HCAI details 2025 Title 24 updates affecting hospitals, imaging rooms, temporary structures and psychiatric care
October 28, 2025 | Department of Health Care Access and Information, Agencies under Office of the Governor, Executive, California
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The Department of Health Care Access and Information (HCAI) outlined key 2025 updates to Title 24 on March 29, 2025, during a public webinar, noting the California Administrative Code became effective March 29, 2025, after filing with the Secretary of State. HCAI said the changes affect hospital seismic evaluation procedures, review and submittal responsibilities for design professionals and contractors, and facility-specific provisions for imaging rooms, temporary structures and tents, sterile compounding pharmacies, and psychiatric and chemical-dependency service areas.
Why it matters: the updates clarify who may submit plans to HCAI, tighten submittal and compliance-reporting expectations, and provide new advisory guidance (including the A10 imaging-room guide and several design advisory guides) intended to reduce late-stage licensing delays and align Title 24 with other regulatory requirements such as NFPA 99, USP sterile-compounding rules, and CDPH (Title 22) licensing expectations.
Mia Marbelli, supervisor of the Building Standards Unit at HCAI, said the Administrative Code follows a different effective-date rule than other parts of Title 24 and that the Administrative Code took effect 03/29/2025 after commission approval and filing with the Secretary of State. Marbelli drew attention to Chapter 6 seismic-evaluation changes for hospital buildings and to a series of spring webinars produced by HCAIs seismic compliance unit that addressed new submission processes and a law (Assembly Bill 869) that allows an eligible rural or small hospital to request up to a three-year delay in compliance if certain criteria are met and HCAI concurrence is obtained.
HCAI described several procedural and jurisdictional clarifications. Chapter 7 was rewritten in places to itemize required submission documents; HCAI said it coordinated with the Board for Professional Engineers, Land Surveyors, and Geologists to allow fire-protection engineers to prepare and submit documents for projects that fall within their responsible charge. The agency also clarified that, when a firm rather than an individual prepares construction documents, the firm remains the responsible party if personnel change.
On changes to approved work and nonmaterial alterations (NMAs), Samantha Miller, senior architect in HCAIs Building Standards Unit, summarized revisions to CAN 7-153b that define material versus nonmaterial changes, describe the concurrence process for NMAs in the field, and add change forms, logs and an illustrated workflow. Miller said the CAN has been adjusted since April to ensure it aligns with the administrative-code amendments and to make clear that the CAN examples are illustrative, not an exhaustive list.
HCAI also announced administrative changes to reporting and compliance: final verified compliance reports and final test-and-inspection reports must be filed with the office (rather than preliminary or unverified reports) to support final approvals.
Part 2, Volume 1 changes include jurisdictional clarifications for chemical dependency recovery hospitals established under Assembly Bill 2096: where such services are delivered in a freestanding chemical-dependency recovery hospital (not part of an OSHPD/Jurisdiction 1 or 2 acute-care facility), the project is enforced by the local building department, HCAI said. Temporary structures remain subject to specific OSHPD guidance; the updated CAN says OSHPD/HCAI will permit only one extension for temporary structures when cause is demonstrated and the request is granted before final approval expires. The CAN also clarifies when temporary equipment may qualify as interim equipment tied to a construction schedule and revised construction documents (ACD).
Tents intended for patient care were addressed: HCAI explained that three jurisdictional approvals are typically required (local building and fire departments for placement, anchorage and access; the California Department of Public Health for the limited set of patient-care processes allowed in tents; and HCAI for project impacts to permanent structures and utility connections).
On imaging rooms, HCAI revised the definition of invasive procedure to better align with the Facility Guidelines Institute (FGI) explanatory notes and to replace vague terminology with a probabilistic risk threshold (for example, a greater-than-5% probability for certain classifications). HCAI introduced an A10 guide recommending use of a critical risk assessment (CRA) in the patient-safety portion of a projects functional program to assign imaging-room classes and to avoid late-stage licensing delays; the guide includes three class-specific checklists as appendices. Miller said HCAI contacted FGI about using the FGI CRA template but FGI declined, so project teams are encouraged to reference the 2026 FGI guidance when it becomes available.
