Abstract
Healthcare facility design in Arizona is governed by a structured regulatory framework that distinguishes between licensed healthcare institutions and general outpatient facilities. This distinction is particularly important when comparing Ambulatory Surgery Centers (ASC) and Medical Office Buildings (MOB). Ambulatory Surgery Centers are regulated as licensed health care institutions under the authority of the Arizona Department of Health Services, while Medical Office Buildings are generally regulated through local building jurisdictions unless specific services trigger licensure requirements.
As demonstrated in ARCHSOL’s extensive portfolio, this distinction is not theoretical. It directly shapes planning strategy, infrastructure investment, and project delivery across Arizona health systems. ARCHSOL’s work on perioperative expansions, outpatient procedure environments, and diagnostic-driven MOB facilities reflects a consistent need to align early programming decisions with regulatory classification. Whether supporting surgical environments that require full compliance with state licensure and clinical infrastructure standards or designing flexible outpatient settings that operate within a commercial code framework, the firm’s experience reinforces that classification drives both design complexity and long-term operational performance. This paper evaluates statutory requirements, administrative rules, and the resulting design implications for architecture and engineering teams working within Arizona.
Regulatory Authority and Facility Classification
Ambulatory Surgery Centers in Arizona are formally classified as outpatient surgical centers under Arizona Administrative Code Title 9, Chapter 10. These facilities fall under the jurisdiction of the Arizona Department of Health Services and must obtain licensure before operation. According to Arizona Revised Statutes §36-421, any construction or modification of a licensed health care institution requires review and approval by the state, including submission of architectural plans that demonstrate compliance with applicable regulations.¹ This requirement establishes a direct relationship between architectural documentation and regulatory approval and positions design teams as a central component of compliance.
Medical Office Buildings, in contrast, are not inherently classified as licensed health care institutions. These facilities are typically regulated under local building codes adopted from the International Building Code and enforced by municipal authorities.² Unless a Medical Office Building includes services that meet licensure thresholds, such as surgical procedures or anesthesia beyond minimal sedation, the facility does not require oversight from state health regulators. This distinction establishes two fundamentally different regulatory pathways that directly influence project delivery.
Licensing and Plan Review Requirements
The licensing process for Ambulatory Surgery Centers requires submission of detailed architectural and engineering documentation to the Arizona Department of Health Services Office of Medical Facilities. This process includes evaluation of life safety systems, engineering infrastructure, clinical workflow, and infection control design. The Arizona Administrative Code specifies minimum standards for outpatient surgical centers, including operational policies, governance structures, and physical plant requirements that must be reflected in the design documents.³ These requirements are codified in rules such as Arizona Administrative Code R9-10-902 and Arizona Administrative Code R9-10-918, which define both administrative and physical environment standards.⁴
Medical Office Buildings follow a significantly different pathway. Plan review is conducted at the local level through city or county permitting processes, and approval is based on compliance with adopted building codes, zoning requirements, and accessibility standards such as the Americans with Disabilities Act.² Because these facilities are not licensed by the state in most cases, architectural teams are not required to demonstrate compliance with healthcare-specific administrative rules. This results in a more streamlined approval process with fewer regulatory checkpoints.
Physical Plant and Engineering Design Requirements
Ambulatory Surgery Centers must comply with detailed physical plant standards that are specific to healthcare environments. The requirements outlined in Arizona Administrative Code R9-10-918 mandate that facilities provide appropriate space, equipment, and systems to support surgical procedures and patient recovery.⁴ These standards require integration of medical gas systems, surgical-grade ventilation, sterile processing workflows, and emergency power systems. The design must also align with nationally recognized standards such as NFPA 99, Health Care Facilities Code, and ASHRAE Standard 170, Ventilation of Health Care Facilities, both of which are commonly referenced in state regulatory expectations.⁵⁻⁶
Engineering systems in Ambulatory Surgery Centers are designed to support patient safety and clinical outcomes. Ventilation systems must maintain pressure relationships and air change rates appropriate for surgical environments, while electrical systems must provide redundancy through essential electrical systems that support life safety and critical operations.⁵
Medical Office Buildings are not subject to these healthcare-specific physical plant standards. Their engineering systems are designed primarily for occupant comfort and general outpatient use. Ventilation systems typically follow commercial standards rather than clinical pressurization requirements, and there is no requirement for medical gas infrastructure or redundant electrical systems.² This allows for greater flexibility in system design and reduces both initial construction costs and long-term operational complexity.
