U.S. Assisted Living Market Outlook 2026 to 2030: Industry Analysis, Occupancy, Costs, Regulation and the Lender's View
By Michal Mohelsky, J.D., FMVA | Principal, MMCG Invest, LLC | September 2026
1. Summary: a demand cycle without a building cycle
Assisted living has never had fundamentals this strong, and it has never built this little. In the second quarter of 2026, assisted living occupancy across the 31 NIC MAP Primary Markets reached 88.4%, the twentieth consecutive quarterly increase, while assisted living inventory grew 0.3% year over year against a long-run average above 3% (1). Across the 99 Primary and Secondary Markets, senior housing units under construction fell below 24,000, the lowest count since mid-2012 (2). The national median private-pay rate is $6,200 a month, up 5% in a year and 21.6% since 2022 (3).
The 2015 to 2019 cycle taught the industry what happens when capital arrives before residents do: a construction wave, three years of lease-up pain, and communities that never crossed 80% occupancy. This cycle is the mirror image. Residents are arriving and construction capital is not. NIC MAP's construction lending series fell to $143 million in the fourth quarter of 2025 (4). CBRE's developer survey puts the all-in cost of a new senior housing unit at $388,830 and the return on cost at 8.1%, against a 7.0% stabilized cap rate, a spread too thin to move most lenders (5). An existing community trades at roughly 45% of that replacement cost. As long as buyers can acquire occupied beds for less than half the cost of building them, they will.
Three things follow. First, occupancy keeps rising, with majority assisted living properties on a path to cross 90% by early to mid-2027 on NIC MAP's projection, because nothing started in 2026 can open before 2028 on a 29-month construction cycle (2, 6). Second, pricing power is real but already moderating: in-place assisted living rates grew 5.3% in June 2026 after 6.4% in March, and move-in discounts widened to 1.1 months of rent (7). Third, the operating recovery is uneven. NIC's September 2026 margin analysis shows the top quartile of for-profit assisted living above a 40% EBITDAR margin and the bottom quartile still negative (8). The market is rewarding operators, not buildings.
For lenders the picture is favourable on collateral and demanding on credit. Core Class A assisted living cap rates compressed to 6.5% in CBRE's April 2026 survey, 50 basis points inside where they stood a year earlier, and deal flow ran at 80 announced transactions a month in the first half of 2026 with assisted living the largest segment (9, 10). HUD Section 232 closed a record $5.96 billion in fiscal 2025 (11). But the loans that reach SBA, USDA and community bank desks are not Class A. They are 40 to 120 bed communities in secondary markets, owner-operated, exposed to labor that runs 40% of revenue, to state Medicaid rates that face federal pressure from fiscal 2028, and to an immigrant workforce that supplies 23% of direct care hours in residential care (12, 13, 14). The underwriting question in 2026 is not whether demand exists. It is whether this operator, in this state, at this cost basis, can convert it.
This report assembles the record. It sizes the industry from official sources and explains why the published figures disagree by more than two to one. It sets out demand, occupancy, pricing, supply, operating economics, regulation and capital as of the third quarter of 2026, and closes with the view we bring to feasibility work for SBA 7(a), SBA 504, USDA Business and Industry and conventional lenders.
2. The count: how big assisted living is, and why nobody agrees
The first fact a credit memo should carry is that there is no single official size for U.S. assisted living. There are two federal frames that measure different things, and a market research industry that measures neither.
The supply frame is the CDC's National Post-acute and Long-term Care Study (NPALS). Its 2022 wave counts 32,200 residential care communities with 1,313,600 licensed beds, an average of 41 beds, 81.5% for-profit, 57% chain-affiliated and 45% authorized to accept Medicaid (15). NPALS counts every state-regulated community with four or more beds that provides room, board, around-the-clock supervision and help with personal care, regardless of what the state calls it. It excludes one to three bed homes and facilities licensed only for people with mental illness or developmental disabilities. The CDC publishes two resident counts for the same year, 988,800 in its overview tables and 1,016,400 in Data Brief 506, and does not explain the gap (15, 16). Either way, residents divided by licensed beds gives whole-industry occupancy of 75% to 77%, ten points below the professionally managed metro sample NIC MAP tracks. That gap matters for anyone underwriting a small or rural community, and we return to it.
The revenue frame is the Census Bureau. Its Service Annual Survey puts 2022 revenue for employer firms in NAICS 623312, Assisted Living Facilities for the Elderly, at $37.3 billion, of which $5.5 billion was tax-exempt (17). The series grew 4.5% a year from 2018 to 2022 and 9.6% in 2022 alone. It has not been extended past 2022 because Census folded the survey into a new integrated program that so far publishes only at the two and three digit level. The problem with $37.3 billion is what 623312 leaves out: assisted living wings inside continuing care campuses and communities with on-site nursing are coded to NAICS 623311 or 623110, and non-employer operators are outside the survey altogether. The combined 6233 group, CCRCs plus assisted living, reported $78.4 billion (17). Revenue per licensed bed under the narrow code works out to about $28,400 a year, less than 40% of the CareScout annual median, which is the clearest evidence that the narrow code captures well under half of the money.
A bottom-up rebuild lands between the two Census figures. One million residents at the $74,400 CareScout annual median gives $74 billion to $76 billion of resident spending. Taking 1.31 million licensed beds at NIC MAP's 88.4% occupancy and $6,200 a month gives $86 billion, which overstates because it applies metro occupancy and one-bedroom pricing to six-bed homes and Medicaid residents.
Exhibit 1: Sizing U.S. assisted living, official frames against syndicated estimates
Measure | Figure | Year | Basis |
Residential care communities | 32,200 | 2022 | CDC NPALS, state-regulated, four or more beds |
Licensed beds | 1,313,600 | 2022 | CDC NPALS |
Residents on a given day | 988,800 to 1,016,400 | 2022 | CDC NPALS overview tables versus Data Brief 506 |
Revenue, NAICS 623312 employer firms | $37.3 billion | 2022 | Census Service Annual Survey |
Revenue, NAICS 6233 (CCRCs plus assisted living) | $78.4 billion | 2022 | Census Service Annual Survey |
Bottom-up, residents x annual median cost | $74 billion to $76 billion | 2025 pricing on 2022 residents | MMCG calculation from NPALS and CareScout |
Bottom-up, beds x NIC occupancy x monthly median | $86 billion | 2025 to 2026 | MMCG calculation, upper bound |
IBISWorld | $45.5 billion | 2026 | Syndicated, NAICS-aligned |
Grand View Research | $52.0 billion; $91.8 billion in a separate 2022 product | 2026 | Syndicated, definition not disclosed |
Fortune Business Insights, U.S. | $48.8 billion | 2026 | Syndicated |
Persistence Market Research | $52.4 billion | 2026 | Syndicated |
MarkWide Research | $114.8 billion | 2026 | Syndicated, includes memory care, definition not disclosed |
Sources: CDC NCHS NPALS 2022 (15, 16); U.S. Census Bureau Service Annual Survey via FRED (17); CareScout 2025 (3); NIC (1); syndicated publishers as named (18). Bottom-up rows are MMCG arithmetic.
The syndicated figures range from $45.5 billion to $114.8 billion for the same country in the same year. They are not competing measurements. They are different, mostly undisclosed, definitions, and the same publisher can hold two of them at once. We do not use any of them as an underwriting input, and we do not think a lender should. For an industry-size statement, the Census 623312 figure is the defensible floor and the 6233 figure the defensible ceiling. For a loan, national size is irrelevant beside the subject's licensed capacity, trailing occupancy and rent roll.
