Compliance for Senior Care Facilities.
Assisted living, memory care and skilled nursing are covered, and this sits alongside health licensing rather than inside it. Most of the work is documenting systems your team already maintains.
July 1, 2027
Your compliance deadline, then re-reporting every five years.
Coverage
Is Your Facility Covered?
You’re covered if the building is more than 20,000 gross square feet. Resident rooms, dining, therapy, administration and back-of-house all count toward that figure. Above 50,000 square feet the building moves into a larger-buildings program that adds a performance target you have to meet, so the threshold is worth measuring precisely rather than estimating.
Continuum-of-care campuses are assessed on metering and ownership rather than care level: buildings sharing meters on adjoining property under single ownership can comply as a group, filing one plan and one maintenance program between them. Communities offering only independent living are generally treated as multi-family residential instead.
This Applies To
Operators, Owners and Facilities Directors.
Assisted living, memory care, skilled nursing and continuum-of-care communities in Washington, and the management companies that run them.
Requirements
Three Things to Compliance.
There is no performance target to hit. You calculate an energy use intensity target, report your actual performance against it, and that’s the whole obligation — no performance standard for these buildings takes effect before the end of the 2031 legislative session. Nothing here requires you to change how you care for residents.
Benchmark
Twelve consecutive months of whole-building energy use in ENERGY STAR Portfolio Manager, producing your weather-normalized energy use intensity.
Energy Management Plan
Energy performance goals, your EUI target, annual comparison against it, and how you inform residents about efficient energy use.
O&M Program
An inventory of major systems, maintenance tasks, frequencies and who is responsible for them, per ASHRAE Standard 100-2018.
The binding constraint is twelve consecutive months of whole-building energy data, measured within two years of submission — there is no way to manufacture that history retroactively. Your O&M program, by contrast, only has to be implemented by your compliance date; you do not need to run it for a year first. Round-the-clock operation is an advantage here: a full year of real operating data is already being generated.
The Stakes
What Non-compliance Costs.
The maximum administrative penalty is $0.30 per square foot of gross floor area, assessed every compliance period — every five years. Paying it doesn’t discharge the obligation; it buys five years and the same bill again.
Miss the deadline and you’ll receive a notice with at least 30 days to cure. Respond within that window with documentation demonstrating compliance and fines are waived — and you may remain eligible to apply for the early adopter incentive, which pays $0.30 per square foot for doing the same work ahead of time. Respond without it, or elect to pay rather than comply, and you’re assessed the maximum and may lose that eligibility entirely.
The O&M Program
Systems You Already Maintain.
The maintenance program is where care facilities have the most existing material and the most to translate. Nothing below asks you to run equipment differently — it asks you to write down what you run, how often, and who owns it.
Backup power
On-site power generation is named in the standard’s scope, so generators belong in the inventory alongside HVAC — not treated as life-safety equipment sitting outside the energy program.
Redundant HVAC
Redundant and medical-grade systems are inventoried like any other equipment. What the program wants is the maintenance schedule you already run, written down with frequencies and owners.
Control settings
Set points, schedules and sequences of operation are explicitly inspected and maintained, and building management system data can serve as the evidence.
Ageing equipment
The documentation package has to identify systems or components operating beyond their useful life — a capital-planning conversation most facilities are already having.
Emergency information
The document directory must keep emergency information immediately available, including staff and agency notification procedures. Care facilities generally have this already; it just has to live with the program.
Repeat findings
If two consecutive inspections turn up the same unacceptable condition, the owner has to investigate and analyze the cause rather than log it again.
Existing logs
Commerce is explicit that existing operations and maintenance procedures can be reviewed and updated to meet the standard rather than written from scratch, and publishes a tool for building the inventory and task lists.
Common Questions
Frequently Asked Questions.
No. The Clean Buildings Performance Standard is a separate obligation with its own statute, its own deadline and its own portal. Licensing inspections and facility surveys don’t satisfy it, and compliance here doesn’t affect them. It is additive paperwork rather than overlapping paperwork.