Operational and Clinical Considerations Influencing Design
The regulatory definition of an Ambulatory Surgery Center establishes that patients must be admitted, treated, and discharged within a twenty-four-hour period without requiring inpatient hospitalization.³ This definition influences spatial planning, patient flow, and recovery area design by requiring efficient circulation between preoperative, procedural, and recovery zones.
Additionally, Ambulatory Surgery Centers are required to implement infection control programs, quality assurance processes, and incident reporting systems as part of their licensure obligations.³ These operational requirements directly inform architectural decisions related to separation of clean and soiled pathways, material selection, and environmental controls. Federal oversight through the Centers for Medicare and Medicaid Services further reinforces these standards for facilities seeking reimbursement eligibility.⁷
Medical Office Buildings do not operate under the same clinical constraints. Their function is limited to outpatient consultation, diagnostics, and low acuity services that do not require the same level of environmental control or operational oversight. As a result, design decisions are driven more by tenant flexibility and leasing considerations than by regulatory clinical requirements.
Life Safety and Code Implications
Ambulatory Surgery Centers are typically classified under healthcare occupancy provisions within the NFPA 101 Life Safety Code. This classification requires enhanced life safety features, including compartmentalization, fire-rated construction, and redundant systems to protect patients who may not be capable of self-evacuation.⁸ Arizona regulations require compliance with nationally recognized accreditation standards, which often incorporate these life safety provisions into facility design and operation.¹
Medical Office Buildings are generally classified as business occupancies and are subject to standard fire protection and egress requirements under the International Building Code.² These facilities do not require the same level of redundancy or compartmentalization because occupants are assumed to be capable of independent evacuation. This difference significantly impacts both architectural layout and engineering system design.
Figure 1. Building Classification Comparison
The key distinction is that an Arizona ASC is a licensed outpatient surgical center under state health regulations, while the IBC occupancy classification depends on whether patients are rendered incapable of self-preservation by the care being provided. Under the IBC, a typical MOB is generally classified as Group B Business, while an outpatient surgical environment is evaluated as either Group B ambulatory care or, in certain cases, Group I 2, depending on patient condition and occupant characteristics. Arizona separately requires ASC licensure through ADHS.
| Category | ASC in Arizona | MOB in Arizona |
| Arizona facility status | Licensed outpatient surgical center under state rules | Typically not licensed unless services trigger it |
| Primary regulator | Arizona Department of Health Services, plus the local authority having jurisdiction | Local authority having jurisdiction |
| Typical IBC occupancy lens | Ambulatory care use with potential reduced self-preservation; may escalate based on conditions | Group B Business |
| Key classification trigger | Whether care renders patients incapable of self-preservation | Occupants capable of self-preservation |
| Length of stay | Less than 24 hours | Less than 24 hours |
| State plan review impact | Required | Not required |
| Physical plant expectations | Surgical and recovery infrastructure with clinical systems | Standard commercial systems |
| Life safety impact | Enhanced requirements due to patient condition | Standard business occupancy |
| Mechanical and electrical impact | Clinical systems with redundancy and specialized ventilation | Commercial systems |
| Best early design question | Will care reduce patient self-preservation | Is use limited to outpatient office functions |
Determining the Right Facility Path
A Client Guide for Ambulatory Surgery Centers and Medical Office Buildings
Early in planning, one of the most important decisions is whether a facility should be developed as an Ambulatory Surgery Center or a Medical Office Building. This distinction affects regulatory requirements, project timeline, infrastructure investment, and long term operational flexibility. The following questions are designed to help clarify the appropriate path and align your project with the correct framework from the outset.
Understanding Your Clinical Intent
The first step is to clearly define how the facility will be used.
Will procedures be performed that go beyond standard office based care? If so, will those procedures involve sedation or anesthesia? Consider whether patients will require recovery time before discharge, and whether any services resemble those typically performed in an operating room environment.
If the answer to these questions is yes, the facility may fall under licensure requirements governed by the Arizona Department of Health Services.
Evaluating Patient Condition and Safety
Building classification is heavily influenced by patient condition during care.
Will any patients be unable to exit the building on their own due to sedation or treatment? If so, how many patients may be in this condition at one time? Will staff need to assist patients during an emergency?
These factors are critical under the International Building Code and may shift the project into a more highly regulated category with enhanced life safety requirements.
Clarifying Licensing and Operational Goals
Your operational goals play a significant role in determining the correct pathway.
Do you intend to license the facility as an Ambulatory Surgery Center? Will you pursue certification through the Centers for Medicare and Medicaid Services? Are there future plans to expand into procedural or surgical services?
