{ "name": "REIT monitoring evaluation checklist for senior housing & care portfolios", "description": "Sixteen evaluation criteria for a real-time REIT monitoring solution, each with the question to ask, why it matters, the evidence to request, and five evidence states.", "url": "https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria", "publisher": "SeniorCRE, LLC", "asOf": "October 9, 2026", "lastUpdated": "2026-10-15", "license": "https://seniorcre.com/terms", "reviewStatus": { "editorial": { "name": null, "reviewDate": null, "disposition": "Pending named editorial review" }, "productOwner": { "name": null, "reviewDate": null, "disposition": "Pending named product-owner review" }, "taxCounsel": { "name": null, "reviewDate": null, "disposition": "Pending named tax-counsel review" } }, "taxRules": { "trsSecuritiesAssetLimit": 0.25, "priorTrsSecuritiesAssetLimit": 0.2, "grossIncomeLimits": [ 0.95, 0.75 ], "effectiveTaxYearsBeginningAfter": "2025-12-31", "assetMeasurement": "quarter-end", "incomeMeasurement": "tax-year", "exchangeIdentificationDays": 45, "exchangeCompletionMaximumDays": 180, "exchangeCompletionRule": "earlier-of-180-days-or-return-due-date-including-extensions" }, "statutorySourceChecked": "2026-10-15", "trsAssetRule": "No more than 25% of the value of total REIT assets may consist of securities of one or more TRSs under IRC §856(c)(4)(B)(ii) for taxable years beginning after December 31, 2025 (Public Law 119-21 §70439). The amendment replaces 20% with 25%; earlier tax years require the applicable historical rule. This is a quarter-end securities asset-value limit, not a TRS gross-income cap. The annual 95% and 75% gross-income tests are separate; §856(l) defines TRS status and election. Tax counsel must confirm entity-specific application, valuation and relief.", "statusScale": [ { "key": "under-evaluation", "label": "Not confirmed — scope under evaluation", "meaning": "Not an approved product commitment. Product-owner scope and tax-counsel review are required before any build or reliance claim." }, { "key": "design-intent", "label": "Designed — not built", "meaning": "Specified approach, not implemented in any community. Synthetic examples do not establish working governance or operator validation." }, { "key": "roadmap", "label": "Roadmap — approved scope, not built", "meaning": "Committed on the build queue and not yet built. Require approved scope and acceptance gates; do not assume a delivery date." }, { "key": "built", "label": "Demonstrable — built, synthetic or historical data only", "meaning": "Shipped in the product and demonstrable on request against synthetic or historical data." }, { "key": "production-proven", "label": "Production-verified", "meaning": "Running in an operator production environment with a measured outcome an auditor could inspect. SeniorCRE claims no row at this status as of October 9, 2026." } ], "criteria": [ { "id": "asset-test", "number": 1, "category": "REIT qualification", "criterion": "IRC §856 75% asset test: quarter-end evidence and between-close warnings", "questionToAsk": "Can the platform preserve statutory quarter-end asset-test evidence for each REIT taxpayer, recompute provisional warnings between closes, and show the source values behind the numerator and denominator?", "whyItMatters": "Qualification follows the REIT taxpayer, not a blended portfolio average. Asset tests apply at statutory quarter-end; provisional monitoring does not change that measurement date. Counsel determines entity scope, valuation and any relief.", "evidenceToRequest": "A recomputation for one entity and one prior period you select, with the source rows behind both sides of the ratio.", "seniorcreStatus": "under-evaluation", "vendorScore": "", "vendorNotes": "" }, { "id": "income-tests", "number": 2, "category": "REIT qualification", "criterion": "95% and 75% gross income tests with RIDEA/SHOP treatment", "questionToAsk": "How are the annual 95% and 75% gross income tests distinguished from provisional year-to-date views, and how are REIT income lines mapped through a RIDEA/SHOP structure with counsel-approved classifications?", "whyItMatters": "Changes in operating revenue can require a classification review; legal structure, contracts and applicable tax rules determine treatment, not acuity alone.", "evidenceToRequest": "The classification rule set, the line-level mapping for one RIDEA entity, and the change history on both.", "seniorcreStatus": "under-evaluation", "vendorScore": "", "vendorNotes": "" }, { "id": "trs-cap", "number": 3, "category": "REIT qualification", "criterion": "§856(c)(4)(B)(ii) 25% TRS securities asset limit for applicable 2026 tax years", "questionToAsk": "Does the platform track TRS securities against the 25% asset limit for tax years beginning after December 31, 2025, distinguish earlier-year rules, preserve quarter-end values, and name who is alerted to provisional drift?", "whyItMatters": "The cap is discovered late when it is assembled at close. Drift that is visible in week six is a decision; the same drift at close is an exception report.", "evidenceToRequest": "Quarter-end TRS securities values and total REIT asset values, the taxpayer’s tax-year start and applicable rule version, plus provisional alert thresholds, recipients and fired-alert history.", "seniorcreStatus": "under-evaluation", "vendorScore": "", "vendorNotes": "" }, { "id": "distribution", "number": 4, "category": "REIT qualification", "criterion": "90% distribution requirement rollforward for the current tax year", "questionToAsk": "Can