How to relocate a licensed IOP or PHP to a new location

The short version

Moving a licensed Texas IOP or PHP takes three filings and a lot of notices. HHSC processes a change of address as a new site (a Form 3207 change-in-status application), the new building needs its own zoning approval, certificate of occupancy and fire inspection, and every insurance plan, NPPES, CAQH and TMHP needs the new service address before the first claim from it. Plan on four to six months.

• Start four to six months out. The city, HHSC and the insurance plans each move at their own pace, and the plans are usually the slowest.
• Plan the HHSC filing as a new site, not a quick address update, and don't treat anyone at the new address until HHSC has what it needs.
• Get the new building approved for your use before you sign: zoning in writing, then the certificate of occupancy and fire inspection after any build-out.
• Update every payer before the first claim from the new address: NPPES, CAQH, each facility contract, TMHP and the Medicaid plans, and Medicare if you're enrolled.
• Never leave a gap. HHSC retires a site's license when services stop there for more than 60 days, unless you've asked for inactive status (26 TAC 564.406).

1. What HHSC requires for a new site

A Texas program that treats substance use disorders holds a chemical dependency treatment facility license from the Texas Health and Human Services Commission (HHSC), under Health and Safety Code chapter 464 and 26 TAC chapter 564. Two things decide how a move is handled:

• HHSC processes a site move as a new site. HHSC's instructions for Form 3207, the chemical dependency treatment facility license application, say a change in address is processed as a new site. Form 3207 is also the change-in-status application for a facility that's already licensed, filed with the Form 3209 checklist for change-in-status applicants, Form 3208 and the supporting documents.
• The change-in-status rule (26 TAC 564.405) requires an application, fees and HHSC's written approval before a facility adds or moves a residential site, adds beds or adds detoxification. For outpatient services, the rule asks for written notice to HHSC licensing before you add a new service. Read with the Form 3207 instructions, the safe plan for an outpatient move is a change-in-status application for the new site, filed well before the move, with HHSC's answer in writing.

Practical points from doing it:

• Fees. As of October 2026, 26 TAC 564.408 sets a $1,200 base fee for initial and renewal licenses and $125 for each outpatient or residential site at a separate physical address. Ask HHSC which fee applies to your filing; fees are paid by cashier's check or money order.
• Old rule numbers. HHSC's form instructions still cite 25 TAC chapter 448. Those rules moved to 26 TAC chapter 564 on April 30, 2024, mostly without changing the text, so 448.405 is now 564.405.
• Be ready for a site review. Ask HHSC whether it will look at the new site before or after you move, and have the binder ready either way: the lease, the certificate of occupancy, the fire inspection, the updated emergency plan and evacuation map, and your policies with the new address.
• Keeping the old site too? Adding a location is a different question from moving. Texas law exempts certain satellite locations operating under a licensed outpatient facility's supervision and within its license (Health and Safety Code 464.003), and HHSC lists a satellite site notification form (Form 3214) on its chemical dependency treatment facility page. Ask HHSC in writing whether your second location qualifies before you rely on it.
• Mental-health-only programs aren't under chapter 564. A freestanding mental health IOP may not hold a facility license at all; confirm with HHSC and your attorney what, if anything, has to be filed.

Update your operational plan and policies with the new address, rooms and evacuation routes at the same time as the filing. Surveyors read the emergency plan against the building they're standing in.

2. Zoning, occupancy and fire, again

Your current certificate of occupancy belongs to your current building. The new one needs its own approvals, in this order:

1. Zoning, in writing, before the lease. Ask the city whether an outpatient treatment program is allowed at the address. A medical office use isn't always the same thing as a treatment program in a city's code.
2. A lease with a way out if zoning, the certificate of occupancy or HHSC approval falls through, and enough free rent to cover any build-out. Overlap the old and new leases by at least a month.
3. Build-out and permits: group rooms sized for your groups, private offices with sound privacy, accessible entrances and restrooms, locked records and medication storage, exit signs and emergency lighting.
4. Certificate of occupancy and fire marshal inspection. Keep both; HHSC and your accreditor will ask for them.
5. Run a fire drill in the new building in the first weeks and post the new evacuation map. Our sister product Comply covers fire drill requirements.