3. Who runs it: chains at the top, six-bed homes in the tail
Assisted living is a fragmented industry with a consolidated top tier. The ten largest seniors housing operators on the 2025 ASHA 50 managed 268,963 units across every care segment; even if every one of those units were an assisted living bed, that would be 20.5% of the NPALS licensed base, and the true share is materially lower because the ASHA count includes independent living (19). Against 32,200 communities, the top ten operators' 2,074 properties are 6.4%. The chains run big buildings. The tail runs small ones.
The tail is larger than employer-based statistics show. California, the largest state market, licenses assisted living, board and care, memory care and CCRC residential units under a single Residential Care Facility for the Elderly license; the state's own budget analysts found, in the last published breakdown, that 79% of roughly 7,500 RCFEs were licensed for four to six beds (20). The trade association counts more than 7,800 RCFEs housing over 210,000 residents, against a Census count of about 4,100 establishments with employees in the same industry code (20). The difference is thousands of owner-operated homes that appear in a licensing registry and nowhere else. Florida licenses 2,985 assisted living facilities ranging, in the state's own words, from one resident to several hundred, and has been legislating a fourth specialty license for memory care with rules due by October 2026 (21).
At the top, 2026 brought the first change in a decade. Discovery Senior Living, at 46,608 units across 413 properties, overtook Brookdale (42,697 units, 538 communities) as the largest operator on the 2026 ASHA 50; Welltower remained the largest owner at 130,957 units (19). The five largest operators manage 31% of the units on the list. Brookdale and Sonida, the only two public companies among the fifty largest operators, together manage 9%. Ownership and operation are separating: the REITs own the real estate and pay a third-party manager under a RIDEA structure, so the credit a lender is exposed to is the management agreement, not the balance sheet on the deed.
Exhibit 2: Largest U.S. seniors housing operators and owners
Rank | Operator, June 2026 | Properties | Units |
1 | Discovery Senior Living | 413 | 46,608 |
2 | Brookdale Senior Living | 538 | 42,697 |
3 | LCS | 129 | 39,200 |
Owner, June 2025 | |||
1 | Welltower | 1,067 | 112,641 |
2 | Ventas | 756 | 73,570 |
3 | Brookdale Senior Living | 376 | 32,448 |
Source: ASHA 50, 2025 and 2026 editions, as published by ASHA and reported by Seniors Housing Business and McKnight's Senior Living (19). Units include independent living, assisted living and memory care. Welltower's 2026 owned count is 130,957 units.
Consolidation is running at a record pace. LevinPro LTC counted 871 publicly announced seniors housing and care transactions in 2025, 20.8% above the previous record, with $30.5 billion of disclosed value, and a further 481 deals in the first half of 2026 (10). Assisted living was the plurality property type in every quarter, at 41% to 50% of announced deals. The buyers are consolidating the middle of the market, not the six-bed tail, which remains an owner-operator business financed, when it is financed at all, by SBA lenders and community banks.
4. Demand: age, dementia and the turnover most pro formas ignore
The demographic case is arithmetic, and it is prepaid. Every American who will be 85 in 2031 turned 80 this year. Census projections put the 85+ population at 6.7 million in 2020, 9.1 million in 2030 and 14.4 million in 2040; the Administration for Community Living's figure for 2022 is 6.5 million, rising to 13.7 million by 2040 (22). The 2030s, when the post-war cohort passes 85, add more people to that age band than the decades on either side. Assisted living is an 85+ product: 52.8% of residents were 85 or older in 2022, 62% needed help with three or more activities of daily living, and 44% carried a diagnosis of Alzheimer's or another dementia (16).
Dementia compounds the age curve. The Alzheimer's Association's 2026 report counts 7.4 million Americans 65 and older living with Alzheimer's dementia, 11% of that age group, rising to 13.8 million by 2060 (23). Prevalence steps from 5.2% at ages 65 to 74 to 13.8% at 75 to 84 and 35.8% at 85 and above (23). Because prevalence nearly triples between the 75 to 84 band and the 85+ band, and because the 85+ band grows fastest, memory care demand should outgrow assisted living demand through the forecast period. NIC's penetration data already show it: metro assisted living penetration was unchanged from 2017 to 2023, while memory care penetration rose from 1.2% to 1.4% of 75+ households (24).
That flat assisted living penetration is the number to respect. NIC measures occupied senior housing units against households aged 75 and older; the 31-market average was 9.3% in 2023, ranging from 21.6% in Minneapolis to 4.2% in Las Vegas (24). A fivefold spread across metros and almost no movement over time means penetration is a local constant more than a national trend. A feasibility study that projects a metro's penetration above its own history is making the one assumption most likely to fail.
Demand also has to fill a hole before it can fill a building. NIC's operator data put the median assisted living stay at about 25 months and the median memory care stay at about 18 months (25). A 100-unit assisted living community at 90% occupancy therefore turns over roughly 48% of its residents a year and needs about 43 move-ins, or 3.6 a month, to stand still. A 40-unit memory care wing needs two a month. Sonida reports that 70% of its leases renew in the first quarter (12). The marketing budget, the referral network and the discount on new move-ins should be sized for that churn before any absorption is credited.
Exhibit 3: Turnover a stabilized community must replace each year
Community | Occupied units at 90% | Stay | Annual turnover | Move-ins needed per year | Per month |
100-unit assisted living | 90 | 25 months (NIC median) | 48% | 43 | 3.6 |
100-unit assisted living | 90 | 3.5 years (ASHA mean) | 29% | 26 | 2.1 |
40-unit memory care | 36 | 18 months (NIC median) | 67% | 24 | 2.0 |
Source: NIC median length of stay and ASHA/ProMatura 2025 resident survey mean (25); MMCG calculation, turnover equals 12 divided by stay in months.
5. Occupancy and pricing in 2026
Occupancy has risen for twenty straight quarters, and the pace is slowing as markets fill. Assisted living occupancy in the 31 Primary Markets moved from 84.3% in the second quarter of 2024 to 88.4% in the second quarter of 2026, a gain of 4.1 points in eight quarters (26, 1). Quarterly gains have narrowed from 0.7 or 0.8 points in 2024 to 0.4 points in 2026, and net absorption of about 3,700 units in the second quarter of 2026 was the smallest in the series (27). That is what practical capacity looks like, not weakening demand: fifteen of the 31 markets were at or above 90%, and across the 99 Primary and Secondary Markets 57 were above 90% and 23 above 92% (27, 2). The gap between independent living (91.3%) and assisted living narrowed to 2.9 points, the smallest since 2014 (1).
Exhibit 4: Assisted living occupancy and inventory, NIC MAP 31 Primary Markets
Quarter | Senior housing occupancy | Assisted living occupancy | Year-over-year inventory growth | Units under construction |
2Q 2024 | 85.9% | 84.3% | 1.5% (assisted living 1.6%) | under 27,000 |
4Q 2024 | 87.2% | 85.5% | about 8,800 units added in 2024 | under 22,000 |
2Q 2025 | 88.1% | 86.4% | 1.0% | not published |
4Q 2025 | 89.1% | 87.7% | under 1% | not published |
1Q 2026 | 89.5% | 87.9% | 0.4% (assisted living 0.4%) | about 16,400 |
2Q 2026 | 89.9% | 88.4% | 0.4% (assisted living 0.3%) | under 16,000 |
Source: NIC and NIC MAP quarterly releases, 2Q 2024 through 2Q 2026 (26, 27, 1). NIC revises prior quarters; figures are as first published.
