"Red Light" at Admission: How Form LIC 602A Blocks Moves to Assisted Living and What to Do About It
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Moving an elderly person into a long-term care facility in California is not only a difficult emotional step but also a collision with strict bureaucracy. Often, families find the perfect place, but at the last minute receive a rejection due to a single checkmark on a document.
This document is Form LIC 602A (Physician's Report).
In California, laws strictly divide care into "medical" and "social." Institutions like Assisted Living (RCFE) hold a social license: they help with dressing and walking but do not have the right to treat complex diseases. Because of this, certain health conditions automatically trigger a "red light" for admission.
In this article, we will explain in simple terms which diagnoses are prohibited, why a doctor might accidentally block a move, and how to legally bypass these restrictions.
Why You Might Be Refused: The Difference Between RCFE and SNF
To understand the essence of the problem, you need to know how the system divides facilities. In California, there are two main types of care homes:
SNF (Skilled Nursing Facility): These are full-fledged medical institutions ("Nursing Homes"). Licensed nurses are on duty 24/7, capable of administering IVs and treating open wounds.
RCFE (Residential Care Facility for the Elderly): These are "care and supervision" facilities (Assisted Living). The staff here helps with daily life but often does not have medical training.
The Main Rule: Since there is no constant medical supervision in an RCFE, the law (Title 22) prohibits them from accepting people with conditions requiring complex medical intervention.
Anatomy of the Problem: Form LIC 602A
Form LIC 602A is the report the treating physician fills out before discharge. It is on the basis of this report that the director of the care facility makes a decision. Errors here are fatal.
Main Traps in Form LIC 602A
| Section of Form | What is the Danger (Red Flag) | How to Avoid Rejection |
| Tuberculosis (TB) | The doctor writes “Test not done” or “Positive in the past” but does not attach an X-ray description. | Ensure it is written: “Test negative” or “Chest X-ray clear.” |
| Mobility | The doctor checks “Bedridden,” but the facility does not have a license for bedridden residents. | Check the facility’s license. If the patient can transfer themselves, they are not bedridden. |
| Mental | Risk of “Wandering” (elopement/running away) is noted. | Such a patient will only be accepted by a secured unit (Memory Care). Ordinary Assisted Living will refuse. |
| Eating | Checkmark on “Dependent”. | If the patient can hold a spoon themselves, ask to mark “Assistance Needed,” not Dependence. |
The "Red List": Prohibited Conditions
Below are the conditions with which, by law (Section 87615), one cannot enter a standard Assisted Living facility.
1. Stage 3 and 4 Pressure Injuries (Bedsores)
These are deep wounds where damage is not just to the skin but tissues or bones are visible.
Why it's not allowed: They require sterile dressings. RCFE staff do not know how to do this.
Important: Stage 1 and 2 pressure injuries (surface) are allowable if a nurse visits the patient.
2. Feeding Tubes (Gastrostomy and Probes)
Nasogastric Tube (through the nose): Absolute ban. It displaces easily, and food can get into the lungs.
Gastrostomy (through the stomach): Prohibited, but there are exceptions.
3. Tracheostomy
An artificial opening in the throat for breathing.
Why it's not allowed: If the tube gets clogged with mucus, staff have only minutes to clear it. Without skills, this is deadly dangerous.
4. Active Infections (e.g., Staph/MRSA)
If the infection is active — refusal. If the person is simply a carrier — admission is possible.
5. Total Care (Dependence) — The Most Common Mistake!
The law prohibits accepting those who depend on help for ALL basic activities: bathing, dressing, toileting, transferring, and eating.
How to Turn on the "Green Light": Hospice
There is a legal way to bypass almost all prohibitions of the "Red List." This is the Hospice Waiver. If the doctor admits the patient has a terminal stage, and the family connects Hospice, the rules change.
What Changes with Hospice Connection
| Health Condition | Standard Admission (Without Hospice) | Admission with Hospice (Hospice Waiver) |
| Pressure Injury Stage 1–2 | ✅ Allowed (with nurse) | ✅ Allowed |
| Pressure Injury Stage 3–4 | ⛔ Prohibited (Refusal) | ✅ Allowed |
| Gastrostomy (G-Tube) | ⛔ Prohibited (hard to get exception) | ✅ Allowed |
| Nasogastric Tube | ⛔ Prohibited | ✅ Allowed |
| Tracheostomy | ⛔ Prohibited | ⚠️ Allowed (rarely, depends on facility) |
| Total Dependence (Total Care) | ⛔ Prohibited | ✅ Allowed |
Condition: The facility itself must have permission to work with hospice, and the hospice service must be connected before or on the day of the move.
Exceptions for Those Not in Hospice
What to do if a person has a gastrostomy but is not dying and does not qualify for hospice?
You can try to obtain a special Exception. The facility writes a letter to the regulator and proves it can ensure safety (for example, hires a private nurse).
Reality: This is a long process. For deep pressure injuries, exceptions are almost never granted. For stable gastrostomies — there are chances.
Action Plan for the Family
To avoid receiving a refusal at the last moment, follow this algorithm:
Audit: Do not send the form blindly. Ask the doctor to show you the document before sending it.
Skin Check: If a bedsore has healed, ensure the doctor wrote "Healed" or "Currently Stage 2."
Skills Check: If the patient can eat themselves, insist the doctor marks "Assistance Needed," not "Dependent."
Strategy: If the condition is severe (bedsores, tubes), immediately discuss the possibility of hospice in the hospital. This is your "golden key" to placement.
Conclusion
Medical necessity often crashes against legal wording. The "Red Light" is not the spite of administrators, but a way to protect the facility's license. However, knowing the rules of the game and using the tables from this article to check documents, you can ensure comfortable care for your loved one.
References
California Department of Social Services (CDSS) – Form LIC 602A: Physician's Report for Residential Care Facilities for the Elderly.
California Code of Regulations (CCR), Title 22 – Section 87615: Prohibited Health Conditions.
California Code of Regulations (CCR), Title 22 – Section 87612: Restricted Health Conditions.
California Code of Regulations (CCR), Title 22 – Section 87633: Hospice Care for Terminally Ill Residents.
California Code of Regulations (CCR), Title 22 – Section 87616: Exceptions for Health Conditions.
California Code of Regulations (CCR), Title 22 – Section 87459: Functional Capabilities.
California Code of Regulations (CCR), Title 22 – Section 87609: Allowable Health Conditions.
Community Care Licensing Division (CCLD) – RCFE Evaluator Manual: Regulation Interpretations and Procedures.
