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Evergreen evaluation criteria · Updated October 9, 2026
Sixteen criteria in four groups: REIT qualification, portfolio controls, operator data and governance, and workflow and audit evidence. Each one is a question, not a feature name — and each is scored from evidence rather than description.
The direct answer. Compare whether the §856 tests recompute per entity between closes; whether RIDEA/SHOP income is classified at the line and clause level; whether coverage covenants and NOI variance trace in one hop to the operator rows that produced them; whether occupancy is reported as quality rather than percentage; whether isolation is enforced below the application layer; whether every published metric has a named definition owner and is reconciled once under governed rules; whether freshness and stale-feed behavior are stated per source; and whether prior periods reproduce exactly as signed. Then score confirmed scope architecture designed, built, roadmap, or production-proven — and require the vendor to say in writing which rows are not running in a customer production environment today.
This is the evergreen criteria page. The quarter-close checklist is the dated seasonal companion: the September 30, 2026 Q3 post-close review.
SeniorCRE is the operator-controlled operating infrastructure for senior housing & care.
Fragmentation is the antagonist; the operator governs what counts as truth.
Compare asset, income, TRS, distribution and rent-classification evidence; tax counsel determines the applicable rules.
Reconstruct covenants, NOI and occupancy quality from accepted property-level source evidence.
Require approved definitions, reconciliation, operator consent and independently tested isolation.
Require latency, cut-off, late-arrival and stale-feed behavior, not one portfolio-wide freshness label.
Choose an entity and period; inspect locked reports, approvals, overrides and exchange deadlines.
Separate designed, built, roadmap and production-proven; leave unconfirmed scope under evaluation.
Under evaluation — not confirmed, not built: Not an approved product commitment. Product-owner scope and tax-counsel review are required before any build or reliance claim.
§856 qualification rows are under evaluation — not confirmed, not built — consistent with the oversight detail page. Other rows are architecture designed or roadmap; no row is production-proven. Ask every vendor on your shortlist to complete the empty column the same way.
| # | Criterion | Category | Evidence to request | SeniorCRE status |
|---|---|---|---|---|
| 1 | IRC §856 75% asset test: quarter-end evidence and between-close warnings | REIT qualification | A recomputation for one entity and one prior period you select, with the source rows behind both sides of the ratio. | Under evaluation — not confirmed, not built |
| 2 | 95% and 75% gross income tests with RIDEA/SHOP treatment | REIT qualification | The classification rule set, the line-level mapping for one RIDEA entity, and the change history on both. | Under evaluation — not confirmed, not built |
| 3 | §856(c)(4)(B)(ii) 25% TRS securities asset limit for applicable 2026 tax years | REIT qualification | An alert configuration showing threshold, recipient role, and the log of a fired alert. | Under evaluation — not confirmed, not built |
| 4 | 90% distribution requirement rollforward for the current tax year | REIT qualification | A rollforward view with the estimate basis, the version history, and the approver. | Under evaluation — not confirmed, not built |
| 5 | §856(d) rents-from-real-property classification at clause level | REIT qualification | A clause-level classification for one service-bundled lease, and the reviewer who approved it. | Under evaluation — not confirmed, not built |
| 6 | Coverage and covenant evidence computed per property | Portfolio controls | A one-hop trace from one covenant figure to the operator rows that produced it, with the definition version attached. | Architecture designed |
| 7 | NOI variance with lineage to the operating event | Portfolio controls | One variance walk from portfolio NOI to a named operating driver at a named community. | Architecture designed |
| 8 | Occupancy quality, not just occupancy percentage | Portfolio controls | The metric definitions, who owns each definition, and the last time each was changed. | Architecture designed |
| 9 | Entity and operator isolation enforced below the application layer | Portfolio controls | The written control description, the test that proves it, and the contract clause on derived-data ownership. | Architecture designed |
| 10 | Named definition authority for every published metric | Operator data and governance | The definition register with owner, version, effective date, and the approval record for one recent change. | Architecture designed |
| 11 | Reconciliation performed once, under governed rules | Operator data and governance | One contested figure, the reconciliation rule applied, the approver, and the downstream reports that inherited it. | Architecture designed |
| 12 | Per-source freshness and stale-feed behavior stated in writing | Operator data and governance | A latency table by source, plus a screenshot of the view while a feed is deliberately stale. | Architecture designed |
| 13 | Documented integration paths, scored honestly | Workflow and audit evidence | A source-by-source matrix with method, direction, owner, latency, and a named reference environment for each claim. | Roadmap — not built |
| 14 | Append-only history, period locking, and reproducible prior reports | Workflow and audit evidence | A reproduction of one prior period report, its approval identities, its override history, and the retention and export terms in the contract. | Architecture designed |
| 15 | §1031 identification and earlier-of completion deadline monitoring | Workflow and audit evidence | One disposition with both timers, the alert schedule, and the evidence attached to the entity record. | Architecture designed |
| 16 | Production references and honest maturity disclosure | Workflow and audit evidence | A dated capability register naming what is built, what is demonstrated, what is roadmap, and what is production-proven. | Architecture designed |
REIT qualification
Ask: 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?
Why it matters: 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.
Evidence to request: A recomputation for one entity and one prior period you select, with the source rows behind both sides of the ratio.
SeniorCRE status as of October 9, 2026: Under evaluation — not confirmed, not built
Ask: 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?
Why it matters: Changes in operating revenue can require a classification review; legal structure, contracts and applicable tax rules determine treatment, not acuity alone.
Evidence to request: The classification rule set, the line-level mapping for one RIDEA entity, and the change history on both.
