Proposed changes to guidelines regulating new construction and major renovations to assisted living communities and other residential care facilities could make it more difficult for providers to design communities to meet residents’ needs and wants, according to Argentum.
Last week, Argentum submitted comments on the draft proposal for the Facility Guidelines Institute 2026 FGI Facility Code. The senior living group seeks flexibilities relating to minimum ratios of single and double occupancy rooms and minimum square footage of dining space.
The 2026 code seeks to set a standard ratio whereby 80% of a community’s residents would live in single-resident rooms and a maximum of 20% of residents would live in double-resident rooms. Argentum called for this requirement to be removed, noting that no data support the proposed ratios.
“This should be left to market conditions to determine the ratio of single and double occupancy, innovation in the market to meet local needs, and to ensure that married couples are able to find placement,” the comments read.
The association also noted in its comments that implementing the ratios could result in providers currently participating in Medicaid assisted living waivers for the elderly to discontinue their participation in the program.
“As a result, Medicaid residents will not be able to find placements, [will be] unable to afford assisted living settings independently, and will be forced into skilled nursing facilities at more than twice the cost to federal and state governments,” Argentum’s comments read. “Removing this requirement will allow assisted living residents using Medicaid programs to continue to receive services.”
Further, Argentum stated, providers predominantly serving residents who pay for assisted living through their own funds would be challenged to serve low-income residents.
Another requirement Argentum addressed in its comments calls for a minimum of 25 square feet per resident in dining halls. The association said that no data support the proposed minimum space requirements, and adhering to them would “hamper the ability for communities to design alternative dining settings to meet resident preferences, such as resident dining pods located at several locations throughout a community, or smaller, more intimate settings instead of a single general purpose dining hall.”
“Communities should have flexibility to structure mealtimes and maximize space efficiency, such as neighborhood dining facilities that offer more home-like environments,” Argentum’s comments read.
The FGI Guidelines and FGI Facility Code documents provide guidelines for the design and construction of healthcare facilities, defined as including assisted living communities, residential care communities, nursing homes, hospice facilities and adult day facilities. The Joint Commission, federal agencies and states use the guidelines and facility code when reviewing, approving and financing facility project plans; surveying, licensing, certifying or accrediting newly constructed facilities; or developing their own codes.
A new edition of the FGI Guidelines/FGI Facility Code is published every four years based on a three-year revision cycle during which the public can comment. The revision process will begin this fall, with a final version to be voted on in November 2025. Final guidelines will be published in spring 2026.
