The Department of Health Care Access and Information on Thursday rolled out an automated Seismic Compliance Plan application and a separate delay application tied to Assembly Bill 869, and published PIN 80 and accompanying regulations that HCAI says were filed with the Secretary of State Feb. 27 and become effective Mar. 29, 2025. Both the Seismic Compliance Plan and any AB 869 delay application must be submitted by Jan. 1, 2026, HCAI said during a webinar led by Ollie Sumer, supervisor of HCAI’s Seismic Compliance Unit.

HCAI framed the tools as a transparency and tracking upgrade: the compliance plan is implemented as two high-level tables that list a facility’s chosen compliance method for each building and a building-by-building milestone schedule. “Basically, it is a super simple, two brief tables that identify seismic scope and schedule to achieve compliance,” Sumer said on the webinar. The delay application is a single requested deadline date plus attachments verifying eligibility and supporting documentation.

Why it matters: the change centralizes previously paper or PDF submissions, lets HCAI monitor progress against critical milestones and activates accountability measures — including fines and, in extreme cases, blocking building permits for an entire facility — if milestones are missed. HCAI emphasized that a facility seeking a delay must submit both the Seismic Compliance Plan and the delay application; hospitals that are already compliant do not need to apply.

Who may seek a delay: AB 869 provides a delay mechanism for certain hospitals, HCAI said. Potentially eligible facilities include small hospitals (50 or fewer licensed beds), rural hospitals (as defined in the Health and Safety Code and MSSA classifications), critical access hospitals, recipients of the Distressed Hospital Loan Program, and certain healthcare district hospitals, subject to specific statutory conditions and documentation. HCAI said it identified about 130 facilities that appear to meet at least one of those categories and posted that list on its report portal for facilities to verify. HCAI will accept challenges to its classifications and will correct errors on request.

Application and review process: the compliance plan is entered through HCAI’s e‑services portal (ESP). HCAI said each facility’s building inventory will be prepopulated in the portal; applicants must select a compliance method for each building (for example, retrofit, demolition, or removal of general acute-care services), add short narratives and, where available, project numbers. The building-milestones table lets applicants add up to 10 milestone lines per building and mark one or more as critical; HCAI recommended choosing critical milestones that reflect the project’s critical path because those milestones are used to judge whether a facility is on track.

HCAI described key portal features and recordkeeping: contact information must be kept current (HCAI will send remarks and letters to listed contacts), each compliance plan record will use a stable ID in the form CP-[facility number], approved plans can be amended and earlier versions remain accessible as historical records, and most compliance-plan submissions require no attachments. Facilities need a facility PIN to submit; unauthorized users cannot finalize applications.

Delay specifics and deadlines: HCAI said AB 869 allows eligible hospitals to request a delay of the 2030 seismic compliance deadline for certain hospitals, with a possible additional discretionary two-year delay for “circumstances beyond the hospital’s control” if HCAI later determines continuing distress. HCAI said delay requests should align with the final completion date specified in a facility’s seismic compliance plan and that the department has a 120-day target to review a complete delay application. For system-level financial-distress claims (a system with two or more licensed hospitals), HCAI requires documentation showing the system’s continuing distress and expects semiannual updates; HCAI provided Feb. 1 and Aug. 1 each year as reevaluation points.

Financial verification and metrics: for eligibility tied to financial distress, HCAI listed typical financial documents and metrics it will review, and recommended including a narrative plus two-year cash-flow projections. PIN 80 and HCAI’s guidance identify metrics such as days cash on hand, current ratio, operating margin, net cash runway and debt-service coverage ratio; HCAI noted those figures are similar to parameters used in its Distressed Hospital Loan Program reviews.

MPC/SPC and related scheduling: HCAI reiterated that MPC and SPC deadlines and processes differ. It listed existing MPC-related milestones discussed in the webinar: submission of MPC evaluation reports (noted as Jan. 1, 2025), owner submittal of MPC construction documents (noted as March 1, 2026) and obtaining a building permit for MPC (noted as March 1, 2028). HCAI said those MPC dates are unchanged by AB 869 and that the delay mechanism is intended to provide additional time for construction; HCAI encouraged facilities to coordinate SPC work with MPC construction work when feasible to save time and money.

Enforcement if milestones are missed: HCAI said the compliance plan’s critical milestones are linked to accountability measures. If a facility misses critical milestones and does not engage to get back on track, HCAI may assess fines and, as a second-tier measure, block issuance of building permits for all nonexempt projects at the facility. HCAI said exceptions to a permit block include maintenance, emergency repairs and projects that are required for seismic compliance.

Public transparency and updates: HCAI will publish submitted compliance plans and status summaries on each facility’s detail page on the HCAI website. The facility page will show critical and noncritical milestone status, whether a plan is approved, denied or remarked, and related comments. HCAI said it will continue improving that public visualization and encouraged facilities to hold periodic meetings with HCAI (quarterly or otherwise) to discuss progress.

What HCAI said about the new regulations and PIN 80: HCAI told webinar attendees the regulations’ final express terms were filed Feb. 27 and that PIN 80 — which HCAI described as the portal for the streamlined application and the new delay application guidance — was posted the week of the webinar. HCAI said the regulations take effect on Mar. 29, 2025.

Webinar speakers and contact: the presentation was led by Ollie Sumer, identified as supervisor for the Seismic Compliance Unit at the Department of Health Care Access and Information; Kelly served as the webinar host/moderator. HCAI asked facilities to send questions to seismiccomplianceunit@hcai.ca.gov and to check the HCAI portal for handouts, recordings and the PIN 80 materials.

Looking ahead: HCAI emphasized the department’s goal of tracking progress centrally, preventing unnecessary spending on nonrequired work and helping facilities achieve compliance. The department also said it will monitor progress toward any additional discretionary two-year delay after Jan. 1, 2030, and that additional delay requests will use the same application process and will require updated compliance-plan milestones and supporting documentation.