HCAI reviews hospital nonstructural seismic deadlines, launches A13 phased bracing process

Ali Sumer, supervisor of the Seismic Compliance Unit at the Department of Health Care Access and Information (HCAI), outlined state deadlines and practical guidance for hospital nonstructural seismic upgrades during a two‑hour HCAI webinar.

Sumer said the agency’s goal is “to prepare the hospitals and [to] design and construct to resist, insofar as practical, the forces generated by earthquake, gravity and winds,” and emphasized that the MPC rating system focuses on nonstructural systems that most affect a facility’s ability to provide care after an earthquake.

Why this matters: HCAI told hospitals it is enforcing near‑term administrative deadlines for nonstructural evaluations and multi‑year construction milestones tied to California code changes and AB 869. Facilities that do not meet staged submittal and permit deadlines risk being categorized as no longer providing general acute care in affected buildings, which changes compliance obligations and published facility status.

The presentation covered three main topics: how HCAI is tracking current SPC (structural) and MPC (nonstructural) inventories, the submission and reporting steps hospitals must use in the agency’s Seismic Compliance Plan portal, and a new advisory procedure (the “A13 guide”) for phased, above‑ceiling bracing intended to reduce operational disruption.

Inventory and current status HCAI staff reviewed its inventory numbers and said about 655 buildings remain classified SPC 2 and 38 are SPC 1, categories that require resolution before the structural deadline. On the nonstructural side, Sumer said MPC 4 and MPC 4d ratings are increasing as hospitals submit evaluations and retrofit work; he also reported 246 buildings classified MPC 3 and said “almost half” of the inventory is MPC 2. HCAI has reviewed thousands of evaluation reports and is largely caught up with back‑check comments, though a small number remain in queue.

Deadlines and reporting steps Sumer walked through the deadlines hospitals must report and track in HCAI’s automated Seismic Compliance Plan (the agency’s e‑services portal): - Nonstructural evaluation submission deadline that already applied: 01/01/2024 (HCAI reminder). - 01/01/2025 was noted for AB 869 extension‑related submittals. - All facilities must submit a Seismic Compliance Plan by 01/01/2026. - Construction documents for MPC 4, MPC 4d and MPC 5 must be submitted by 03/01/2026. - Permits must be obtained by 03/01/2028. - The general construction completion date for non‑AB 869 facilities remains 01/01/2030; AB 869 extension dates govern affected facilities’ final completion.

Sumer explained HCAI will ask hospitals to enter milestones (construction‑document submission, permit dates, completion status) into the Seismic Compliance Plan and monitor progress through comments visible in the portal. HCAI staff noted that January deadlines were shifted to March to avoid calendar‑day conflicts around holidays and vacations.

Operational plans and MPC 4d HCAI stressed that MPC 4d evaluations must include an owner‑approved operational plan that explains how continuous operation will be achieved through selective bracing and operational strategies. Sumer warned evaluators and owners not to include sensitive security details (for example, staff phone numbers) in versions of operational plans that HCAI posts publicly; HCAI said it is acceptable to submit a full technical version for review and a redacted public version for posting.

Sumer said hospitals should identify source buildings (central utility plants) and pass‑through buildings because MPC 4d compliance often requires bracing source equipment and the utilities feeding critical areas. He said HCAI is advising that central utility plants be treated as MPC 4 candidates in practice, since leaving the source unbraced undermines any operational plan that aims for facility‑wide continuous functionality. Sumer also summarized typical requirements for elevator selection (a minimum of one elevator for level 2 and level 3 strategies) and explained that MPC 5 eligibility requires a building to meet MPC 4/4d standards and provide 72 hours of water, fuel and sewer capacity.

A13 phased bracing guide To reduce repeated ceiling access and operational disruption, HCAI introduced an advisory A13 process for existing above‑ceiling utilities and components only. Sumer said the A13 approach is optional, is intended only for existing systems (not new equipment), and relies on a phased workflow: gather existing drawings and typical details (OPM details), preapprove typical details with HCAI, perform milestone‑based site verifications with the design professional of record (DPR) present, update as‑built bracing layout drawings at each milestone, and submit final bracing layouts at project closeout.

Key points about the A13 process included: - Use A13 only when existing documentation and access limitations make full preconstruction surveys impractical; if a site‑visit inventory is already comprehensive, a traditional pre‑construction approach may be faster and less costly. - The DPR (licensed design professional) must make on‑site decisions; contractors should not substitute for the DPR’s determinations. - HCAI will spot‑check and sign off on milestones rather than review every incremental change; updates must be kept as part of project records and will be required at final closeout. - Changes that deviate from preapproved typical details are treated as either non‑material adjustments (NMA) or as additional construction documents (ACD). Staying within OPM‑based details reduces ACDs and speeds approvals; if many ACDs are needed, HCAI recommends switching to the traditional approach.

Operational and documentation guidance Sumer also recommended practical steps that hospitals and design teams should follow: include summary tables up front in evaluation reports (so future reviewers see the ‘‘big ticket’’ retrofit items at a glance), keep separate project records for tenant improvements versus MPC utility upgrades, take comprehensive photographs and retain them as part of the project record, and use the portal’s TIO/milestone entries to track phased work (the DPR should own the TIO entries, not the contractor).

How to get help HCAI asked attendees to use the Seismic Compliance and Safety pages on the HCAI website for building lists and downloadable inventories and said a consolidated PDF of facility MPC/SPC status is available for download and conversion to spreadsheet format. HCAI requested that facilities contact the agency if they believe the portal shows incorrect submission status for their projects.

Sumer closed by noting HCAI will continue to refine the A13 guide and publish new versions with clarifications and examples; he invited technical questions by email to seismiccomplianceunit@hcai.ca.gov.

The webinar included a brief Q&A logistics note from the moderator and instructions for downloading the slide handout and the recorded presentation from the HCAI website.

Ending HCAI’s presentation was procedural and advisory; no formal regulatory actions or votes were taken during the webinar. The session focused on operationally practical ways hospitals, design professionals and contractors should document, phase and report MPC 4/4d work to meet state deadlines and to minimize patient‑care disruptions during seismic retrofits.