OSHPD HCAI Process Guide for Healthcare MEP Projects

Healthcare facility construction in California operates in a regulatory environment with no equivalent in any other building sector. Hospitals, skilled nursing facilities, and certain outpatient buildings are subject to state-level plan review and construction inspection by the California Department of Health Care Access and Information (HCAI) — the successor agency to the former Office of Statewide Health Planning and Development (OSHPD). Every significant change to a regulated healthcare facility’s MEP systems, from a boiler replacement to a new patient wing, must receive HCAI approval before work can begin.

The technical standards applied by HCAI to MEP systems are among the most demanding in any building sector. Ventilation requirements reference ASHRAE 170, a healthcare-specific standard with air change rates, pressure relationships, and humidity controls that bear little resemblance to commercial building standards. Seismic requirements treat hospitals as Occupancy Category IV critical facilities, imposing the most stringent equipment anchorage and bracing standards in the California Building Code. And HCAI’s field inspection regime extends continuous oversight from permit issuance through project closeout.

Budlong has engineered MEP systems for healthcare facilities subject to HCAI (and previously OSHPD) review for decades, spanning acute care hospitals, veterans affairs medical centers, mental health facilities, and specialty outpatient clinics. This guide distills that institutional knowledge into a practical resource for healthcare owners, project executives, and design teams navigating the HCAI process.

What Is HCAI and What Replaced OSHPD?

The Department of Health Care Access and Information (HCAI) was created effective July 1, 2022, when California reorganized several state health-related agencies. The Facilities Development Division (FDD) of HCAI assumed all regulatory functions previously performed by the Office of Statewide Health Planning and Development (OSHPD), including plan review, construction oversight, and field inspection for regulated healthcare facilities.

The regulatory framework itself did not change significantly with the agency reorganization. HCAI FDD continues to apply the same California Building Code healthcare-specific requirements, the same OSHPD administrative bulletins, and the same OSHPD OPA equipment pre-approval listings that governed the sector under OSHPD. The organizational change was administrative; the technical and procedural requirements for MEP engineers remain essentially unchanged. Industry professionals, contractors, and equipment manufacturers continue to reference “OSHPD requirements” as shorthand for the healthcare-specific provisions now administered by HCAI FDD.

Which Healthcare Facilities Require HCAI Review?

Not all California healthcare facilities are regulated by HCAI. The agency’s jurisdiction is defined by California Health and Safety Code Section 1250 et seq. and extends to licensed healthcare facilities in specific occupancy categories.

The boundary between HCAI jurisdiction and local AHJ jurisdiction is significant because it determines which code standards apply, what plan review timeline to expect, and what field inspection regime governs construction. When a project involves expanding a licensed HCAI-regulated facility into an adjacent space that was previously outside the regulated envelope, the entire project may fall under HCAI jurisdiction even if only a portion of the work touches the licensed facility.

HCAI MEP Review Scope and Standards

HCAI MEP review is more comprehensive and more technically demanding than local AHJ plan check for commercial buildings. HCAI reviewers apply multiple overlapping standards simultaneously, and they are specialists in healthcare occupancy requirements — not generalist plan checkers reviewing a wide variety of building types.

Mechanical Systems

HCAI reviews HVAC systems for compliance with ASHRAE 170 (Ventilation of Health Care Facilities), Title 24 Part 6 energy standards, HCAI’s own mechanical standards and administrative bulletins, and infection control requirements during construction. HCAI mechanical review examines: air change rates and directional airflow (positive or negative pressure) for each clinical space type, filtration requirements by space classification, temperature and humidity control ranges, condensate drainage, and emergency power provisions for critical HVAC systems serving life-safety spaces.

Electrical Systems

HCAI reviews electrical systems for compliance with NFPA 99 (Health Care Facilities Code), NFPA 70 (National Electrical Code) as adopted by California, and HCAI’s healthcare-specific electrical requirements. Critical review areas include: essential electrical system (EES) design with separately derived emergency, critical branch, and equipment branch circuits; generator sizing and transfer switching for life-safety loads; ground fault protection systems; wet location electrical installation in patient care areas; and medical gas outlet locations and electrical coordination in patient rooms and procedure areas.