Facilities that pursue licensure must comply with Arizona Administrative Code requirements, which influence both design and delivery.
Identifying Infrastructure Needs
Facility systems often reveal the true nature of the project.
Will the building require medical gas systems, such as oxygen or vacuum? Are sterile processing areas or clean and soiled separation needed? Will backup power be required to support clinical operations? Are there specialized ventilation or pressurization requirements for procedure spaces?
If these elements are part of your program, the project is likely aligned with an Ambulatory Surgery Center level of design.
Considering Schedule, Cost, and Risk
Regulatory classification also affects project delivery.
How important is speed to market? Are you prepared for state level plan review and approval timelines? Does your budget account for enhanced infrastructure and compliance requirements?
Understanding these factors early helps avoid redesign, delays, and unexpected costs.
A Simple Way to Think About It
At its core, the decision comes down to one defining question:
Are you creating a facility for office based care, or one that supports procedures that change a patient’s condition?
How ARCHSOL Supports Your Decision
ARCHSOL works with healthcare organizations across Arizona to navigate this decision early in the planning process. By aligning clinical intent, regulatory requirements, and infrastructure strategy from the outset, we help ensure that each project follows the correct pathway, reducing risk and supporting efficient delivery.
This proactive approach allows your team to move forward with confidence, knowing the facility is positioned for both regulatory approval and long term success.
Conclusion
The regulatory framework governing healthcare facilities in Arizona establishes a clear distinction between Ambulatory Surgery Centers and Medical Office Buildings. Ambulatory Surgery Centers are highly regulated environments that require licensure, state oversight, and strict compliance with healthcare-specific design standards. These requirements affect every aspect of architecture and engineering, from spatial planning to mechanical system design and life safety strategy. Medical Office Buildings, by contrast, operate within a commercial regulatory framework that allows for greater flexibility and reduced complexity.
For architecture and engineering teams, early identification of facility classification is essential. Misalignment between intended use and regulatory pathway can result in redesign, increased costs, and project delays. A thorough understanding of Arizona-specific regulations allows design teams to align infrastructure, compliance strategy, and project delivery from the outset, ensuring both regulatory approval and long term operational success.
References
- Arizona Secretary of State. Arizona Administrative Code, Title 9, Chapter 10. Accessed March 26, 2026. https://apps.azsos.gov/public_services/Title_09/9-10.pdf
- Arizona Department of Health Services. Outpatient Surgical Centers’ new rules 2014. Accessed March 26, 2026. https://www.azdhs.gov/documents/director/administrative-counsel-rules/rules/rulemaking/hci/outpatient-surgical/hci-outpatient-surgical-new-rules-2014.pdf
- International Code Council. International Building Code Chapter 3: Occupancy Classification and Use. Accessed March 26, 2026. https://codes.iccsafe.org/content/IBC2021P2/chapter-3-occupancy-classification-and-use
- International Code Council. 2012 IBC Handbook excerpt, Section 422 Ambulatory Care Facilities. Accessed March 26, 2026. https://media.iccsafe.org/news/eNews/2014v11n1/2012_ibc_handbook_p117-119.pdf
- International Code Council. Code Update: Ambulatory Health Care Facilities. Published April 6, 2009. Accessed March 26, 2026. https://media.iccsafe.org/news/eNews/2009v6n11/codeupdate.pdf
- Electronic Code of Federal Regulations. 42 CFR Part 416, Ambulatory Surgical Services. Accessed March 26, 2026. https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-416
- Centers for Medicare & Medicaid Services. Ambulatory Surgical Centers. Updated April 22, 2025. Accessed March 26, 2026. https://www.cms.gov/medicare/health-safety-standards/certification-compliance/ambulatory-surgery-centers
About ARCHSOL, LLC
ARCHSOL is an Arizona-based healthcare architecture and planning firm focused on designing high-performing environments that support clinical care, operational efficiency, and long-term adaptability. The firm partners with health systems and providers on projects ranging from ambulatory facilities to major hospital expansions, bringing a strong understanding of complex healthcare environments, infrastructure, and phasing within active campuses. ARCHSOL integrates Real Time Visualization into its workflow to help stakeholders experience spaces early, align decisions, and reduce uncertainty. With a collaborative, hands-on approach, the team delivers thoughtful solutions that simplify complexity and support both providers and the communities they serve.
Media Contact: Matthew Knapp | Marketing and Communications | Email: mknapp@archsol.wpenginepowered.com