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TDLR Architectural Barriers program

Lesson 9: Registration, review, and inspection under TDLR

Who registers a project, the fee structure, and the RAS's role in review and inspection · 14 practice questions

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Reading

TAS is not self-enforcing. The Texas Department of Licensing and Regulation (TDLR) administers a registration, review, and inspection process for covered projects, and this lesson covers how that process works from an owner's perspective, since GCHS acts as an owner or developer on its own construction and rehabilitation projects.

The registration threshold

A project must be registered with TDLR through TABS, its online registration system, when its estimated construction cost is $50,000 or more. Projects below that threshold are not required to register, though TDLR's fee page says a project under $50,000 may still register on the Special Project Registration form with the standard $175 filing fee. The underlying TAS technical requirements still apply to the construction itself regardless of registration status. Registration and technical compliance are two separate questions, a project can be too small to register and still be required to meet TAS.

Filing fees

TDLR's fee schedule lists a $175 project filing fee and a $300 late project filing fee, and its registration help sheet shows them together as "$175 registration fee ($300 late registration fee)." The fee page ties the late fee to a project registered after construction is complete. Neither page says the $300 is added on top of the $175, so confirm with TDLR how the two apply to a late project. Either way, registering on time costs less than registering after the fact.

Special review and inspection fees

Beyond the filing fee, TDLR's fee schedule lists a special review or inspection fee of $215 per hour, with a one-hour minimum charge. It is separate from the flat filing fee paid at registration. TDLR's fee page also says that for projects submitted to a registered accessibility specialist or a contract provider, only the project filing fee is required (it makes that statement for projects not subject to the Act that register for services), so confirm which fees apply to your project.

Which TAS edition applies

The 2012 TAS, the edition this entire course is built around, took effect March 15, 2012 (the date on the TAS title page). TDLR applies the edition that matches the project's registration date, not when construction finishes, so a project registered on or after March 15, 2012, is reviewed against the 2012 TAS, and an earlier registration falls under the earlier 1994 TAS. Confirm the current wording in 16 TAC Chapter 68 before relying on the cutoff. For older GCHS property, the TAS text itself helps: each altered element must meet the current requirements (Section 202.3), while path-of-travel elements previously built or altered under the April 1, 1994 TAS have safe harbor and are subject to the 2012 TAS only when those elements are themselves being altered (Section 202.4).

The Registered Accessibility Specialist's role

A Registered Accessibility Specialist, an RAS, is a specialist licensed by TDLR who can perform plan review and site inspection work on a registered project. TDLR issues the license and can sanction an RAS, so the RAS answers to the regulator and not only to the owner who engages the review. How reports are filed and by what deadlines is set by TDLR's rules in 16 TAC Chapter 68, which this lesson does not restate, so check them before relying on a date.

Owner responsibilities in the process

As the owner, GCHS is responsible for registering a covered project (TDLR treats registration after construction is complete as late), for having the plans reviewed and the finished work inspected by TDLR, an RAS, or a contract provider, and for retaining project documentation, so that corrective work identified during inspection can be documented and resolved on the timelines TDLR's rules set rather than left open indefinitely.

How this lesson connects to the technical lessons before it

Lessons 1 through 8 covered what TAS requires technically: scope, building blocks, routes, doors, stairs, restrooms, signage, and kitchens. This lesson covers the administrative side, registering the project, paying the fees, and working with the RAS who checks the technical work against those exact requirements. Getting the technical details right in lessons 1 through 8 is what makes the registration and inspection process in this lesson go smoothly rather than surface corrective work late in a project.

TDLR project registration and review sequence A sequence diagram showing a project reaching the fifty thousand dollar construction cost threshold, registering with TABS before construction with a one hundred seventy five dollar fee, plan review and site inspection with a TDLR special fee of two hundred fifteen dollars per hour, and findings reported under TDLR rules. $50,000+ project registration threshold TABS registration $175 fee, before construction starts RAS plan review and site inspection TDLR special fee $215/hr Report to owner Filed per TDLR rules Late filing fee: $300 (check TDLR fee page) Which TAS edition? Registered on/after 3/15/2012: 2012 TAS Registered before: 1994 TAS applies instead
Registration and review are administrative, not technical, but they check a project against the technical requirements from lessons 1 through 8, with findings reported under TDLR's rules.

Practice questions

1. At what construction cost threshold must a project be registered with TDLR through TABS?

  1. $10,000
  2. $25,000
  3. $50,000
  4. $100,000

2. Does a project below the $50,000 registration threshold still have to meet TAS's technical requirements?

  1. No, projects below the threshold are entirely exempt from TAS, because the standards attach only to projects that register with TDLR at all
  2. Only if the owner voluntarily requests a review
  3. Technical compliance only applies to projects above $100,000
  4. Yes; registration and technical compliance are separate questions, and the underlying TAS requirements still apply to the construction

3. What is the standard TABS filing fee?

  1. $500
  2. $100
  3. $175
  4. $250

4. What is TDLR's listed late project filing fee, which the fee page ties to a project registered after construction is complete?

