Not necessarily. The result on a d20 to hit roll can easily double as a hit location roll, for example. One could arbitrarily determine what % of overall hit points would be assigned to each hit location (call it head, torso, and each limb - no need to go to the nth degree). The hard part would be in determining what percentage of hit points at each location results in what penalties. I'd rework critical hits so that they result in a chance for bleeding out, going into shock (which would require a Con check to shake off), etc.
I *really* loved Twilight:2013's system which inspired me to think about how to use similar concepts for 5e. That system calculated a "base" hit points per each hit location and then had multiples of those base hit points to define when you suffered more serious wounds. Rather than subtracting the damage from hit points until you hit zero, the hit points just acted as cues for wound levels. Those wound levels determined penalties and special effects. Sounds complicated, but since all of the hit point multiples where listed on your character sheet, all you had to do was compare damage received at that location to the hit points. "Got shot in the torso for 12 points. That exceeds your moderate wound threshold for the torso. -2 penalty on all physical actions, perform a check to see if you go into shock - fail the check by enough and you start bleeding out." They had four different wound levels with an optional rule for insta-kills to simulate head shots, being blown up by an IED, etc.
It would require some work to tailor such concepts to a fantasy or sci-fi game, but I imagine it could be done (I saw someone had adapted the rules for use in their Firefly game). Its a shame that TW:2013 went out of print since the core mechanics were supposed to be tailored for use with fantasy/sci-fi settings and released as a stand-alone system.