You can optimize roaming for non-802.11k clients by generating a prediction neighbor list for each client without sending an 802.11k neighbor list request. When prediction based roaming enables a WLAN, after each successful client association/re-association, the same neighbor list optimization applies on the non-802.11k client to generate and store the neighbor list in the mobile station software data structure. Clients at different locations have different lists because the client probes are seen with different RSSI values by the different neighbors as the clients usually probe before any association or re-association. This list is created with the most updated probe data and predicts the next AP that the client is likely to roam to.
https://www.cisco.com/c/en/us/td/docs/wireless/controller/8-1/Enterprise-Mobility-8-1- Design-Guide/Enter prise_Mobility_8-1_Deployment_Guide/Chapter-11.html