HUD HCV Guidebook § 3

Attendance
Some PHAs require that all adults in each household attend the briefing, while other PHAs require attendance
only by the head of household. The benefit of requiring all adult household members to attend the briefing is
that it is the best guarantee that everyone is informed about the program, particularly the family obligations
and grounds for termination of assistance. Proponents of requiring all adult family members to attend the
briefing argue that the likelihood of misreporting income, fraud, and lease violations decreases when all adult
members are briefed. However, one major disadvantage of this approach is that it can create scheduling
problems for both the PHA and the family. When an adult household member misses the briefing and it
cannot be rescheduled promptly, costly delays in issuance and leasing can occur.
Weighing the pros and cons of both approaches, a PHA will want to determine a policy that best meets its
needs. Note that the inability of all adult family members to attend the briefing cannot be considered grounds
for denial of assistance. PHAs must also grant reasonable accommodation requests that may be necessary
for persons with disabilities in accordance with Federal civil rights laws.

Group Versus Individual Briefings
Families selected to participate in the HCV program may be briefed individually or in a group setting. There
are advantages and disadvantages to both approaches. Should a group briefing be held, families should be
presented with the opportunity to speak to an agency representative one-on-one so that sensitive questions
may be asked and answered. See the following table which describes in detail the advantages and
disadvantages of group and individual briefings.

Type of
 Briefing     Advantages                                               Disadvantages

 Group        · Allows the PHA to better control the workload          · Often does not encourage or allow
 Briefings    distribution of its leasing staff so that the PHA can    sufficient time for questions to be raised
              allocate sufficient time to other leasing activities.    by families and answered by PHA staff. (If
                                                                       group sessions are held, the PHA should
              · Efficient method for briefing a large number of
                                                                       allow time for one-on-one meetings to
              families as quickly as possible.
                                                                       address individual questions and
              · Increases likelihood that families receive a           concerns following the briefings.)
              consistent message from the PHA.
                                                                       · Slows the leasing process as families
              · Families can learn from others with similar            wait to be briefed.
              problems and questions and can share ideas and
                                                                       · The larger the group, the less effective
              experiences.
                                                                       the briefing.
              · Typically more appropriate for large programs,
              programs with aggressive leasing schedules, and
              programs with a heavy workload and limited staff.
 Individual   · Families can be briefed immediately after they are     · May spread leasing staff too thin if they
 Briefings    selected and determined eligible without having to       are conducting too many individual
              wait for the next scheduled briefing.                    briefings, decreasing their ability to
                                                                       complete other important processing
              · Individual attention helps to clarify search process
                                                                       functions.
              and program requirements, increasing likelihood
              that the family will be successful in leasing up.        · Increases likelihood of inconsistency in
                                                                       information if more than one person is
              · More time can be spent explaining program
                                                                       conducting the individual briefings.
              benefits and encouraging families living in high-
              poverty census tracts to move to lower-property
              areas.
              · Affords more privacy and tailoring to meet family’s
              needs.
              · Typically more appropriate for PHAs with limited
              leasing activities.

      Length, Location, and Time
The length of the briefing is an important consideration. On the one hand, the briefing covers a substantial
amount of important information, including some topics that may be complex and confusing to a Housing
Choice Voucher holder who has limited program knowledge. Because of this, enough time should be

allocated for the briefing to ensure that all topics are adequately covered. On the other hand, if the briefing is
too long, the voucher holder may lose interest or have difficulties taking time off work. Most agencies limit the
briefing to no more than one hour. Briefings are usually held during regular business hours at the PHA’s
central office, but they can be held anywhere, including remotely via webcast, video call, or other methods at
any time.

