Impacts of COV-19 on Resident and Local Government Consultation Requirements (Section 18)

• PHA Plan. Public meeting(s) required. HUD is permitting flexibilities. See FAQs.

• Resident Consultation. Remote or online meetings already permitted.  Section 18 and 24 CFR part 970 requires PHAs to consult with residents who will be affected by the demolition/disposition, PHA-wide resident organizations that will be affected by the demolition or disposition (if any), and the Resident Advisory Board (RAB). PHAs have flexibility in this area. SAC reviews a PHA’s evidence of consultation on a case-by-case basis. HUD does not consider it appropriate to specify how many meetings are necessary for resident consultation (or the form of the meeting).  As part of their application submissions, PHAs must submit a description with supporting evidence of their consultations.  In the case of an online meeting (i.e. Zoom), evidence could include screenshots, documentation of how the residents were notified (i.e. email, written notification to every household’s door). PHAs must inform residents of their right to submit written comments.  If a PHA receives written comments, it must submit those comments, along with its evaluation, as part of the Section 18 application. 
• Local Government Consultation. Remote or online meetings already permitted.  24 CFR part 970 requires PHAs to develop applications in consultation with appropriate government officials.  PHAs must describe the consultation process (dates, meetings, issues raised and PHA’s responses).  PHAs have flexibility in this area.

Impacts of COV-19 on Resident and Local Government Consultation Requirements (Section 22) (including Streamlined Voluntary Conversion)

• PHA Plan. Public meeting(s) required. HUD is permitting flexibilities. See FAQs.
• Significant Resident Participation in development of VC Plan.  Public meeting(s) required.

• Conversion Assessment (waived for SVC).  Public meeting(s) required.  The PHA must hold at least one public meeting with residents of the affected site.  972.224(b)(2)(iii).  HUD is permitting flexibilities. See FAQs.
• Conversion Plan. Public meeting(s) required.  The PHA must hold at least one public meeting with residents of the affected site.  972.224(b)(2)(iii). HUD is permitting flexibilities.  See FAQs.
• Family Briefing (to obtain Tenant-Consent to PBV units).  Appendix A of PIH Notice 2019-05.  In-person meeting(s) required.  HUD is permitting flexibilities. See FAQs.

• Local Government Consultation.  No meetings required.  Written certification acceptable.  PHAs may satisfy by obtaining a certification from the appropriate state or local officials that the conversion plan is consistent with that jurisdiction’s Consolidated Plan. 24 CFR 972.227(b). 

Alternative Communications

In fulfilling the resident consultation/participation requirements described above, and in providing relocation notices and assistance, HUD recommends that PHAs develop a process that includes various forms of alternative communication methods so that all residents can receive information and participate in the process regardless of their individual circumstances. Below are some suggested methods by which to share information with residents:

• Set up teleconference calls in the place of in-person meetings, ensuring that residents have enough prior notice and receive clear directions (particularly those with limited technological access/abilities).
• Provide flyers/notices to residents at each unit with updates about how information can be obtained regarding the Section 18 demo/dispo or streamlined voluntary conversion (SVC) process.
• Post notices in common areas of the property.
• Provide letter updates in resident mailboxes.
• Provide text and/or email updates to residents.
• Share a sign-up sheet with residents to meet 1-on-1 with office staff or by phone.
• Create online materials (video or other) available to all residents.
• Create and distribute a survey for residents to gather information about their questions, experience, and preferences.
• Ensure that all residents have contact information (phone and email) for PHA staff should they have questions.