Licensing & Certification
Primary care clinics are required to be licensed through the authority of the California Department of Public Health (CDPH) Licensing & Certification Program (L&C). The L&C program utilizes standards defined in state and federal law and regulations to evaluate health facility compliance. The Office of Statewide Health Planning and Development (OSHPD) is responsible for writing regulations pertaining to licensed clinics. These regulations are identified in Title 24, the California Building Standards Code as “OSHPD 3”. OSHPD 3 requirements are applied to clinics that are licensed pursuant to Health and Safety Code Section 1200, which includes primary care and specialty care clinics.
Applying for a Clinic License
The Centralized Applications Branch (CAB) at the state level in Sacramento is responsible for initial review of all licensing applications. Applications deemed complete are then passed on to one of the 15 regional district offices (DO)s that perform site surveys, investigate complaints, and issue licenses if all requirements have been met.
Clinic sites have several options available to them when seeking licensure. The application types refer to different processes, but result in the same license type being issued. In addition, a site that is open for 30 or fewer hours per week can choose to operate an intermittent clinic and be exempt from the licensure process, (see “Clinics Exempt from Licensure”, below, for information on establishing an intermittent clinic).
- Initial/Primary Care Clinic (PCC): An application is required in order to establish a license for a primary care clinic. The application process for an initial/PCC is detailed on the CAB website, linked below. Online application?
- Affiliate: An organization with at least one clinic that has held a valid, unrevoked, and unsuspended license for at least five (5) years immediately prior to the date of application with no history of repeated or uncorrected serious violations affecting patient safety, constituting “immediate jeopardy,” and no pending action to suspend or revoke its license, becomes eligible to use the affiliate process to secure a license for an additional site. The affiliate process results in the same license type as an initial/PCC but requires less documentation from the applicant, and affiliate applications receive priority in processing over other application types.
- Consolidated: An organization with an existing licensed clinic that seeks to license an additional clinic location that is within 0.5 miles of the existing licensed site, may opt to use the consolidated licensing process instead of the initial or affiliate. The consolidated licensing process requires even less upfront documentation than the initial and affiliate processes, and thus is the most streamlined licensing option.
In order to apply for a primary care clinic license, please visit the Centralized Applications Branch’s website. Applications are accepted via paper-based forms or through the online application.
Applying for Medi-Cal Certification
Each licensed clinic that will participate in the Medi-Cal program is required to individually certify and enroll. For clinics required to be licensed, CAB also processes the forms required for Medi-Cal certification. The forms should be submitted simultaneously with the appropriate licensing application as outlined on the primary care clinic application checklist here, and once processed by CAB, will be forwarded to DHCS Provider Enrollment Division. For FQHCs, this is the beginning of the PPS rate-setting process for Medi-Cal.
Clinics Exempt from Licensure
Health & Safety Code (HSC) Section 1206 lists types of clinics that are exempt from the licensure process, including intermittent clinics.
- Intermittent: A clinic that is operated by a licensed primary care clinic and that is operated on separate premises from the licensed clinic and is only open for limited services of no more than 40 hours a week.
In order to establish an intermittent clinic, clinics must address the following:
1. Medi-Cal Enrollment: The clinic must notify DHCS Provider Enrollment Division (PED) of the intermittent site so that it can be added to the parent clinic’s provider master file. The notification to PED should include the following:
- HRSA Notice of Award: For FQHCs, the intermittent site must be added to HRSA scope, resulting in a Notice of Award specifying the intermittent site’s location. The Notice of Award must be provided to PED.
2. Notification to CAB: While not required before the establishment of an intermittent location, clinics are required to notify CAB of any intermittent clinics being operated by a parent clinic at the time of the parent clinic’s license renewal. CAB is working to update the renewal form so that there is dedicated space to report this information but in the meantime, clinics should provide CAB with written notice at the time of the parent clinic’s renewal. The written notice shall include the following information regarding the addition of an intermittent clinic(s). Clinics can verify that this process has not changed by visiting the CAB web page here :
- The name of the "Parent" primary care clinic. Include the facility number, license number, address, and contact information.
- All the facilities operating as an intermittent clinic(s) under the "Parent" primary care clinic. Include the intermittent clinic(s) name, address, daily hours of operation and total per week, and contact information for each intermittent clinic(s).
- STD 850: Submit a completed Fire Safety Inspection Request (STD 850) for each intermittent clinic.
Once the information is received by CAB, they process and re-issue the parent license so that it reflects the operation of the intermittent clinic(s). CAB does not send this information to PED, so clinics need to make sure they have completed Step 1, above, in order to be eligible for Medi-Cal reimbursement.
Note: Intermittent clinics must enroll directly with Medicare and receive their own PTAN. Medicare requires that the intermittent clinic be listed on the parent license prior to enrollment approval, (step 2, above).
It is recommended that existing intermittent clinics notify CAB of their current hours of operation any time those change.
Resources & Tips
- CAB Contacts and Web Page: Licensing and certification guidance as well as CAB contact information can be found on this web page.
- Intermittent Clinic Checklist for CAB Website*: This document was provided by CAB on 12/19/18. Clinics can contact the CAB to ensure that these processes have not changed and/or can visit the CAB web page to verify. *Please note that the parent clinic's facility number is NOT required, despite being included on the checklist.
- STD 850 - Fire Clearance: In order to assist clinics with fire authorities who may be hesitant to accept a clinic-initiated STD 850, the CAB website provides a checklist for Primary Care Clinic licensing that includes a cover letter to Fire Authorities in the State of California, alerting them that the STD 850 form can be initiated either by the clinic directly, or by the CAB staff. In addition, CAB has provided a pre-populated STD 850 form that clinics can use which includes the Licensing Agency Name and Address. Clinics having trouble obtaining a fire clearance from their local authority may contact the CAB to request that CAB initiate the form on their behalf. Please note that the STD 850 should be obtained prior to submitting any application or change request.
- CDPH 270 - Written Certification of Title 24 Compliance: This form may be completed by a licensed architect OR by the local building authority, (at the clinic's discretion), in order to meet licensure requirements.
- 2018 DRAFT AB 2428 Consolidated Licensure & Reimbursement FAQs
- 2018 DRAFT AB 2204 Intermittent Clinic Hours of Operation FAQs
CPCA Staff Contact
Please contact Emily Shipman, Associate Director of Health Center Operations, at email@example.com or call (916) 440-8170 for licensing-related inquiries.