Why Section 106 Matters: Preserving VA’s Historic Healthcare Legacy

Adam Ogrzewalla, AIA NCARB

As the Department of Veterans Affairs modernizes its healthcare infrastructure, an increasing number of projects are taking place within buildings and campuses recognized as historic resources. For architects and engineers, Section 106 of the National Historic Preservation Act is therefore more than a regulatory requirement—it is a critical design and project-delivery consideration.

A Growing Historic Footprint

The VA’s healthcare portfolio contains a remarkable record of American architectural, medical, and military history. Many VA medical centers and campuses were established generations ago, including facilities associated with the National Home for Disabled Volunteer Soldiers and later, periods of federal healthcare development. Across the collection, numerous individual buildings, structures, and historic districts are listed or determined eligible for the National Register of Historic Places (NRHP).

This growing recognition of historic VA resources changes the way renovation projects must be approached. A project that appears to be a conventional renovation, infrastructure replacement, addition, or site improvement may also constitute an undertaking affecting a historic property. The design team must understand that context before major design decisions are made.

Section 106 Begins with Documentation

Section 106 compliance begins with a clear understanding of existing historic resources. Building and campus documentation provides the factual basis for evaluating how proposed work may affect character-defining features, historic relationships, materials, circulation patterns, landscape elements, and significant spaces.

For VA healthcare projects, this documentation can be especially important because modernization frequently occurs within active clinical environments. Existing conditions must be evaluated not only for function and code compliance, but also for historic significance. The resulting information allows the project team to distinguish between elements that can be modified freely, elements requiring careful treatment, and features that may warrant preservation or mitigation.

Closing the Knowledge Gap

A recurring challenge on VA healthcare projects is that facility engineers and planners may not fully understand when Section 106 applies or how early decisions can affect historic resources. Because their focus is often on clinical operations, infrastructure reliability, life safety, accessibility, and project schedule, preservation requirements may be seen as separate from project planning rather than as part of it.

Closing this knowledge gap requires early collaboration among planners, engineers, architects, cultural resource specialists, and VA stakeholders. When Section 106 expectations are explained at the start of planning, teams can identify historic constraints sooner, avoid unnecessary redesign, and integrate preservation considerations into practical facility solutions.

Compliance Should Influence Design—Not Follow It

One of the most common project risks is treating Section 106 as a documentation exercise that occurs after the design has already been developed. When historic preservation review begins late, design alternatives may be limited and seemingly minor decisions can trigger redesign, additional consultation, or schedule impacts.

Integrating Section 106 considerations during planning and early design gives the design team greater flexibility. Historic context can inform programming, phasing, exterior alterations, interior interventions, site circulation, new construction, and material selections. Early coordination also creates a clearer path for consultation with the State Historic Preservation Officer, Tribal Historic Preservation Officers when applicable, and other consulting parties.

Documentation Protects More Than Buildings

Historic documentation is not simply about preserving an old building. It preserves information about the evolution of veterans’ healthcare and the federal government’s commitment to serving those who served.

When adverse effects cannot be avoided, mitigation may include detailed photographs, measured drawings, written histories, or other documentation aligned with established preservation standards. These records provide a permanent account of resources that might otherwise be altered or lost. On VA campuses, they also contribute to the broader story of American healthcare, architecture, and veterans’ services.

A Strategic Advantage for Project Delivery

Section 106 compliance should be viewed as an opportunity to improve project delivery rather than an administrative obstacle. Early documentation reduces uncertainty, supports informed design decisions, and helps project teams anticipate preservation issues before they become schedule or cost problems.

For VA projects, the goal is not to stop modernization, but to guide it responsibly meeting today’s clinical, operational, safety, and accessibility needs while respecting the historic resources entrusted to the VA. As more VA buildings and campuses gain historic recognition, integrating Section 106 into the design process will become increasingly essential.

The Takeaway

For today’s VA healthcare design teams, historic preservation is becoming an increasingly routine part of federal project delivery. The strongest projects recognize Section 106 early, document existing conditions thoroughly, coordinate with the appropriate stakeholders, and use that information to shape—not constrain—the design.

The result is a more predictable project and a stronger facility: one that supports the future of veteran healthcare while respecting the history that made these campuses significant in the first place.

DESIGNING FOR THE FUTURE. DOCUMENTING THE PAST.

Thoughtful Section 106 planning allows VA healthcare facilities to evolve without losing the architectural and cultural legacy that defines them