the platform show the annual 90% distribution rollforward against REIT taxable income computed without the dividends-paid deduction and excluding net capital gain, with counsel-approved assumptions and separate treatment of other distribution or excise-tax considerations?", "whyItMatters": "The distribution decision depends on an estimate that changes through the year. A static report dated at close is not a monitoring capability.", "evidenceToRequest": "A rollforward view with the estimate basis, the version history, and the approver.", "seniorcreStatus": "under-evaluation", "vendorScore": "", "vendorNotes": "" }, { "id": "rents", "number": 5, "category": "REIT qualification", "criterion": "§856(d) rents-from-real-property classification at clause level", "questionToAsk": "Is rent classification evaluated per lease clause, or set once at the lease header?", "whyItMatters": "Senior housing rent is service-bundled. A lease-header classification hides the impermissible-service question that a clause-level reading surfaces.", "evidenceToRequest": "A clause-level classification for one service-bundled lease, and the reviewer who approved it.", "seniorcreStatus": "under-evaluation", "vendorScore": "", "vendorNotes": "" }, { "id": "covenants", "number": 6, "category": "Portfolio controls", "criterion": "Coverage and covenant evidence computed per property", "questionToAsk": "Are LCR, DSCR, and coverage covenants computed from property-level operating rows, and can one published figure be reconstructed from source in one hop?", "whyItMatters": "A covenant certificate you cannot reconstruct is a certificate you are asserting on trust. Lenders and auditors test the reconstruction, not the dashboard.", "evidenceToRequest": "A one-hop trace from one covenant figure to the operator rows that produced it, with the definition version attached.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "noi-variance", "number": 7, "category": "Portfolio controls", "criterion": "NOI variance with lineage to the operating event", "questionToAsk": "When portfolio NOI moves against budget, does the platform attribute the variance to the operating event — census, acuity, agency labor, ancillary revenue — or only to the ledger account?", "whyItMatters": "An account-level variance tells you the amount. An event-level variance tells you what to do about it, which is the entire reason a REIT monitors an operator.", "evidenceToRequest": "One variance walk from portfolio NOI to a named operating driver at a named community.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "occupancy-quality", "number": 8, "category": "Portfolio controls", "criterion": "Occupancy quality, not just occupancy percentage", "questionToAsk": "Can the platform report payer mix, level of care, length of stay, and move-out velocity beside the occupancy percentage, on the same definitions the operator approved?", "whyItMatters": "Two portfolios at the same occupancy carry different revenue durability. Percentage alone cannot price that difference.", "evidenceToRequest": "The metric definitions, who owns each definition, and the last time each was changed.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "isolation", "number": 9, "category": "Portfolio controls", "criterion": "Entity and operator isolation enforced below the application layer", "questionToAsk": "Where is tenant isolation enforced — in application code, or at the database row level — and what is the control description you can give our security reviewer?", "whyItMatters": "Operator confidentiality requires tested isolation across ordinary and privileged access paths; a row-level design alone is not proof of effective control.", "evidenceToRequest": "The written control description, the test that proves it, and the contract clause on derived-data ownership.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "definition-authority", "number": 10, "category": "Operator data and governance", "criterion": "Named definition authority for every published metric", "questionToAsk": "For each metric the REIT publishes, who holds the definition — the REIT, the operator, or the vendor — and how is a definition change approved and versioned?", "whyItMatters": "Most portfolio disputes are definitional, not arithmetic. Until definition authority is named, every operator can be right and the numbers can still disagree.", "evidenceToRequest": "The definition register with owner, version, effective date, and the approval record for one recent change.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "reconciliation", "number": 11, "category": "Operator data and governance", "criterion": "Reconciliation performed once, under governed rules", "questionToAsk": "When the operator’s number and the REIT’s number differ, where is the difference resolved, and does the resolution persist downstream or get re-argued in every report?", "whyItMatters": "Reconciling in each report is how a portfolio ends up with several defensible versions of one figure. Reconcile once under governed rules and stop re-reconciling downstream.", "evidenceToRequest": "One contested figure, the reconciliation rule applied, the approver, and the downstream reports that inherited it.