Last Updated: 09/20/2022

HCSMP Consistency Determination Process

The Health Care Services Master Plan (HCSMP) requires that certain new medical use development projects in San Francisco apply for a Consistency Determination from the Health Commission and Planning Commission, verifying that the proposed medical use supports the HCSMP Recommendations & Guidelines.

The Planning Department, in conjunction with SFDPH, must determine whether certain Medical Use projects, as defined by the Planning Code, align with the Health Care Services Master Plan (HCSMP) by making a "Consistency Determination."

Projects subject to HCSMP Requirements

Projects that include Hospitals / Medical Centers (Planning Code Sections §102, §790.44, §890.44) or Health Service / Medical Service (§102, §790.114, §890.114) uses are subject to the HCSMP and are required to obtain a Consistency Determination if they meet the following size thresholds:

  • A change of use to a Medical Use that occupies 10,000 gross square feet or greater –or–
  • An expansion of an existing Medical Use by 5,000 gross square feet or greater.

Consistency Determination Review Process


The process is explained below and illustrated in the following graphic.

  1. Applicants must complete and submit a HCSMP Consistency Determination Application as part of any applicable entitlement or building permit application.
  2. The Planning Department will conduct an initial review of the Consistency Determination Application to ensure that the project scope triggers the need for a Consistency Determination per San Francisco Ordinance No. 300-10. If Planning confirms that the project is subject to a Consistency Determination, Planning will then forward the Consistency Determination Application to DPH for their review.
  3. DPH staff will review the Application and accompanying justification to determine whether the project is consistent with HCSMP Recommendations and Guidelines. Based on its review, DPH staff will present the recommendation to the Health Commission (either as an informational item, or as an item for discussion). DPH will then recommend that the project be assigned one of three possible HCSMP Consistency Determination outcomes: Consistent, Consistent and Recommended for Incentives, or Inconsistent.
  4. DPH staff will forward their final recommendation regarding a project's Consistency with the HCSMP back to the Planning Department.
  5. Planning will post the final determination on its website for a 15-day public comment period.

Consistency determination flow chart.

Consistency Determination Outcomes

Consistent Applications: Applications found to be Consistent with the HCSMP will be issued a Consistency Determination by the Planning Department, which will be posted on the Planning Department's website for 15 days. If the Planning Department receives no "substantive arguments", as determined by the Planning Director, the Consistency Determination will become final. If, however, the Planning Department receives substantive written objections, the application will be processed as an inconsistent application.

Consistent and Recommended for Incentives: Applications that DPH staff recommends as "Consistent and Recommended for Incentives" will be forwarded to the Health Commission for review at a public hearing. If the Health Commission concurs with the DPH staff recommendation, the application will undergo a similar review process as described for Consistent Applications, above. However, in addition, these applications will be reviewed on a case-by-case basis by Planning and DPH to determine appropriate project incentives, based on the project's health care benefits to the City's vulnerable populations. Projects that are seeking incentives should also consult the Department's Planning Director Bulletin No.2.

Inconsistent Applications: Applications that DPH staff recommends as "inconsistent" will be forwarded to the Health Commission for review at a public hearing. If the Health Commission disagrees with DPH staff and finds the application to be consistent with the HCSMP, it will issue findings to this effect. If the Health Commission agrees with DPH staff and finds the application to be inconsistent, it will make recommendations to achieve consistency. The Health Commission must submit its findings or recommendations to the Planning Commission within 30 days of receipt of the application.

The Planning Commission must hold a public hearing within 30 days of receiving the findings from the Health Commission (or at the same time as it considers other entitlements associated with the application) and make a determination as to whether or not to issue a Consistency Determination. The Planning Department may not approve any permit or entitlements for a Medical Use project that does not have a Consistency Determination unless the Planning Commission identifies countervailing public policy considerations that justify such approval.


Any person may file an appeal within 30 days of the issuance or denial of a Consistency Determination. If the Board of Supervisors has appeal authority to review the associated entitlement(s), the appeal should be made to the Board of Supervisors. In all other cases, the appeal should be filed with the San Francisco Board of Appeals. The Board of Supervisors and the Board of Appeals have the authority to reverse the Planning Department's or Planning Commission's determination.

Consistency Determination Letters