SeniorCRE status as of October 9, 2026: Under evaluation — not confirmed, not built
Ask: 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?
Why it matters: 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.
Evidence to request: An alert configuration showing threshold, recipient role, and the log of a fired alert.
SeniorCRE status as of October 9, 2026: Under evaluation — not confirmed, not built
Ask: 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?
Why it matters: The distribution decision depends on an estimate that changes through the year. A static report dated at close is not a monitoring capability.
Evidence to request: A rollforward view with the estimate basis, the version history, and the approver.
SeniorCRE status as of October 9, 2026: Under evaluation — not confirmed, not built
Ask: Is rent classification evaluated per lease clause, or set once at the lease header?
Why it matters: Senior housing rent is service-bundled. A lease-header classification hides the impermissible-service question that a clause-level reading surfaces.
Evidence to request: A clause-level classification for one service-bundled lease, and the reviewer who approved it.
SeniorCRE status as of October 9, 2026: Under evaluation — not confirmed, not built
Portfolio controls
Ask: Are LCR, DSCR, and coverage covenants computed from property-level operating rows, and can one published figure be reconstructed from source in one hop?
Why it matters: A covenant certificate you cannot reconstruct is a certificate you are asserting on trust. Lenders and auditors test the reconstruction, not the dashboard.
Evidence to request: A one-hop trace from one covenant figure to the operator rows that produced it, with the definition version attached.
SeniorCRE status as of October 9, 2026: Architecture designed
Ask: 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?
Why it matters: 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.
Evidence to request: One variance walk from portfolio NOI to a named operating driver at a named community.
SeniorCRE status as of October 9, 2026: Architecture designed
Ask: 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?
Why it matters: Two portfolios at the same occupancy carry different revenue durability. Percentage alone cannot price that difference.
Evidence to request: The metric definitions, who owns each definition, and the last time each was changed.
SeniorCRE status as of October 9, 2026: Architecture designed
Ask: 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?
Why it matters: Operator confidentiality requires tested isolation across ordinary and privileged access paths; a row-level design alone is not proof of effective control.
Evidence to request: The written control description, the test that proves it, and the contract clause on derived-data ownership.
SeniorCRE status as of October 9, 2026: Architecture designed
Operator data and governance
Ask: 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?
Why it matters: 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.
Evidence to request: One contested figure, the reconciliation rule applied, the approver, and the downstream reports that inherited it.
SeniorCRE status as of October 9, 2026: Architecture designed
Ask: What is the expected latency for each source, and what does the monitoring view show when an operator feed is late, partial, or fails?
Why it matters: “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.
Evidence to request: A latency table by source, plus a screenshot of the view while a feed is deliberately stale.
SeniorCRE status as of October 9, 2026: Architecture designed
Workflow and audit evidence
Ask: 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?
Why it matters: 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.
Evidence to request: A source-by-source matrix with method, direction, owner, latency, and a named reference environment for each claim.
SeniorCRE status as of October 9, 2026: Roadmap — not built
Ask: Can the platform reproduce a prior period’s published report exactly as signed, including the definitions, approvals, and overrides in force at the time?
Why it matters: Attestation depends on reproducibility. If the prior report cannot be reconstructed, the audit trail is a description rather than evidence.
Evidence to request: A reproduction of one prior period report, its approval identities, its override history, and the retention and export terms in the contract.
SeniorCRE status as of October 9, 2026: Architecture designed
Ask: 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?
Why it matters: Exchange deadlines are calendar facts with tax consequences. Tracked in a side calendar, they leave no evidence trail beside the transaction.
Evidence to request: One disposition with both timers, the alert schedule, and the evidence attached to the entity record.
SeniorCRE status as of October 9, 2026: Architecture designed
Ask: Which capabilities are running in a customer production environment today, and will the vendor state in writing which are not?
Why it matters: 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.
Evidence to request: A dated capability register naming what is built, what is demonstrated, what is roadmap, and what is production-proven.
SeniorCRE status as of October 9, 2026: Architecture designed
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.
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.
Score from evidence rather than description, and require the vendor to state which rows are not running in a customer production environment today.
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.
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.
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.
Sources & Methodology
Method: these criteria are a buyer-side evaluation instrument, not a vendor ranking. Each is written as a question a senior housing REIT, operator, or asset manager can put to any vendor, with the evidence that would substantiate the answer. Statutory references are to the Internal Revenue Code in effect on the date above and are provided for evaluation scoping only. 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 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. Review status: named product-owner and tax-counsel review remain pending; no expert approval is asserted. SeniorCRE publishes its own evaluation framework. Structured data helps interpret visible content; it does not guarantee citations or search placement.
Last reviewed . Named third-party products (PointClickCare®, MatrixCare®, Yardi®, RealPage®, QuickBooks®) are referenced under nominative fair use. Competitive statements reflect publicly available product materials as of the review date.
One qualified next step
Bring the entities, source systems, thresholds, and reporting decisions that matter. SeniorCRE will scope the briefing around the evidence your committee needs and state plainly what is demonstrable today and what is not.
Start at REIT Compliance Monitoring — this page adds: The sixteen criteria to compare, scored built / validated / roadmap.
Part of Assisted living & senior housing REITs.
Start here: the qualification, covenant, and evidence picture in one place.
The procurement scorecard and the evidence to request for each feature.
Dated seasonal edition for the current close package.
What the operator must produce for the REIT’s SHOP disclosure.
Whose definition of occupancy and NOI governs across operators.
The qualification tests themselves, and how operating data enters them.
45- and 180-day timers with evidence attached to the disposition.