What Is the Plan of Operation?
The Plan of Operation is a required narrative document that every RCFE license applicant must submit to CDSS. It describes how the facility will operate on a daily basis. Without it, CDSS will not process a license application.
The requirement comes from CCR Title 22, §87206, which states that applicants must submit "a written plan of operation for the residential care facility." Unlike the Section A forms, which are standardized, the Plan of Operation is a narrative you write specific to your facility.
What Must the Plan of Operation Cover?
While CDSS does not prescribe an exact format, inspectors expect the Plan to address all of the following areas:
Organizational Structure
Who owns the facility, who the administrator is, how many staff members will be employed, and the chain of supervision. An organizational chart is typically included as an exhibit.
Resident Population
The types of residents the facility plans to serve: ambulatory vs. non-ambulatory, memory care, bedridden, or other special populations. This section also covers admission criteria and what conditions or care needs exceed the facility's scope.
Staffing Plan
Minimum staffing ratios, administrator hours and on-call procedures, and how staffing will be maintained during evenings, weekends, and holidays. CDSS inspectors pay close attention to whether the staffing plan is realistic for the number of residents described.
Activities and Programming
A summary of the activity programming the facility will provide, including any specialized programming for residents with cognitive impairment. CDSS requires RCFEs to offer activities that promote resident engagement and wellbeing.
Medication Management
A brief description of how medications will be handled, stored, and documented. This section references your more detailed medication management policy but must be addressed in the Plan of Operation itself.
Emergency and Disaster Procedures
A summary of how the facility will respond to emergencies including fire, natural disaster, and medical emergencies. The Plan typically references your full Emergency Disaster Plan as an exhibit.
Transportation
Whether the facility will provide transportation, what vehicles will be used, driver qualifications, and how off-site activities are supervised.
Common Mistakes That Cause Rejection
CDSS processing data suggests that 40-60% of first-time RCFE applications receive a Request for Additional Information (RAI). The Plan of Operation is the most commonly cited document requiring revision.
- Too vague: Phrases like "we will follow all CDSS regulations" are not a plan. CDSS wants specific procedures, not statements of intent.
- Inconsistent with Section A: If your Plan says you'll have 4 full-time caregivers but your Section A organizational chart shows 2, CDSS will flag the discrepancy.
- Missing special populations: If you plan to serve residents with dementia but don't address it in your Plan, CDSS will request a revision.
- No staffing model: A staffing plan that doesn't address nights, weekends, and administrator on-call requirements is incomplete.
How to Write a Plan of Operation That Gets Approved
The most effective Plans of Operation are specific, internally consistent, and use the regulatory language CDSS inspectors are familiar with. Key tips:
- Cross-reference every claim in the Plan with your Section A forms. Staff counts, capacity, and administrator information must match exactly.
- Use the exact language from CCR Title 22 when describing required procedures (e.g., "residents will receive an individualized needs and services plan per CCR §87463").
- Address your actual planned population specifically, including any special care designations you intend to apply for.
- Have a second person review the Plan against CDSS's published guidance before submission.
Regnexify’s RCFE Plan of Operation ($369) is written in the format CDSS expects, with all required sections pre-built for your customization.
Does the Plan of Operation Expire?
The Plan of Operation submitted for initial licensing does not have a formal expiration date, but CDSS may request an updated Plan when you:
- Change your administrator
- Modify your licensed capacity
- Add a special care designation (e.g., dementia)
- Respond to deficiencies cited during an inspection
Best practice is to review and update your Plan of Operation at least annually, even if CDSS does not specifically request it.