Note: The first part of this column described the founding of The Osborn in 1908 by Miriam Osborn and the highlights of its formative years, guided by her talented legal advisor, John W. Sterling.
The centennial history of The Osborn, published in 2008, noted that in the 1970s, the management and board of trustees were faced with increased nursing home regulations and a decline in the number of residents. After careful study, the board adopted a plan, called “Pathway 2000” that called for construction of 26 new buildings as well as renovation of three existing buildings.
The plan also called for converting The Osborn from a nursing home into a continuing care retirement community (CCRC), which provides a continuum of health services to seniors. As a CCRC, it would provide independent living as well as assisted living and skilled nursing levels of care for its residents all on one campus. As the medical needs of residents change, the level of care also increases.
According to public records, the total cost of construction, completed in two phases, was $135 million. In phase one, The Osborn renovated the original buildings and built two new resi,dential structures, which together became known as Sterling Park. It also built the Pavilion, a skilled nursing facility with 84 beds on two floors. The second phase included construction of additional garden homes and two additional residential buildings, designated as 3000 and 4000.
From 1908 until 1996, The Osborn enjoyed a 100 percent charitable use tax exemption with respect to its property. In 1997, however, the Rye assessor revoked Osborn’s tax-exempt status, which the Board of Assessment Review partially restored. The Osborn then began legal proceedings to restore its full charitable tax exemption or a hospital use tax exemption. The Rye City School District was also named as a defendant, given its stake in the past and future tax revenues.
In 2007, the trial court held that The Osborn was only entitled to a partial tax exemption and issued a determination of the value of The Osborn’s property. The Appellate Court, in its 2010 decision, held that The Osborn was not entitled to any charitable use tax exemption because too few of its residents rely on the facility’s charity to support the conclusion that the property is being used principally or primarily for a charitable purpose.
In 2022, The Rye Record published a letter from William Pearson, written as a member of The Osborn Board of Trustees, which said, in part:
“It should be noted that the senior facility is Rye’s second largest property taxpayer, investing over $46 million in local property taxes over time, benefitting the Rye City School District, the City of Rye, as well as Westchester County. The Osborn currently pays over $2.2 million in annual property taxes.”
However, as a qualified charitable institution, The Osborn is not subject to federal or state tax, and contributions to its foundation are tax deductible.
A study of senior living facilities in 1984 reported that there were about 200 CCRCs in the nation, but that number has since grown to over 2,500, according to one recent study. In 2025 Newsweek published a ranking of “America’s Best Continuing Care Retirement Communities.” It identified the leading 300 CCRCs in the United States and ranked The Osborn among the top 100 nationwide.