Remote Briefings
HUD does not have explicit requirement for briefings to be held in person. Advances in technology provide
options for PHAs and families to participate remotely. Briefings may be conducted telephonically, via video-
teleconferencing, or through other virtual platforms absent a request by a party for an in-person hearing or
briefing.
PHAs that opt to conduct remote briefings must provide an opportunity for remote briefing participants to ask
questions. Also, PHAs must meet certain requirements to ensure their technology platform is accessible for
persons with disabilities. Under Section 504 and the ADA, PHAs are obligated13 to take appropriate steps to
ensure effective communication with applicants, participants, members of the public, and companions with
disabilities using appropriate auxiliary aids and services (AA/S). PHAs are required14 to furnish appropriate
AA/S to afford individuals with disabilities an equal opportunity to participate in, and enjoy the benefits of,
each of the PHA’s services, programs, and activities.
In addition, PHAs are required15 to make reasonable accommodations in policies, practices, and procedures
to ensure persons with disabilities have equal opportunity to participate in all the PHA’s privileges, benefits,
and services unless providing them would be an undue financial and administrative burden or a fundamental
alteration of the program. In such cases, the PHA is still required to provide any other reasonable
accommodation up to the point that would not result in an undue financial and administrative burden on the
particular recipient and/or constitute a fundamental alteration of the program.
For a remote briefing, steps for an accessible platform include ensuring any information, websites, emails,
digital notifications, and platforms are accessible for persons with vision, hearing, and other disabilities.
Helpful guidelines for ensuring the accessibility of web-based and digital materials are available through the
World Wide Web Consortium’s Web Accessibility Initiative.
Effective communication for persons with various disabilities could be provided in a digital context.
Individualized AA/S may include audio description, captioning, sign language and other types of interpreters,
keyboard accessibility, accessible documents, screen reader support, and transcripts. Under Section 504 and
the ADA, the type of auxiliary aid or service necessary to ensure effective communication will vary in
accordance with the method of communication used by the individual, the nature, length, and complexity of
the communication involved, and the context in which the communication is taking place. Important
information is conveyed during briefings. PHAs must give primary consideration to the auxiliary aid or service
requested by or requested on behalf of the individual with a disability. In order to be effective, auxiliary aids or
services as this term is defined in 28 CFR 35.104 and 24 CFR 8.3 must be provided in accessible formats, in
a timely manner, and in such a way as to protect the privacy and independence of the individual with a
disability as this term is defined in 28 CFR 35.108 (see also 28 CFR 35.160(b)(2) and 24 CFR 8.6).

13
   28 CFR 35.160(a)(1); 24 CFR 8.6
14
   28 CFR 35.160(b)(1); 24 CFR 8.6; 24 CFR 100.202(b); 24 CFR 100.204(a)
15
   24 CFR 8.33; 28 CFR 35.130(b)(7); 24 CFR 100.204

