Where Healthcare Uses Are a Yes

1. Opening Insight

We ran 72,834 political transcript chunks through our healthcare and medical office filter, across 194 municipalities in 22 states, from January 2024 through April 2026. The question: where is medical development actually getting approved, and what does the approval path look like?

The conventional answer would be “wherever the big health systems are expanding.” Houston. Dallas. Atlanta. Go to the hospital anchor; follow the spending.

The data says something more useful.

Healthcare approvals split into two distinct markets. The exciting market is what most operators see: named health systems filing named rezonings, campus expansions with multiple variances, master plans with medical uses negotiated in. Oklahoma City alone carries 403 approved healthcare-related actions and 483 rezoning chunks tagged to healthcare terms, more than Houston, Boise, and Phoenix combined. These are entitlements won through champions, public hearings, and often protest rates above 90 percent.

The boring market is what most operators miss. Tampa’s zoning code contains 110 medical-related use permissions, and 93 of them are permitted by right. That is the highest by-right count in our 51-municipality ordinance dataset. Medical office, clinic, urgent care, and hospital-adjacent uses are permitted across a majority of Tampa’s commercial and mixed-use districts without a conditional use permit hurdle. MOB projects in Tampa rarely need a political vote. They need a building permit.

Both markets produce approvals. The difference is timeline, cost, and political risk exposure.

The exciting market rewards operators with strong government affairs bench depth, patience for public hearings, and the ability to absorb six to twelve additional months of carry. The boring market rewards operators who read the zoning code before they buy the dirt.

For most MOB product, the boring market is the cheaper market. Healthcare real estate teams underwriting multi-market pipelines should be segmenting by approval path, not just by health system footprint.

Where your next deal closes may have less to do with the hospital down the street and more to do with what the code says about the parcel across it.

2. Market Snapshot

Three municipalities illustrate the split:

Oklahoma City, OK (exciting market, champion required). OKC is the single biggest surprise in the healthcare dataset. Mercy Health Center, Inc. filed SPUD-1648 to rezone 512 South Mustang Road; Planning Commission recommended approval unanimously. Oklahoma Baptist Homes for Children filed SPUD-1759 at 11400 South Pennsylvania Avenue. The SPUD framework is healthcare-compatible, but it still requires the rezoning process, public hearings, and in some cases intense protest. A separate Roberts Road rezoning in the same dataset was denied with a 97.79 percent protest vote. OKC approves healthcare, but it approves through politics.

Tampa, FL (boring market, no champion required). 93 by-right medical uses in the Unified Development Code. Transcript activity is moderate at 65 approved healthcare-touch actions, not because nothing is happening, but because healthcare rarely needs to make it to the council dais. For BayCare, AdventHealth, or HCA Florida MOB projects, Tampa removes the most expensive and unpredictable part of the entitlement timeline: the political vote. The code already said yes.

Hillsborough County, FL (hybrid path, pre-coded PD). PD 24-0538 on Boyette Road rezoned an 18-acre parcel to Planned Development for 57 single-family units plus a 22,000-square-foot freestanding emergency room. A prior application was denied for density bonus overreach; the re-filed version without the bonus won staff support and moved forward. The freestanding ER is now a documented template, not an exception. This is the middle path: PD zoning that bundles medical into an entitled site plan, negotiated once and then repeatable.

3. What This Means for Operators

Three patterns from the data that should change how you evaluate MOB and health-facility sites:

Segment markets by approval path, not by health system logo. A target list that ranks metros by hospital presence will identify where demand exists. It will not identify where entitlement converts fastest. The highest volume of by-right medical uses in our dataset is not in a Top 20 health-system metro. It is in Tampa, Goldsboro NC, Fuquay-Varina NC, and Morrisville NC. These are not the first markets on a national MOB expansion list. They should be.

Pre-coded PD districts de-risk the biggest entitlement variable. Pearland’s Ivy District, Leesburg’s Orange Bend Mixed-Use, and Daytona Beach’s PD-RD (Redevelopment) districts all include healthcare in their coded use tables. When medical is pre-approved inside a Planned Development framework, the entitlement conversation shifts from “can we” to “how.” That is a different negotiation, with a different timeline and a different cost profile.

Opposition is not evenly distributed, even within approval-friendly metros. Pearland carries 22 opposition flags tied to healthcare development, the highest opposition count in the dataset, despite favorable code language. Harnett County, NC denies rezonings using boilerplate findings of fact even where the Land Use Plan supports the use. The lesson is not to avoid these markets. The lesson is that the entitlement cost has two components: the zoning code and the political climate. Underwrite both.

4. Full Study Link

The Healthcare & Medical Offices Momentum Index, covering 194 municipalities, 72,834 transcript mentions, and a cross-reference of 51 zoning ordinances for by-right and conditional medical use permissions, is available in the library

The report includes tiered municipality rankings (Active Demand, Code-Driven, Emerging and Opposition Watch), named project profiles with transcript quotes (Mercy Health SPUD-1648, Harris Health Casa de Amigos, Rockwall Medical Building, June Lake Gateway code amendment), and the by-right ordinance permissions data referenced in this issue.

5. Closing Line

Some municipalities cheer healthcare. Some just process it. Both approve. Know which path you’re buying.