Usually as a senior care community or residential care facility — and helpfully, those carry the same energy target whether the standard files them under healthcare or under lodging and residential, so the classification argument matters less than it looks. Communities offering only independent living are generally treated as multi-family residential instead, which carries a different target and no upper size limit — see multi-family buildings.
It depends on metering and ownership rather than care level. Buildings sharing energy meters on adjoining property under single ownership are “connected buildings,” and buildings interconnected by conditioned space form a “complex” — either can comply as a group, filing one Energy Management Plan and one O&M program on Form J instead of Form A. A group works to the earliest compliance date among its buildings, and Commerce needs at least 180 days’ notice. Where care levels sit in one building under one meter, it is a mixed-use target calculation rather than separate filings.
No, and this is the one place round-the-clock operation works in your favor administratively. Most building types have their target scaled up or down by weekly operating hours; senior care carries a flat factor across every hours band, so there is no shift calculation to argue about. There is also an allowance specific to health care: you may use different weekly hours if systems have to run longer to protect patient and staff safety, provided you document the reason in your Energy Management Plan.
Senior care communities and residential care facilities carry a site energy target of 78 kBtu/ft²/yr in western Washington and 82 in the east. If your building or an addition was permitted on or after July 1, 2016, that drops by 15 percent for the qualifying floor area. You report against the number — you are not required to reach it.
Yes. The program covers the building envelope and every system that directly or indirectly consumes energy — envelope, domestic hot water, HVAC, refrigeration, lighting, controls, electric power distribution and on-site power generation. Generators fall squarely inside that last category. Maintenance is established per the manufacturers’ requirements, which is likely what you already follow.
Much of it will. The standard wants an inventory of components, a preventive maintenance schedule and task list for each, defined indicators of unacceptable performance, named responsibilities, and records demonstrating the plan is running. Commerce says outright that existing procedures can be reviewed and updated to meet this rather than rewritten. The tracking method is up to you — a CMMS, a work-order system, a spreadsheet or a paper binder all qualify, as long as results are retained.
Possibly not. Above 50,000 sq ft of institutional and other nonresidential floor area, a building moves into a larger-buildings program with an energy performance target you have to meet — a different pathway from the one this page describes, and a more demanding one. The threshold is worth confirming precisely rather than estimating. Contact us and we’ll point you in the right direction.
Setting your building up in ENERGY STAR Portfolio Manager and feeding it twelve consecutive months of whole-building energy data. Portfolio Manager calculates your weather-normalized energy use intensity — total energy divided by gross floor area, in kBtu per square foot per year. You then share the property with Commerce read-only, and the Clean Buildings Portal pulls the numbers through as Form C. Commerce recommends registering under a generic organizational account so the login survives staff turnover.
It’s a living document the owner reviews and signs every year. It names an energy manager, and records your energy use in Portfolio Manager, your target, and an annual comparison against it. It also documents changes in occupancy, operating hours and equipment; how you inform residents and staff about efficient energy use; a training plan for maintenance personnel; a capital plan for replacing failed equipment with ENERGY STAR rated models; and a contact list. The O&M program sits inside it — as does any extended-hours justification for patient and staff safety.
Every system that uses energy. For each, you inventory the components, set a preventive maintenance schedule and task list, and define what unacceptable performance looks like. The plan names who performs each task and who authorizes it, keeps records proving it’s running, flags anything operating past its useful life, and keeps a clearly organized document directory with emergency information immediately to hand.
A Qualified Energy Manager, through the Clean Buildings Portal, using a Secure Access Washington account. A QEM is an individual, not a firm — someone who has completed Commerce’s Tier 2 training and then meets any one of three routes: two years of commercial building operations or energy management experience, a supervised full-time fellowship or internship of at least six months that produced a successful compliance application, or Building Operator Certification Level I. Anyone meeting the broader Qualified Person definition also qualifies. Because an owner can fill any role in the standard, a facilities director who meets the definition can serve.
Still Not Sure?
Want the specifics for your building? Book a walkthrough and we’ll map it with you, or put your address into the Compliance Navigator for your tier, your deadline, and the property details behind them.