HCAI also amended the medical-gas and outlet table (Table 12.24.406.1) to add an instrument-air column and new footnotes for central sterile processing areas, aligning locations for instrument air with the 2018 FGI medical-gas table and HCAIs adoption of NFPA 99 requirements. The agency issued its first nurse-call design advisory guide to clarify electrical placement, test procedures, temporary-system sequencing and repair parameters; presenters noted the earlier PIN 60 that informed the guide has since been rescinded.
Sterile-compounding and pharmaceutical-service provisions were consolidated and clarified: HCAI created a sterile-pharmacy compounding guide that compiles requirements across multiple California code titles, cleans up regulatory citations, adds mechanical-code requirements in checklists and graphics, and defines a hazardous-drug storage room consistent with United States Pharmacopeia (USP) requirements (negative pressure, external ventilation and 12 air changes per hour for certain compounding/storage areas). The guide also clarifies allowed pass-throughs and refrigerator pass-through restrictions for hazardous-drug areas.
Several patient-space clarifications were made across facility types: HCAI removed a vague suitable for hanging full-length garments requirement and now requires each patient space (including skilled nursing and psychiatric units) to include a separate wardrobe, locker or closet for each patients belongings; for anti-ligature psychiatric installations the code clarifies folded-shelf or garment arrangements instead of hanging fixtures. The agency clarified pediatric and adolescent patient areas must be separate from adult nursing units though common areas may be shared at different times, and added activity-space requirements for psychiatric nursing units that mirror related 12.28 provisions. Emergency-department fast-track areas were clarified to distinguish walled fast-track rooms from open-bay fast-track areas and to set minimum area and handwashing-station rules.
Other edits included alignment with Title 22 on rehabilitation services and outpatient-adjacent requirements; confirmation that procedure rooms are permitted (but optional) in surgical clinics when they meet the applicable 12.24 requirements; and a note that special treatment programs (STPs) must meet a 30-bed minimum per Title 22 interpretations (HCAI said it will adjust code wording in a future cycle to reflect that the 30-bed threshold applies to the STP rather than the entire skilled-nursing facility).
Presenters answered a subset of questions during the webinar and said that technical and project-specific questions would be downloaded and addressed offline; they said the slide handout will appear on the HCAI website in about one week and a recording and Q&A in about two weeks. Simrit (moderator) reiterated how attendees may obtain the materials and that the regs unit email displayed on the webinar will be available for follow-up.
Provenance: this article summarizes HCAI webinar remarks and guidance delivered by Mia Marbelli (Building Standards Unit supervisor) and Samantha Miller (senior architect) and draws from the webinar Q&A and CAN/guide references the presenters cited. The article does not infer approvals or legal effects beyond the references made on the webinar.
Why it matters: the updates clarify who may submit plans to HCAI, tighten submittal and compliance-reporting expectations, and provide new advisory guidance (including the A10 imaging-room guide and several design advisory guides) intended to reduce late-stage licensing delays and align Title 24 with other regulatory requirements such as NFPA 99, USP sterile-compounding rules, and CDPH (Title 22) licensing expectations.
Mia Marbelli, supervisor of the Building Standards Unit at HCAI, said the Administrative Code follows a different effective-date rule than other parts of Title 24 and that the Administrative Code took effect 03/29/2025 after commission approval and filing with the Secretary of State. Marbelli drew attention to Chapter 6 seismic-evaluation changes for hospital buildings and to a series of spring webinars produced by HCAIs seismic compliance unit that addressed new submission processes and a law (Assembly Bill 869) that allows an eligible rural or small hospital to request up to a three-year delay in compliance if certain criteria are met and HCAI concurrence is obtained.
HCAI described several procedural and jurisdictional clarifications. Chapter 7 was rewritten in places to itemize required submission documents; HCAI said it coordinated with the Board for Professional Engineers, Land Surveyors, and Geologists to allow fire-protection engineers to prepare and submit documents for projects that fall within their responsible charge. The agency also clarified that, when a firm rather than an individual prepares construction documents, the firm remains the responsible party if personnel change.
On changes to approved work and nonmaterial alterations (NMAs), Samantha Miller, senior architect in HCAIs Building Standards Unit, summarized revisions to CAN 7-153b that define material versus nonmaterial changes, describe the concurrence process for NMAs in the field, and add change forms, logs and an illustrated workflow. Miller said the CAN has been adjusted since April to ensure it aligns with the administrative-code amendments and to make clear that the CAN examples are illustrative, not an exhaustive list.