The metro spread is seven points. Boston (93.3%), San Francisco (92.7%) and Baltimore (91.8%) lead; Miami (86.2%), Atlanta (86.5%) and San Antonio (87.0%) trail (27). The leaders are the coastal and Northeastern markets where entitlement is hardest; the laggards are Sun Belt metros still absorbing 2017 to 2020 deliveries. The weakest market in 2026 sits 1.7 points above the weakest market in 2025.
Pricing is firm and decelerating. Same-store asking rent growth in the Primary Markets ran 4.3% in the third quarter of 2025, with assisted living at 4.4%, and stayed in a 4% to 5% band in the first quarter of 2026, against a pre-pandemic norm of 3% to 3.5% (28). NIC MAP's Actual Rates series, drawn from operator records on more than 300,000 units rather than from asking rents, tells the more useful story. In-place assisted living rates grew 5.3% in June 2026, down from 6.4% in March; initial rates for new move-ins grew 6.4%, down from 8.1%; and the discount from asking to initial rate widened to 9.4%, or 1.1 months of rent, from 0.8 months (7). Memory care asking rents were rising 5.1% in mid-2025 while initial rates rose 2.2%, with discounts averaging 1.2 months (25). The headline is still above 5%. The rent a new resident pays is growing more slowly, and the gap is widening. We underwrite effective rent growth of 3% to 4% for assisted living and less for memory care, not the asking-rate print.
The price level is set by CareScout. Its 2025 Cost of Care Survey, released March 2, 2026, collected more than 25,000 provider-reported rates and puts the national median for a private one-bedroom assisted living unit at $6,200 a month, or $74,400 a year, up 5% after a double-digit increase in 2024 (3). The state range is nearly threefold, from $4,369 in Mississippi to $12,096 in Hawaii. Cumulative growth from 2022 to 2025 was 21.6% nationally, about 6.7% a year, with Connecticut roughly doubling and North Dakota falling 8%; single-state changes of that size reflect sample shifts as much as pricing and should not be used as rent assumptions (3). Memory care is not surveyed. Consumer referral data put the memory care premium near 20%, and NIC's operator data imply closer to a third; we use a documented range of 20% to 35% and set the subject's premium from a local survey (29, 25).
Exhibit 5: Assisted living median monthly cost and the home care crossover, selected states, 2025
State | Assisted living, monthly | Non-medical caregiver, hourly | Hours a week at which home care costs more |
Hawaii | $12,096 | $41 | 68 |
Massachusetts | $9,600 | $40 | 55 |
New York | $7,110 | $35 | 47 |
California | $7,000 | $40 | 40 |
Minnesota | $6,572 | $44 | 35 |
Ohio | $6,102 | $34 | 41 |
Texas | $5,666 | $30 | 44 |
Florida | $5,610 | $32 | 41 |
Georgia | $5,300 | $32 | 38 |
South Dakota | $4,900 | $44 | 26 |
Alabama | $4,425 | $27 | 38 |
Mississippi | $4,369 | $24 | 42 |
United States | $6,200 | $35 | 41 |
Source: CareScout 2025 Cost of Care Survey, ranked state tables (3). Crossover is MMCG arithmetic: monthly assisted living cost divided by the hourly rate and by 4.333 weeks.
The crossover column is the substitution risk in one number. At the national median of $35 an hour, in-home care costs more than assisted living once a person needs about 41 hours a week, under six hours a day; a semi-private nursing home room at $9,581 a month becomes the more expensive option above 63 hours (3). In the Upper Midwest and Mountain states, where caregivers are expensive relative to buildings, assisted living is the cheaper option at three to four hours of daily care. In Hawaii and the Northeast, it has to win on supervision and dementia care rather than price. Memory care wins everywhere, because 24-hour supervision is far past any crossover.
6. Supply: why a record demand cycle is producing almost no buildings
Supply has contracted every year since 2017, and the contraction is not reversing. Assisted living units under construction peaked at 10.1% of inventory in late 2017. By the first quarter of 2025, starts in the Primary Markets fell to 1,076 units, the fewest since the second quarter of 2009 (26). Rolling four-quarter starts now equal 0.7% of inventory and units under construction 2.2%, against NIC's rule of thumb that anything under 5% is manageable (2). Nearly 60% of the 140 metros NIC MAP tracked in the third quarter of 2025 had no senior housing project under way, up from a third three years earlier (28). With a 29-month average build cycle, a project that breaks ground in the fourth quarter of 2026 opens in 2029. NIC MAP does not expect substantial new inventory before 2030 (2, 6).
The constraint is cost against value. CBRE's second-quarter 2026 survey of 36 projects puts total development cost at $388,830 per unit, or $364 per square foot of gross building area, up 23.6% since 2023; hard costs are $262.75 a square foot, soft costs 16.2% of the total, land 8.1%, and furniture and fixtures, which CBRE describes as having surged, $11,900 a unit (5). The Weitz cost brief for mid-2026 prices mid-level assisted living construction at $281 to $358 per gross square foot and high-acuity assisted living and memory care at $365 to $454, and projects 3% to 4% annual escalation driven by labor and tariffs rather than material shortages (30). Tariffs of 50% on steel, aluminum and copper, duties near 45% on Canadian softwood, and a 2026 tariff on Canadian cement, plywood and furniture are real but second-order: we estimate their direct effect at 1.5% to 2.5% of hard cost, with the larger damage in contractor contingency pricing and longer preconstruction.
Against that cost, CBRE's developers report an 8.1% untrended return on cost and a 7.0% stabilized cap rate, a 110 basis point spread (5). Developers and construction lenders have historically wanted 150 to 200 basis points for carrying construction and lease-up risk. Against core Class A assisted living at 6.5%, the spread reaches 160; against a non-core assisted living exit near 7.1%, it is about 100; against Class A memory care at 8.0%, it is close to zero. CBRE's own conclusion in April 2026 was that market rents in most core markets remain well below the level that makes development feasible, having put the gap at 15% to 20% in its prior edition (9). Brookdale's chief executive has said publicly that rents would need to rise 30% to 40% nationally for new construction to pencil (31).
Our arithmetic runs higher still at the national median. Taking CBRE's cost, an 8.5% required yield, 92% stabilized occupancy and a 30% to 35% margin, a new assisted living unit needs $8,550 to $9,980 a month in revenue per occupied unit. The national median is $6,200. In Alabama or Arkansas, at state medians near $4,500, ground-up assisted living at national average cost does not work at any spread; it needs a cost basis near $250,000 a unit or a USDA or SBA capital structure that tolerates thinner coverage.
Exhibit 6: Development yield against trading value, 2026
Measure | Value | Source |
Total development cost per unit | $388,830 | CBRE Q2 2026, 36 projects (5) |
Hard cost per unit | about $281,900 | 72.5% of total, MMCG arithmetic |
Untrended return on cost | 8.1% | CBRE (5) |
Stabilized cap rate, developer survey | 7.0% | CBRE (5) |
Core Class A assisted living cap rate | 6.5% | CBRE investor survey, April 2026 (9) |
Core Class A memory care cap rate | 8.0% | CBRE investor survey, April 2026 (9) |
Rolling four-quarter price per unit, senior housing | $174,000 to $175,000 | NIC MAP, 3Q 2025 (32) |
Trading value as share of replacement cost | about 45% | MMCG arithmetic |
Required revenue per occupied unit, new build | $8,550 to $9,980 a month | MMCG arithmetic, assumptions in text |
National median assisted living rate | $6,200 a month | CareScout 2025 (3) |
Sources as noted in the table.
