Not All Sprinklers Are Equal, and Insurers Are Taking Notice in Senior Living

Senior living operators that assume a sprinkler system automatically satisfies insurers’ expectations are increasingly finding that assumption tested, according to a whitepaper from Gallagher Property Risk Engineering.

The report said underwriters are no longer evaluating buildings as simply “sprinklered” or “unsprinklered” but are instead scrutinizing system type, the presence of non-sprinklered concealed spaces, water supply adequacy, and maintenance and impairment history. Gallagher noted that many senior living communities are built with NFPA 13R systems because of cost advantages and code allowances, even though those systems, according to the report, are “often not designed to prevent large property losses,” particularly when fires occur in concealed spaces or detection is delayed.

System Type Reshapes Underwriting Outcomes

According to Gallagher, NFPA 13 systems are designed to control or suppress fires across a wide range of scenarios, including certain concealed spaces, making them more effective at limiting fire spread and total-loss exposure. NFPA 13R systems, by contrast, were developed narrowly to support life safety by giving residential occupants time to escape, and they permit sprinklers to be omitted from spaces such as attics, according to the report. NFPA 13D systems, intended primarily for one- and two-family dwellings, offer even more limited protection and are typically restricted in senior living settings, Gallagher said.

That distinction, once largely technical, is now showing up directly in coverage terms, the report said. Gallagher pointed to industry loss data showing that fires involving concealed spaces or incomplete sprinkler coverage can produce disproportionately large claims. As a result, senior living facility operators are facing increased underwriting questions and engineering reviews, higher deductibles or retentions for less robust systems, reduced capacity from certain carriers, and greater expectations for documented risk-improvement plans, according to the whitepaper.

Gallagher also cautioned that code compliance should not be equated with adequate protection, since building codes establish minimum life safety requirements rather than optimal risk-mitigation strategies.

Citing research from the National Institute of Standards and Technology, the report said fires can spread rapidly through unprotected void spaces, bypassing sprinkler coverage and compromising structural elements before suppression takes effect. In senior living facilities, that risk is compounded by building size, interconnected spaces and combustible furnishings, potentially leading to significant structural damage, extended business interruption and resident displacement, according to the report.

Wildfire and Smoke Exposure Extend Beyond the Building

Risk is also growing outside the building envelope, particularly in the wildland-urban interface, or WUI, the report said. Fire authorities estimate more than 60,000 U.S. communities are exposed to WUI fire conditions, according to Gallagher, and 2025 wildfires in California alone damaged or destroyed more than 16,000 structures, many within WUI zones. The report also cited incidents in Colorado, Texas and Massachusetts, along with growing exposure in Arizona, Oregon, Washington and parts of the Southeast, as population growth pushes development into fire-prone areas.

For senior living operators, Gallagher said this introduces exterior ignition from embers and radiant heat, rapid fire spread through landscaping, potential simultaneous impacts across multiple campus buildings, and evacuations under compressed timelines. The report also highlighted smoke infiltration as a distinct hazard: during wildfire incidents, smoke can enter buildings through outdoor-air intakes and envelope leakage points, rendering a facility unsafe for residents even without direct flame contact, particularly given residents’ potential sensitivity to air quality and limited mobility.

Recent Incidents Illustrate Escalation Risk

The report cited several 2025 events to demonstrate how quickly conditions can worsen even in code-compliant buildings.

A fire at an assisted-living facility in Fall River, Massachusetts, resulted in multiple fatalities, injuries and large-scale resident displacement, with investigators examining ignition source, fire growth and evacuation challenges. An explosion and fire at an assisted-living campus in Denver led to multiple hospitalizations and displaced dozens of residents. During Los Angeles-area wildfires, hundreds of residents from senior living and health care facilities were evacuated, and some facilities were destroyed, according to the report.

Gallagher noted that even smaller incidents, such as rooftop or exterior equipment fires, can trigger escalated emergency response due to smoke conditions and resident vulnerability.

Obtain the whitepaper here. &