California Healthcare Minimum Wage Guide: SB 525 & SB 828 Rules
California enacted historic healthcare wage legislation under Senate Bill 525 (codified at California Labor Code §§ 1190.1–1190.4) and trailer bill SB 828. Effective October 16, 2024, hundreds of thousands of California healthcare employees became entitled to new wage floors ranging from $18.00 to $23.00+ per hour, escalating toward a universal $25.00 per hour rate across four statutory facility schedules.
Verify Your Healthcare Facility Rate & Overtime Pay
Determine your statutory healthcare minimum wage across all 4 covered facility schedules, check effective date phase-ins, and calculate exact overtime and double-time premiums.
1. Legislative Background & Effective Dates (SB 525 & SB 828)
Senate Bill 525 was signed into law in October 2023 to establish a statewide minimum wage standard for healthcare workers. In June 2024, the California Legislature enacted SB 828 and budget trailer legislation, which formally set the operative effective date to October 16, 2024.
Under California Labor Code § 1190.2, the healthcare minimum wage supersedes both the standard statewide minimum wage ($16.50/hr in 2025; $16.90/hr in 2026) and any municipal wage ordinances that are lower than the applicable healthcare facility rate.
2. The Four Covered Facility Schedules
Unlike a uniform minimum wage, SB 525 divides covered healthcare employers into four distinct statutory categories with differing phase-in schedules:
| Facility Category | Oct 16, 2024 | July 1, 2025 / 2026 | Ultimate Target ($25.00/hr) |
|---|---|---|---|
| Schedule 1: Large Health Systems 10,000+ FTEs, Dialysis Clinics, Large County Facilities | $23.00/hr | $24.00/hr (2025) $25.00/hr (2026) | July 1, 2026 |
| Schedule 2: High Government Payer Mix Hospitals with ≥90% Medicare/Medi-Cal, Rural Hospitals | $18.00/hr | +3.5% annual statutory increases | July 1, 2033 |
| Schedule 3: Community & Free Clinics FQHCs, Community Clinics, Free Clinics | $21.00/hr | $21.00/hr (2025) $22.00/hr (2026) | July 1, 2027 |
| Schedule 4: Other Covered Facilities Skilled Nursing Facilities (SNFs), Other Health Centers | $21.00/hr | $21.00/hr (2025) $23.00/hr (2026) | July 1, 2028 |
3. Broad Job Scope: Who Is a "Covered Healthcare Employee"?
A common misconception among employers is that SB 525 applies only to licensed medical personnel like nurses or physician assistants. The statutory definition is significantly broader.
Under California Labor Code § 1190.1, a covered employee includes any person employed by a covered healthcare facility who provides patient care, healthcare services, or services supporting the provision of healthcare:
Direct Clinical & Patient Care
- • Certified Nursing Assistants (CNAs)
- • Medical Assistants & Phlebotomists
- • Patient Care Technicians
- • Dialysis Technicians & Dental Assistants
Support, Facilities & Administrative
- • Janitorial & Environmental Service Workers
- • Hospital Cafeteria & Food Service Staff
- • Security Guards & Maintenance Crews
- • Medical Billing, Intake & Scheduling Clerks
Contracted and subcontracted workers who perform work on-site at a covered facility for an employer providing healthcare services are also covered under the statutory mandate.
4. Healthcare Overtime Calculations
Under California Labor Code § 510, overtime premiums are calculated as a multiplier of the employee's true regular rate of pay. When SB 525 raises the baseline hourly wage, the statutory overtime premiums increase proportionally:
Schedule 1 Large Health System Overtime Breakdown ($23.00 Base Rate)
- • Regular Hourly Rate: $23.00/hr
- • Daily Overtime (Hours 8.01–12.0 @ 1.5x): $23.00 × 1.5 = $34.50/hr
- • Daily Double-Time (Hours 12.01+ @ 2.0x): $23.00 × 2.0 = $46.00/hr
- • 7th Day Overtime (First 8.0 hrs @ 1.5x): $23.00 × 1.5 = $34.50/hr
- • 7th Day Double-Time (Hours 8.01+ @ 2.0x): $23.00 × 2.0 = $46.00/hr
5. The Salary Basis Exemption for Healthcare Workers
SB 525 also updated the statutory minimum salary required to maintain exempt white-collar status (executive, administrative, or professional) at covered healthcare facilities.
Under California Labor Code § 1190.2, an exempt healthcare employee must be paid a monthly salary of no less than:
Exempt Minimum Salary = Greater of: (1.5 × Applicable Healthcare Minimum Wage × 2,080 hours) OR (2.0 × California Statewide Minimum Wage × 2,080 hours)
For example, at a Schedule 1 facility with a $23.00/hr healthcare minimum wage, 150% is $34.50/hr, yielding an annual exempt salary floor of $71,760.00 (which exceeds the standard statewide 2025 non-exempt threshold of $68,640.00).
Frequently Asked Questions About SB 525 Healthcare Minimum Wage
When did the California SB 525 healthcare minimum wage take effect?↓
The California healthcare worker minimum wage officially took effect on October 16, 2024, following legislative adjustments enacted under trailer bill SB 828 (which moved the original June 1, 2024 implementation date to October 16, 2024).
What types of healthcare facilities are covered under SB 525?↓
Under California Labor Code § 1190.1, covered facilities include acute care hospitals, psychiatric hospitals, skilled nursing facilities (SNFs), licensed clinics, dialysis clinics, county-operated healthcare facilities, and specialized health centers. Medical practices operated by sole practitioners with fewer than 20 physicians are generally excluded unless part of an integrated health system.
Which employee job roles qualify for the healthcare minimum wage?↓
SB 525 applies broadly to all employees of covered healthcare facilities who provide patient care, healthcare services, or services supporting the provision of healthcare. This includes not only nurses and medical assistants, but also hospital janitors, food service workers, security personnel, clerical staff, medical billers, and patient transport workers.
How does SB 525 affect healthcare overtime rates in California?↓
Because overtime must be calculated using the employee's true regular rate of pay under Labor Code § 510, healthcare overtime rates must be based on the higher SB 525 base wage. For example, a worker under Schedule 1 with a $23.00/hr base rate earns an overtime rate of $34.50/hr (1.5x) and a double-time rate of $46.00/hr (2.0x).
What is the salary threshold for exempt healthcare workers under SB 525?↓
Under California Labor Code § 1190.2, to qualify as an exempt executive, administrative, or professional employee at a covered facility, the employee must receive a monthly salary equivalent to at least 150% of the applicable healthcare minimum wage or 200% of the statewide minimum wage, whichever is greater, for full-time work.
Primary Legal Authorities & Statutory References
- • California Labor Code §§ 1190.1–1190.4: Statutory definitions, facility schedules, and wage rates for health care workers.
- • Senate Bill 525 (Stats. 2023, ch. 890): Healthcare worker minimum wage enactment.
- • Senate Bill 828 (Stats. 2024, ch. 37): Amendment establishing operative effective date of October 16, 2024.
- • California Department of Industrial Relations (DIR): Healthcare Worker Minimum Wage FAQ and Enforcement Bulletins.