“Multigenerational Household” for COVID-19 Vaccine Purposes

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On January 6, 2021, the Washington State Department of Health released an estimated timeline for priority vaccination for COVID-19 and who qualifies.  The release got buried in the rubble of a very busy news day, given what occurred in the “other Washington” on that date.  But the observant eye saw something in the timeline that has raised questions in the minds of many people not previously considered at “high risk.”

The second highest priority – “Tier B1” – for vaccination starting in January includes “all people 50 years or older in multigenerational households.”  Clients have called me about this priority, wondering if they qualify.  After all, they are over fifty and live with their children in what would seem like a “multigenerational household.”  Unfortunately for those clients, the answer is not that simple.

How Does the Department of Health Define “Multigenerational Household”?

The Department of Health offers little guidance as to what a “multigenerational household” is.  The chart above includes the parenthetical statement that a multigenerational household is a “home where individuals from 2 or more generations reside such as an elder and a grandchild.”  The glossary of terms issued with the chart (click here) defines the term the same way.

The definition offered by the Department of Health is as clear as mud.  Technically speaking, every household where a parent lives with a child would be a household where “individuals from 2 or more generations reside.”  Even a household with a  50-year-old parent and a 15-year-old child would, under such interpretation, qualify for vaccination under Tier B1.  I do not believe that is what DOH intended, and the example given in the definition confirms that.  The “such as” example suggests that there must be an “elder” in the household.  Faced with this definitional ambiguity, let’s dig deeper into what DOH has said about its timeline for priority vaccination.

In its COVID-19 Vaccine Prioritization Guidance and Interim Allocation Framework (click here), DOH offers context for the B1 tier:

The [B1] tier focuses on protecting those who are driving hospitalization and face high rates of severe morbidity and mortality in order to reduce the burden on hospitals that keeps us in an emergency state. We also want to recognize that there are older adults and elders who may be vulnerable and unable to live independently similar to those in community-based, congregate care settings (Phase 1a) but their families care for them at home. In addition, we recognize that many families – especially those disproportionately affected by COVID – live in multi-generational homes that put the older adults and elders in the household at significantly higher risk for acquiring infection. Because these individuals are among disproportionately affected groups, they are also at risk for higher rates of severe morbidity and mortality.

This statement makes clear that the multigenerational household classification is intended to protect older adults and elders unable to live independently or in a care facility, and who live with a younger generation that may care for them or for which they care.

Twice the foregoing quote references “disproportionately affected groups.” DOH identifies communities that have been disproportionately impacted by COVID-19 to include “communities of color, refugees, immigrants, farmworkers, people with disabilities, people experiencing homelessness, and people with underlying health conditions.”  A fundamental goal of DOH’s vaccine prioritization framework is to address inequities in health care which are the result of broader societal and structural factors like racism and other forms of oppression. These structural factors, DOH reports, result in differential access to resources, services, and opportunities, including access to health care.  In this context, DOH identifies people who have been disproportionately impacted by COVID-19 because of systemic inequities to be communities of color, people with limited English proficiency, individuals with disabilities, and low-income people.  To bring it full cycle, DOH observes that these communities are more likely to live in multigenerational households.

Does Anyone Else Provide a Definitive Definition of “Multigenerational Household” That May Provide Guidance Here?

That a multigenerational household is one which houses an elder, or at least is one with more than a parent and a youth child, is supported by definitions of the term in other contexts.  For example, the U.S. Census Bureau defines multigenerational households as households that consist of “three or more generations of parents and their families.”  The Census Bureau’s definition, however, is inconsistent with DOH’s express statement that a household with “2 or more generations” can qualify.

The Pew Research Center, which studies social and demographic trends, characterizes multigenerational households as one of the following:

  • Two generations: Parents or in-laws or adult children aged 25 or older; a person from either generation can be the head of household.
  • Three generations: Parents or in-laws, adult children (and spouse or children-in-law), and grandchildren.
  • Skipped generations: Grandparents and grandchildren whose parents are dead or unable to care for them.
  • More than three generations: The ages in the household can range from infancy to extreme old age.

The AARP Public Policy Institute defines multigenerational household as one in which the “householder” lives in any of the following combinations:

  • Householder, child, and grandchild
  • Householder with parent
  • Householder with parent and child
  • Householder with grandchild
  • Householder with parent, child, and grandchild
  • Householder with parent and grandchild.

AARP expressly excludes from the definition households comprised just of parents and children, regardless of the age of the child.

The common theme in these definitions is that a multigenerational household is one where either an elder like a grandparent lives, or the youngest generation resident is an adult.  A household with a 55-year-old parent and a 15-year-old child would not, under any of these definitions, qualify as a multigenerational household.

Conclusion

Tier B1 is the second highest priority in Washington for vaccination.  People 70 years and older are at high risk for severe COVID-19 and are deserving of such high priority.  People 50 years and older who live with such high risk family members are also deserving of such high priority for the sake of protecting those high risk individuals.  But a 50-year-old parent, who otherwise does not present with “high risk” circumstances, living with a youth child should not receive the second highest priority for vaccination.

While the literal words of Washington’s vaccine priority timeline may indicate otherwise, a multigenerational household is one where an elder resides or where the youngest generation is adult.  I suspect that when DOH moves Washington State to Tier B1, it will issue further guidance as to which households qualify as multigenerational.


Helsell Fetterman LLP closely follows Governor Inslee’s COVID-19-related proclamations, guidance, and statements on reopening business in Washington and we are available to advise and assist you in tailoring your reopening and operations to meet these evolving standards.  For further information or assistance, please contact Scott Collins (scollins@helsell.com).


About the Authors

Scott Collins

As managing partner of Helsell Fetterman since 2001, Scott Collins understands the operational aspects of business and how legal issues must be addressed within greater business considerations. Utilizing that perspective, he provides clients with cost-effective legal counsel achieving practical results that serve their business goals.

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