LIC 602A and Mental Health: Documenting Cognitive and Behavioral Needs
What LIC 602A Is and Why It Matters
LIC 602A — the Physician’s Report for Residential Care Facilities for the Elderly (RCFE) — is a required medical form used in California before someone moves into assisted living. It’s issued by the California Department of Social Services (CDSS) to confirm that a potential resident’s health and care needs fit within the non-medical scope of an RCFE.
The report includes information about physical health, mobility, cognition, medications, and behavioral needs. RCFE staff use it to create an individualized care plan and to determine whether the facility can safely meet the resident’s needs.
Under Title 22, §87458, every RCFE must keep a current medical assessment signed by a licensed healthcare provider within the past year. While CDSS doesn’t require this exact form, its structure covers all mandatory elements and is recognized statewide as the standard.
The main purpose of LIC 602A is to act as a gatekeeping tool — preventing facilities from admitting residents who need a higher level of skilled nursing care. Incomplete or inaccurate documentation of cognitive or behavioral issues can put residents at risk and expose facilities to regulatory penalties.
Key Sections of the LIC 602A Form
Physician’s Evaluation
The form must be completed by a licensed physician (MD or DO), nurse practitioner (NP), or physician assistant (PA). It includes a physical exam, current diagnoses, medications, tuberculosis screening results, and cognitive assessment.
Diagnoses and Medication
The clinician lists all relevant conditions — including mental health diagnoses — and must indicate whether the resident can self-manage medications. If not, the RCFE must provide trained staff under Health & Safety Code §1569.69 to assist safely.
Cognitive Conditions
This section identifies any cognitive impairment such as dementia or neurocognitive disorder and how it affects daily activities (ADLs). If a resident can no longer perform essential ADLs independently, the RCFE may not legally retain them.
Behavioral Expressions
The revised LIC 602A highlights specific behavioral indicators: disorientation, lack of impulse control, unsafe wandering, elopement, hallucinations, and others. These details help facilities assess risk and decide if they can provide a safe environment.
| Section of LIC 602A | Information Documented | Purpose |
|---|---|---|
| Physician’s Evaluation | Physical exam, tuberculosis test, mobility and cognitive check | Confirms medical stability for RCFE admission |
| Diagnoses & Medication | All active diagnoses, prescribed drugs, allergies, treatment plans | Defines medication support and care plan scope |
| Cognitive Conditions | Memory loss, dementia, or neurocognitive disorder | Determines supervision needs and care compatibility |
| Behavioral Expressions | Disorientation, impulse control issues, hallucinations, wandering | Assesses behavioral risks and safety requirements |
Admission and Retention Rules
RCFEs provide non-medical supervision and cannot legally house residents with uncontrolled psychiatric conditions or persistent aggressive behavior.
If the form notes hallucinations, severe confusion, or poor impulse control, admission is only allowed when there’s a clear treatment plan and trained staff in place. Otherwise, the facility must decline or later discharge the resident.
Optimistic or inaccurate assessments can lead to inappropriate placements and distressing transfers for vulnerable older adults when their conditions worsen.
Oversight, Documentation Accuracy, and Compliance
CDSS Inspections
During routine inspections, CDSS reviews each resident’s LIC 602A to confirm it’s complete, truthful, and updated. Any significant change in a resident’s condition requires a new assessment. Failing to update records may result in citations or license suspension.
Accuracy Concerns
Advocacy groups such as California Advocates for Nursing Home Reform (CANHR) warn that some clinicians underreport behavioral or mental health conditions to simplify admission. This practice can endanger residents and violate regulations.
Legislative Action: AB 1766
In 2021, Assembly Bill 1766 required CDSS to collect annual data on residents with Severe Mental Illness (SMI) in RCFEs and Adult Residential Facilities. This law reflects the ongoing need for better, standardized documentation — something LIC 602A alone hasn’t fully achieved.
Staff Training and Behavioral Care
Medication Assistance
If LIC 602A shows a resident needs help managing medications, RCFE staff must complete specific training:
24 hours (including 8 hours of practice) for large facilities;
4 hours minimum for small ones.
Dementia and Behavior Management
Training covers non-drug interventions, de-escalation strategies, and understanding how medications affect cognition. Staff learn to manage aggression, wandering, and other behaviors compassionately and safely.
PRN Medication Oversight
The form also lists “as needed” (PRN) medications. Frequent PRN use for behavior control without matching documentation in LIC 602A can trigger regulatory review and indicate gaps in care planning.
Conclusions and Policy Recommendations
The Role of LIC 602A
This form is the foundation of risk management and compliance in California’s assisted living system. It protects residents by ensuring their cognitive and behavioral needs match what non-medical facilities can legally provide.
Steps for Improvement
Strengthen communication between physicians and RCFE administrators.
Increase CDSS oversight of documentation accuracy.
Introduce a digital version of LIC 602A that must be updated with each health change.
Looking Ahead
Data collected under AB 1766 could help reform how RCFEs are funded — for example, through a tiered reimbursement model that reflects residents’ cognitive and behavioral complexity as documented in LIC 602A.
LIC 602A is more than a bureaucratic requirement. It’s a safety tool that determines whether older adults receive appropriate, respectful, and lawful care — and whether facilities uphold the standards that protect them.
Sources Used
California Department of Social Services (CDSS) — LIC 602A: Physician’s Report for Residential Care Facilities for the Elderly (RCFE)
California Code of Regulations (Title 22, Division 6, Chapter 8) — Residential Care Facilities for the Elderly, §§87455–87458 (Admission, Retention, and Medical Assessment Requirements)
California Health and Safety Code §1569.69 — Medication Assistance and Staff Training Requirements for RCFE Personnel
California Department of Social Services – Community Care Licensing Division (CCLD) — Evaluator Manual: Residential Care Facilities for the Elderly
California Advocates for Nursing Home Reform (CANHR) — Reports on Documentation Accuracy and Oversight in Assisted Living Facilities
California Legislative Information — Assembly Bill No. 1766 (Bloom, 2021): Data Collection on Residents with Severe Mental Illness in RCFEs and ARFs
Centers for Disease Control and Prevention (CDC) — Guidelines for Tuberculosis Screening in Long-Term Care Facilities
