Senior Housing Due Diligence: 60 Day Checklist
Author Rod Khleif: Top Multifamily Real Estate Mentor, Best Selling Author & Host of Top Real Estate Investing Podcast
I have bought and sold more than 2,000 units, and the single biggest lesson senior housing taught me is that the senior housing operator matters more than the building. I have watched a beautiful 120 bed assisted living community bleed cash under a weak operator, and I have watched a tired 1980s building throw off double digit yields because the right team was running it. If you only vet one thing before you wire your deposit, vet the operator. This guide gives you the exact scorecard I use to do it.
Table of Contents
I have walked more than 2,000 units through inspection periods, and senior housing due diligence is the only kind where the most expensive problems are never in the building. They are in the license file, the payroll register, and the census report. A roof you can price. A pending state citation, a director of nursing who quit last week, or a census propped up by a Medicaid waiver that ends in March can erase your equity before you ever fix a shingle. This is the checklist I use to find those problems inside a standard inspection period.
Table of Contents
Senior housing due diligence is the inspection period review of a licensed care community across five areas: licensing and survey history, people and payroll, census and revenue, physical plant and life safety, and legal and contracts. Because you are buying an operating business with a license, the business records matter as much as the building, and the biggest risks hide in files an apartment inspection never opens.
In apartments, due diligence is a rent roll audit, a lease file review, a property condition report, and a Phase I environmental. You are confirming that the income is real and the building will not fall down. Senior housing includes all of that and then adds an entire second layer: is the license clean, are the people staying, is the census real, does the building meet life safety code for a licensed facility, and do the contracts let you actually run the thing after closing.
Here is the plain language on the three terms that show up in every senior housing diligence file. Census is the count of residents in the building on a given day, and it drives revenue the way occupancy drives an apartment deal, except residents also pay for care levels that change month to month. A state survey is the unannounced inspection a licensed community receives, and its findings, called deficiencies or citations, are public record. A plan of correction is the operator’s written response to a deficiency, and an open plan of correction at closing can become your problem the moment the license transfers.
The stakes are different too. In an apartment deal, a diligence miss costs you a capital expense. In senior housing, a diligence miss can cost you the license, and without the license there is no business, only a building full of people who need care you are no longer allowed to provide. That is why I treat this checklist as a gate, not a formality. If you have not chosen your segment yet, start with the five types of senior housing, because the diligence load climbs with every rung.
Check your current inspection period plan against this list. Two or more and you are inspecting a building when you should be inspecting a company.
The framework below fixes all seven. It is built around five buckets so nothing falls between the cracks of the real estate team and the operations team.
The Five Bucket Diligence Sweep is the framework I use to organize senior housing due diligence so the operations risk gets the same rigor as the physical plant. Each bucket has an owner, a document list, and a pass or fail question. You run all five in parallel from day one. If you want to see these run against a live deal with the actual document requests, that is what we do at the Multifamily Bootcamp, where senior housing has become one of the most requested breakout topics.
Pull the current license, its expiration date, the licensed bed count versus the physical bed count, and every state survey for the last three years. Log each deficiency, its severity, whether it repeated, and whether the plan of correction was accepted. Confirm with the state whether the license transfers to a new owner or must be reissued, and how long that takes. In many states a change of ownership triggers a new application and a pre licensure survey, and that timeline needs to sit inside your contract, not after it. Pass question: can you own and operate this building legally on the day after closing?
Request the full payroll register for trailing twelve months, the staffing schedule for the last eight weeks, agency staffing invoices, and the employee roster with hire dates. Calculate turnover by role. Identify the executive director, director of nursing, and sales director, and find out how long each has been there and whether they are staying. Review any pending wage claims, workers compensation history, and the employee handbook. Pass question: will the people who produce the NOI still be there in month two?
Get the daily census for trailing twelve months, not a monthly summary. Reconcile it to the rent roll and to bank deposits. Break revenue into base rent, care level fees, and ancillary income. Identify the payer mix: private pay, long term care insurance, Medicaid waiver, veterans benefits. Check move in and move out dates against the resident agreements and look for residents on discounted or waived rent. Pass question: is the revenue real, private pay dominant, and repeatable?
Order a property condition assessment from a firm that does licensed care facilities, not apartments. It must cover sprinkler coverage and inspection records, fire alarm and call system, generator capacity and test logs, kitchen hood suppression, elevator certificates, and egress compliance for the licensed occupancy. Add a Phase I environmental and a roof and mechanical review. Pass question: does the building meet the life safety code the license requires, and what does the gap cost?
Review the resident agreements for rate increase language and termination terms. Review the management agreement, every vendor contract with a term over one year, the pharmacy and dietary contracts, any Medicaid provider agreements, and pending or threatened litigation. Pull the entity’s tax returns and reconcile to the financials. Check for liens, judgments, and any regulatory enforcement history on the operator and the owner. Pass question: can you step into these contracts and this history without inheriting a lawsuit or a lock in?