The average traded senior housing asset changed hands at $174,000 to $175,000 a unit in late 2025, up 43% in a year and still about 45% of CBRE's replacement cost (32). That number, more than any regulatory or labor variable, explains the missing building cycle. An acquisition at $175,000 plus a $50,000 to $75,000 repositioning produces an all-in basis near 60% of new construction and needs roughly half the NOI per unit to clear the same yield. Capital is going there. Welltower closed 80 seniors housing operating acquisitions totalling $5.4 billion in the first half of 2026 at a 5.1% going-in yield (33).
The one form of new supply that still works on cost is the small home. A ten to sixteen bed residential model, permitted by right at six beds in California, Minnesota and Florida and at ten in Arizona, works out to $117,000 to $140,000 a bed in the last documented Green House cost data from 2014, which escalates to perhaps $170,000 to $220,000 today, roughly half the purpose-built figure (34). It leases up in months rather than years and carries higher key-person and exit risk. For SBA and USDA lenders, the ten to sixteen bed format in a state with favourable licensing thresholds is more financeable than either a six-bed home, which usually works only on owner-provided labor, or an 80-unit ground-up project at today's yields.
For the projects that do open, lease-up should be the fastest since 2016. NIC's long-run benchmark had assisted living and memory care reaching a median 89% occupancy eight quarters after opening; the 2017 to 2020 vintages did far worse, and more than half of 2020 openings never crossed 80% (35). Absorption has now outpaced supply for twenty quarters. A spring 2026 investor survey projected assisted living and memory care absorption of zero to four units a month (35). We underwrite three to four net move-ins a month for assisted living and one to two for memory care, 25% to 30% pre-leased at opening, stabilization at 90% in 18 to 24 months, and a 30-month downside.
7. Operating economics: margins, labor and liability
The recovery in operating results is real and concentrated. NIC's September 2026 analysis of for-profit assisted living finds the median EBITDAR margin back at roughly its 2018 level after collapsing in 2021, with the upper quartile above 40% and the lower quartile still negative in 2025 (8). NIC also observes that much of the post-2021 rent growth has gone to absorbing cost inflation rather than to margin. Public operators cluster at the top of the range. Sonida reported a same-store margin of 32.6% in the second quarter of 2026, up 250 basis points, on occupancy of 87.8% and RevPOR of $5,372, with assisted living at $5,890 and memory care at $7,439 a month (12). Welltower's seniors housing operating portfolio grew same-store NOI 20.5% with RevPOR up 5.2% and occupancy up 330 basis points (33); Ventas grew same-store cash NOI 16% at a 31% margin and reported incremental flow-through of 55% (36). American Healthcare REIT and National Healthcare Properties, with older and smaller portfolios, reported margins of 22.3% and 22.4% (37). Brookdale's consolidated occupancy of 82.4%, and its chief financial officer's remark that occupancy had not moved as quickly as expected, show that older, larger portfolios are not sharing equally (38).
Exhibit 7: Second-quarter 2026 operator disclosures
Operator | Occupancy | Rate growth | Same-store NOI growth | Margin |
Sonida Senior Living | 87.8% same-store, up 240 bps | RevPOR up 4.9% | up 16.9% | 32.6% same-store |
Welltower SHO | up 330 bps | RevPOR up 5.2% | up 20.5% | over 32% (call commentary) |
Ventas SHOP | up 300 bps | RevPOR up 5% | up 16% | 31% (investor slides) |
Brookdale | 82.4% consolidated, up 230 bps | same-community RevPOR up 4.1% | adjusted EBITDA up 4.3% | not disclosed on this basis |
American Healthcare REIT SHOP | not quantified | not disclosed | up 20.5% | 22.3% |
National Healthcare Properties SHOP | 84.1%, up 140 bps | RevPOR $6,390, up 5.9% | up 20.1% | 22.4% |
Sources: company earnings releases and call transcripts for the quarter ended June 30, 2026 (12, 33, 36, 37, 38). Welltower and Ventas margin levels are from call commentary and slides rather than the filed releases.
Labor decides which quartile a community lands in. Sonida's disclosed labor cost of 40.4% of revenue is the best public benchmark; lender guidance puts total operating expenses for stabilized assisted living and memory care at 55% to 70% of revenue, direct care at 40% to 50% of expenses, and third-party management fees at 4% to 6% of revenue (12, 39). The wage base is low and rising. The most recent industry-specific federal wage table, for CCRCs and assisted living combined, puts personal care aides at a mean of $16.87 an hour, nursing assistants at $18.10, licensed practical nurses at $29.51 and registered nurses at $37.11, all as of May 2023; every operator we read describes scheduling programs to offset wage inflation rather than any relief in wages (40). Payroll for the combined group was $33.3 billion in 2022, and employment stood near 981,000 in mid-2024 (17, 40).
Immigration policy has become a labor variable with dates on it. KFF finds immigrants are 23% of direct care workers in residential care facilities, and at least one in five of them come from countries covered by the 75-country immigrant visa suspension of January 2026 (14). The Supreme Court's June 25, 2026 decision allowing the termination of Temporary Protected Status for Haiti affected more than 300,000 people; Salvadoran TPS ended September 9, 2026; family reunification parole for seven countries ended in December 2025 (14). Trade associations have said publicly that providers may limit admissions or close units, and Wisconsin operators have reported dropping overseas hiring plans (14). The national share understates exposure in South Florida, the New York metro and New England, where the Haitian and Salvadoran workforce is concentrated. In those markets we stress wages 3% to 5% above the base case.
Liability is the other operating line that has repriced. Average indemnity on senior care claims rose from $179,000 in 2019 to $253,000 in 2024; falls are 54% of assisted living case volume, with dementia present in three quarters of them; memory care claims run about 23% above other assisted living claims; and California claims average $409,000 against $228,000 elsewhere, which is why California is the one state where professional liability capacity has retreated to the excess and surplus market (41). Property insurance is softening, and named-storm deductibles are easing from 5% toward 2% to 3% for clean portfolios (41). We budget general and professional liability from the operator's loss runs and jurisdiction, not from a national rate.
8. Regulation and the Medicaid overlay
Assisted living is regulated by the states, and the states are busy. NCAL's 2025 regulatory review found that 18 states, counting the District of Columbia, changed their assisted living rules during 2025, most often on direct care staff training (10 states), administrator training (9) and staff scheduling (7) (42). Florida's 2026 session advanced a memory care specialty license that would bind any facility with a single memory care resident, or advertising memory care, with agency rules due by October 1, 2026 (21). There is no federal definition; GAO's June 2026 review notes that states use terms from personal care home to home for the aged, and at least one licenses the service agency rather than the building (43). The consequence for a lender is that the license type, licensed capacity and the specific health services provided under it must be stated in the study, because SBA eligibility turns on them.
Medicaid is a minority payer that matters at the margin. Seventeen percent of residential care residents had Medicaid paying for some of their services in 2022, and the 2020 wave showed the share at 24% in communities of 4 to 25 beds against 15% above 50 beds (16). Forty-one of 47 responding states cover home care services in assisted living, 34 cover personal care, 29 make it available around the clock, and only ten require facilities to accept new Medicaid residents (44). Medicaid does not pay room and board anywhere. GAO put federal Medicaid and traditional Medicare spending in assisted living at no less than $12 billion in 2024, of which $8.5 billion was Medicare, mostly hospice, and at least $3.5 billion federal Medicaid for about 300,000 beneficiaries (43). The waiver channel is capped: 41 states kept waiting lists in 2025 covering 607,000 people, with an average wait of 15 months on waivers for older adults (45).
