CDC "Fully Vaccinated" Recommendations and Affordable Housing

Regulation | March 12, 2021 | by Linda Couch

Housing providers are eager to understand what CDC’s March 8, Interim Public Health Recommendations for Fully Vaccinated People mean to them.

Housing providers are eager to understand what CDC’s March 8, Interim Public Health Recommendations for Fully Vaccinated People mean to them.

The March 8 interim public health recommendations say that fully vaccinated people can:

  • Visit with other fully vaccinated people indoors without wearing masks or physical distancing.
  • Visit with unvaccinated people from a single household who are at low risk for severe COVID-19 disease indoors without wearing masks or physical distancing.
  • Refrain from quarantining and testing following a known exposure if asymptomatic.

For now, fully vaccinated people should continue to:

  • Take precautions in public like wearing a well-fitted mask and physical distancing.
  • Wear masks, practice physical distancing, and adhere to other prevention measures when visiting with unvaccinated people who are at increased risk for severe COVID-19 disease or who have an unvaccinated household member who is at increased risk for severe COVID-19 disease.
  • Wear masks, maintain physical distance, and practice other prevention measures when visiting with unvaccinated people from multiple households.
  • Avoid medium- and large-sized in-person gatherings.
  • Get tested if experiencing COVID-19 symptoms.
  • Follow guidance issued by individual employers.
  • Follow CDC and health department travel requirements and recommendations.

For independent living settings like affordable senior housing, the March 8 CDC interim recommendations for fully vaccinated people do not propel a housing community to restructure its activities, services, and use of common spaces.

The March 8 CDC Interim Public Health Recommendations for Fully Vaccinated People are not to be confused with the March 10 CMS and CDC guidance for personnel, patients, and residents in healthcare settings regarding visitation and work restrictions for asymptomatic healthcare personnel, patients, and residents. This March 10 guidance is not applicable to independent living affordable senior housing communities.

HUD has not changed any of its policies. And, CDC’s considerations for multifamily owners, updated on February 25, on their own do not point to any sea change for housing providers.

In affordable senior housing communities, whether and how much to restrict visitor access has been, and continues to be, up to the HUD-assisted owner (and in compliance with any state or local policies) (see Q38 on page 34 of HUD’s COVID-19 Frequently Asked Questions for multifamily housing). Since April 2020, HUD has recommended any visitor restrictions be done as part of a broader, publicly announced plan to respond to the COVID-19 National Emergency and in consideration that residents will still need to receive essential services, such as food deliveries, medications, and personal care assistants.

From HUD’s perspective, providers cannot restrict activities or services to only those vaccinated. This would be akin to providing services / activities to people based on their health status, which isn’t allowed.

HUD has been clear that owners have no legal justification for requiring residents to provide information on their private medical history, including whether they’ve been vaccinated, and [owners] certainly cannot exclude residents from activities based on private health information.

It’s best to continue following CDC guidance, which still generally recommends utilizing social distancing measures, as well as of course state and local directives or restrictions.

HUD still points assisted housing owners and managers to the CDC’s Considerations for Owners and Operators of Multifamily Housing that includes Populations at Increased Risk for Complications from COVID-19, which were updated February 25.

The CDC’s February 25 considerations encourage owners and managers to:

  • Promote behaviors that reduce spread.
  • Encourage mask wearing.
  • Encourage social distancing.
  • Maintain healthy environments in common areas, with emphasis on ensuring adequate air ventilation.

The CDC considerations also provide suggestions to ensure safe congregate spaces, such as recommendations for modified layouts, physical barriers and guides, and to close or stagger or restrict in number the use of indoor shared spaces such as game rooms, computer rooms, exercise rooms, and lounges.

On “encouraging social distancing,” the multifamily considerations remind us that, in general, interacting with more people, especially closely and for longer times, increases risk of getting and spreading COVID-19. And, CDC still says we should avoid gatherings of 10 or more people, encourage social distancing by asking workers and residents who are not from the same household and visitors to stay at least 6 feet apart whenever possible, and to avoid close contact with visitors.

Regarding the recommended behavior of residents in their own apartment homes, the Monday (March 8) CDC interim guidance for fully vaccinated people is meaningful and will greatly help with isolation. But, for apartment buildings, we’re awaiting further guidance from CDC and HUD before we recommend practices outside of existing recommendations.

CDC March 8 Interim Public Health Recommendations for Fully Vaccinated People.

Article on the March 11 CDC and CMS guidance for healthcare personnel, patients, and residents.