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HCAI explains hospital seismic compliance plan requirements, deadlines and milestone examples

August 28, 2025 | Department of Health Care Access and Information, Agencies under Office of the Governor, Executive, California


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HCAI explains hospital seismic compliance plan requirements, deadlines and milestone examples
Seismic compliance plans must be submitted by all general acute care hospitals, and HCAI staff outlined how facilities should fill the new online application and choose building-by-building milestones.

Ollie, Seismic Compliance Unit presenter, said: "Seismic compliance plan is required for all hospitals. The deadline to submit is at the end of this year." He told attendees the online application now uses project IDs that begin with "CP-" and consists primarily of two tables: a compliance-method table (one line per building) and a building-milestones table that lists up to 10 milestones per building.

Why this matters: the plan is the high-level roadmap that explains how each hospital building will reach seismic compliance by the applicable completion date. HCAI said the agency will publish submitted plans, reviewer comments and approval status on its facility-detail pages to maintain transparency.

HCAI emphasized the plan is not a set of structural drawings or calculations but an outline of how each building will reach compliance. Ollie said the application will prepopulate buildings and ratings for each facility and that applicants must identify the compliance type for each building, add brief narratives and provide project numbers if available. He said the application asks which legal entity (owner or operator) is financially responsible for upgrades so HCAI can correspond with the correct contact.

On milestones, Hailey, Seismic Compliance Unit presenter, reviewed recommended milestone types and sequencing using fictional site-plan examples. She said applicants should be strategic because the milestones table allows a maximum of 10 entries per building. For retrofit projects that include SPC 4(d), NPC 4 (or 4d) and NPC 5 work, she recommended combining evaluation-report submittals, construction-document submittals, intermediate construction progress milestones (HCAI prefers 20% and 50% as indicators of momentum) and construction-final entries. As an example, Hailey said: "we are recommending you use the 20% completion milestone" as an intermediate marker because it shows the project has momentum.

HCAI also advised campuses with multiple buildings to list NPC 5 milestones on only one building and reference that building from other buildings that will achieve NPC 5, to reduce duplication and simplify future amendments.

Deadlines and review process: HCAI reminded attendees that certain milestone categories carry statutory or program deadlines. HCAI cited two workshop/filing deadlines for construction drawings and permits used in milestone planning: the agency stated construction drawings for certain retrofit paths are due March 1, 2026, and that a permit for those projects must be obtained by March 1, 2028. HCAI reiterated the overarching compliance target tied to the 2030 schedule (referred to repeatedly in the webinar as the "2030 deadline"). Ollie said HCAI will perform a reasonableness review of proposed dates and will contact facilities to resolve unrealistic scheduling (for example, implausibly short design-to-completion timelines). He added that when HCAI issues remarks or requests for additional documentation, "the facility will always have an opportunity to respond" and that review turnaround will be prompt: "it will be less than 120 days turnaround time."

Other guidance and resources: presenters pointed to prerecorded webinars and an example spreadsheet on HCAI’s website that contains multiple, downloadable milestone templates and sample narratives. Ollie referenced a policy intent notice (PIN 80) as a resource that explains regulation details and the process for requesting delays beyond the 2030 schedule. He also noted a February 20 webinar and a state grant referenced in that session as potentially helpful for smaller rural hospitals; the grant was mentioned but not described in detail.

What HCAI will publish: when a plan is submitted HCAI will post the plan and any HCAI remarks, approvals or denials on the facility detail page. The presenters said reviewers’ comments will appear adjacent to specific rows in the milestone tables in the online portal so facilities and the public can see both the plan and agency feedback.

Discussion versus decision: the webinar was informational; there were no motions, votes or formal agency decisions during the session. Presenters described application mechanics, example milestone sequences and HCAI review practices but did not adopt new rules in the webinar.

Next steps for facilities: HCAI recommended (1) download the example spreadsheet and user guide from the HCAI website, (2) populate the two required tables in the online portal (compliance method and milestones) for each building, (3) select reasonable dates for evaluation submissions, construction submittals and intermediate milestones (20% and 50% where possible), and (4) include delay requests and supporting sequencing documentation if applying for an extension beyond the 2030 compliance horizon.

The webinar recording and slide handout will be posted to the HCAI website, and attendees were invited to email seismiccomplianceunit@hcai.ca.gov with questions.

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