A practical guide for medical practice owners, healthcare facility managers, and architects serving healthcare clients in Texas.
Overview
If you own, operate, or design a licensed healthcare facility in Texas, you already know that spaces evolve. An office becomes an exam room. A lab gets an upgrade. A surgery center gets added to the mix. Some of those changes are as straightforward as getting signed drawings and calling a contractor, but others may require a stop along the way. Specifically, certain projects trigger an Architectural Review from the Texas Health and Human Services Commission (HHSC). Managed by HHSC’s Architectural Review Unit (ARU), this process ensures facilities continue to meet state health, safety, and life-safety standards for patient care environments. Knowing when a review applies — and when it doesn’t — can save your team a lot of time and budget downstream.
When Is a Texas HHSC Architectural Review Required?
A review is required whenever a licensed facility undertakes construction, renovation, or a change in service or function, including:
| Construction & Physical Work | Functional / Service Changes |
| New construction or additions | Change of service(s) or function |
| Alterations, renovations, remodeling | Change of licensed bed designations |
| Equipment and finish upgrades | ESRD treatment/training designation changes |
| Repairs or building system upgrades | Change of invasive procedural services |
| Demolition | Removal of a function |
When Is a Review NOT Required?
Good news: not everything triggers a review. Routine maintenance and like-for-like replacements that don’t change a space’s function or layout are generally exempt. Here are a few examples:
- Routine maintenance or upkeep on an existing system
- One-for-one equipment or fixture replacement (same type, same location)
- Replacing a ceiling tile or repainting a wall
- Replacing a desk at a nursing station (moving the station, however, requires a review)
Quick rule of thumb: If the work changes how a space is used, its layout, or the services provided, a review is likely required. If it simply keeps things running as-is, it likely isn’t.
Frequently Asked Questions
Does Converting an Office Into an Exam Room Require a Review?
Yes, and this one catches people off guard. Even if no structural work is involved, converting a space from administrative use to clinical use changes its function, which triggers the review requirement.
Does Adding a Surgery Center to an Existing Facility Require a Review?
Yes. Adding a surgery center involves both construction and a change of invasive procedural services – two independent triggers. It’s a good example of why it’s worth checking early in your planning process.
What Must Be Submitted for an Architectural Review?
Submissions typically include signed architectural drawings and project specifications. Full requirements are outlined in the HHSC ARU Application Instructions (Form 3242).
Key Takeaway
Any work beyond routine maintenance, including construction, renovation, equipment upgrades that change services, or changes to how a space functions, requires an HHSC Architectural Review before work begins. When in doubt, consult a licensed professional engineer or contact HHSC directly.
Official resources: HHSC Architectural Review Overview | ARU Application Instructions (Form 3242)
Need Help Navigating Your Healthcare Renovation?
Healthcare renovations come with a lot of moving parts, from HHSC Architectural Review to FGI Guidelines and local code. At Cleary Zimmermann Engineers, we serve as a high-touch partner on complex healthcare projects, helping our clients stay ahead of compliance requirements from day one.
Reach out to our Healthcare Practice team to discuss your project scope and receive a personalized proposal tailored to your facility’s needs.
Disclaimer: This article is provided for general informational purposes only and does not constitute legal or regulatory advice. Requirements are subject to change. Always verify current requirements directly with HHSC before beginning any project.