HCAI also announced administrative changes to reporting and compliance: final verified compliance reports and final test-and-inspection reports must be filed with the office (rather than preliminary or unverified reports) to support final approvals.
Part 2, Volume 1 changes include jurisdictional clarifications for chemical dependency recovery hospitals established under Assembly Bill 2096: where such services are delivered in a freestanding chemical-dependency recovery hospital (not part of an OSHPD/Jurisdiction 1 or 2 acute-care facility), the project is enforced by the local building department, HCAI said. Temporary structures remain subject to specific OSHPD guidance; the updated CAN says OSHPD/HCAI will permit only one extension for temporary structures when cause is demonstrated and the request is granted before final approval expires. The CAN also clarifies when temporary equipment may qualify as interim equipment tied to a construction schedule and revised construction documents (ACD).
Tents intended for patient care were addressed: HCAI explained that three jurisdictional approvals are typically required (local building and fire departments for placement, anchorage and access; the California Department of Public Health for the limited set of patient-care processes allowed in tents; and HCAI for project impacts to permanent structures and utility connections).
On imaging rooms, HCAI revised the definition of invasive procedure to better align with the Facility Guidelines Institute (FGI) explanatory notes and to replace vague terminology with a probabilistic risk threshold (for example, a greater-than-5% probability for certain classifications). HCAI introduced an A10 guide recommending use of a critical risk assessment (CRA) in the patient-safety portion of a projects functional program to assign imaging-room classes and to avoid late-stage licensing delays; the guide includes three class-specific checklists as appendices. Miller said HCAI contacted FGI about using the FGI CRA template but FGI declined, so project teams are encouraged to reference the 2026 FGI guidance when it becomes available.
HCAI also amended the medical-gas and outlet table (Table 12.24.406.1) to add an instrument-air column and new footnotes for central sterile processing areas, aligning locations for instrument air with the 2018 FGI medical-gas table and HCAIs adoption of NFPA 99 requirements. The agency issued its first nurse-call design advisory guide to clarify electrical placement, test procedures, temporary-system sequencing and repair parameters; presenters noted the earlier PIN 60 that informed the guide has since been rescinded.
Sterile-compounding and pharmaceutical-service provisions were consolidated and clarified: HCAI created a sterile-pharmacy compounding guide that compiles requirements across multiple California code titles, cleans up regulatory citations, adds mechanical-code requirements in checklists and graphics, and defines a hazardous-drug storage room consistent with United States Pharmacopeia (USP) requirements (negative pressure, external ventilation and 12 air changes per hour for certain compounding/storage areas). The guide also clarifies allowed pass-throughs and refrigerator pass-through restrictions for hazardous-drug areas.
Several patient-space clarifications were made across facility types: HCAI removed a vague suitable for hanging full-length garments requirement and now requires each patient space (including skilled nursing and psychiatric units) to include a separate wardrobe, locker or closet for each patients belongings; for anti-ligature psychiatric installations the code clarifies folded-shelf or garment arrangements instead of hanging fixtures. The agency clarified pediatric and adolescent patient areas must be separate from adult nursing units though common areas may be shared at different times, and added activity-space requirements for psychiatric nursing units that mirror related 12.28 provisions. Emergency-department fast-track areas were clarified to distinguish walled fast-track rooms from open-bay fast-track areas and to set minimum area and handwashing-station rules.
Other edits included alignment with Title 22 on rehabilitation services and outpatient-adjacent requirements; confirmation that procedure rooms are permitted (but optional) in surgical clinics when they meet the applicable 12.24 requirements; and a note that special treatment programs (STPs) must meet a 30-bed minimum per Title 22 interpretations (HCAI said it will adjust code wording in a future cycle to reflect that the 30-bed threshold applies to the STP rather than the entire skilled-nursing facility).
Presenters answered a subset of questions during the webinar and said that technical and project-specific questions would be downloaded and addressed offline; they said the slide handout will appear on the HCAI website in about one week and a recording and Q&A in about two weeks. Simrit (moderator) reiterated how attendees may obtain the materials and that the regs unit email displayed on the webinar will be available for follow-up.
Provenance: this article summarizes HCAI webinar remarks and guidance delivered by Mia Marbelli (Building Standards Unit supervisor) and Samantha Miller (senior architect) and draws from the webinar Q&A and CAN/guide references the presenters cited. The article does not infer approvals or legal effects beyond the references made on the webinar.
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