Two federal changes sit inside the term of a ten-year loan. Public Law 119-21, enacted July 4, 2025, freezes new provider taxes and, from fiscal 2028, steps the hold-harmless threshold for expansion states down from 6% to 3.5% by fiscal 2032, while capping new state-directed payments (13). Nursing facility taxes are exempt from the step-down; the state budgets that fund assisted living waivers are not. HCBS is optional Medicaid spending, which makes waiver rates and slots the natural place for states to absorb the loss. The work requirements and six-month redeterminations apply to expansion adults, not to the aged and disabled pathway most assisted living residents use. Separately, the CMS Access Rule's 80/20 provision, which requires 80% of Medicaid payments for homemaker, home health aide and personal care services to reach direct care workers, has not been rescinded: reporting begins in 2028 and the requirement binds from July 9, 2030 (46). It names those three services, not bundled assisted living waiver services, so it reaches assisted living only where a state bills personal care separately in that setting. For a private-pay project these are footnotes. For a project whose plan depends on a state waiver rate, they are the credit.
9. Capital markets and the lender's view
Capital for stabilized assisted living is open and getting cheaper. CBRE's April 2026 investor survey, its eighteenth, put core Class A assisted living at a 6.5% cap rate, down 28 basis points in six months and roughly 50 inside the 7.0% of April 2025; core Class A memory care stood at 8.0%, independent living at 5.9% and skilled nursing at 10.9% (9). Every respondent reported rates flat or lower. The share expecting further compression fell from 84% to 59%, and 82% underwrite rent growth of 3% to 7% (9). JLL's blended senior housing cap rate was 6.2% at year-end 2025, a 210 basis point spread to the ten-year Treasury against a long-run 416, and assisted living was the most targeted segment, named by 40% of investors (47). The top of the market clears well inside the surveys: Welltower's first-half 2026 acquisitions went in at 5.1%, and it sold 44 triple-net properties at 7.5% (33).
Exhibit 8: Cap rates by segment, core Class A, CBRE investor survey
Segment | April 2026 | Change from October 2025 | April 2025 |
Active adult | 5.3% | down 20 bps | not stated |
Independent living | 5.9% | down 24 bps | not stated |
Assisted living | 6.5% | down 28 bps | 7.0% |
CCRC and life plan | 7.9% | down 21 bps | not stated |
Memory care | 8.0% | down 24 bps | rose 8 bps that survey |
Skilled nursing | 10.9% | down 13 bps | not stated |
Source: CBRE U.S. Senior Housing & Care Investor Survey, H1 2026 and H1 2025 editions (9). Survey opinions of a repeat panel, not closed-transaction rates.
Liquidity is at a cyclical high. Announced deal count ran at 80 a month through the first half of 2026, up 25.7% year over year in the second quarter, with $7.8 billion of disclosed value; private capital took 50% of 2025 volume and REITs 32%, up from 24% (10, 47). Price per unit reached $182,800 at year-end 2025 on JLL's series (47). None of this prices a 60-bed owner-operated community in a secondary market, which should be valued off the non-core and Class B tier, 58 basis points wider than core on CBRE's spread and wider in practice.
The debt that reaches that community comes through four channels, and the eligibility rules differ in ways that decide the structure.
HUD Section 232 is the takeout. Fiscal 2025 closed $5.96 billion across 337 loans, up 89% by dollars, at an average loan of $17.6 million; 329 of the 337 were 223(f) refinances or acquisitions, and lenders attribute the surge to bridge-to-HUD exits (11). Firm commitments ran $7.5 billion to $8.1 billion depending on the source, and the application backlog fell from 130 to 29. Through the fiscal 2026 midpoint, lenders had closed 190 loans totalling about $3.2 billion (11). An assisted living facility must have at least 20 beds and serve frail elderly unable to perform three activities of daily living; the Express Lane introduced in June 2025 processes low-risk 223(f) loans at up to 70% loan-to-value (11). The agencies are the other takeout. Fannie Mae requires 1.40x debt service coverage where more than half the property is assisted living or dementia care; Freddie Mac waives its refinance test at 55% loan-to-value only where coverage reaches 1.55x for assisted living and 1.75x for stand-alone memory care (48). Neither lends on lease-up.
SBA 7(a) and 504 are where owner-operators start, and the rule is precise. Under SOP 50 10 8, effective June 1, 2025, a business licensed as an assisted living facility that provides healthcare or medical services, which the SOP defines to include wellness checks, medication monitoring and part-time medical staff on site, is an eligible operating business; a residential facility that is not so licensed and provides no such services is a passive business and is not (49). That test is why stand-alone independent living does not qualify and licensed assisted living does. The second test is control: a management agreement that gives a third-party manager sole discretion makes the borrower passive. The owner must approve the budget, approve significant expenditures, control the bank accounts and employ the staff. Special-purpose property, which the SOP names to include nursing homes and assisted living, requires a going-concern appraisal allocating value among land, building, equipment and intangibles, raises the 504 equity injection to 15%, and to 20% for a new business (49). Nothing in the SOP mandates a feasibility study; the authority is 13 CFR 120.160(b), and lenders order one where repayment rests on projections, which for a start-up or ground-up assisted living project is always. SOP 50 10 8.1 governs loans numbered on or after October 1, 2026, splits change-of-ownership into four types and requires a quality of earnings report on acquisitions at $3 million and above (49). Combined 7(a) and 504 exposure per borrower doubled to $10 million from July 4, 2026 (49).
USDA Business and Industry covers for-profit rural assisted living outside towns of 50,000, with a fiscal 2026 guarantee of 85% below $5 million and 80% above, a 3% initial fee and 0.55% annual, and terms to 40 years (50). The eligibility language is narrower than SBA's: 7 CFR 5001.105 admits nursing homes and assisted living facilities where constant medical care is provided and available on site, and excludes independent living. A home offering only help with daily activities may not clear that bar. Unlike SBA, the regulation mandates an independent feasibility study for any guaranteed loan above $1 million to a new entity or new activity (50). Community Facilities, for nonprofit and public borrowers in towns under 20,000, lists assisted living among eligible healthcare facilities (50).
Exhibit 9: Federal credit channels for assisted living, 2026 parameters
Program | Who qualifies | Gating test | Leverage or coverage | Feasibility study |
SBA 7(a) | Licensed assisted living providing health services; owner-occupied through an EPC and operating company | License plus meaningful oversight of any manager | 1.15x DSCR over $350,000; 10% equity injection | Discretionary, 13 CFR 120.160(b) |
SBA 504 | Same | Special-purpose property | 15% equity, 20% if new business | Discretionary |
USDA Business and Industry | For-profit, rural under 50,000 | Constant medical care on site | 85% guarantee under $5 million, 80% above; up to 40 years | Mandatory above $1 million, new entity or activity |
USDA Community Facilities | Nonprofit or public, towns under 20,000 | Eligible healthcare facility | Direct and guaranteed, up to 40 years | Per agency |
HUD 232 and 223(f) | 20 or more beds, frail elderly | Continuous protective oversight | 80% LTV for-profit, 85% nonprofit; 1.45x DSCR; Express Lane at 70% | Market study |
Fannie Mae and Freddie Mac | Stabilized IL, AL and MC | Majority assisted living or dementia care | 1.40x (Fannie); 1.55x AL and 1.75x MC for Freddie's refinance waiver | Not construction |
Sources: SBA SOP 50 10 8 and 8.1 (49); USDA Rural Development and 7 CFR Part 5001 (50); HUD Section 232 program parameters and lender league reporting (11); Fannie Mae and Freddie Mac term sheets (48).
