The HCAI plan review process, explained
If you design or build healthcare facilities in California, your drawings go through plan review by the Department of Health Care Access and Information — HCAI, the agency formerly known as OSHPD. This guide walks through how that review actually works, why timelines stretch, and what teams can do about it.
What HCAI is, and who must submit
HCAI enforces California’s building standards for hospitals and many other healthcare facilities. Construction and alteration projects at those facilities don’t go through the local building department the way ordinary projects do — the drawing set is submitted to HCAI, reviewed by its plan review staff for conformance with the California Building Standards Code (Title 24, including the healthcare-specific amendments) and applicable Title 22 requirements, and construction is then observed under HCAI’s inspection regime.
How a submission flows
- Submit through eSP. Projects are filed through HCAI’s electronic Services Portal, which runs on the Accela platform — drawings, documents, and the back-and-forth of review all live there.
- First review. Plan reviewers across disciplines (architectural, structural, mechanical, electrical, fire & life safety) examine the set. HCAI publishes turnaround goals — on the order of 80 days for a first structural review.
- Comments come back. Findings arrive as review comments — typically a return letter plus a comment spreadsheet organized by discipline, each comment citing the code section at issue.
- Respond and backcheck. The design team revises the drawings, answers each comment in a response-to-comments format, and resubmits. The backcheck review has its own published goal — on the order of 40 days.
- Repeat until approved. If the responses raise new issues or miss the mark, another cycle begins. Approval comes only when all disciplines clear.
Why timelines stretch
The published goals are per cycle, and cycles multiply. A set that draws heavy comments in first review can spend an extra backcheck round — or two — before approval, and each round is weeks of reviewer queue plus the design team’s own response time. On a hospital project, plan review isn’t one line in the schedule; it can be the critical path for months. Every avoided cycle is roughly 40+ days of calendar time back.
The underused resource: HCAI’s own standard comments
Here’s the detail many teams miss: HCAI publishes its reviewers’ standard comment libraries, organized by discipline and code year. These are, quite literally, the comments reviewers issue — which makes them a free, public QC checklist. A set internally reviewed against the standard comments for its disciplines and code edition walks into first review with the predictable findings already resolved.
If you disagree with a comment
Comment disputes have a formal path: HCAI’s electronic Comment and Process Review (eCPR) process, which escalates through several levels of the agency, with the Hospital Building Safety Board above that. In practice, most comments are better resolved by a clear, code-cited response in the normal backcheck round — escalation is for genuine disagreements, not routine friction.
Cutting comment counts before you submit
- QC against the standard comment libraries for every discipline in the set.
- Confirm the code edition that applies to your project before detailing — comments citing the wrong-year code are self-inflicted.
- Make the response-to-comments disciplined: answer the comment asked, cite the sheet and code section, and don’t introduce unreviewed changes silently — surprises found in backcheck start new cycles.
- Run a pre-submission review with fresh eyes — human, software, or both — against Title 24 and Title 22 as a reviewer would read them.
That last item is what ProjectOpsIQ Plan Check is being built to do: an automated pre-submission review that returns reviewer-style comments in the spreadsheet format HCAI uses, before the submission clock starts.