OSHPD seeks public input on Title 24 clinic rules; proposes clarifications for primary care facilities

The Office of Statewide Health Planning and Development—uilding standards unit (part of the Department of Health Care Access and Information) held a public meeting to request stakeholder input on Title 24 regulations for primary care clinics and to update the guidance document known as CAN 1-7-2100. OSHPD staff said they will circulate draft regulatory language in August, seek further public comment and aim to submit code changes to the California Building Standards Commission in December; any approved changes would appear in the 2025 supplement and take effect July 2027.

The meeting matters because the changes would clarify which outpatient facilities must meet specific Title 24 clinic rules and could alter minimum construction requirements that affect small community clinics, conversions of medical offices to licensed clinics and local plan review. "The purpose of today's meeting is to write some of the primary care clinics regulations," said Mia Marbelli, supervisor of the building standards unit, who led the webinar and asked for written comments by June 30.

OSHPD and CDPH coordination: OSHPD staff explained that Title 24 building standards (including the California building, electrical, mechanical and plumbing codes) apply where clinics are licensed by the California Department of Public Health (CDPH) and that Title 22 licensing rules often reference Title 24. Andrew Barbuska and Nate Gilmore, branch chiefs with CDPH, joined the meeting; OSHPD said it will coordinate changes with CDPH and the State Fire Marshal and will clarify how the health and safety code defines which clinics are eligible for licensure.

Major topics discussed

Scope and scoping language: OSHPD identified the need to clarify the code's charging and scoping language that tells users which facilities must comply with Chapter 12.26 (the clinic sections). Staff proposed adding pointers to the Health and Safety Code so users can more quickly determine whether a site is a "primary care clinic" for…