HUD Makes Emergency Call Systems Optional at Certain Elderly Housing Properties

HUD has eliminated a longstanding emergency call system requirement for certain elderly multifamily housing properties, but owners must verify that the new policy applies before removing any equipment.

Notice H 2026-06, issued September 10, removes Section 100-2.20 from HUD Handbook 4910.1, Minimum Property Standards for Housing. That section required covered elderly properties with 20 or more units to provide an emergency call system in each bathroom and at one bed location in every apartment.

Under the revised policy, emergency call systems are optional at properties covered by the notice.

The change does not allow owners to abandon broken pull cords or disconnect equipment while leaving resident controls in place. Owners must remove inoperable systems. Working systems that remain available to residents continue to be evaluated under HUD's NSPIRE Call-for-Aid System standard.

Which Properties Are Covered

Notice H 2026-06 applies to elderly multifamily housing projects with 20 or more units that are subject to HUD's Minimum Property Standards under:

• 24 CFR Part 200, Subpart S, covering applicable housing constructed under HUD mortgage insurance; or

• 24 CFR 891.120, as it applies to the Section 202 Supportive Housing for the Elderly program.

HUD specifies that the notice applies to Section 202 elderly housing and does not apply to Section 811 housing for persons with disabilities.

The notice also explains that the Minimum Property Standards generally do not apply to uninsured properties with Section 8 Housing Assistance Payments contracts. Section 202/8 properties are an exception.

This means owners cannot determine coverage simply by asking whether a property serves older adults or has a Section 8 contract. They must examine the property's original program, mortgage insurance status, HAP contract and other governing documents.

The Previous Requirement

Before the change, HUD's Minimum Property Standards required an emergency call system in each bathroom and at one bed location in every unit at covered elderly properties containing at least 20 apartments.

Properties commonly satisfied this requirement with hard-wired pull cords connected to a front desk, call center or emergency response service. HUD previously allowed owners to use wireless or electronic systems when those alternatives met the functional requirements.

HUD said many older systems have become difficult or expensive to repair. A nonfunctioning system can give residents a false sense of security and expose the property to serious inspection findings.

HUD also cited insurance concerns. According to the notice, some properties with emergency call systems have experienced difficulty obtaining commercial insurance because insurers view the equipment as creating potential liability.

Owners Now Have Three Main Options

Owners of covered properties should evaluate their systems and select one of three approaches.

Keep the Existing System

An owner may continue furnishing and maintaining an operable emergency call system.

If the system remains available to residents, it must function properly and remain accessible. It also remains subject to NSPIRE inspection requirements.

Replace or Modernize the System

Owners may replace older pull-cord equipment with modern wireless or electronic technology.

A replacement system should be evaluated against the property's resident needs, operating procedures, monitoring arrangements, insurance requirements and any separate contractual obligations.

Retire the System

A covered owner may remove an emergency call system that is no longer required.

If the system is operable, the owner must notify tenants in advance and consider the comments received before removing it.

If the system is inoperable, HUD requires its removal. An owner should not disconnect the equipment and leave pull stations, buttons or other resident-facing controls in place.

Broken Systems Must Be Removed

The clearest operational instruction in Notice H 2026-06 concerns equipment that no longer works.

HUD requires owners to remove inoperable pull-cord systems and other inoperable emergency call systems.

Leaving a broken system in place may cause residents to believe that assistance will be summoned during an emergency. It can also create an NSPIRE finding if the resident-facing components remain installed.

Owners should inventory every pull station, button, annunciator, alarm, light, speaker and monitoring connection before deciding that a system has been properly retired.

Working Systems Remain Subject to NSPIRE

Removing the Minimum Property Standards mandate does not eliminate the NSPIRE Call-for-Aid System standard.

If an emergency call system remains available to residents, an inspector may evaluate whether it is accessible and functions as designed.

Under HUD's current NSPIRE standard, the following conditions are classified as Life-Threatening deficiencies:

• The system is blocked;

• A pull cord ends more than six inches above the floor;

• The system does not produce its intended sound or light;

• The system fails to transmit a signal to the annunciator;

• The annunciator identifies the wrong room;

• A required pull cord is missing; or

• A pull cord is tied up so it cannot be used.

Life-Threatening deficiencies carry a 24-hour correction requirement.

Properties that keep their systems should maintain inspection and testing records. HUD's NSPIRE guidance states that an inspector does not need to test individual stations when the property provides comprehensive third-party inspection documentation dated within the previous 12 months.

