Yes, if it operates more like an apartment complex (longer stays/leases, not week to week or other transitory arrangements), then I would likely say "12 Units" for such a facility. However, if it operates more as a medical facility, then it is not reportable for HMDA. If a mix of both, then it depends on what the PRIMARY use is. For the original question, I believe 11 Total Units is correct, as others noted.
5. Properties with service and medical components. For purposes of § 1003.2(f), a property used for both long-term housing and to provide related services, such as assisted living for senior citizens or supportive housing for persons with disabilities, is a dwelling and does not have a non-residential purpose merely because the property is used for both housing and to provide services. However, transitory residences that are used to provide such services are not dwellings. See comment 2(f)-3. Properties that are used to provide medical care, such as skilled nursing, rehabilitation, or long-term medical care, also are not dwellings. See comment 2(f)-3. If a property that is used for both long-term housing and to provide related services also is used to provide medical care, the property is a dwelling if its primary use is residential. An institution may use any reasonable standard to determine the property's primary use, such as by square footage, income generated, or number of beds or units allocated for each use. An institution may select the standard to apply on a case-by-case basis.