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Act Now! Avoid survey citations on new California requirements for alternate power.

Most California communities are not compliant with new alternate power regulations and may be at increased risk of survey citations.

In an effort to aid sheltering in place and reduce unnecessary loss of life, California has enacted new regulations (see Pin 74) increasing load requirement and coverage for alternate sources of power in the instance of power loss.

California Health and Safety Code 1418.22 requires Skilled Nursing Facilities (SNFs) to provide alternate sources of power to systems which support resident health and safety. If you do not have a letter of compliance from HCAI you will be non-compliant. In order to ensure you aren’t cited, your community’s alternate sources of power must now support the following incremental loads:

  • Heating and cooling systems to maintain safe temperatures
  • Life-saving equipment
  • Oxygen-generating devices

Additionally, SNFs are now required to have sufficient fuel onsite to maintain power for no less than 96 hours of continuous operation. Previous requirements to maintain emergency loads was 6 hours.

According to the Advisory Guide provided by the Department of Health Care Access and Information (HCAI), the majority of California skilled nursing facilities are unlikely to achieve compliance without a construction project. As noted, many facilities have alternate sources of power, but do not generally back-up heating and cooling SNF Alternate Sources of Power Assessment equipment. Additionally only subacute SNFs historically backed up life-saving equipment and oxygen-generating devices. Finally, while system design may specify onsite storage sufficient for more than 6 hours operation, it is likely very few facilities have intentionally provided more than the code minimum.

Therefore HCAI has developed a 2-step process:
  1. SNF Alternate Sources of Power Assessment
    Facilities should identify HVAC, life-saving equipment and oxygen-generating devices, as well as the method to ensure 96 hours of continuous operation, and complete the online SNF Backup Power Assessment. The assessment helps HCAI to determine whether the facility is already compliant with the new requirements. Facilities that believe they are compliant must include the following attachments:

    1. Floor plan showing location of all systems and area of coverage
    2. Documentation substantiating compliance for each system listed required by HSC §1418.22. This documentation must also address how existing systems provide coverage for the 96 hour minimum.
    3. Local approvals as required

    Facilities that suspect they are not compliant may include a proposed remediation as an attachment to their Assessment.

  1. HCAI Determination
    Process for Compliant Determination: If HCAI determines the facility is compliant, they will engage California Department of Public Health (CDPH) to concur with the determination and the assessment will be closed with compliance. Process for Non-compliant Determination: If HCAI determines the facility is not compliant, the assessment will be closed without compliance. A standard construction project to modify the existing electrical distribution system and bring the facility into compliance will be needed. After the construction project is closed a new assessment will be required. This process continues until HCAI closes the assessment with compliance.
Don’t delay. The deadline to be in compliance has already passed. Act fast to avoid survey citations. Not sure where to begin? Let our team at TELS® Building Services help you through the process. Reach out for technical expertise on alternative power source options, project management support from qualification to modification or installation or regulatory guidance on the SNF Alternate Sources of Power Assessment. Act now as equipment lead time and municipal approvals may be delayed.

Call 888-433-3224 or fill out the request form below to begin.

How do I work with Direct Supply on this?

Our process makes it easy for you:

Coordinate required documents

Prepare a facility plan and/or proposed remediation

If required, begin engineering

Receive all necessary approvals and permits

Procure equipment & complete construction

Successful Projects Start with TELS

Every day, communities just like yours turn to TELS® Building Services for large projects. With more than 7,500 projects completed annually across the country, there’s nothing our team can’t handle. Whenever you contract with TELS, you get access to industry-leading brands at competitive pricing on a wide range of equipment, including HVAC, plumbing and kitchen. Engineering to installation, let us handle the details. All of them.

  • Proposed Remediation
  • Qualification
  • Engineering
  • Procurement
  • Project Construction
  • And Much More


HCAI – Department of Health Care Access & Information


April 24, 2024
March 26th, 2024
November 9th, 2023
June 27th, 2023

Start Today! Consult with the experts at TELS on corrective action to work toward compliance.

The materials, comments and other information offered here are intended to provide general information and may not apply to all facilities. You are responsible for determining regulatory compliance for your particular facility. More information is available here: Pin 74 and Advisory Guide.

All products and services are subject to Direct Supply’s standard terms and conditions found at This material is intended only for business purchasers; resale of these products to consumers is expressly prohibited. Other limits may apply and are subject to change. © 2023 Direct Supply, Inc. All rights reserved.