Arizona Department of Health Services Long Term Care Facility Regulation Follow-up Report

A September 2019 Arizona Auditor General Report found ADHS hadn’t been investigating (or not timely investigating) long-term care facility complaints. The Auditor General made 5 recommendations to the Department. ADHS (Colby Bower) replied to the Auditor’s report by disputing most of the findings rather than admitting to the shortcomings and committing to make changes.

Because the Christ-era Department disputed the 2019 findings and made no effort to correct the deficiencies- it comes as no surprise that the Auditor General’s May 2022 30-month follow-up found ADHS had not implemented any of the recommendations.

The Auditors found additional significant complaint-prioritization and investigation failures, including inappropriately closing most high-priority complaints without a required on-site investigation.

The Auditors read ADHS the Riot Act in the May 2022 report and made 4 additional recommendations in our 30-month follow-up report. Perhaps the most shocking findings were:

Between 7/1/19 and 4/21/21 ADHS (under the leadership of former Director Christ and Assistant Director Colby Bower) lowered the priority level of 98% of their open high priority complaints, giving them months more time to investigate and giving the appearance they were making improvements. ADHS leadership then CLOSED 79% of those former high priority complaints without ever doing an investigation.

See Auditor General’s Office Produces Scathing Review of ADHS’ Nursing Home Complaint Investigations During the Director Christ Era

AZ Failed to Properly Investigate Nursing Home Complaints, Report Says

Last week the Auditor General released a newer update… a 36-month review of the 2019 initial report. Last week’s review is the first follow-up report examining ADHS’ actions after Cara Christ &  Colby Bower left the agency for Blue Cross Blue Shield of AZ.

Good news this time. The auditors found ADHS had begun making progress correcting the earlier egregious findings. It’s clear that under the new leadership (after Christ/Bower left) ADHS had internally conceded there were large shortcomings in their performance and they began to make positive changes.

Arizona Department of Health Services Long Term Care 36-month Review (

The attitude that things need to change began in late 2022 as shown by the fact that the Auditors found ADHS had begun implementing 6 of the Auditor’s 9 recommendations. Importantly, the agency did not dispute the findings as they had done during Director Christ’s tenure.

Tom Salow, new chief of the Licensing Division, posted a blog last week that reflects the new attitude at the Agency committing to fix their problems rather than sweeping them under the rug as had occurred during the previous administration.

See: A recent audit of the Long Term Care Licensing system shows room for improvement to address issues with complaint processing ADHS Blog (

“There were significant changes to the ADHS Division of Licensing leadership team prior to the release of the 2022 Report. Our current leadership team agrees with the AZAG that no excuses can justify the additional findings in the 2022 Report, and the failure to implement the recommendations from the 2019 Report. We recognize the importance of correcting these issues to help ensure the health and safety of the vulnerable populations that reside in Arizona’s LTC facilities.”

I was able to attend a stakeholder meeting last week at ADHS and was impressed with the candor the team spoke with as they admitted that the findings of the 30-months follow up were a ‘wake up call’.

The problems and staffing shortages that are a legacy of decisions made during the Ducey Administration didn’t develop overnight – and fixing the damage won’t be immediate, but I’m finally confident they are honestly working to correct the disturbing findings in the 2019 and 2022 Audit reports.

See: Report: Arizona Health Department may still put seniors at risk (