ADHS 2025 Rule Updates: What Arizona Facility Operators Need to Know Right Now

If you operate an assisted living facility or behavioral health residential facility (BHRF) in Arizona, 2025 is not a year to sit back and assume your compliance program is still current. The Arizona Department of Health Services (ADHS) has rolled out some of the most significant regulatory changes in recent memory — and the deadlines are either already here or fast approaching.

So, is your facility ready? Let's break down what's changed, what it means for your day-to-day operations, and how you can stay ahead of the curve.

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Memory Care Is Now a Licensed Service Category

One of the biggest shifts for assisted living facilities comes from House Bill 2764, which adds a formal "Memory Care Services" license subclass under Arizona law. Effective July 1, 2025, any ALF that provides or advertises memory care services must hold this new subclass from ADHS — no exceptions.

What does that mean in practice?

• New intake requirements: Facilities must obtain a medical provider certification confirming that each resident's admission to a memory care setting is appropriate.
• Biannual physician reviews: Every memory care resident must be re-evaluated by a physician or medical provider every six months to confirm that placement remains appropriate.
• Environmental standards: Facilities need specialized signage, visual cues, and a secure physical layout designed to prevent elopement — plus a written Elopement Evacuation Plan and biannual drills.

If your facility has been informally offering memory care services without a formal designation, now is the time to get your application in order. Missing this deadline could put your license at risk.

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Staff Training Just Got More Specific (and More Mandatory)

Alongside the new memory care license subclass, HB 2764 introduces mandatory dementia-specific training for staff working in memory care settings:

• Direct care staff and contractors: 8 hours of initial ADHS-approved dementia training, plus 4 hours of annual continuing education
• Managers: An additional 4 hours of memory care leadership training on top of the above

Training must be conducted in person by qualified trainers and cover topics like communicating with cognitively impaired residents and managing challenging behaviors. Documentation of completed training must be available during inspections.

Are your training records organized and inspection-ready? This is exactly the kind of requirement that catches facilities off guard when a surveyor shows up unannounced.

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APS Registry Checks Are Now Required for All Staff

Here's one that many facilities may have overlooked: HB 2764 requires ALFs to check all staff against the Adult Protective Services (APS) Registry. The deadline for checking current employees was March 31, 2025 — and all new hires must be checked before they begin work.

Anyone found on the APS Registry for substantiated claims of abuse, neglect, or exploitation is prohibited from working in an ALF. Proof of these checks must be kept in each employee's personnel file.

If you haven't completed these checks yet, this needs to move to the top of your to-do list immediately. ADHS's new enforcement framework includes civil monetary penalties of up to $1,000 per resident, per day for violations — and a new "immediate jeopardy" classification for situations that pose serious risk of harm to residents.

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Hospital Transfers Now Require Standardized Documentation

Effective January 1, 2024, Senate Bill 1157 established new information-sharing requirements when ALF residents are transferred to hospitals. When a resident leaves your facility via emergency services, you must provide a standardized written document that includes:

• Reason for transfer
• Current medication list and allergies
• Physician and power of attorney contact information
• Medical history and advance directives

Hospitals are also now required to send a comprehensive discharge plan back to your facility when a resident returns. This is a two-way street — and it's designed to reduce care gaps during transitions.

If your facility doesn't yet have a standardized transfer form that covers all of these elements, ACG Compliance can help you build one as part of our policies & procedures development services.

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BHRFs: The Licensing Process Has Gone Fully Digital

For behavioral health residential facilities, the most immediate operational change is the mandatory transition to ADHS's electronic Licensing Management System (LMS). Paper applications and renewals are no longer accepted — everything must go through the online portal.

The good news? This change has dramatically reduced processing times, from a median of 124 days down to approximately 25 days. The catch is that your administrative team needs to be fully trained on the new system and using it exclusively.

ADHS is also increasing oversight across the board for BHRFs, including more frequent inspections and 60-90 day "touchpoints" for newly licensed facilities. If you're in the early stages of licensure, expect a check-in from ADHS — and make sure you're ready to demonstrate compliance from day one.

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What Should You Do Right Now?

Whether you operate an ALF, a BHRF, or both, here's a practical starting point:

• ALFs: Confirm whether your services qualify as "memory care" under the new ADHS definition and apply for the license subclass if needed. Complete APS Registry checks for all current staff if you haven't already. Update your hospital transfer documentation to meet SB 1157 requirements.
• BHRFs: Ensure your team is using the electronic LMS for all licensing activities. Review your inspection readiness and prepare for increased ADHS oversight.
• All facilities: Review your policies and procedures against the new requirements. Update staff training records and make sure documentation is organized and accessible.

Feeling overwhelmed by the scope of these changes? You're not alone — and you don't have to navigate them by yourself.

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How ACG Compliance Can Help

At ACG Compliance, we specialize in helping Arizona assisted living and behavioral health facilities stay ahead of regulatory changes — not scrambling to catch up after the fact. Our services are designed specifically for Arizona operators:

• Licensing & Compliance Setup Package ($2,500–$5,000): End-to-end support for new licensure or license subclass applications, including the new Memory Care Services subclass
• Policies & Procedures Development: Customized, ADHS-compliant policy manuals that reflect the latest rule changes
• Licensing Readiness Checklists: Step-by-step tools to confirm your facility meets every current requirement before a surveyor arrives
• Staff Documentation Templates: Ready-to-use forms for APS Registry checks, training records, hospital transfer documentation, and more
• Audit Readiness Support: Proactive review of your compliance program so you're never caught off guard

The regulatory landscape in Arizona is moving fast. The facilities that thrive are the ones that treat compliance as an ongoing process — not a one-time checkbox.

Ready to make sure your facility is fully aligned with the latest ADHS requirements? Visit us at acgcompliance.com or reach out directly at [email protected]. We're here to help you build a compliance program that protects your residents, your staff, and your license.