PHAs may never request or require that individuals with disabilities provide their own auxiliary aids or services,
including for remote briefings. PHAs may not16 rely on an adult or minor child accompanying a person with a
disability to interpret or facilitate communication for such person, except in an emergency involving an
imminent threat to the safety or welfare of an individual or the public where there is no interpreter available;
or where the individual with a disability specifically requests that the accompanying adult interpret or facilitate
communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for
such assistance is appropriate under the circumstances.
If no method of conducting a remote briefing is available that appropriately accommodates an individual’s
disability, the PHA may not hold that against the individual and their inability to participate in the remote
briefing. The PHA should consider whether postponing the remote briefing to a later date is appropriate or
whether there is a suitable alternative to meet the participant’s satisfaction more expeditiously, such as
conducting the briefing in-person.
PHAs must take reasonable steps to ensure full and meaningful access to the remote briefing for Limited
English Proficiency (LEP) persons consistent with its obligations under Title VI of the Civil Rights Act of 1964.
The obligation to provide meaningful access for LEP persons regarding remote briefings is particularly
important meaning that the PHA will generally need to coordinate with a remote language interpretation
service prior to the briefing. Further, conferencing technology may provide for remote interpretation; if video
technology is available, remote interpretation using video is generally preferred over voice-only because of the
additional visual cues. PHAs cannot rely on minors to interpret. For written materials, PHAs should engage
with a language translation service. All written materials related to the remote briefing, whether paper or
electronic, and whether provided before, during, or after the briefing, may need to be provided in a translated
format.
In addition to ensuring that a PHA’s technology platform is accessible for persons with disabilities and LEP
persons, PHAs must identify and resolve technology barriers prior to conducting the remote briefings. The lack
of technology or inability to use technology for a remote briefing can impose a disadvantage for individuals or
families that may not be apparent to the PHA. Thus, the PHA should determine if barriers exist prior to
scheduling the remote briefing. If the family does not have proper technological access which will allow the
individual to fully participate, then the remote briefing should be postponed, or an in-person alternative must
be provided. If the participant does not have proper technological access and the remote briefing warrants
postponement due to the lack of proper access, the PHA may not hold against the individual his or her inability
to participate in the remote briefing. See Notice PIH 2020-32 for best practices in making the determination
if a remote hearing or remote briefing can take place.
If video or telephone conference is used for the remote briefing, all materials being presented, whether paper
or electronic, must be provided to the individual or family prior to the remote briefing. Individuals or families
may prefer paper printouts over electronic documents due to lack of access to printers, difficulty viewing
detailed documents on a cell phone, or difficulty viewing screensharing on an app. Any materials made
available to the individual or family must meet the requirements for accessibility for persons with disabilities
and persons with LEP.
The PHA must establish written procedures of all aspects of how the remote hearing or remote briefing will be
conducted and the procedures should be readily available to the public. The procedures should also explain
how documents will be presented prior to the remote briefing. Note that when making procedures readily
available to the public, PHAs must still meet their obligations under Section 504 and the ADA to effectively

16
     28 CFR 35.160-164; 24 CFR 8.6

communicate with persons with disabilities and under Title VI of the Civil Rights Act of 1964 to provide
meaningful access to individuals with LEP.
For documents that contain Personally Identifiable Information (PII) and are provided prior to the remote
briefing, the PHA is responsible for minimizing the risk of exposure or misuse of the data collected, used, and
shared. PHAs must safeguard sensitive information, including all PII at all times. PII is information that can
be used to distinguish or trace an individual's identity, either alone or when combined with other personal or
identifying information directly linked or linkable to a specific individual. Examples of PII include name, Social
Security Number, biometric records, date and place of birth, and mother's maiden name. PHAs are reminded
not to transmit sensitive PII via an unsecured information system (e.g., electronic mail, Internet, or electronic
bulletin board) without first encrypting the information and ensuring that the recipient can decrypt it. See
Notice PIH 2015-06 for more regarding privacy protection.
If PHAs would like to implement remote briefings, PHAs must17 update its administrative plan to include
provisions to allow for the use of mail, electronic mail, webcast, and/or video call, as appropriate. When
considering how the remote briefing will be conducted, the PHA shall ensure that electronic information stored
or transmitted is secure per Notice PIH 2015-06, meets the requirements for accessibility for persons with
disabilities and persons with LEP in Section 5 of Notice PIH 2020-32, considers technology barriers described
in Section 6 of Notice PIH 2020-32, and explains how documents will be presented prior to a remote briefing
in Section 7 of Notice PIH 2020-32. See the table below for considerations in determining the location and
time of briefings.

Considerations for Determining Briefing Location and Time

 · Is the PHA’s central office easily accessible, or would it be more convenient for the client if the briefing
 were offered at another public site (e.g., local community center, church, or public housing site) or
 remotely?
 · Are there families with special needs and persons with disabilities who may require the briefing to be
 scheduled at some other location, such as the applicant’s home or another PHA office or remotely?
 · Is the geographical area large enough so that it is more practical to hold briefings at various sites
 throughout the jurisdiction or remotely?
 · Would working families find early morning, evening, or weekend briefings more convenient to attend?
 · When considering remote briefings, do the families have proper technological access which will allow
 them to fully participate?

17
     24 CFR 982.54(d)(1)