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Regulatory & PolicySeptember 20269 min read

572 Of The 696 Beds In This Week's Illinois Trade Are Paid At 54.75 Percent Of A Nursing Home Rate

A long-held family portfolio of two Illinois facilities traded this week carrying CCRC licences and 696 beds. The trade press called them supportive living, assisted living and skilled nursing, and most readers will have filed that as a care-type description. It is not. Supportive living is a named Illinois Medicaid waiver programme whose per diem is set by formula at 54.75 percent of the regional nursing facility rate, and 572 of those 696 beds sit inside it. That changes what the asset is, who can buy it, and when the revenue line has to be re-authorised.

The Supportive Living Program per diem is “currently calculated at 54.75% of the average total nursing facility services per diem rate in the providers' specific rate setting region,” with dementia care settings paid at “150% of the regular SLP per diem rate within their rate setting region,” across seven rate setting regions statewide; HFS publishes rate sheets effective January 1, April 1 and July 1, 2026 (Illinois Department of Healthcare and Family Services, Supportive Living reimbursement page)
The Rate Is A Formula, Not A Market Price
The programme runs on Section 1915(c) waiver 0326.R05.00, approved July 1, 1999, with the current term effective October 1, 2022 and an expiration date of September 30, 2027 (Medicaid.gov, demonstration and waiver list entry 81526)
The Authorising Waiver Expires Inside A Normal Hold
One facility with 349 supportive living beds and 49 skilled nursing beds, the other with 223 supportive living and 75 skilled nursing — 696 beds combined, of which 572 are supportive living, summed by us from the four reported counts; both carry CCRC licences, combined occupancy was approximately 75 percent, the seller was a long-time family owner, and the transaction closed within nine months (Levin Associates, The SeniorCare Investor, September 10, 2026)
What Actually Traded This Week
Illinois obtained “a waiver to allow payment for services that are not routinely covered by Medicaid” — personal care, homemaking, laundry, medication assistance, social and health activities, recreation and 24-hour staff — while “the resident is responsible for paying the cost of room and board at the facility” (Illinois Department of Healthcare and Family Services, Supportive Living Program)
The Resident Still Pays The Rent

A Care Type That Is Actually A Payer

On September 10, 2026, the trade press reported that a family which had owned two Illinois senior care facilities for a long time finally sold them. One comprises 349 supportive living beds and 49 skilled nursing beds; the other 223 supportive living and 75 skilled nursing. Both hold CCRC licences, both offer supportive living, assisted living and skilled nursing, combined occupancy was approximately 75 percent, and the deal closed within nine months of the owner deciding to move ([Levin Associates, The SeniorCare Investor, September 10, 2026](https://seniorcare.levinassociates.com/2026/09/10/three-senior-care-communities-change-hands/)).

That is 696 beds, summed from the four reported counts, of which 572 are supportive living. Eighty-two percent of the bed count.

Most people reading that headline will have processed "supportive living" as a description of acuity — somewhere between independent and assisted, presumably private pay, presumably priced like assisted living. It is none of those things. Supportive Living is the name of an Illinois Medicaid programme, and a bed inside it is a Medicaid revenue line with a state-set rate. If you underwrite those 572 beds at assisted living economics you will be wrong by a wide margin, in a direction that does not recover.

What The Programme Actually Is

Illinois runs the Supportive Living Program as, in the state's own words, "an alternative to nursing home care for low-income older persons and persons with physical disabilities under Medicaid." The state obtained "a waiver to allow payment for services that are not routinely covered by Medicaid," and those services are enumerated: personal care, homemaking, laundry, medication assistance, social and health activities, recreation, and 24-hour staff to meet residents' scheduled and unscheduled needs ([Illinois HFS, Supportive Living Program](https://hfs.illinois.gov/medicalprograms/slf.html)).

One sentence on that page carries most of the economics: "The resident is responsible for paying the cost of room and board at the facility."

So the structure is split. Medicaid, through the waiver, pays for the *service* package. The resident pays the *room and board*. That is a genuinely different revenue architecture from a private-pay assisted living community, where one all-in monthly rate covers rent, services and care, is set by the operator, and moves with the market. Here the larger and more clinically variable half of the revenue is set by the State of Illinois and the smaller half is a shelter charge against a low-income population.

The Rate Is A Formula

This is the number that should reframe the asset. Illinois does not negotiate supportive living rates, and it does not index them to assisted living market rents. It computes them:

> The Supportive Living Program per diem is "currently calculated at 54.75% of the average total nursing facility services per diem rate in the providers' specific rate setting region."

Dementia care settings are paid at "150% of the regular SLP per diem rate within their rate setting region," the state operates seven rate setting regions, and rate add-ons currently include funding for quality and nutrition assistance. HFS publishes rate sheets with effective dates of January 1, April 1 and July 1, 2026 ([Illinois HFS, Supportive Living reimbursement](https://hfs.illinois.gov/medicalproviders/medicaidreimbursement/supportivelivinging.html)).

Read that formula slowly, because three things fall out of it.

First, supportive living revenue is a derivative of nursing home rate setting. The SLP per diem does not have its own independent political constituency or its own rate case. It is a percentage of something else. Every force that moves the average nursing facility per diem in a given region — wage index pressure, state budget cycles, nursing home rate reform, provider assessment changes — moves supportive living revenue with it, at 54.75 percent of the amplitude, whether or not anyone in the supportive living sector was at the table.