Bucket 2 is the one that decides most deals, because the people are the operator. If the executive director and director of nursing are leaving with the seller, you are not buying a business, you are buying a building and a recruiting problem. My guide on how to vet a senior housing operator is the deeper dive on that bucket.
The seller will hand you a package. Your job is to verify it against the record, and most of the record is public.
Survey history comes from your state’s licensing agency, usually the Department of Health, Department of Social Services, or Agency for Health Care Administration depending on the state. For skilled nursing, Medicare Care Compare publishes surveys, staffing data, and quality ratings for every certified facility. Search the community by name and address, download every survey in the last three years, and build a deficiency log before you read a word the seller wrote.
Market context comes from the National Investment Center for Seniors Housing and Care, which publishes occupancy, rent, and construction pipeline data by metro and segment. You are checking whether the community’s census sits above or below the market average, and whether new supply is about to open within a ten mile drive.
Life safety requirements come from the state fire marshal and the licensing statute for your segment. Most states publish their assisted living rules online, and the physical plant chapter tells your inspector exactly what to check.
Corporate and litigation history comes from the Secretary of State business search, the county court records, and a national litigation search on the operator and the ownership entity. Licensing actions against the administrator come from the state license lookup for that credential.
Before you start the 60 day sequence, it helps to know where investors have already been burned. I wrote down the most common mistakes after watching them repeat across hundreds of deals, and the diligence chapter maps almost exactly to the five buckets above. Click the cover below to download the free book and keep it beside your document request list.
Download the free book on the mistakes most apartment buyers make →
Negotiate a 60 day inspection period on any licensed community. Thirty days is enough for an apartment building. It is not enough to verify a license, a payroll, and a census. Here is the sequence.
One request, organized by bucket, with a seven day deadline for the seller. Include the daily census, the payroll register, three years of surveys, the license, the resident agreement template and a sample of executed agreements, every contract over one year, and the trailing twelve financials with bank statements.
While the seller assembles the package, pull every survey, the license status, litigation, and the NIC market data yourself. Build the deficiency log and the market comparison before the seller’s version arrives.
Tie the daily census to the rent roll to the bank deposits for at least six months. Flag any resident whose rent does not appear in deposits, any care level fee that does not match the care plan, and any payer source that is not private pay.
Walk the building with an inspector who does licensed care facilities, plus the fire marshal report and generator and sprinkler logs in hand. Price every life safety gap as a closing condition, not a post closing project.
Sit with the executive director, director of nursing, and sales director individually. Ask what they would fix, what keeps them up at night, and whether they plan to stay. Their answers tell you more about the business than the financials do.
Get written confirmation from the state on whether the license transfers or must be reissued, and the timeline. Build that timeline into the closing date and make license issuance a closing condition.
Every failed pass question becomes either a price reduction, a seller credit, a closing condition, or a walk. Present the findings as a single memo to your partners and your lender before the contingency deadline.
Here is what the sweep turned up on three real world profiles that all looked fine from the broker package.
The 72 unit assisted living community at 91 percent occupancy passed four buckets and failed on physical plant: the generator could not carry the building’s life safety load, a $180,000 fix that became a seller credit. The 96 unit assisted living and memory care campus at 88 percent occupancy passed on the building and failed on census: eleven residents were on a Medicaid waiver program that the state had frozen to new enrollment, meaning every one of those units would reprice down at turnover. That finding cut the offer by $1.4 million. The 40 bed memory care home at 95 percent occupancy passed everything except people: the director of nursing had given notice, the executive director was the seller, and turnover was running 70 percent. The buyer walked. Same broker package language on all three. Completely different outcomes once the buckets were run.
This is the comparison I wish someone had shown me before my first care community. The left column is what a good apartment inspection covers. The right column is what senior housing adds.
| Apartment Inspection vs Senior Housing Due DiligenceTHE SECOND LAYER A LICENSE ADDS | ||
|---|---|---|
| Regulatory | Certificate of occupancy and code violations | License status, transfer path, and three years of state surveys |
| People | Confirm the property manager will stay | Payroll register, turnover by role, agency invoices, key staff interviews |
| Income | Rent roll audit and lease file review | Daily census tied to resident agreements, care plans, and bank deposits |
| Building | Standard property condition assessment | PCA for licensed facilities with sprinkler, generator, call system, egress |
| Contracts | Service contracts and lease terms | Resident agreements, management agreement, pharmacy, dietary, Medicaid provider |
| Litigation | Basic entity search | Operator and owner litigation, licensing actions, enforcement history |
| Timeline | 30 days is standard | 60 days minimum, longer if the license must be reissued |
Every row in the right column takes time, which is why the inspection period has to be longer. It is also why the sellers who resist a 60 day period are usually the ones with something in bucket one or bucket three.
