HUD 223(f) Express Lane criteria for nursing homes, 2026

HUD’s Express Lane gives a 232/223(f) application priority in the underwriting queue if the loan is small relative to value and the facility has a clean recent record. The current criteria, from HUD’s Office of Residential Care Facilities on March 31, 2026, are a 70% maximum loan to value, at least 2.0 times coverage on the skilled nursing portion using unadjusted trailing 12-month NOI, CMS overall and health inspection ratings of at least 2 stars, no abuse icon, an operator in place for at least two years, and a loan of no more than $50 million ($70 million around New York City).

ORCF launched the program on June 11, 2025 and revised it twice. HUD’s own words on queue placement: “Express Lane applications will have queue priority.” If HUD decides during review that a deal does not qualify, the application goes back into the regular 223(f) queue by its original submission date, so trying costs little.

The full list

All of these must be met (as of March 31, 2026):

Criterion	Requirement
Loan to value	70% maximum, supported by in-place, normalized T-12 NOI
Coverage, skilled nursing portion	2.0x on unadjusted T-12 NOI, including the replacement reserve deposit
Coverage, other portion	1.6x on the same basis
CMS overall rating	2 stars or more
CMS health inspection rating	2 stars or more
CMS abuse icon	none
FHA history of controlling participants	no FHA insurance claims and no defaults of 60+ days
Revenue from a special use (a specialized service line)	20% of revenue or less
Operator tenure	2 years or more at the facility (owner, or the lessee in a lease)
Loan amount	$50 million, or $70 million in the greater New York City area
Readiness	ready to underwrite, with no pending environmental, previous participation or corporate credit review issues

“Unadjusted” means no changes to NOI at all: no add-back for bad debt, management fee or a rate increase. The normalized NOI used for the value side may reflect only a Medicaid rate increase already in effect with a rate letter, plus management fees, real estate taxes and reserves.

Compare that with standard 223(f) sizing at up to 80% of value and 1.45 coverage. A deal that needs the full 80% is not an Express Lane deal.

How many facilities clear the CMS part

The star ratings, the abuse icon and, roughly, operator tenure can be checked from public data. In CMS’s September 2026 file:

• 10,501 of 14,690 certified nursing homes have both an overall and a health inspection rating of 2 or more and no abuse icon.
• 2,982 have a 1-star overall rating, 2,715 have a 1-star health inspection rating, and 1,429 carry the abuse icon (many fail on more than one).
• 125 have no overall rating at all, which also fails the screen.
• Of the 2,060 facilities with an active FHA loan matched (a few carry more than one loan) in HUD’s September 30, 2026 file, 1,540 pass the CMS screen.

Every SNF Register facility page shows its own ratings and abuse icon, so the screen takes a few seconds per building. The ratings move: CMS refreshes them monthly, and a new standard survey can drop a health inspection rating by a star overnight. Check them again the week the application goes in.

What the screen cannot tell you

The rest of the criteria live in the deal. Of the deal tests, 2.0 times coverage on unadjusted NOI is the hardest to clear: a facility at 1.6x on underwritten NOI may be at 1.3x unadjusted. The two-year operator test also catches facilities that changed operators recently, which the CMS change-of-ownership file and each facility page’s ownership history will show.

If the numbers are close, run them through the sizer. Its value test uses 80%, so multiply your value by 0.875 to approximate a 70% cap, and enter unadjusted T-12 (trailing 12-month) NOI so its coverage figure compares with 2.0.