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How Long Does it Take CCL to Issue an RCFE License?
Pursuant to Health and Safety Code, Section 1569.10, any individual or legal entity providing or intending to provide care and supervision to the elderly in a residential facility shall obtain a current valid license. Residential Care Facilities for the Elderly (RCFEs), more commonly referred to as assisted living facilities, are licensed by the Department of Social Services, Community Care Licensing Division (CCL). Prior to accepting residents, facilities must secure a license by completing a 3-component application process, plus other requirements detailed here. According to CCL’s website, facilities can expect the entire application process to be completed within 90 to 120 days.
The final component of the licensing process is a pre-licensing inspection conducted by CCL’s Regional Office responsible for facilities in the area. The pre-licensing visit is scheduled prior to licensure and is performed to ensure the facility meets licensing requirements. CARR has consistently been receiving complaints from both potential licensees, as well as current licensees seeking to expand their operations, regarding the length of time it takes CCL to issue a license.
Facilities cannot begin the application process without a physical location for CCL to inspect, nor can facilities accept residents into an unlicensed facility. Maintaining an unoccupied (non-revenue generating) facility for any length of time is quite costly, especially in Southern California. The timeliness of licensure is, therefore, critical to the financial viability of a facility. Due to the increased number of requests for assistance, CARR decided to look into the matter.
The goal of the following analysis was to review how long, on average, it takes for facilities to receive a license from CCL. The brief analysis reviewed licensing data on facilities located in Region 8 –San Diego and Imperial Counties – between 01/01/11 and 12/31/16.
Data and Methods
Using CCL’s data download dated 3/1/17 and documents from a follow-up CPRA request dated 3/14/17, CCL’s licensing patterns were reviewed. CARR analyst, removed from the download, all facilities classified as closed, on probation, or pending. The total number of days between a facility’s first pre-licensing date and its licensing date were recorded. The number of days between the pre-licensing visit and date of licensure were used to determine the length of the licensing process. Facilities were also stratified by bed capacity (1-6 beds, 7-15, 16-49, 50-99, 100+) to examine any variation between the licensing of small versus large facilities.
From 01/01/11 to 12/31/16, CCL licensed 213 facilities in Region 8. A third (75%) of the licenses issued went to facilities serving 6 or less residents (Table 1) with the longest average wait time for the 100+ and 16-49 bed categories (Table 2).
The data shows the overall average number of days for a facility to receive their license after their pre-licensing visit was 113 days (around 3.5 months). While a majority of facilities received their license within 120 days of their pre-licensing visit (132 facilities), almost 40% (81 facilities) received their license after the 120 days. Of those facilities receiving their license after 210 days (or 7 months) following their licensing visit, 80% were small 6-bed facilities.
Table 1: Facilities Receiving Licenses from 2011-2016 (N=213)
Table 2: Average Number of Days from Pre-licensing Visit to Licensure Date
A number of variables can affect the timeline for the application process. Some are within CCL’s control, some within the facilities and others are simply uncontrollable. When a pre-licensing visit is scheduled, however, facilities typically have secured all necessary clearances and completed all the required paperwork. With the exception of unforeseen areas of non-compliance that would trigger another pre-licensing visit, it is not unreasonable for facilities to expect a timely turnaround from visit to licensure.
Based on these findings for Region 8, CCL is reaching its goal of 90-120 days approximately 60% of the time, only if their measure of 120 days is strictly based on the time between a pre-licensing visit and the official date of licensure. This analysis was not able to factor in the time lapse for the early stages of the applications process (i.e. completing Components I, II and III which in itself is lengthy—requiring a formal orientation, personal interview, in-office session for additional review of Title 22 regulations, plus coordination with the Fire Marshall and other institutions for permits and clearances).
It is not CARR’s position to promote an expedited application process that dilutes the vetting process, nor do we have enough of a window into CCL’s operations to understand (1) if this lag is systemic throughout the state or (2) what is causing the backlog for some applications.
What we do offer facilities who contact us is the following proven solution: Facilities who contact their local state representatives, explaining to them the financial hardship associated with a delay in licensure, have repeatedly seen their application moved to the front of the line and issued within days. You can find the contact information for your local representative(s) here.
As of 2015, CCL implemented a Central Applications Unit (CAU) in Sacramento to “effectively gain consistency and standardization in the Adult and Senior Care facility applications in a timely and efficient manner”. CARR is currently reviewing CCL licensing data from 2015-2017 to determine how the CAU is improving timeliness.