The published guidance recommends including eligible family at the outset, and each included spouse or child under 21 carries a US$1 million gift and a US$15,000 fee. Later inclusion is not described as free or automatic, and a child who passes 21 in the meantime may no longer be eligible as a derivative.
Include the family when the ages and the budget allow
Hypothetical example: the dentist would rather pay for herself first, see whether the application succeeds, and add her husband and two teenagers afterwards. The official FAQ says each spouse or unmarried child under 21 should be included in the initial application and that each included family member carries a US$1 million gift and US$15,000 processing fee. It does not promise that later additions are automatic or available on the same terms, so the family should not rely on that assumption and should re-verify the current process before paying.
A child who reaches 21 may no longer qualify as a derivative and would then need an independent basis for residence. A husband who is not included receives no status from her application. If the family obtains permanent residence, each admitted member holds permanent residence rather than citizenship, and the gift and fee remain distinct from an EB-5 investment.