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "freshness", "number": 12, "category": "Operator data and governance", "criterion": "Per-source freshness and stale-feed behavior stated in writing", "questionToAsk": "What is the expected latency for each source, and what does the monitoring view show when an operator feed is late, partial, or fails?", "whyItMatters": "“Real time” is not one number across a multi-operator portfolio. Event-driven, hourly, and nightly feeds coexist, and a view that hides which is which invites a decision on stale data.", "evidenceToRequest": "A latency table by source, plus a screenshot of the view while a feed is deliberately stale.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "integration-paths", "number": 13, "category": "Workflow and audit evidence", "criterion": "Documented integration paths, scored honestly", "questionToAsk": "For each named incumbent system — accounting, property, clinical — is the interface specified, built, or roadmap, and is any of it live in a customer production environment today?", "whyItMatters": "Integration is where evaluation timelines break. A named logo on a slide is not an interface, and an interface exercised against an export file is not a live connection.", "evidenceToRequest": "A source-by-source matrix with method, direction, owner, latency, and a named reference environment for each claim.", "seniorcreStatus": "roadmap", "vendorScore": "", "vendorNotes": "" }, { "id": "audit-log", "number": 14, "category": "Workflow and audit evidence", "criterion": "Append-only history, period locking, and reproducible prior reports", "questionToAsk": "Can the platform reproduce a prior period’s published report exactly as signed, including the definitions, approvals, and overrides in force at the time?", "whyItMatters": "Attestation depends on reproducibility. If the prior report cannot be reconstructed, the audit trail is a description rather than evidence.", "evidenceToRequest": "A reproduction of one prior period report, its approval identities, its override history, and the retention and export terms in the contract.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "exchange-timers", "number": 15, "category": "Workflow and audit evidence", "criterion": "§1031 identification and earlier-of completion deadline monitoring", "questionToAsk": "Are 45-day identification and completion by the earlier of 180 days or the tax-return due date including extensions tracked in the platform, with qualified-intermediary evidence attached to the disposition?", "whyItMatters": "Exchange deadlines are calendar facts with tax consequences. Tracked in a side calendar, they leave no evidence trail beside the transaction.", "evidenceToRequest": "One disposition with both timers, the alert schedule, and the evidence attached to the entity record.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" }, { "id": "production-references", "number": 16, "category": "Workflow and audit evidence", "criterion": "Production references and honest maturity disclosure", "questionToAsk": "Which capabilities are running in a customer production environment today, and will the vendor state in writing which are not?", "whyItMatters": "A vendor who will not separate built from production-proven in writing will not separate them at implementation either. Ask for the distinction and keep the answer.", "evidenceToRequest": "A dated capability register naming what is built, what is demonstrated, what is roadmap, and what is production-proven.", "seniorcreStatus": "design-intent", "vendorScore": "", "vendorNotes": "" } ], "evaluationWorkflow": [ { "step": 1, "name": "Scope the evaluation by entity, not by portfolio", "detail": "List every entity, fund, and operator in scope, and name which qualification tests, covenants, and exchange workflows apply to each. A portfolio-average scope cannot test what qualification tests at entity grain." }, { "step": 2, "name": "Put the same sixteen questions to every vendor", "detail": "Ask each criterion verbatim and record the answer in the vendor’s own words. Do not accept a feature list in place of an answer to the question asked." }, { "step": 3, "name": "Score each row not confirmed, designed, roadmap, demonstrable, or production-verified", "detail": "Score from evidence rather than description, and require the vendor to state which rows are not running in a customer production environment today." }, { "step": 4, "name": "Test one entity and one period you choose", "detail": "Have the vendor recompute the qualification tests and reconstruct one published figure from source rows, for an entity and a prior period they did not select." }, { "step": 5, "name": "Verify isolation, definition authority, and export rights in contract language", "detail": "Obtain the isolation control description, the definition-authority register, the derived-data ownership clause, and the termination export terms from the agreement rather than the deck." }, { "step": 6, "name": "Restate roadmap scope as approved acceptance gates", "detail": "Total the scorecard, then require approved scope, dependencies and acceptance tests before treating a roadmap row as a commitment. Anything left unstated will be assumed present and discovered absent." } ], "disclaimer": "Not tax, legal, or investment advice. Confirm every Internal Revenue Code position with your tax counsel. Named trademarks are used for identification only; no new competitor-product review is claimed by this update. Reference comparison materials retain their own evidence dates. Content updated 2026-10-15. Capability evidence cut-off remains October 9, 2026. Statements about SeniorCRE reflect status as of the same date: §856 qualification under evaluation (not confirmed, not built), other rows design intent or roadmap, not implemented in any community and not operator production." }