Four license types. One portfolio. Almost nothing in common except the resident.
Skilled nursing carries a federal certification regime with a published rating. Assisted living and memory care are state-licensed across fifty divergent regimes. Independent living is mostly housing law until the day someone delivers care in it. This page maps obligation categories across all four — federal, state, conditional, or not applicable — and links every federal statement to its primary source.
On this page
A mixed-portfolio operator is not running one compliance program with local variation. It is running a federally certified program, a state-licensed care program, a dementia-care endorsement with its own disclosure and egress conditions, and a housing business — under one balance sheet and, usually, one compliance officer. The obligations do not scale from one to the next; they are different instruments with different evidence, different retention, and different audiences.
Select the segments you operate. Federal obligations are cited to primary sources. State obligations are marked as variable rather than tabulated nationally — the shape of the obligation is durable, the threshold is yours to supply.
The answer to a mixed portfolio is not four compliance systems. It is one record whose entities are shared and whose grain is segment-aware, so a portfolio roll-up can state which convention produced each figure.
This is the operator-controlled operating record applied to compliance: the obligation, its source, its threshold, its evidence, its owner, and its review date, governed where the data lives rather than where it is displayed. Read the entity specification on the operating record , the staffing-data detail on PBJ and staffing compliance , and the payer-driven obligations on value-based care and risk contracts .
Segment-aware entity grain, per-community obligation records with source, threshold, owner, and review date, and immutable audit logging on privileged functions — exercised in validation environments. LIVE means shipped in main and exercised in validation environments, not operator production.
No EHR, CRM, state-agency, CMS, HIE, or payor integration is live in operator production today, and no clinical data is transmitted to any external party today. Survey, PBJ, and licensure data are operator-supplied. Connector scope is sequenced in the implementation plan.
Key points
- Medicare and Medicaid certification under 42 CFR Part 483, Subpart B, with survey by the state agency on CMS’s behalf and federal enforcement remedies.
- A state license that fixes what level of care may be delivered, admission and retention limits, and the conditions under which a resident must be discharged to a higher level.
- A required written disclosure of the specialized care claim: philosophy, staffing, training, security measures, activities, costs, and the conditions of discharge.
- Sufficient nursing staff, licensed nurse coverage, and registered nurse coverage provisions under the federal participation requirements.
- Mandatory quarterly submission of payroll-verified staffing hours and daily census, used to produce publicly reported staffing measures.
- Prescribed orientation, annual training hours, and competency validation, including dementia-specific training where the state requires it.
- Criminal background screening and, for certified settings, checks against the nurse aide registry and federal exclusion lists.
- A prescribed assessment instrument on a prescribed schedule, with entry, discharge, and re-entry tracking records that also feed payment and public quality measures.
Frequently asked questions
- Is this matrix legal or regulatory advice?
- No. It is an operating-record scoping tool. It maps which categories of obligation attach to which license types so that a mixed-portfolio operator can design one record that satisfies several regimes. Federal citations are named and linked; state obligations are described as variable because they are. Confirm every state-level item against your own licensure regime and counsel before relying on it.
- Why not publish a state-by-state table?
- Because we could not keep it current, and a stale compliance table is worse than none. Assisted living and memory care requirements change through licensure rulemaking in fifty jurisdictions on independent schedules. What is durable across states is the shape of the obligation — disclosure, staffing, training, service planning, incident reporting, egress — so the matrix is organized by obligation category and the state-specific values are treated as operator inputs.
- Our portfolio is mixed. Do we need two operating records?
- No, and running two is the failure mode this page exists to prevent. The entities are shared — resident, census day, staff hour, service event, incident, disclosure. What differs is the required grain, the retention period, and the reporting destination. One record with segment-aware grain satisfies both regimes; two records guarantee that portfolio roll-ups reconcile to nothing.
- Independent living looks nearly empty in the matrix. Is it actually low risk?
- It is low in licensure obligations and not low in risk. Fair housing and ADA duties apply in full, and the material exposure is the drift between what is marketed, what is contracted, and what staff actually do. The moment services are delivered in practice, licensure questions attach regardless of how the building is described. That drift is a records problem before it is a legal one.
- Does SeniorCRE guarantee compliance or automate survey readiness?
- No. SeniorCRE does not certify, guarantee, or attest compliance, and no compliance outcome is attributable to the platform. What the operating record does is make the underlying facts sourceable: which obligation applies to which community, what evidence exists, when it was last reviewed, who attested it, and where the source system of record sits. Judgment and accountability stay with the operator.
- Can SeniorCRE pull our survey, PBJ, or state licensure data automatically today?
- No. No vendor, EHR, state-agency, CMS, or payor integration is live in operator production today, and no clinical data is transmitted to any external party today. The entities and controls described here are shipped in main and exercised in validation environments. Connector scope is sequenced in the implementation plan.
https://seniorcre.com/compliance-by-segment