Texas HSC Chapter 331

Chapter 331 for Ambulatory Surgical Centers (ASCs)

Texas ASCs are covered by HSC Chapter 331 with no headcount test. Here is what ambulatory surgical center administrators must document for survey-readiness.

VIGILO Compliance Editorial Team7 min

Ambulatory surgical centers are a covered facility class under Texas HSC Chapter 331 — with no headcount test. Coverage is automatic for a licensed ASC, unlike the two-RN trigger that gates nursing facilities and home health agencies. That means every Texas ASC must maintain a full workplace violence prevention program and be ready to show it at survey.

ASC administrators often assume a workplace violence mandate is a hospital concern. It is not. This guide lays out exactly what Chapter 331 requires of an ASC, how to right-size the program to a surgical-center footprint, and what a surveyor opens to verify it. For the coverage map across all facility classes, see is my facility covered by HSC Chapter 331 and our pillar, Texas SB 240 & HSC Chapter 331 compliance.

#ASCs are covered automatically

Chapter 331 defines its covered facilities by reference to existing Texas licensing chapters. Ambulatory surgical centers — licensed under HSC Chapter 243 — are named directly, alongside general and special hospitals, mental hospitals, and freestanding emergency centers.

Facility classHeadcount test?Covered?
Hospitals (general / special / mental)NoneYes — always
Ambulatory surgical centers (ASCs)NoneYes — always
Freestanding emergency centers (FSEDs)NoneYes — always
Nursing facilities / HCSSAs≥ 2 employed RNsOnly above the threshold

(Source: Texas HSC Chapter 331; SB 240, 88th Leg., 2023.)

There is no "small ASC exemption" and no perceived-risk carve-out. A single-OR center sees the same coverage requirement as a multi-suite surgical hospital. The program can be scaled to the center's size and risk profile, but it must exist in full.

#What the ASC program must contain

Chapter 331 requires the same six core elements of an ASC that it requires of a hospital:

  1. A workplace violence prevention committee with the required members — a registered nurse who provides direct patient care, plus the conditional physician and security-services seats where the center employs those roles.
  2. A facility-specific written plan tailored to the ASC environment.
  3. Annual training for staff, documented.
  4. A confidential reporting and anti-retaliation policy.
  5. Post-incident response — acute treatment access and work-assignment adjustment.
  6. An annual plan evaluation reported to the governing body.

The committee is often the first sticking point for a small ASC. The good news: Chapter 331 lets you re-authorize an existing committee — a safety, quality, or medical-executive committee — to serve as the WVP committee, provided it is formally chartered for the purpose and includes the required members.

#Right-sizing the plan to an ASC — without thinning it

An ASC's risk environment is genuinely different from an emergency department's, and a defensible plan should reflect that rather than copy a hospital's. The error to avoid is adopting a hospital template wholesale, which a surveyor will flag as non-facility-specific. See why generic WVP plans fail surveys.

An ASC worksite analysis should address the hazards that actually exist in a surgical center:

ASC-specific considerationWhat to document
Pre-op and recovery areasAnxious patients, controlled-substance presence, post-anesthesia confusion.
Front desk and waiting roomThe first point of contact and a common flashpoint for family frustration.
Scheduling and billing conflictsDisputes that escalate at check-in or discharge.
After-hours and low-staffing periodsSmaller centers may have fewer staff present; document the coverage reality.
Egress and safe-room mappingThe physical side of the worksite analysis, sized to a smaller footprint.

Right-sizing means the content matches the ASC — not that any required element is dropped. The committee, plan, training, policy, post-incident response, and annual evaluation all remain mandatory.

#What a surveyor reviews at an ASC

A HHSC licensing surveyor verifies the ASC's program through documents:

  1. The committee charter and roster, confirming required members (or documented conditional-seat exclusions).
  2. The facility-specific written plan, checked for ASC-specific content.
  3. Training records — rosters, dates, completion or competency evidence.
  4. The confidential reporting and anti-retaliation policy.
  5. The post-incident response procedure.
  6. The most recent annual plan evaluation and proof it reached the governing body.
  7. Committee minutes for the trailing twelve months.

The most common ASC deficiencies are a hospital template adopted without tailoring, a committee with no minutes, and a missing annual evaluation — the same patterns that trip up larger facilities, just at a smaller scale.

#How an ASC gets survey-ready

  1. Accept that you are covered. Skip the "are we really in scope" debate — ASCs are covered as a class.
  2. Charter or re-authorize a committee and seat a true direct-care RN; resolve the conditional seats deliberately.
  3. Write a plan that reads like your center, not like a hospital — anchored on an ASC worksite analysis.
  4. Document training, policy, and post-incident response.
  5. Run the annual evaluation to your governing body on a dated schedule.
  6. Keep it in one binder a surveyor can navigate quickly.

ASCs that want a focused gap check use a survey-readiness audit scoped to a surgical center, or build the program turnkey through our workplace violence prevention program. Our ambulatory surgery centers page details the class-specific build, and the Chapter 331 compliance checklist lets you self-audit first.

An ASC's program should be lean, accurate, and unmistakably its own. Build it to the center's real environment, keep the committee alive on paper, and the survey takes care of itself.


Sources: Texas Health & Safety Code Chapter 331 (SB 240, 88th Leg., 2023); HSC Chapter 243 (ASC licensing); 26 TAC §133.55; HHSC Provider Letter PL 2024-10. This article is general compliance information, not legal advice.

From this article

Frequently asked questions

Are ambulatory surgical centers covered by Texas Chapter 331?

Yes. Ambulatory surgical centers (ASCs) are a covered facility class under HSC Chapter 331 with no headcount test — coverage is automatic, unlike the two-RN trigger that applies to nursing facilities and home health agencies. A licensed Texas ASC must maintain a workplace violence prevention program.

What must a Texas ASC document for Chapter 331?

An ASC must maintain a workplace violence prevention committee with the required members, a facility-specific written plan, annual training, a confidential reporting and anti-retaliation policy, post-incident response procedures, and an annual plan evaluation reported to its governing body. The program must be tailored to the ASC's actual environment, not a hospital template.

Does a low-acuity ASC still need a full Chapter 331 program?

Yes. Chapter 331 covers ASCs as a class regardless of perceived risk level. A center that sees few behavioral encounters still needs the committee, plan, training, policies, post-incident response, and annual evaluation. The program can be right-sized to the ASC's footprint, but every required element must exist and be documented.

Turn this guidance into a survey-ready program

VIGILO builds, documents, and maintains the workplace violence prevention program of record — committee, written plan, training, and binder — aligned to Chapter 331, the Joint Commission, and OSHA.

CallRequest an Audit