Second, the rate is regional, not facility-specific. Seven regions across the state means the same operating model produces materially different top lines depending on which side of a regional boundary the building sits. A buyer comparing two Illinois supportive living assets is not comparing two rate environments they can diligence building-by-building; they are comparing two regional averages of a different asset class.

Third, the dementia multiplier is the only real pricing lever in the model. At 150 percent of the regular regional per diem, a dementia care setting earns roughly half again per bed-day. In a private-pay portfolio, memory care commands a premium because families will pay it. Here the premium exists because the state wrote it into the methodology. The strategic consequence is the same — mix matters enormously — but the mechanism is regulatory, and it can be amended in a way a private market rate cannot.

The Expiration Date Nobody Prices

Section 1915(c) waivers are not permanent grants. They are time-limited authorities that have to be renewed.

The Illinois Supportive Living Program operates under waiver 0326.R05.00, originally approved July 1, 1999, with the current term effective October 1, 2022 and an expiration date of September 30, 2027 ([Medicaid.gov, waiver list entry 81526](https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/81526)).

That is roughly twelve months from today, and it sits inside the first year of any normal five-to-ten-year hold on the asset that just traded.

The honest read is that this is a renewal, not a cliff. The programme has been running since 1999 and has been renewed through five prior iterations — the R05 in the waiver number is itself the evidence. Illinois is not likely to strand thousands of residents. Nobody should underwrite a total revenue stop on September 30, 2027.

But "it will be renewed" and "it will be renewed on identical terms" are different statements, and only the first one is safe. Renewals are where methodologies get revisited, where a 54.75 percent factor becomes a different percentage, where participant caps and quality add-ons get reopened, and where a state under budget pressure finds a lever it can pull without a headline. A buyer taking on 572 supportive living beds is taking a one-year position on the terms of a waiver renewal, whether or not the offering memorandum frames it that way. At minimum that belongs in the model as a sensitivity, and arguably in the purchase agreement as a diligence item.

What This Does To The Buyer Pool

The thing that makes this transaction instructive is how narrow it makes the market.

To own these beds you need to be able to hold Illinois licences, operate inside a Medicaid waiver programme, manage the documentation and eligibility machinery that Medicaid participation requires, and live with a rate you cannot raise. That excludes most of the private-pay capital that has been setting record per-unit prices this year. The REIT bid that has been clearing Class-A assisted living in supply-constrained infill markets is simply not a bidder here, because the product does not produce the private-pay rate growth that bid is underwriting.

The contrast available this same week is stark. Brookdale reported August 2026 weighted average consolidated occupancy of 83.2 percent, up 50 basis points month over month and its highest level since the pandemic, with consolidated month-end occupancy at 84.5 percent ([Levin Associates, The SeniorCare Investor, September 10, 2026](https://seniorcare.levinassociates.com/2026/09/10/brookdale-sees-occupancy-jump-in-august/)). That is the private-pay sector's census recovery showing up in the numbers, and it is the story capital is chasing.

Against that, a 75 percent occupancy Illinois supportive living portfolio looks like a problem. It may be the opposite. At 75 percent there are roughly 174 empty beds across 696, and in a programme where the rate is fixed by formula, the entire value-creation case is census rather than rate — which is a cleaner thesis than hoping for pricing power, because filling beds is an operating discipline and rate is a political outcome. The buyer who wins here is not the one who pays the most; it is the one who can actually run a Medicaid-waiver building.

How To Underwrite It

Separate the bed count by payer before anything else. 572 and 124 are not one number. Model supportive living beds against the regional SLP per diem and skilled beds against the facility's Medicaid and Medicare mix. A blended per-bed assumption across all 696 is the error that makes this deal look either cheap or expensive for entirely fictional reasons.

Pull the actual regional rate sheet, not a state average. HFS publishes them with quarterly effective dates. Find the provider's rate setting region, take the published sheet, and apply the dementia multiplier only to beds genuinely licensed and operating as dementia care settings.

Underwrite room and board as a separate, collectible line. It is the resident's obligation, not Medicaid's, and against a low-income population it carries real collection risk and essentially no escalation story. Diligence the bad-debt history on that line specifically.

Treat September 30, 2027 as a dated event in the model. Not as a termination, but as the date the rate methodology is next legitimately open. Run a sensitivity on the 54.75 percent factor and see what a few hundred basis points does to value at the cap you are underwriting.

Diligence the CCRC licence separately from the beds. Both facilities hold one, and a CCRC licence brings its own regulatory perimeter and its own transfer mechanics that are independent of the supportive living certification.

The Point

The nine-month close on this transaction, after a seller who had considered divesting two years earlier and stood down, is the honest timeline for a licensed, Medicaid-exposed Illinois asset. Licence and certification transfers run on a regulatory clock that does not care about a financing commitment expiry.

And the broader lesson generalises well past Illinois. Terms that read like care types in a deal announcement — supportive living here, but also residential care, adult foster care, assisted living waiver beds elsewhere — are frequently the names of state Medicaid programmes with their own rate formulas, their own waiver expirations and their own buyer pools. The word in the headline describes who pays, not what the building looks like.

Nobody disclosed a price on this one, so there is no per-bed comparable to take from it. What there is to take is the reading discipline: when 82 percent of the beds in a portfolio are named after a state programme, the first document to request is not the rent roll. It is the rate sheet.

Disclaimer: This report is provided for informational purposes only and does not constitute investment advice. Data sourced from Bureau of Reclamation, NIC MAP, American Lung Association, and other public institutional sources. Crawford Commercial Group Real Estate Group. April 2026.

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