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 (DOs) 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 differ based on the organization’s current standing with CDPH and whether they have previously held a license. In addition, a site that is open for 40 or fewer hours per week can choose to operate as an intermittent clinic and be exempt from the licensure process. To apply for a primary care clinic license, please visit the Centralized Applications Branch’s website. Applications are accepted via mail on paper-based forms.
- Initial/Primary Care Clinic (PCC): An application is required to establish a license for a primary care clinic. The application process for an initial/PCC is detailed on the CAB website.
- Affiliate: An organization with at least one clinic that has held a valid, unrevoked, and unsuspended license for at least five 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.
- Mobile: To obtain an Initial Mobile license, you must complete the required application packet. An organization that meets the criteria for an Affiliate license can apply for an Affliate Mobile License. Refer to HSC sections 1200 through 1245 for licensure requirements. Refer to HSC sections 1765.101 through 1765.175 for information regarding Mobile Health Care Units.
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.
Health & Safety Code (HSC) Section 1206 lists types of clinics that are exempt from the licensure process, including intermittent clinics which are defined as clinics operated by a licensed primary care clinic operated on separate premises from the licensed clinic and only open for limited services of no more than 40 hours a week.
To establish an intermittent clinic, licensees are required to notify the Provider Enrollment Division (PED) of DHCS so the clinic’s Provider Master File (PMF) can be updated. Clinics are also required to report new intermittent sites to the Centralized Applications Branch (CAB) of CDPH during or before the parent clinic’s annual license renewal. CAB then updates the parent license to reflect the intermittent clinic. Clinics can follow the steps below to establish new intermittent locations:
STEP ONE: As described above, 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 (PMF). The notification to PED should include the following:
- [FQHCs Only] 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.
- Memo: Clinics must submit a letter to the Department of Health Care Services (DHCS) Provider Enrollment Division (PED), on corporate letterhead, requesting enrollment of the intermittent site. Guidance on the required content of the notification to PED can be found here.
Note: Once the information is received by PED, clinics are eligible for reimbursement under the parent site’s rate for services provided at the intermittent site. Clinics wishing to check the status of their request to PED can reach out to PED-FSP@dhcs.cs.gov .
STEP TWO: CAB has developed an intermittent clinic checklist that lists the documents required for establishing new intermittent sites, converting existing licensed sites to intermittent, as well as reporting changes to intermittent sites.
- Notification to CAB: The name of the "Parent" primary care clinic (include the license number, address, and contact information) and the facility operating as an intermittent clinic under the "Parent" primary care clinic, (name, address, daily hours of operation, total hours per week, and contact information).
- Note: Although the intermittent clinic checklist does not request form STD 850 for Fire and Life Safety requirements you must obtain clearance with this form, or the local equivalent, and keep it on file for your intermittent site.
Once CAB receives the notification, they update and re-issue the parent license to reflect the addition of the intermittent clinic(s). Clinics can verify that the notification process has not changed by visiting the CAB web page here.
Note: Intermittent clinics must enroll directly with Medicare and receive their own Provider Transaction Access Number (PTAN). Medicare requires that the intermittent clinic be listed on the parent license prior to enrollment approval.
Mobile Clinic Webcast: Mobile units help ensure the availability of quality health care services for patients who receive care in remote or underserved areas and for patients who need specialized types of medical care provided in a cost-effective way. This webcast provides an overview of how to establish a mobile clinic.
Mobile Clinic Licensing 101: CPCAunderstanding licensing requirements for a mobile clinic operated by a Primary Care Clinic in California as enforced by the California Department of Public Health (CDPH).
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.
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.
- City Business License – Each municipality will have different requirements based on what is being opened, but for a basic non-profit public facing clinic most—if
- Biohazardous Waste Transport Permit – Managed by county agencies and the quantity of waste created and how it is handled may trigger the need for this permit
- California Department of Industrial Relations – If running an elevator in one of your clinics
- Dental Board of California – if running any dental clinics or using a mobile unit for dental services
- Motor Carrier Permit/CA Number – If using a mobile unit to provide any care
CPCA Staff Contact
Please contact Elle Grant, Senior Program Coordinator, at firstname.lastname@example.org or call (916) 440-8170 for licensing and provider enrollment-related inquiries.