Construction debt is the thin layer. JLL's practitioners describe construction terms at 60% to 65% loan-to-cost and 250 to 325 basis points over the index, with guarantees that burn down as the project de-risks; NIC MAP recorded $277 million of senior housing construction lending in the third quarter of 2025 and $143 million in the fourth, while permanent volume reached $4.2 billion in the second half of 2025, the most since 2019 (6, 4). Bridge debt for lease-up runs 24 to 36 months at 400 to 700 basis points over SOFR on broker quotes, and its exit is HUD (39). A construction lender sizes to the takeout coverage the stabilized pro forma must clear, which puts the 1.40x to 1.55x agency floors, not the 1.15x SBA floor, at the center of a ground-up underwriting.
Distress, where it exists, is asset-specific. Gibbins Advisors counted 13 senior care Chapter 11 filings above $10 million in liabilities in 2025, up from 11, while healthcare filings overall fell 21% (51). The documented assisted living events of 2025 and 2026 are lender receiverships on individual communities and management platform failures, not portfolio collapses (51). There is no senior housing CMBS delinquency series to cite because the sector is too small in that market to be broken out. The communities that fail are older, smaller, Medicaid-exposed or operator-weak.
10. Outlook, 2026 to 2030
What follows is our view as of September 2026 and is labelled as such.
Occupancy keeps rising through 2028, then plateaus. Nothing started in 2026 opens before 2028, and starts have not turned. NIC MAP projects majority assisted living above 90% by early to mid-2027 and industry-wide stabilized occupancy near 93% by 2028; we regard the first as likely and the second as a ceiling, because the whole-industry base already sits ten points below the metro sample and the marginal community is not the one being filled (2, 28). The net absorption series is slowing, which is what capacity looks like.
Rent growth moderates to 3% to 4% effective. Asking rates will print above 4% for another year; in-place and initial rates are decelerating faster and discounts are widening (7). Affordability is the constraint. The national median has risen 21.6% in three years against wage growth near 2.5%, and the largest cohort of 85-year-olds in history enters the market from 2031 (3, 22). We expect the price gap between top-quartile and bottom-quartile communities to widen rather than the national median to keep compounding.
Supply stays short until at least 2029. NIC MAP's August 2026 outlook puts the cumulative need at 576,000 additional units by 2030 and more than a million by 2035, with starts down 67% since 2021 (52). That figure replaces the 806,000 that circulated earlier in the year, including in our own May report, and the two rest on different methods rather than a revision of demand. New product will come from three places, in order: repositioning of the 40% to 50% of stock that is 25 or more years old, ten to sixteen bed residential homes in states that permit them by right, and ground-up construction in the handful of coastal and Northeastern markets where rents already clear the feasibility line.
Cap rates compress modestly and then stop. Fifty basis points of assisted living compression is behind us, and the share of investors expecting more has fallen by a quarter (9). We carry terminal cap rates flat to current in feasibility work and do not project further compression into the exit.
The risks are operating risks. Labor supply in immigrant-dependent markets, state waiver rates after the fiscal 2028 provider tax step-down, and liability severity in California are the three we would name, in that order. None is a demand risk. The demand is prepaid.
11. What this means for a feasibility study
A study a lender can rely on in this cycle starts from the operator, not from the demographic curve. We state the license type, the licensed capacity and the specific health services provided, because SBA and USDA eligibility turn on them and because the whole-industry occupancy base is not the NIC MAP base. We size the primary market area from age- and income-qualified households, state the penetration the market has actually achieved, and do not project above it. We model turnover from median stay, not mean stay, so the required move-ins are visible before absorption is credited. We compute the revenue per occupied unit a new build requires from the subject's own cost basis, set it beside the local rent survey, and state the gap. We underwrite effective rents, labor at 38% to 45% of revenue, a stabilized margin of 25% to 32% unless the operator's own trailing statements prove better, liability from loss runs, and the state's waiver rate and slot position wherever Medicaid is more than a footnote. Where the subject is ground-up, we size to the takeout coverage, not to the construction lender's or the SBA's floor.
None of that requires a national market size. All of it requires the record set out above.
Frequently asked questions
What is the assisted living occupancy rate in 2026? Assisted living occupancy in the 31 NIC MAP Primary Markets was 88.4% in the second quarter of 2026, up 0.4 points and the twentieth consecutive quarterly gain; majority assisted living properties across the 99 Primary and Secondary Markets were 88.6% occupied (1, 2). Across all 1.31 million licensed beds, including small and rural communities outside the NIC MAP sample, the occupancy implied by CDC resident counts is about 75% to 77% (15, 16).
How much does assisted living cost in 2026? The CareScout 2025 Cost of Care Survey, released March 2, 2026, puts the national median at $6,200 a month, or $74,400 a year, ranging from $4,369 in Mississippi to $12,096 in Hawaii (3). Memory care typically runs 20% to 35% above assisted living.
How many assisted living facilities are there in the United States? The CDC's 2022 count is 32,200 residential care communities with 1,313,600 licensed beds (15). Trade and vendor directories publish higher counts because they include one to three bed homes and settings outside state licensing, and lower figures still in circulation come from earlier survey waves.
How big is the U.S. assisted living market? Census data put 2022 revenue at $37.3 billion for assisted living facilities for the elderly as a standalone industry code and $78.4 billion including CCRC-based care (17). Resident spending computed from CDC resident counts and the CareScout median is $74 billion to $76 billion. Syndicated estimates of $45 billion to $115 billion reflect undisclosed definitions rather than measurement.
Can SBA or USDA loans finance assisted living? Yes. Under SOP 50 10 8 a licensed assisted living facility providing health services is an eligible SBA business, while unlicensed residential facilities, including most independent living, are not; management agreements must leave the borrower with meaningful oversight (49). USDA Business and Industry guarantees for-profit rural assisted living where constant medical care is available on site, and requires an independent feasibility study above $1 million for a new entity or activity (50).
Why is so little assisted living being built? Development costs $388,830 a unit and returns 8.1% on cost against a 7.0% stabilized cap rate, while existing communities trade near 45% of replacement cost (5, 32). Rents in most markets sit 15% to 20% or more below the level that makes new construction feasible (9).
Request a Feasibility Study https://calendar.app.google/EJzWEz3GCqLY2jU86
Michal Mohelsky, J.D. | Principal | mmcginvest.com
Contact: michal@mmcginvest.com
Phone: (628) 225-1125
Working with MMCG
MMCG Invest, LLC prepares lender-facing feasibility studies for assisted living, memory care and senior housing projects financed through SBA 7(a) and 504, USDA Business and Industry and Community Facilities, HUD Section 232 and conventional bank and life company debt. Our studies are prepared under USPAP discipline, cite a document for every claim, and set out demand, supply, pricing, operating and capital assumptions in the form a credit committee can test. To discuss a project, contact Michal Mohelsky at michal@mmcginvest.com or (628) 225-1125.
This report is provided for informational purposes and does not constitute investment, legal or lending advice. Forward-looking statements in Section 10 reflect MMCG's view as of September 2026 and may prove wrong. Third-party data are believed reliable but are not warranted.
