The Honorable Gary R. Herbert
350 North State Street, Suite 200
PO Box 142220
Salt Lake City, Utah 84114-2220
Lt. Governor/Governor-elect Spencer Cox
350 North State Street, Suite 220
P.O. Box 142325
Salt Lake City, Utah 84114-2325
J. Stuart Adams
President – Utah State Senate
320 State Capitol
Salt Lake City, Utah 84114
Speaker – Utah State House of Representatives
350 North State, Suite 350, P.O, Box 145030
Salt Lake City, Utah 84114
Re: Utah Vaccination Plan and the Inclusion of Individuals with ID/DD
Dear Governor Herbert, Governor-elect Cox, President Adams, and Speaker Wilson
As three agencies that represent the interests of Utahns with Intellectual and Developmental Disabilities (ID/DD), we write to you today, along with our other organizational signatories, to urge you to protect some of our State’s most vulnerable with the COVID-19 vaccine. While we greatly appreciate the current vaccination plan including long-term care (LTC) residents and those in congregate living facilities in phase 1 b of the rollout, we believe it is essential to include individuals with ID/DD living in the community in this phase of the vaccination plan.
There has been a great deal of information about the threat posed to individuals living in LTC facilities and other congregate settings; however, studies also indicate that those with ID/DD are also at an increased risk. In fact, a recent study showed that the risk of death for these individuals is around three times greater as compared to others. [i] Another study even showed that, for individuals with Down syndrome, the mortality rate was ten times greater.[ii]
Moreover, individuals receiving home and community-based services (HCBS) may have a more difficult time mitigating the risk of contracting COVID-19 due to their disability. Many of these individuals rely on personal care services where they will have close contact with individuals who live outside their home. We would be remiss if we did not also recommend those personal care workers should be prioritized for vaccination, much like LTC staff. With that in mind, the risks go beyond mortality, as these individuals and their personal care workers could also contribute to community spread due to their necessary close contact.
We certainly recognize the difficult task the State has in determining who will receive priority for the limited quantities of a vaccine. There are many deserving populations. Even so, we ask that you prioritize Utahns in the community with ID/DD in phase 1 b of the State’s vaccination plan. Determining the exact number of vaccinations required is unknown; however, the Division of Services for People with Disabilities has roughly 6600 individuals in services and another 3000+ waiting. Even with the inclusion of personal care workers, it is a relatively small number of doses to prevent the possibility of increased community spread and mortality when our healthcare system is already nearing its breaking point.
While the risk of spread is reduced for those in HCBS compared to those in congregate settings-one of the many reasons we believe access to HCBS is critical- the data supports an increased rate of mortality for those with ID/DD. We urge you to do all you can to protect those with ID/DD outside of LTC and congregate settings as well as those who reside in them.
Thank you for your consideration of this request. Please do not hesitate to contact any of us if you have any questions or concerns.
Disability Law Center
Utah Developmental Disabilities Council
Utah State University
Center for Persons with Disabilities
We are joined by the following organizations:
Utah Parent Center
Utah Association of Community Services
Legislative Coalition for People with Disabilities
Disabled Rights Action Committee
Utah Department of Health
PO Box 141000
Salt Lake City, UT 84114-1000
Ann Silverberg Williamson
Utah Department of Human Services
195 North 1950West
Salt Lake City, Utah 84116-3100
Dr. Angela Dunn
Bureau of Epidemiology, Department of Health
288 North 1460 West
P.O. Box 142104
Salt Lake City, Utah 84114-2104
- [i] FAIR Health, Risk Factors for CO VID-19 Mortality Among Privately Insured Patients: A Claims Data Analysis,
available at https://s3.amazonaws.com/media2.fairhealth.org/whitepaper/asset/Risk%20Factors%20for%20COVID-19%20Mortality%20among%20Privately%20Insured%20Patients%20-%20A%20Claims%20Data%20Analysis%20-%20A%20FAIR%20Health%20White%20Paper.pdf.
- [ii] Clift, Coupland, Keogh, et al., COVID-19 Mortality Risk in Down Syndrome: Results From a Cohort Study Of 8
Million Adults, Annals of Internal Medicine (Oct. 2020), available at,