Published October 2026
Most medical offices and clinics in California are permitted by the city or county building department, not the state. The state agency, HCAI (the Department of Health Care Access and Information, formerly OSHPD), reviews hospitals, skilled nursing facilities and a short list of clinics that choose it.
The short version
- A doctor’s office that is not licensed by the California Department of Public Health is usually a Group B business occupancy. It follows the regular building code, and OSHPD 3 does not apply.
- Clinics licensed under Health and Safety Code Section 1200, and hospital outpatient clinics under Section 1250, are OSHPD 3. They follow CBC Section 1226.
- OSHPD 3 clinics are still reviewed and inspected by the local building department.
- HCAI reviews OSHPD 1 general acute care hospitals, OSHPD 2 skilled nursing and OSHPD 5 acute psychiatric hospitals. State law preempts local review for these.
What counts as OSHPD 3
OSHPD 3 is about licensing, not the word “clinic” on the door. It covers clinics licensed by CDPH, including:
- Primary care clinics
- Specialty clinics, such as surgical and chronic dialysis clinics
- Hospital outpatient clinical services
- Alternative birthing, rehabilitation and psychology clinics
A medical office building leased to physicians who are not licensed as a clinic is not OSHPD 3. That is why the tenant mix decides the design.
When the state reviews a clinic
HCAI can review some clinics in three cases:
- The local building department declines to certify OSHPD 3 compliance, and HCAI does an OSHPD 3-only review.
- The clinic asks HCAI to review it, either for all of Title 24 or for OSHPD 3 only.
- A hospital places a freestanding outpatient building fully under HCAI.
These options apply to specialty clinics and hospital outpatient buildings. Primary care, alternative birthing and rehabilitation clinics cannot choose HCAI review.
What to watch out for
- Licensing after the fact. A suite built as an ordinary office may need upgrades if a tenant later licenses it as a surgical or dialysis clinic.
- Hospital-owned space. If a hospital system is the tenant, ask early whether the building will be outpatient space under Section 1250 or under HCAI.
- Different reviewers, different schedules. Local plan check and HCAI review run on separate tracks. Plan the permit path before schematic design.
How we use it
On the Arcadia Medical Office Building, three stories of clinic suites, the first question is which tenants will be licensed and which will not. That sets the code path for each suite. At the other end of the scale, our Foothill Community Hospital concept in El Monte is the kind of building that goes to HCAI. See our healthcare work.
Three stories of clinic suites in Arcadia.
Have a lot in mind?
Send us the address and we’ll tell you what it can hold. Book a free consultation → · Follow @ydsarch on Instagram