The documentation must address all parts of the system.

Partial Abandonment Can Still Create Inspection Risk

NSPIRE provides a path for recognizing an abandoned system, but the resident-facing controls must be removed.

Inspectors are directed not to evaluate an abandoned call-for-aid system when all pull stations have been removed and only equipment such as indicator lights, audible indicators or the annunciator panel remains.

HUD identifies the absence of a resident-facing user interface as the primary consideration.

Owners should therefore avoid simply cutting wires, tying cords, covering buttons or placing an out-of-service notice over a station. Those measures may still leave what appears to be an available emergency system in the apartment.

Separate Agreements May Still Require a System

Notice H 2026-06 removes the requirement from HUD's Minimum Property Standards. It does not automatically cancel requirements contained in other documents.

An emergency call system may still be required by:

• A HUD grant agreement;

• A regulatory agreement or contract;

• Financing documents;

• State or local building codes;

• Licensing requirements;

• Accessibility obligations;

• Resident service commitments;

• Insurance conditions; or

• Another property-specific agreement.

HUD says owners with a separate HUD business agreement requiring an emergency call system may request an amendment to remove that requirement under the revised policy.

Owners should obtain the amendment before acting. The new notice does not amend individual agreements automatically.

Tenant Notice Is Required Before Removing a Working System

An owner who decides to remove an operable system must notify tenants in advance and consider their comments.

The notice does not establish a specific notice period or prescribe a particular form. Owners should document when the notice was delivered, how it was made accessible, what comments were received and how management considered those comments.

Residents may rely on the existing system when deciding how to respond to medical emergencies. Tenant communication should clearly state:

• Which equipment will be removed;

• When the change will occur;

• Whether an alternative system will be provided;

• How residents should request emergency assistance after removal;

• Who residents should contact with questions; and

• How residents may request a reasonable accommodation.

Fair Housing and Accessibility Duties Continue

The policy change does not eliminate an owner's obligations under federal fair housing and accessibility laws.

A resident with a disability may request an emergency communication device, modification, auxiliary aid or another accommodation based on an individual disability-related need. Those requests must be evaluated under the applicable requirements of Section 504, the Fair Housing Act and the Americans with Disabilities Act.

An owner should not treat Notice H 2026-06 as a blanket basis for denying accommodation requests or removing equipment required for a particular resident.

Properties should coordinate system decisions with their reasonable accommodation procedures and review whether effective communication requirements apply.

HUD Encourages Regular Welfare Checks

When a property does not have a functioning emergency call system, HUD encourages owners to conduct regular welfare checks, particularly for residents who live alone or have limited mobility.

The notice does not create a mandatory schedule for those checks. Each property should consider its staffing model, resident needs, privacy requirements, service coordination and emergency procedures.

A written welfare-check policy can help staff respond consistently. The policy should explain when checks occur, how residents provide consent, what staff should do when a resident does not respond and when emergency services should be contacted.

What Owners Should Do Now

Owners and management agents should not begin by removing equipment. They should first determine whether the notice applies and whether another requirement remains in effect.

A complete review should include:

1. Confirm whether the property is elderly housing with 20 or more units.

2. Identify whether the property is subject to HUD's Minimum Property Standards.

3. Determine whether the property is covered by Section 202, Section 202/8, HUD mortgage insurance or another program.

4. Review grant agreements, regulatory agreements, contracts and financing documents.

5. Check state and local codes, licensing rules and insurance requirements.

6. Inventory every emergency call system and document whether it functions.

7. Repair and maintain any system that will remain available to residents.

8. Remove inoperable resident-facing equipment.

9. Notify tenants before removing an operable system and consider their comments.

10. Review reasonable accommodation and effective communication obligations.

11. Establish alternative emergency procedures and welfare-check practices where appropriate.

12. Retain testing, removal, tenant-notice and policy documentation for future HUD review.

Questions about Notice H 2026-06 may be submitted to HUD at AssetManagementPolicy@hud.gov.

The Bottom Line

HUD has made emergency call systems optional at certain elderly multifamily properties with 20 or more units by removing Section 100-2.20 from its Minimum Property Standards Handbook.

The change creates flexibility, but owners still face clear compliance responsibilities.

Working systems may remain in service, but they remain inspectable under NSPIRE. Broken systems must be removed. Owners must notify tenants and consider their comments before removing working equipment. Separate contracts, laws or accessibility obligations may still require a system.

Every affected owner should complete a property-specific review before repairing, replacing or retiring emergency call equipment.