) the April 1, 2026 coverage determination’s failure to address the claims as filed in the February 13, 2026 Third-Party Claimant Notice. These are separate legal duties, and neither has been satisfied.
[Sections I and II omitted. Legal argument and the underlying claim, outside this record.]
III. The Documented ADA Failure
The documents enclosed with this letter support each factual statement made below and are provided so GIRMA’s principal-level leadership has the full record of notice, non-response, and claim-handling sequence.
The following events are documented in written correspondence preserved in full. Each created an obligation that GIRMA did not fulfill:
• March 13, 2026: Written notice of disability provided. Accommodation requested. Formal ADA documentation offered. Accessible communication channel and phone contact requested. No response.
• March 16, 2026: Follow-up submitted, marked time-sensitive. No response.
• April 1, 2026: Coverage determination issued. Zero reference to disability, accommodation requests, ADA Coordinator, or grievance procedure. Interactive process required by 28 C.F.R. § 35.130(b)(7)(i) was never initiated.
• April 2, 2026: Formal written objection submitted to supervisor level, with full CC distribution. No response.
• April 6, 2026: Fourth written accommodation request submitted to supervisor level. No response.
• April 12, 2026: Formal Title II compliance demand delivered to supervisor level. No response as of the date of this letter.As of the date of this letter, GIRMA and Gallagher Bassett have failed to respond to five documented written communications seeking accommodation, accommodation-related process relief, or reassignment spanning thirty-two days. No ADA Coordinator has been identified. No grievance procedure has been provided. No accommodation has been offered or implemented. [Sentence redacted. Outside this record.]
The accommodation requests documented above were necessitated in part by GIRMA’s own intake system, which generated seven automated claim files from claimant correspondence within 72 hours of initial contact — none of which identified an accessible clarification pathway, an ADA Coordinator, or a grievance procedure.
[Sentence redacted. Outside this record.]
[Section IV, The Federal Funding Context, omitted.]
V. What GIRMA Must Do
Within ten business days of receipt of this letter, GIRMA must provide, in writing:
• The name, title, office address, and direct contact information for the employee designated as GIRMA’s ADA Coordinator under 28 C.F.R. § 35.107(a).
• A copy of GIRMA’s grievance procedure for disability-related complaints under 28 C.F.R. § 35.107(b).
• The identity of the individual responsible for handling the March 13 and March 16, 2026 accommodation requests, and the basis on which those requests received no substantive response before the April 1, 2026 determination was issued.
• Written confirmation of whether Claim No. [redacted] will be reopened and reevaluated by a new claims handler against the claims as identified in the February 13, 2026 Third-Party Claimant Notice.
• Whether Gallagher Bassett has been formally designated by GIRMA to receive, route, and implement accommodation requests on GIRMA’s behalf in the claims-handling process — and if so, the name and direct contact information of the person at Gallagher Bassett responsible for that function.Nothing in this letter waives any rights, claims, remedies, or objections arising from GIRMA’s handling of this matter to date.
[Section VI, The Consequence of Non-Response, omitted.]
[signature redacted]
Cited in
the May 1 Westbury letter, April 12 demand, Larry Hanson, the GIRMA, GMA, and Gallagher Bassett record.
Correction history
Published September 5, 2026. No corrections yet.
I have invited GIRMA, GMA, and Gallagher Bassett to identify any inaccuracy on this page. As of September 5, 2026, it has identified none.
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