Both: it depends on whether one stipulates an air temperature or case temperature for the measurement. This resource and its sequel explain the whys, wherefores, and relevant procedures for analysis of such things.
Lacking specific knowledge of the design in question, I can’t say if the difference in min gain would matter much. As sloppy a parameter as hFE is, good designs tended to leave quite a bit of margin. Here’s the longer short list if you wanted to look at some of the other options.