Independent living lite is a marketing phrase with no regulatory meaning anywhere, so it won't defend anything. The line you care about is your state's statutory definition of an assisted living or residential care facility, and in most states that definition triggers on the provider furnishing or arranging assistance with activities of daily living, medication administration, or both, to residents in the building. A shower assist is hands-on ADL help by almost any state's language. Medication reminders sit in a narrower band, because many states distinguish reminding and self-administration from administering, and a few don't distinguish at all. Whether your menu crosses the line depends entirely on how your state's statute and regulations read, so this is a health care regulatory attorney question in your state before it's a pricing question.
The third-party agency structure is real and widely used. The mechanics that make it hold up are that the licensed home care agency contracts directly with the resident, the resident chooses and can decline, the agency bills the resident, and you don't take a cut or make the service a condition of tenancy. Regulators and plaintiffs' lawyers look through the structure where the landlord owns the agency, refers exclusively, marks up the service, or puts the charge on the rent statement as you've described. Billing it yourself is the specific detail I'd change first.
Two other things move before the licensure question resolves. Your general liability and umbrella carriers underwrite by exposure class, and a building providing personal care reprices or gets non-renewed. Agency financing documents and any HUD-insured loan will have permitted-use and services language you'd need to read closely.
Housekeeping and laundry, by contrast, are hospitality services and generally sit outside care licensure, though again the definitions are state-specific. If you want to keep residents longer without changing your regulatory profile, that end of the menu plus a good agency referral list is where operators start.