The seller’s package is a starting point. This table shows what you accept from the package and what you verify against the public record or the raw data yourself.
| Seller Package vs Verified RecordWHAT TO ACCEPT AND WHAT TO PULL YOURSELF | ||
|---|---|---|
| Survey history | Summary letter saying surveys are clean | Every survey downloaded from the state portal and logged |
| Occupancy | A single month census at 92 percent | Daily census for twelve months reconciled to deposits |
| Staffing | Org chart with titles | Payroll register and eight weeks of schedules with agency invoices |
| Revenue | Trailing twelve income statement | Bank statements tied to census and care level billing |
| License | Copy of the certificate | Written confirmation from the state on the transfer path and timeline |
| Life safety | Last fire marshal visit passed | Generator, sprinkler, and alarm logs plus a licensed facility PCA |
| Key staff | Seller says everyone is staying | Individual interviews with the ED, DON, and sales director |
Verification takes twenty to thirty hours across the five buckets. Against a seven figure equity check on a licensed business, it is the cheapest insurance you will ever buy.
Inside the Warrior community, senior housing diligence stories have become a regular feature of deal reviews. Ali Choucri made his first major Warrior acquisition a 196 unit senior housing community on Long Island that was distressed precisely because the prior buyer had skipped the business side of diligence. He walked in knowing what the census really was, what the survey history looked like, and which people would stay, and that knowledge is what turned a distressed asset into a discount instead of a trap.
Watch the Full Interview
Ali walks through what causes distress in senior living assets, how he found it in diligence, and how he repositioned a 196 unit community.
Radhika Rastogi came on the podcast to explain how she turned a bankrupt senior home into a $2.2 million asset in 90 days, and the turnaround only worked because diligence told her exactly which of the five buckets was broken before she wrote the check. Anthony Metzger, who went from teaching grade school to raising millions, learned the same lesson across asset classes: the deals that hurt him were the ones where he inspected the property and skipped the business. And Ryan Byrne laid out on the Lifetime Cash Flow podcast why the operating numbers are the real estate in this asset class.
Rod Khleif: “In senior housing the building is the easy part. Inspect the license, inspect the people, inspect the census. If those three are wrong, no roof in the world will save you.”
Q: What does senior housing due diligence include?
A: Senior housing due diligence covers five areas: licensing and survey history, people and payroll, census and revenue, physical plant and life safety, and legal and contracts. It includes everything in an apartment inspection plus the business records of the licensed care operation.
Q: How long should a senior housing inspection period be?
A: Negotiate at least 60 days. Verifying the license transfer path, reconciling a daily census to cash, and running a licensed facility life safety inspection cannot be done reliably in the 30 days typical for apartments. If the state requires a new license application, the closing date should sit after the expected issuance.
Q: What is a state survey in senior housing?
A: A state survey is the unannounced inspection a licensed community receives from its state regulator. Findings are called deficiencies or citations, and the operator must respond with a plan of correction. Surveys are public record and the last three years should be reviewed in every acquisition.
Q: Does the license transfer when you buy a senior housing community?
A: It depends on the state and the segment. Some states allow a change of ownership notice with the existing license, while others require a new application and a pre licensure survey that can take 60 to 120 days. Confirm the path in writing with the state before you set a closing date.
Q: What is the biggest red flag in senior housing due diligence?
A: A census that does not reconcile to bank deposits. It usually means residents on discounted rent, payer sources that are ending, or move outs the seller has not reported. Repeat survey citations and departing key staff are close behind.
Q: How do you verify census in senior housing?
A: Request the daily census for trailing twelve months, tie each resident to an executed resident agreement, match the billed rate and care level to the care plan, and reconcile total billed revenue to bank deposits month by month. Any gap larger than two percent needs an explanation.
Q: What life safety items matter most in a senior housing inspection?
A: Sprinkler coverage and inspection records, fire alarm and resident call systems, generator capacity to carry the life safety load, kitchen hood suppression, elevator certificates, and egress compliance for the licensed occupancy. Gaps in these are closing conditions, not post closing projects.
Q: Should I review resident agreements during due diligence?
A: Yes, every one of them. Resident agreements control rate increase rights, care level pricing, and termination terms. A community full of agreements with capped increases or waived care fees has a revenue ceiling the financials will not show you.
Q: Who should be on a senior housing due diligence team?
A: A healthcare real estate attorney, a property condition inspector who does licensed facilities, a senior housing accountant or consultant for census and payroll reconciliation, and your operator. The operator should walk the building and interview the staff as part of the sweep.
Q: What happens if diligence finds an open citation?
A: Require the seller to have the plan of correction accepted by the state before closing, or hold an escrow sized to the cost of correction plus any penalty. Never close with an open citation and no written path to clearance, because the license risk transfers with the sale.
Running the Five Bucket Sweep on your first licensed community is a lot easier when you have watched it done on someone else’s deal first. That is what the Multifamily Bootcamp is for: real deals, real document requests, and a room full of investors who are already buying senior housing and will tell you what they found.
Join us at the next Multifamily Bootcamp and run your first diligence sweep with us →
Want to start with the fundamentals first? The free book covers the mistakes that cost investors the most, and the diligence chapter maps straight onto the five buckets.
Disclaimer: This article was written with the help of AI and reviewed by Rod and his team.
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