Plumbing and Medical Gas Systems

HCAI reviews plumbing systems and medical gas systems for compliance with the California Plumbing Code, NFPA 99 Chapter 5 (Gas and Vacuum Systems), and HCAI’s healthcare-specific plumbing standards. Medical gas systems — including piped oxygen, medical air, nitrous oxide, vacuum, and waste anesthetic gas disposal — require HCAI review and must be installed by ASSE-certified medical gas technicians.

ASHRAE 170: The Ventilation Standard for Healthcare Facilities

ASHRAE 170 (Ventilation of Health Care Facilities) is the primary ventilation reference standard for HCAI-regulated facilities. It establishes minimum air change rates, pressure relationships, filtration requirements, temperature ranges, and relative humidity ranges for each clinical space type — from operating rooms and isolation rooms to patient corridors and clean workrooms.

ASHRAE 170 requirements are substantially more demanding than ASHRAE 62.1 commercial building ventilation standards. A general office space under ASHRAE 62.1 might require 0.06 to 0.1 cfm per square foot of outdoor air. An operating room under ASHRAE 170 requires a minimum of 20 total air changes per hour, with a minimum of 4 of those as outdoor air, maintained at positive pressure relative to adjacent spaces, with HEPA filtration at the supply, within a temperature range of 68 to 75°F and a relative humidity range of 20 to 60 percent.

The interaction between ASHRAE 170 ventilation requirements and Title 24 Part 6 energy standards creates design challenges. Title 24 requires demand-controlled ventilation in high-occupancy spaces, but ASHRAE 170 requires minimum constant air volumes in many clinical spaces regardless of occupancy. The mechanical engineer must demonstrate to HCAI that ASHRAE 170 minimum air changes are maintained even as Title 24 DCV controls operate — typically through a minimum air volume override in the HVAC control sequence and clear documentation in the sequence of operations narrative submitted to HCAI.

The HCAI Submittal and Plan Review Process

The HCAI plan review process follows a defined sequence that differs in important ways from the local AHJ plan check process used for commercial buildings.

Stage 1: Pre-Application Meeting

For complex new construction or major renovation projects, HCAI encourages — and in some cases requires — a pre-application meeting between the project team and HCAI staff before submitting documents. This meeting allows HCAI reviewers to identify potential compliance issues early, clarify interpretation questions, and define the submittal requirements for the specific project type. Experienced healthcare MEP teams use pre-application meetings proactively to align on complex ASHRAE 170 interpretation questions before design development is complete.

Stage 2: Permit Application and Initial Submittal

The permit application initiates formal HCAI review. For regulated facilities, HCAI is the permitting authority — the local building department does not issue a building permit until HCAI grants project approval. The initial submittal package must include complete construction documents for all disciplines, Title 24 energy compliance documentation, geotechnical reports, and applicable HCAI-required forms and checklists.

Stage 3: Plan Review

HCAI assigns specialist reviewers for structural, architectural, and MEP disciplines. For complex hospital projects, MEP review may involve multiple HCAI reviewers across mechanical, electrical, and plumbing subdisciplines. Plan review timelines for new hospital construction range from 6 to 18 months. HCAI publishes current estimated review times on its website, but actual timelines depend on document completeness and the complexity of correction responses.

Stage 4: Correction Cycles and HCAI Approval

HCAI issues a Deficiency List documenting all plan check corrections required before approval can be granted. Responses must address each deficiency with revised drawings, calculations, or written justifications citing applicable code sections. Multiple correction cycles are common on complex hospital projects. HCAI approval is documented through a Permit to Construct, which is then provided to the local AHJ for any locally required permits.

Seismic Requirements for Hospital MEP Systems

California hospitals are classified as Occupancy Category IV (essential facilities) under ASCE 7, the highest importance category, requiring the most stringent seismic design provisions in the California Building Code. This classification reflects the critical role hospitals play during and after seismic events — they must remain operational when they are most needed.

For MEP engineers, Occupancy Category IV seismic requirements mean that all nonstructural components — mechanical equipment, HVAC units, electrical switchgear, transformers, distribution panels, piping systems, ductwork, and conduit — must be designed and braced to resist seismic forces at the Importance Factor Ip = 1.5 level. This is a 50 percent increase in design force compared to standard commercial buildings at the same site.