  1. There is no late fee; the $175 filing fee applies whenever a project registers, however late
  2. $100 on top of the standard fee, capped at the cost of the plan review
  3. $450, the $175 filing fee plus a $275 penalty for registering late
  4. $300, listed by TDLR as the late project filing fee

5. What is TDLR's hourly rate for special review or inspection services, and what is the minimum charge?

  1. $300/hour, 1-hour minimum
  2. $150/hour, 2-hour minimum
  3. $175/hour, no minimum
  4. $215/hour, 1-hour minimum

6. Is the special review/inspection fee the same as the TABS filing fee?

  1. The review/inspection fee replaces the filing fee entirely
  2. Yes, they are the same fee charged twice
  3. No; the filing fee is a flat $175 paid at registration, while the review/inspection fee is a separate $215/hour charge for the actual review work
  4. No, only one of the two fees is ever charged on any given project

7. The 2012 TAS took effect March 15, 2012. Which edition would generally apply to a project registered on March 20, 2012?

  1. The 2012 TAS, because it was registered on or after March 15, 2012
  2. The 1994 TAS, because construction on most such projects started before 2012 and the earlier edition governs until completion
  3. Whichever edition the owner prefers
  4. Both editions apply simultaneously

8. What determines which TAS edition applies to a project, registration date or construction completion date?

  1. Neither; it depends solely on the building's original construction year
  2. Registration date
  3. The date the owner takes occupancy
  4. Construction completion date

9. A building's path-of-travel elements were built under the April 1, 1994 TAS. A primary function area is later altered under the 2012 TAS. Must those unaltered path-of-travel elements be retrofitted to the 2012 TAS solely because of that alteration?

  1. Yes, all existing elements update automatically to the newest edition whenever any part of the building is altered anywhere on the site
  2. No; they have safe harbor and must meet the 2012 TAS only when the path-of-travel elements themselves are being altered
  3. Yes, but only if the building is over 20 years old
  4. The edition question does not arise for alterations, since TAS applies only to newly built structures

10. What does a Registered Accessibility Specialist (RAS) do on a registered project?

  1. Only reviews plans and never inspects the completed site, leaving field verification to the local building official
  2. Represents the owner's interests exclusively, with no accountability to TDLR and no exposure to sanctions
  3. Issues the building's certificate of occupancy
  4. Performs plan review and site inspection as a specialist licensed by TDLR

11. Why does it matter that an RAS is licensed by TDLR rather than acting only as the owner's advocate?

  1. Because TDLR licenses and can sanction RASs, the review answers to the regulator and not only to the owner
  2. It has no practical effect; the license is only a title, and an RAS's review carries no more weight than any consultant's opinion
  3. It means the owner never receives a copy of the findings
  4. It only matters for state-owned buildings

12. What are GCHS's responsibilities as an owner on a covered project, according to this lesson?

  1. Only paying the filing fee; the RAS handles everything else
  2. Registering the project, having the plans reviewed and the finished work inspected, and retaining documentation so corrective work can be resolved on TDLR's timelines
  3. Registering only after construction is complete
  4. Owners have no responsibilities; TDLR manages the entire process

13. How does this lesson's administrative content relate to lessons 1 through 8?

  1. It covers the administrative process (registering, fees, the RAS) that checks the technical requirements from lessons 1-8
  2. It only applies to projects that fail their technical review and are then referred to TDLR for corrective action
  3. It replaces the technical requirements from lessons 1-8 with a simpler administrative standard once a project is registered
  4. It is entirely unrelated; registration has nothing to do with the technical work

14. A GCHS project costs $48,000 in construction. Must it register with TABS?

  1. Yes, because it is close to the threshold
  2. Registration depends only on the building's use, never its cost
  3. No, it falls below the $50,000 threshold, though it may register on the Special Project Registration form for the $175 fee, and TAS's technical requirements still apply
  4. Yes, all projects regardless of cost must register

Glossary

TABS
Texas Architectural Barriers online System, TDLR's system for registering covered construction projects.
Registration threshold
The $50,000 estimated construction cost at which a project must register with TDLR through TABS.
RAS
Registered Accessibility Specialist; a TDLR-licensed specialist who can perform plan review and site inspection on a registered project.
Special review/inspection fee
TDLR's listed $215-per-hour charge, one-hour minimum, for special review or inspection services, separate from the flat filing fee.
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