Hello and welcome to today's Navigate Tuesday Tip. I'm Pam. And today we are gonna be talking about scripts and how they can really help you with fair housing compliance and making sure that the same answer gets to applicants and residents every time on the same subject. So inconsistency is one of the things that can result in fair housing complaints and it can be several

areas that they generate a complaint, but one of those is the feeling that the way you answer questions or provide information to one group is different than the information another group gets. So people can make the allegation that, this group doesn't get the same information, so they're at a disadvantage, so it has a disparate impact.

Individual phrasing is one of those things and that can just result from being more comfortable talking to one person than another. But if there are different phrases used and because there may be differing levels of knowledge, experience or comfort level working with the public, these can create inconsistencies in the information that applicants and tenants receive. And sometimes that can lead to a misunderstanding, to confusion.

or to differences in messaging in your property.

There are many occasions when you may want to use a script. Application inquiries are one of them, wait list inquiries, drop-ins, reasonable accommodation requests, or maintenance requests. Anybody who comes in contact with any staff at your property should get generally the same information. If you as the property manager are the only one who should be talking about applicants,

Pam Kazlauskas (01:55.43)
status on a wait list, then everybody else at the property should be saying, I'm sorry, I can't give you that information. You need to speak to the property manager. And one of the areas where we tend to not think about this a lot is with maintenance requests. Maintenance staff see the residents all the time, but they often don't get the same level of fair housing training that

the office staff gets. So it's really critical to make sure that maintenance staff understands what their requirements are when they get certain requests. Service call requests, reasonable accommodation requests. And it's also important to train your maintenance staff that if they hear anything that may hint at a reasonable accommodation request, they're to bring it to somebody's attention. Because

They may not know that some things are reasonable accommodation requests when they don't sound like a direct accommodation request. If Mrs. Smith is commenting to maintenance staff that they had to park all the way at the end of the parking lot and that really hurt because she just had surgery on her foot, maintenance may just be empathizing with them. They may not know that that really is kind of a way of asking for some assistance with her parking.

So make sure that everybody knows anything like that should come to whoever handles reasonable accommodation requests. What makes a good script is language based on programmatic restrictions. So questions where anybody is asking, do I qualify, before you are looking at an actual application is very risky. Generally, you want to answer questions like, do I qualify?

once you have the information necessary to determine that. But you can give information on things like, yes, we have subsidy available through the Section 8 program, or we are a 202.8 program, which means that every household has to have a co-head, or spouse that's 62 or over. Again, that question is potentially risky because you're talking about eligibility before you're looking at an application. Gender.

Pam Kazlauskas (04:15.854)
race and disability neutral language is critical. There are some older phrases that are now seen as more discriminatory or really just having a perception impact on people that we really probably wouldn't like. Things like a master bedroom or within walking distance and things like, you know, we're located in a really nice African American neighborhood.

That may discourage some people from applying or give the impression that your property is something that it isn't. So you want to keep your language very gender neutral and neutral in terms of any other protected class as well. And again, questions to avoid. Avoid answering questions about anything that involves a protected class or creates the impression that it involves a protected class.

things like the racial or ethnic makeup of your property or area, criminal statistics, and are there other whatever people living at the property. So if I am Hispanic and English is not my first language, I may be asking that question because I want to know if I'm going to feel comfortable at the property. But the reality is that even if that's not the case, even if I'm the first Hispanic resident to live there,

That doesn't necessarily mean I'm not comfortable there. So you just don't want to discourage people from applying to your property. Once they are looking at the application criteria and anything that is key to eligibility, they can make their own decisions. But we don't want to discourage people from just filling out an application.

Guiding principles, don't discourage somebody from applying even if they quote unquote obviously don't qualify. There's no such thing as obviously not qualify. So make sure that basically anyone who asks for an application gets one unless your wait list is closed. You certainly can advise of what wait lists are currently closed. You can answer questions about program restrictions, but

Pam Kazlauskas (06:33.162)
It is safer just to send out an application and let them know that once they've filled out that application and returned it, or once they have it, they can call back and ask some questions based on what they find in that application. It's okay to say to them, our policy is not to answer questions over the phone unless we have sent an application. We'd be happy to send you one and then you can call back if you have any questions.

Things that are risky can include maintenance telling a resident we don't supply bidets. Even though that may be the general rule, it's not true that we would never do that. Or we don't allow dogs over 20 pounds here. You might if there's a service animal involved. Someone saying that there's no other Hispanic people at the property may discourage somebody from applying when they might apply and find that this is a wonderful community for them.

Someone saying the property doesn't allow dogs again. Someone asking an applicant's age or disability status. This can sometimes come up in properties where there's a restriction on how many apartments are reserved for disability households. So somebody might say, you know, I've applied to your property, but I'm not 62. Something as simple as saying, okay, but do you have a disability?

Where you are thinking that's about eligibility criteria, you may create an entirely different experience for the person asking the question. Always easier to send out an application packet and a description and then respond to the questions because you don't want to be seen as discouraging them from applying. All staff should be trained on whether and how to answer questions. Some roles may have different answers, but everybody should know what to do when they're asked.

questions.

Pam Kazlauskas (08:29.688)
So key takeaways, inconsistency is your biggest enemy when you are answering questions and it can create misunderstandings and fair housing risk. Scripts can make things much easier for inexperienced staff. It can avoid mistakes. It can avoid somebody saying things that may be unintentionally misleading. And it ensures that the vital information is conveyed.

And it can help in the case of a fair housing complaint because you have a document of how you answer questions. It's not foolproof, but it helps to show that you are careful not to mislead residents or provide information that causes a fair housing concern.

That's going to do it for today. We'd love to know what you would like to see on the next Navigate Tuesday Tip. You can email your questions and suggestions to Vicki and me at the addresses listed on your screen. Thank you for joining us and we'll see you on the next Tuesday Tip.