References
(1) NIC, Caroline Clapp, "Senior Housing Occupancy Climbs in Second Quarter 2026," July 20, 2026. https://www.nic.org/blog/senior-housing-occupancy-climbs-in-second-quarter-2026/
(2) NIC MAP, "Senior Housing Construction Trends Fall to a 2012 Low | 2Q 2026," July 15, 2026, updated August 19, 2026. https://www.nicmap.com/blog/senior-housing-construction-trends/
(3) CareScout, 2025 Cost of Care Survey: press release, March 2, 2026 (https://investor.genworth.com/news-events/press-releases/detail/1054/carescout-releases-2025-cost-of-care-survey-results); "Ranked Median Costs by State Data Tables," March 6, 2026 (https://assets.carescout.com/x/5c90319b6a/298701.pdf); Christine Healy, "Where Senior Care Costs Are Rising Fastest Across the U.S.," March 16, 2026 (https://www.carescout.com/resources/where-senior-care-costs-are-rising).
(4) Senior Housing News, "Senior Housing Financing Hits Multi-Year Highs Amid Stronger Lender Interest," June 16, 2026, reporting NIC MAP Lending Trends; NIC blog on the 2H 2025 Lending Trends Report, June 15, 2026. https://seniorhousingnews.com/2026/06/16/senior-housing-financing-hits-multi-year-highs-amid-stronger-lender-interest/
(5) CBRE, "2026 Senior Housing Development Costs," July 8, 2026. https://www.cbre.com/insights/briefs/2026-senior-housing-development-costs
(6) Multi-Housing News, "2026 Senior Living Trends: Demand Leads, Capital Reopens," January 2026 (NIC's Lisa McCracken on the 29-month build cycle; JLL's Aaron Rosenzweig on construction terms). https://www.multihousingnews.com/senior-living-trends/
(7) McKnight's Senior Living, "Assisted living, independent living rate growth slows in second quarter: NIC MAP," reporting the NIC blog by Yitao Luo on the NIC MAP Actual Rates Report, June 2026 data. https://www.mcknightsseniorliving.com/news/assisted-living-independent-living-rate-growth-slows-in-second-quarter-nic-map/
(8) NIC, "The Margin Test: Is Strong Senior Housing Occupancy Translating to Profitability?," September 2026. https://www.nic.org/blog/occupancy/
(9) CBRE, U.S. Senior Housing & Care Investor Survey: H1 2026 (June 25, 2026), H2 2025 (December 18, 2025) and H1 2025 (June 17, 2025); McKnight's Senior Living coverage of the H1 2026 segment rates. https://www.cbre.com/insights/reports/us-senior-housing-and-care-investor-survey-h1-2026
(10) Levin Associates, LevinPro LTC: "Seniors Housing and Care M&A Activity Remains Strong in Q2:26," July 21, 2026 (https://www.globenewswire.com/news-release/2026/07/21/3330910/0/en/Seniors-Housing-and-Care-M-A-Activity-Remains-Strong-in-Q2-26.html); 2025 full-year release, January 12, 2026; McKnight's Senior Living Q4 2025 M&A coverage.
(11) Seniors Housing Business, "HUD Healthcare Lenders Post 'Phenomenal' FY 2025 Due to Pent-Up Demand," February 10, 2026 (https://seniorshousingbusiness.com/hud-healthcare-lenders-post-phenomenal-fy-2025-due-to-pent-up-demand/); McKnight's Senior Living, "FHA closes 'landmark year' with $8.1B in firm commitments," and FY2026 midpoint lender closings; HUD Section 232 Handbook, Section II, Chapter 2 (https://www.hud.gov/sites/documents/42321s2c2hsgh.pdf).
(12) Sonida Senior Living, Q2 2026 earnings release (Form 8-K, Exhibit 99.1, August 10, 2026) and earnings call transcript.
(13) Public Law 119-21, July 4, 2025; Congressional Research Service, R48569; Applied Policy, "One Big Beautiful Bill Act Signed into Law." https://www.appliedpolicy.com/one-big-beautiful-bill-act-signed-into-law/
(14) KFF, "Who Are Direct Care Workers and How Might Federal Policy Changes Impact the Workforce?," 2026 (https://www.kff.org/medicaid/what-role-do-immigrants-play-in-the-direct-long-term-care-workforce/); LeadingAge, "Pathways for Foreign-Born Workers" and "Beyond TPS"; McKnight's Senior Living on the June 25, 2026 Supreme Court decision; Wisconsin Watch, September 24, 2026.
(15) CDC National Center for Health Statistics, FastStats, Residential Care Communities, from the NPALS 2022 Biennial Overview (https://www.cdc.gov/nchs/fastats/residential-care-communities.htm); 2022 NPALS Survey Methodology Documentation (https://www.cdc.gov/nchs/media/pdfs/2024/10/2022-NPALS-Survey-Methodology-Documentation.pdf).
(16) NCHS Data Brief No. 506, "Residential Care Community Resident Characteristics: United States, 2022," August 2024 (https://www.cdc.gov/nchs/products/databriefs/db506.htm); NCHS Data Brief No. 454, December 2022.
(17) U.S. Census Bureau, Service Annual Survey, revenue and payroll for NAICS 623312, 623311 and 6233, 2013 to 2022, via FRED series ALFFTERAEEF2623312, ALFFTEREEFF2623312, REVEF623311ALLEST, CCRCAALFFTE216233 and CCRCAALFFTE526233. https://fred.stlouisfed.org/series/ALFFTERAEEF2623312
(18) Syndicated market research, as published on each publisher's landing page in 2026: IBISWorld, Assisted Living Facilities in the US; Grand View Research, U.S. Assisted Living Facility Market 2026 to 2033 and U.S. Assisted Living Facilities Database; Fortune Business Insights, Assisted Living Market; Persistence Market Research, US Assisted Living Facility Market; MarkWide Research, US Assisted Living Facility Market 2026 to 2036. Methodologies are paywalled.
(19) American Seniors Housing Association, 2025 ASHA 50 (https://ashaliving.org/wp-content/uploads/2025/08/2025-ASHA-50-FINAL-Low-Res.pdf); Seniors Housing Business, "2026 ASHA 50: Discovery Overtakes Brookdale as Largest Operator," September 8, 2026; McKnight's Senior Living, 2026 ASHA 50 coverage.
(20) California Legislative Analyst's Office, "Overview of Community Care Licensing," February 2014 (https://lao.ca.gov/handouts/socservices/2014/Overview-Community-Care-021114.pdf); California Assisted Living Association, "RCFEs by the Numbers," citing CDSS data, January 2023.
(21) Florida House of Representatives, bill analyses for CS/HB 1295 (Memory Care) and HB 1057, February 2026, citing AHCA licensing counts. https://www.flsenate.gov/Session/Bill/2026/1295/Analyses/h1295e.HHS.PDF
(22) U.S. Census Bureau, P25-1144, "Demographic Turning Points for the United States: Population Projections for 2020 to 2060" (2017 vintage); Administration for Community Living, 2023 Profile of Older Americans; Pew Research Center, "The oldest Baby Boomers turn 80 in 2026," January 9, 2026.
(23) Alzheimer's Association, "2026 Alzheimer's Disease Facts and Figures," April 21, 2026. https://www.alz.org/alzheimers-dementia/facts-figures
(24) NIC, Omar Zahraoui, "The Sticky Nature of Senior Housing Penetration," May 13, 2024 (https://www.nic.org/blog/the-sticky-nature-of-senior-housing-penetration-a-challenging-puzzle-to-solve/); Senior Housing News, "Culture Counts: Lessons From Operators in the Top Markets for Senior Living Penetration Rates," July 14, 2026.
