Renovating Assisted Living and Memory Care Facilities in Maryland: Codes, Licensing, and Building While Residents Stay

Why Senior Living Is Its Own Kind of Construction

A renovation inside an assisted living or memory care facility is not a commercial fit-out with grab bars added. Three separate rulebooks apply at once: the state health-licensing regulations that govern the operator, the building code that governs the structure, and the life-safety code that governs how residents who may not be able to evacuate on their own are protected from fire. The contractor has to satisfy all three, usually while residents keep living in the building.

Prime Renovations builds medical and healthcare space — including a FastMed urgent care and primary care clinic built inside an operating shopping center — and the same discipline applies here: heavy mechanical and plumbing work, strict code compliance, and construction that respects the people already using the building.

The Licensing Layer: COMAR 10.07.14

Assisted living programs in Maryland are licensed by the Office of Health Care Quality (OHCQ) in the Maryland Department of Health under COMAR 10.07.14, which was substantially revised effective April 28, 2025. The regulations cover the physical plant as well as care and staffing, and they treat Alzheimer’s Special Care Units — memory care — as a distinct, approved unit with its own requirements.

What this means for a construction project: the operator’s license is tied to the building as it was surveyed. Adding resident units, converting common space into bedrooms, or changing where residents sleep changes what OHCQ licensed. Before drawings are finalized, the operator should confirm with OHCQ how the change affects the licensed capacity and whether a survey of the new space is needed before it is occupied. The contractor’s job is to build to the drawings that came out of that conversation, and to hand over a space that passes both the county’s final inspection and the state’s licensing survey.

The Building Code Layer: Which Occupancy Group

Maryland enforces the 2021 International Building Code and 2021 International Existing Building Code statewide, with the 2019 Maryland Accessibility Code and the 2024 editions of NFPA 1 and NFPA 101. Under the IBC, the size of the program decides its occupancy group:

• Group R-4 covers residential care and assisted living for more than five but not more than sixteen residents.
• Group I-1 covers more than sixteen residents, split into Condition 1 (residents who can evacuate without assistance) and Condition 2 (residents who need limited assistance — the usual classification for memory care).

Both groups require an automatic sprinkler system throughout, and I-1 brings additional requirements for fire alarm and smoke detection, corridor and door ratings, and smoke compartments. Because most renovation work in these buildings is a change within the same occupancy, the IEBC’s alteration provisions govern — but the moment a project adds beds, converts a common area to resident rooms, or moves the facility across the R-4/I-1 line, the new work must meet the current code for that use in full.

The Life-Safety Layer: NFPA 101 and Secured Egress

NFPA 101, the Life Safety Code, is where memory care differs most from ordinary residential work. Residents who wander need doors that are secured against exit, and the code allows this only through specific arrangements — delayed-egress locking hardware, or access-controlled egress tied to the fire alarm and sprinkler system so that every door releases automatically on an alarm or power loss. The hardware, its wiring, the signage, and the fire-alarm interface are all inspected together; a door that is simply locked is a code violation and a licensing finding.

Corridors have to remain exits throughout construction. That single requirement shapes every phasing plan in an occupied facility: temporary partitions must be rated and sealed, the alarm system stays live in every occupied area, and a construction door can never become the only way out of a wing.

What Baltimore County Requires

Baltimore County’s Department of Permits, Approvals and Inspections lists assisted living and nursing homes among the uses that need a specialized change-of-occupancy permit, with construction plans reviewed by Environmental Health Services in addition to building plan review. Floor plans are required with the application, and any physical alteration needs its own building permit. In our experience the fastest route is a complete set — sealed architectural drawings plus mechanical, electrical, plumbing and fire-protection sheets — submitted together, so that plan review, the fire marshal, and environmental health all work from the same documents.

Building While Residents Stay

Almost no operator can empty a floor to renovate it. The construction plan therefore has to solve for people who are elderly, often frail, and in memory care frequently disoriented by change. The measures that matter most:

Dust and infection control. Sealed, negative-pressure containment at the work zone, sticky mats and dedicated worker routes, HVAC returns in the work area blanked off so construction dust never reaches resident rooms.

Noise and hours. Demolition and rotary-hammer work scheduled in windows the operator sets — typically late morning through mid-afternoon, never during meals or overnight — with quiet tasks the rest of the day.

Utilities. Every shutdown of water, power, medical gas or fire alarm planned in writing with the operator, kept short, and never overlapping a meal or medication window. Temporary sprinkler coverage or a fire watch where a shutdown is unavoidable.

Egress and wandering. A daily walk-through confirming exits, alarms and secured doors are exactly as they were the day before. Tools, ladders and open cans never left where a resident could reach them.

Staff communication. One point of contact on the owner’s side, a written look-ahead every week, and no surprises for the nurses on the floor.

Where the Cost Goes

Senior-living renovations are plumbing- and life-safety-heavy. When common space becomes resident units, every new unit brings its own bathroom, often a kitchenette, its own exhaust, and its own electrical circuits; the rated partitions and ceilings between units, the fire-alarm and sprinkler extensions, and the secured-egress hardware sit on top of that. Finishes — the part families and surveyors see — are usually a minority of the budget. In this market, adding resident units inside an existing licensed building generally lands in the low-to-mid six figures per unit once life-safety and mechanical, electrical and plumbing work are included, with the position in that range set by the wet-room count, the condition of the existing services, and how much of the building stays occupied. The full breakdown of what drives a conversion budget is in our guide to commercial-to-residential unit conversions in Maryland.

We price this work the way we price everything: a site walk first, then a line-by-line pro-forma estimate with allowances and exclusions visible, subcontractor numbers from the actual drawings, and a Maryland-compliant contract before any work begins.

If you operate an assisted living, memory care or senior housing community in the Baltimore area and are planning added units, a memory-care conversion, or a building-wide refresh, send us the address and the drawings you have. We will tell you what the licensing, code and phasing picture looks like before we talk about a price.

Prime Renovations LLC is an MHIC-licensed (#143153) design-build general contractor based in Baltimore, serving Baltimore City and County, Howard, Anne Arundel and Carroll counties. Call or WhatsApp (410) 260-0070, or use the contact form.