3. Tell every insurance plan

Facility contracts, plan directories and claims systems all hold your service address. Many plans credential each service location, and some want a site visit before a new one is active. Update each of these, and keep the confirmation:

This is the same plan-by-plan follow-up our credentialing service runs for new contracts: written requests, a follow-up every two weeks, and the effective date confirmed in writing. A move doesn't change your tax ID or NPI. If it comes with a new owner or a new legal entity, it's a different and bigger project: see buying or selling a treatment center. If your plans use a carve-out manager, our Quick VOB guide to behavioral health carve-outs shows how to tell who manages the benefit.

4. Tell your accreditor

Joint Commission and CARF both expect an accredited organization to report significant changes, and a new location is one of them, as are a new owner and new services. The accreditor decides whether the new site needs a survey of its own or can wait for your next one. Check your accreditation agreement and the current accreditation manual for the notice window and the form, and send the notice before the move, not after. Plans that require accreditation may ask for proof that it covers the new address.

For the survey itself, see our sister product's Joint Commission behavioral health checklist and CARF survey prep guide.

5. Clients and continuity of care

• Tell clients early and in writing: the new address, the first day there, parking and transit, and who to call. Repeat it in groups for two weeks before the move.
• Check transportation for each client. A move across town can end treatment for a client who rides the bus. Note any client who needs a referral or a schedule change, and document the plan in the chart.
• No missed days. Move over a weekend or a holiday. If a session must be cancelled, document it and offer a make-up; a gap in services can also put a pending authorization or a continued-stay review at risk.
• Telehealth as a bridge, only if telehealth is part of your licensed services and each client's plan covers it, following 26 TAC 564's telehealth rules on consent, identity checks and documentation.
• Update the paperwork: the intake packet, the privacy notice, the client rights posting, the grievance notice and anything else that carries the address. Post the required notices in the new lobby.
• Move the records securely. Paper charts travel locked and logged, with a staff member, never in a mover's truck unattended. Substance use records are protected by 42 CFR Part 2 as well as HIPAA, and 26 TAC 564.508 keeps original records in Texas.
• Tell your referral partners and update public listings: Google Business Profile, FindTreatment.gov, your website and directories, and LegitScript if you advertise. Same name, address and phone everywhere.

A move timeline

This is the order we'd plan it in. Your city, HHSC and your plans set their own pace, so treat the timing as typical, not promised.

Mistakes that cause claim denials after a move

• The address on the claim doesn't match the plan's file. The service facility location on the claim is new, the plan's record is old, and the claim rejects or pends. Hold claims for a plan until its effective date for the new address is confirmed, then send them well inside the timely filing limit.
• NPPES or CAQH not updated. Plans and clearinghouses compare claims to the NPI record, and recredentialing reads CAQH. A stale profile is a slow denial.
• Seeing members at a site the plan hasn't approved. If the plan credentials locations, care at an unapproved one can be out of network.
• Medicaid updated at TMHP but not at the managed care plans, or the other way round. Each plan has its own provider file.
• A gap in services that runs past HHSC's 60 days (what happens then is in our guide to closing or pausing a program), or that interrupts an authorization a client still needs.
• Forgetting the small places the address lives: the fee schedule on file, the EFT enrollment's contact address, statements, good faith estimates and the website's privacy notice.

If a plan wants the new site credentialed like a new facility, budget it like one: see facility contract prices and timelines. A quick chart audit in the first month after a move is worth it too: new rooms and new routines are when signatures and times slip.

Questions

Adding a level of care at the same time? Read how to add PHP or IOP to your program. Opening a second program from scratch? Start with how to start an IOP or PHP in Texas.

Sources

• Texas HHSC, Form 3207, Chemical Dependency Treatment Facility License Application (instructions: change in status; a site move is processed as a new site)
• Texas HHSC, Form 3209, Licensure Application Checklist for Change in Status Applicants
• Texas HHSC, Chemical Dependency Treatment Facilities (forms, including 3214 satellite site notification and 3206 closure)
• 26 TAC 564.405 (changes in status), 564.406 (inactive status and closure), 564.408 (fees)
• Texas Register, Transferred rules, April 5, 2024 (25 TAC 448 to 26 TAC 564)
• Texas Legislature, Health and Safety Code chapter 464 (464.003 satellite locations) and the HB 4298 (2019) bill analysis
• CMS, NPPES; TMHP; eCFR, 42 CFR Part 2; Cornell LII, 26 TAC chapter 564 (telehealth and records rules)