(25) Senior Housing News, "Independent Living Now Holds Pricing Power Over Assisted Living, Memory Care," September 23, 2025, and McKnight's Senior Living coverage of the same NIC data (length of stay, memory care rates and discounts); Senior Housing News, June 4, 2025, on the ASHA/ProMatura "Feel at Home" resident survey.
(26) NIC and NIC MAP quarterly releases and key-takeaway blogs, 2Q 2024 through 1Q 2026, including NIC press releases of July 11, 2024, January 16, 2025, October 2, 2025 and January 15, 2026, and NIC MAP blogs of August 15, 2024, March 18, 2025, July 1, 2025, August 20, 2025 and October 16, 2025; NIC blog, "Senior Housing Occupancy Climbs to 89.5%," May 19, 2026.
(27) NIC and NIC MAP press release, "Occupancy in Senior Housing Climbs as Half of Primary Markets Top 90%," July 9, 2026. https://www.nicmap.com/news/occupancy-in-senior-housing-climbs-as-half-of-primary-markets-top-90/
(28) NIC MAP, "Senior Housing Trends to Watch in 2026" (https://www.nicmap.com/blog/senior-housing-five-key-trends-to-watch-in-2026/); Senior Housing News, "Average Senior Living Occupancy Nears 90%," April 23, 2026.
(29) A Place for Mom, "How Much Does Memory Care Cost? State-by-State Prices," 2026; U.S. News, "How Much Does Memory Care Cost? 2026 State-by-State Guide."
(30) Weitz, Senior Living Construction Costs Brief, 2026 issues, as reported by McKnight's Senior Living and Senior Housing News, "Construction Challenges Linger, Tempering Hopes of Senior Living Development Uptick in 2026," May 18, 2026.
(31) Bisnow, "America Faces A Massive Senior Housing Shortage. Wall Street Sees Opportunity," June 21, 2026, quoting Brookdale CEO Nick Stengle. https://www.bisnow.com/news/national/senior-housing/wall-street-piling-into-senior-housing-as-massive-shortage-looms-135068
(32) NIC MAP, "NIC MAP Releases Top Markets for Senior Housing Transactions of 2025," BusinessWire, December 11, 2025; NIC MAP, "Senior Living Investment Trends."
(33) Welltower Inc., Q2 2026 earnings release (Form 8-K, July 27, 2026) and Form 10-Q for the period ended June 30, 2026. https://www.sec.gov/Archives/edgar/data/0000766704/000076670426000030/well-20260630.htm
(34) Senior Housing News, "Green House Model Gains Traction as Providers See Payoff," April 21, 2014; California Health and Safety Code section 1569.85; Minnesota Statutes section 462.357; Florida Statutes section 419.001; 2026 Arizona Laws chapter 19 (assisted living homes; occupancy; zoning). Escalation to 2026 is an MMCG estimate.
(35) NIC, "Lease-Up Trends by Segment Type," June 6, 2018; NIC MAP, "Senior Housing Property Lease-Up is Taking Longer in Recent Years," updated May 2026; BBG investor survey as reported by Senior Housing News, March 31, 2026.
(36) Ventas Inc., Q2 2026 earnings release (Form 8-K, July 29, 2026) and investor presentation.
(37) American Healthcare REIT, Q2 2026 earnings release and call, August 6, 2026; National Healthcare Properties, Q2 2026 results; National Health Investors, Form 8-K, August 10, 2026; LTC Properties, Form 8-K, August 5, 2026.
(38) Brookdale Senior Living, Q2 2026 earnings release (Form 8-K, August 10, 2026) and earnings call.
(39) Janover Pro, "Assisted Living and Memory Care Financing: A Broker's Guide," 2026 (operating expense ratios, management fees, bridge terms). Broker guidance, not survey data.
(40) U.S. Bureau of Labor Statistics, Occupational Employment and Wage Statistics, May 2023, NAICS 623300 (https://www.bls.gov/oes/2023/may/naics4_623300.htm); BLS Spotlight on Statistics, "How has long-term care employment changed with an aging U.S. population?," October 2024.
(41) The Baldwin Group, "2026 Senior Living Facilities mid-year state of the market" (https://baldwin.com/insights/senior-living-industry-report/); CNA Aging Services Claims Report, 12th edition; Liberty Mutual and Ironshore 2025 claims benchmark, as reported by McKnight's Senior Living.
(42) AHCA/NCAL, "NCAL Report: States Continue Modifying Assisted Living Regulations," 2026, releasing the 2025 Assisted Living State Regulatory Review. https://www.ahcancal.org/News-and-Communications/Press-Releases/Pages/2026-NCAL-Report-States-Continue-Modifying-Assisted-Living-Regulations.aspx
(43) U.S. Government Accountability Office, GAO-26-107884, assisted living, June 2, 2026. https://www.gao.gov/assets/gao-26-107884.pdf
(44) KFF, "What Services Does Medicaid Cover in Assisted Living Facilities?," March 14, 2025, updated August 2025. https://www.kff.org/medicaid/what-services-does-medicaid-cover-in-assisted-living-facilities/
(45) KFF, "A Look at Waiting Lists for Medicaid Home- and Community-Based Services from 2016 to 2025," November 20, 2025. https://www.kff.org/medicaid/a-look-at-waiting-lists-for-medicaid-home-and-community-based-services-from-2016-to-2025/
(46) CMS-2442-F, Medicaid Access Rule, May 10, 2024, adding 42 CFR 441.302(k); Medicaid.gov applicability date chart; CMCS Informational Bulletin, February 26, 2026.
(47) JLL, "Seniors housing investment reaches decade high of $24 billion, as investors eye growth opportunities in 2026," March 12, 2026. https://www.jll.com/en-us/newsroom/seniors-housing-investment-reaches-decade-high-of-24-billion
(48) Fannie Mae, Seniors Housing Financing term sheet (https://multifamily.fanniemae.com/financing-options/seniors-housing/seniors-housing-financing); Freddie Mac Optigo Seniors Housing term sheet, April 2026, as summarized by Janover.
(49) U.S. Small Business Administration, SOP 50 10 8, effective June 1, 2025, Section A, Chapter 1, Paragraph E.3 and Chapter 3; Information Notice 5000-880695, "Issuance of SOP 50 10 8.1," August 14, 2026; SBA press release, "SBA Doubles Cumulative 7(a) and 504 Loan Limit to $10 Million," May 18, 2026; 13 CFR 120.160(b).
(50) USDA Rural Development, Business and Industry Guaranteed Loan program page, updated June 25, 2026 (https://www.rd.usda.gov/programs-services/business-programs/business-and-industry-guaranteed-loan); 7 CFR 5001.105 and 7 CFR Part 5001, Subpart D; USDA Rural Development, Community Facilities Programs.
(51) Gibbins Advisors, Full-Year 2025 Healthcare Bankruptcy Report, January 22, 2026; Senior Housing News, "Senior Care Bankruptcies Rising Even as Healthcare Filings Decline," January 28, 2026; Flanagan & Associates, Healthcare Receiverships docket.
(52) NIC MAP, Senior Housing Market Outlook, Second Edition, and press release "NIC MAP: Senior Housing Supply Gap Creates More Than $1 Trillion Investment Need Through 2050," August 26, 2026 (576,000 units by 2030, more than 1 million by 2035, starts down about 67% since 2021 from more than 30,000 units to roughly 10,000 in 2025). https://www.nicmap.com/news/nic-map-senior-housing-supply-gap-creates-more-than-1-trillion-investment-need-through-2050/
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