With vaccine distribution well underway across the country, affordable senior housing providers are navigating decisions around “reopening” or loosening restrictions at communities while weighing health risks for at-risk residents. Key considerations for changing community policies include:

• Hosting group activities and services on site
• Mask requirements
• Resident access to common areas
• Visitor and essential service provider access to the community
• Frequency of resident wellness checks
• Elevator capacity restrictions
• Resuming dining room service
• On-site staffing
• And much more.

HUD Recommendations

In March 2021, HUD released a “Rights and Responsibilities” chart for both residents and properties during COVID-19. In the document, which is available in English and Spanish, HUD outlines efforts that communities are taking, like keeping units and common areas safe or access units for repair. The chart offers suggestions for both tenants and property staff to mitigate risk, like wearing masks in common areas and defering routine maintenance. 

While the chart does not provide new guidance to properties navigating “reopening discussions,” it does give an overview of CDC’s and HUD’s view of risk mitigation efforts at Multifamily Housing communities serving older adults.

CDC Recommendations

Also in March, the CDC released interim public health recommendations for fully vaccinated people, which state that vaccinated individuals can safely visit indoors with other fully vaccinated individuals without mask wearing or social distancing.

The CDC’s recommendations may impact the individual decisions of residents; however, because housing providers are not in a position to ask for, or to share, resident sensitive medical information (including vaccination status or decisions), the CDC’s recommendations for vaccinated individuals are limited in their application to community-level policies that need to apply broadly to residents, regardless of vaccination status. In addition, the CDC’s recommendations for fully vaccinated people also clearly state that fully vaccinated individuals should continue to wear masks and practice social distancing when in public, which in the housing community setting is anywhere outside of the resident’s unit. 

In lieu of specific guidelines on maintaining safety for all residents, including those who are vaccinated and unvaccinated, housing providers can make risk-based decisions that apply broadly to community policies. According to the CDC’s “Considerations for Retirement Communities and Independent Living Facilities,” the risk of COVID-19 spread increases in the congregate older adult housing setting as follows:

Lower Risk for this Setting:

• Residents do not spend time in each other’s individual living spaces
• Most communal areas (e.g., cafeteria, activity room) are closed
• Workers and residents remain at least 6 feet apart at all times, undergo daily health screenings, and wear masks correctly
• Non-essential volunteers and visitors are not permitted

More Risk for this Setting:

• Residents do not spend time in each other’s individual living spaces
• Individual residents may use properly ventilated communal areas (e.g., dining room) or participate in small group outdoor activities, but they remain at least 6 feet apart at all times.
• Workers, residents, volunteers, and visitors remain at least 6 feet apart at all times, undergo daily health screenings, and wear masks correctly
• Non-essential volunteers and visitors are permitted, but limited

Higher Risk for this Setting:

• Residents spend significant time indoors together, possibly in each other’s living spaces as well as in communal areas
• They may not consistently remain at least 6 feet apart, nor wear masks
• They also frequently spend time in the larger community (e.g., traveling together to attend public events)
• Non-essential volunteers and visitors are not restricted.

The CDC is planning to provide an update on older adult vaccination on May 5 and is seeking feedback on what information is needed. Please send suggestions to lcouch@leadingage.org or jbilowich@leadingage.org. LeadingAge will continue to monitor CDC and HUD guidance for housing providers making decisions that impact the safety of their communities.