PreschoolAttorneyHOWARD WU · ATTORNEY & PRESCHOOL OWNER
← Back to the resource library

Articles · HOWARD WU

Center Application Timing

On this page

DSS’s Centralized Application Bureau

In the past, each CCLD Regional Office handled all center applications (new center, change of component, change of capacity, etc.) within their geographic jurisdiction. Several years ago, however, DSS created a Centralized Application Bureau (CAB), which ostensibly was meant to streamline the application process, insofar as Licensing Program Analysts (LPAs) assigned to CAB would specialize in application processing, thus providing efficiencies.

For a time, I believe some applications were being sent to CAB while others were handled at the Regional Office, as a transition period. My current understanding is that all applications are being sent to CAB, though CAB remains understaffed, and so some applications get sent back to the Regional Office for handling.

Health and Safety Code timing requirements

Health and Safety Code section 1597.13 states, “The department and any local agency with which it contracts for the licensing of day care centers shall grant or deny an application for license within 30 days after receipt of all appropriate licensing application materials, as determined by the department, after a site visit has been completed and the facility has been found to be in compliance with licensing standards. The department shall conduct an initial site visit within 30 days after the receipt of all appropriate licensing application materials.”

This appears to clearly provide that upon submission of a complete application, the pre-licensing site visit must occur within 30 days, and then the licensing decision must occur within 30 days after that.

Section 1597.14 provides for a process for centers to be sold with no interruption to services, and if the steps are followed, the new operator should be able to take over operations within about 30 days, utilizing an Emergency Authorization to Operate.

Section 1596.96 also states that, if the applicant already has a licensed for another facility, their application must be decided within 60 days after a “complete application” is submitted, and if it cannot be decided within that time, a provisional license is to be issued.

Practical timing

However, in speaking with licensees and applicants, and looking at the data, it appears DSS is not even close to meeting the timing requirements.

Looking at the public DSS childcare center database (updated at least monthly), as of September 13, 2026, 495 facilities statewide had some kind of pending center application. I happen to have a copy of the database from May 24, 2026, and running an AI-powered comparison of both documents, it appears:

  • 270 center applications that were “pending” in May 2026 are still pending (thus, over 50% of the applications pending in May are still pending four months later).
  • 192 center applications “pending” in May 2026 are marked as “LICENSED” in September (~37%).
  • 50 facilities with a “pending” application in May are now marked “CLOSED”.
  • 224 facilities submitted an application after the May 24 database was generated, and their applications are still pending.
  • 43 facilities marked “LICENSED” in September do not appear in the May database, suggesting these 43 submitted an application and got that application approved between May 24 and September 13 (though I cannot ascertain how many of these applications were for genuinely new center licenses, or whether some were limited-scope applications by existing licensed facilities just seeking a change of ages served or licensed capacity, etc.).

Unfortunately I don’t have a copy of the database prior to May 2026, so I cannot determine how long any applications were already pending in May. Personally, however, I have had a couple dozen applicants or licensees reach out for legal advice because their license applications have been pending for 9-18 months.

The “Notice of Incomplete Application”

DSS’s delays are likely a violation of law, at least in certain cases, where complete applications have been submitted. And that requirement in the Health and Safety Code—that CCLD’s deadlines are triggered by a “complete application” or “all appropriate licensing materials” is how CCLD seems to get around the deadlines.

CCLD utilizes its LIC184D “Notice of Incomplete Application” form for essentially all requests regarding an application. The form is appropriately utilized if the application is missing a specific form or document, but CCLD will utilize the “Other” field in the form to request even minor changes to submitted documents. In this way, I believe CCLD is able to deem the application “not complete,” and so avoid any of the deadlines set forth in the Health and Safety Code.

More articles →