HUD Eliminates Mandatory Emergency Call Systems in Elderly Housing — What Owners Need to Know

Notice H 2026-06, issued September 10, 2026

On September 10, 2026, HUD's Office of Multifamily Housing issued Notice H 2026-06, revising Chapter 1, Section 100-2.20 (Emergency Call Systems) of the Minimum Property Standards for Housing, 1994 Edition (Handbook 4910.1). The Notice replaces the long-standing requirement that elderly housing projects maintain an emergency call system with an optional framework. The Notice remains in effect until HUD amends, rescinds, or supersedes it.

Who Is Affected

The Notice applies to elderly multifamily housing projects with 20 or more units that are subject to HUD minimum property standards under 24 CFR part 200, subpart S — namely, housing built under HUD mortgage insurance — and to elderly projects subject to 24 CFR § 891.120, which covers the Section 202 Supportive Housing for the Elderly program specifically (not the broader Part 891 programs).

Two applicability points are worth flagging for compliance staff:

• Uninsured Section 8 HAP properties are generally out of scope. Minimum property standards do not apply to uninsured projects with Section 8 Housing Assistance Payments contracts, unless those are Section 202/8 HAP contracts. Uninsured Section 8 properties are instead governed by the NSPIRE physical condition standards under 24 CFR part 5, subpart G.
• Owners with a separate contractual obligation to maintain an emergency call system — for example, under a HUD grant agreement — are not automatically relieved of that duty by this Notice. Those owners must request an amendment to the underlying agreement to strike the requirement.

What Changed

Since the mid-1990s extension of MPS to Section 202 projects, Handbook 4910.1 has required owners of elderly properties with 20 or more units to provide an emergency call system in each bathroom and at one bed location in each unit, so residents can summon help during a fall, fire, or medical emergency.

HUD's stated rationale for revising this requirement centers on three practical problems that have emerged with aging pull-cord systems:

1. Deferred maintenance and false security. Many owners lack the resources to repair or replace inoperable pull-cord systems, leaving residents with a system that appears functional but is not.
2. Inspection exposure. Under NSPIRE standards, a blocked or non-functioning system—or a pull cord mounted more than six inches off the floor—can generate a citable deficiency.
3. Insurability. Even fully operational systems, including newer technologies, commercial insurers increasingly view as a liability risk, complicating owners' ability to obtain coverage.

The result: Notice H 2026-06 strikes Section 100-2.20 outright. Owners no longer must install or maintain an emergency call system as a minimum property standard. Owners may continue to offer one voluntarily, and HUD explicitly permits owners to remove an inoperable system. Where an owner elects to remove an operable system, the Notice imposes two procedural conditions: advance notice to tenants, and consideration of tenant comments received in response. In lieu of a call system, HUD "encourages" — not requires — regular welfare checks, particularly for residents who live alone or have limited mobility.

Pros and Cons

As with most deregulatory HUD guidance, this Notice will affect properties differently, and owners should weigh the following before acting.

Potential benefits:

• Relief from an unfunded, aging capital obligation. For owners carrying inoperable or obsolete pull-cord systems, this Notice removes both the capital burden of replacement and the recurring inspection risk tied to a malfunctioning or non-compliant system.
• Reduced insurance friction. Owners in markets where carriers have flagged call systems as a liability exposure may find this change eases underwriting or renewal conversations.
• Flexibility, not a mandate to remove. The Notice is permissive rather than prescriptive — owners with well-functioning systems that residents value are not required to change anything.

Potential concerns:

• Resident safety and perception. Emergency call systems, however dated the underlying technology, are a tangible safety feature for elderly residents living independently. Removal—even of an inoperable system that residents believed was working—may be received poorly without clear communication and a credible alternative.

• "Welfare checks" is not a defined standard. HUD encourages regular welfare checks as a substitute but does not define frequency, staffing responsibility, or documentation expectations. Owners who remove a call system without adopting a concrete, documented welfare-check protocol may face negligence claims if an incident occurs and no alternative safeguard was in place.
• State and local law may not follow HUD's lead. This Notice changes a HUD minimum property standard; it does not preempt state landlord-tenant law, local building or fire code requirements, or state licensing/certification rules that may independently mandate emergency call or alert systems in senior housing. Owners should confirm state and local obligations before removing any system.
• Underlying agreements survive the Notice. As the Notice itself acknowledges, owners bound by a separate HUD business agreement (grant agreement, contract, etc.) requiring a call system must formally amend that agreement — removal cannot simply proceed under the authority of this Notice alone.
• Tenant notice-and-comment is a procedural requirement, not a formality. Owners electing to remove an operable system should build a real record: written notice to residents, a defined comment period, and documented consideration of comments received, before removal.

Recommended Next Steps for Owners

1. Confirm whether the property is within scope (20+ units, insured Section 202 or MPS-covered project) before assuming the Notice applies.
2. Review any HUD grant agreements, use agreements, or regulatory agreements for independent emergency call system obligations.
3. If you're considering removing an operable system, prepare a tenant notice-and-comment process and document it.
4. Adopt a written welfare-check protocol — frequency, responsible staff, and documentation — before or concurrent with removing any call system.
5. Check state and local law and any state HFA or licensing requirements that may impose independent obligations.

For questions about how Notice H 2026-06 applies to a specific property or portfolio, contact HUD at AssetManagementPolicy@hud.gov or our office for a property-specific compliance assessment.