In practice, hospital MEP seismic compliance requires: HCAI OPA-listed equipment (see Section 7) or site-specific seismic engineering calculations for all major equipment; seismic bracing schedules for all suspended ductwork, conduit, and piping above minimum size thresholds; anchorage calculations and details for floor-mounted mechanical and electrical equipment; and flexible connections at building seismic joints and between equipment with different dynamic characteristics.

OSHPD OPA Listings and Equipment Pre-Approval

One of the most important practical aspects of healthcare MEP design under HCAI is the OSHPD Office of Plan Approval (OPA) pre-approval listing system. HCAI maintains a database of mechanical, electrical, and plumbing equipment that has been pre-approved for use in California healthcare facilities based on seismic qualification testing and code review.

An OPA listing for a specific equipment model means that HCAI has already reviewed and approved the seismic qualification documentation for that equipment. When an OPA-listed item is specified on a project, the design team does not need to submit project-specific seismic engineering calculations for that equipment — a significant time and cost savings. HCAI plan reviewers can quickly confirm OPA listing compliance without extended technical analysis.

When non-OPA-listed equipment must be specified — because an OPA-listed equivalent is not available or does not meet the project’s performance requirements — the design team must submit site-specific seismic engineering calculations, stamped by a California-licensed structural engineer, demonstrating that the proposed equipment and its anchorage design meet the seismic requirements for the site’s seismic parameters and the facility’s Occupancy Category IV classification.

HCAI Field Inspection During Construction

HCAI’s oversight of healthcare construction does not end at plan approval. Unlike most local building department inspections — which are triggered by contractor request at defined construction milestones — HCAI maintains continuous oversight through a system of assigned inspectors, mandatory hold points, and field observation reporting requirements.

For complex hospital projects, HCAI assigns a resident inspector (Inspectors of Record, or IOR) who may be present on-site full-time during critical construction phases. The IOR documents construction progress, verifies compliance with approved drawings, and reports directly to HCAI. The IOR has authority to place holds on work that does not conform to the approved plans.

MEP hold points — required inspections that must be completed and approved before the next phase of work can proceed — are defined in the approved construction documents. Common MEP hold points include: above-ceiling MEP rough-in before ceiling closure; medical gas system rough-in before pressure testing; HVAC system installation before duct sealing; and electrical room installations before energization. Missing a hold point — proceeding with work before the HCAI inspector has approved the prior phase — is a significant compliance violation that can trigger stop-work orders and mandatory correction.

Best Practices for MEP Compliance on HCAI Projects

Experienced healthcare MEP teams share a set of practices that consistently produce better HCAI outcomes: fewer correction cycles, fewer field holds, and more predictable construction schedules.

Engage HCAI Early Through Pre-Application Meetings

Pre-application meetings with HCAI reviewers are an opportunity to clarify complex code interpretation questions before they become plan check corrections. For novel project types — conversion of commercial space to clinical use, renovation of vintage hospital buildings, or new clinical program types that lack clear ASHRAE 170 space classification guidance — early HCAI engagement can prevent months of correction cycle delay.

Specify OPA-Listed Equipment Wherever Possible

Every non-OPA-listed piece of major equipment requires site-specific seismic calculations that add to plan check time and project cost. Budlong’s standard equipment selection process checks OPA listing status before finalizing equipment specifications, substituting OPA-listed alternatives wherever performance requirements can be met.

Develop a Complete Sequence of Operations That Addresses ASHRAE 170 and Title 24 Interaction

The interaction between ASHRAE 170 minimum air change requirements and Title 24 DCV energy control provisions is a common source of HCAI corrections. The HVAC sequence of operations narrative must explicitly address how the control system maintains ASHRAE 170 minimum air volumes at all times, including when Title 24 DCV controls are operating. This narrative should be reviewed by both the energy code compliance team and the HCAI clinical review team before the submittal package is finalized.

Build MEP Hold Points Into the Construction Schedule

HCAI MEP hold points must be treated as hard constraints in the construction schedule. Failing to schedule inspector reviews at the appropriate construction milestones — or proceeding with work without inspector approval — creates compliance violations that can set the project back by weeks. Early coordination with the HCAI inspector on inspection scheduling and hold point timing is essential for schedule management on hospital construction projects.

Healthcare Projects Served by Budlong

11. Related Reading

12. Frequently Asked Questions