Will Humble Opioids, Wills Blog

More Opioid Settlement Money on the Way

Plans to Use the Funds Underway in Some Counties: Little Action at the State Level

Arizona Attorney General Mayes announced this week that Arizona will be getting an added $380 million from a national opioid settlement with drug makers Teva and Allergan, as well as CVS and Walgreens pharmacies. This is on top of the $542M AZ is set to receive over the next 18 years to combat the ongoing opioid epidemic.

This new money ($380M) will arrive over the next 15 years, with $213 million going to local governments and $167 million dedicated to the state level. The tap on the new money is supposed to turn by the end of 2023. The new bolus brings Arizona’s share of money to about $1 billion.

Because the new settlement is so fresh, there’s not much detail about how and when that will be disbursed. However, the earlier settlement ($542M) is going out to all the 90 AZ cities and towns and all 15 counties who signed on to a framework called the One Arizona Memorandum of Understanding (One Arizona Plan).

The One Arizona Plan provides funding for programs to address and ameliorate opioid abuse, and includes reporting requirements for greater transparency of how money is used:

  • 56% of the first settlement is going to local governments for opioid mitigation programs.
  • 44% of the total settlement goes to a State for yet to be determined interventions.
  • Funds must be spent following approved, nationally recognized strategies to pay for future costs incurred by the State and local governments to address the opioid epidemic.

The state opioid funds went to the Attorney General’s Office and neither AHCCCS nor ADHS have received any of the funds. The Attorney General’s Office has suggested legislative appropriation is necessary to spend the state portion of the funds.

The funds are in some ways restricted in that they are supposed to go directly to relief and resources related to opioids, including to diversion programs to prevent people from going to prison for an addiction or substance-use disorder. Arizona is one of 15 states who’ve agreed to make settlement expenditures public: https://www.opioidsettlementtracker.com/publicreporting/#promises

There still isn’t a lot of granularity about how the state and local jurisdictions intend to invest the funds… but county staff is certainly undergoing planning to make sure that they wisely use the funds. A priority for Pima County is to make sure they get input from the community before making decisions- always a good idea.

County health departments apparently don’t need appropriation authority from the legislature and are well into their planning. Here’s a link to what Maricopa has going: Opioid Settlement Planning | Maricopa County, AZ. Pima County has already begun to spend some of their funds, with their Board of Supervisors allocating $180,000 for the immediate purchase and distribution of Narcan (this is a very small portion of what Pima is allocated so you can think of this as an initial down payment on interventions): Opioid mitigation efforts underway in Pima County – AZPM. Next fiscal year, the health department plans to hire staff to oversee community outreach efforts addressing mental health and substance misuse throughout the county.

Arizona Opioid Settlement | Arizona Attorney General (azag.gov)

Will Humble Assurance & Licensure, Behavioral Health, Suicide Prevention, Wills Blog

Governance Reform of the Arizona State Hospital Goes Up in a Puff of Smoke

The two-year effort to improve care at the Arizona State Hospital by building a more accountable and unconflicted governance structure went up in a puff of smoke this week. Senate Bill 1710 – which would have corrected major governance flaws that led to terrible unmitigated outcomes during the Ducey administration vaporized. More on how it happened in a bit.

AZPHA and other stakeholders interested in improving care at ADHS’ Arizona State Hospital have been trying to extricate ASH from the ADHS to remove the conflict of interest that impaired care during the Ducey administration. Rather than being housed within ADHS, the ASH Superintendent would have reported to an independent appointed governing board instead of the ADHS Director, removing the conflict of interest wherein the ADHS is responsible for both running and regulating ASH.

The lack of independent regulation & oversight of the Arizona State Hospital results in poor accountability and can lead to unchecked substandard care when the ADHS Director soft-pedals regulatory oversight to give the appearance that the facilities are providing care that meets standards.

There’s evidence that this occurred during the Ducey Administration.  For example, ADHS’ licensing division investigated multiple suicides and a homicide over the last couple of years and concluded that no significant operating deficiencies led to those deaths and no enforcement actions were advanced. Suicides and homicides only occur in the presence of significant deficient practices that would normally result in enforcement actions.

See: Fixing the Governance Flaw at Our Arizona State Hospital: A Primer

Here’s what went down this week to stop this important governance and accountability reform.

As you’ll recall, SB1710 passed the Senate with wide bipartisan support with a vote of 27-2. The bill got unanimous support in the House Health Committee and passed the Rules Committee. That’s when things got sticky.

Last week, the Governor’s team started expressing ‘deep concern about the civil rights implications of the bill’ (I still don’t know what those civil rights concerns are). That, and the fact that ADHS had signed up against the bill, sent the message to the bill’s sponsor (Senator Gowan) that if SB1710 reached her desk she’d veto it (state agencies never oppose a bill unless directed to by a governor’s team).

I’m reading between the lines here…  but I’m guessing at this point Senator Gowan was thinking “I wonder if I can get at least something out of the bill if I have it amended to become a completely different bill”. Along comes Representative Montenegro in the House Committee of the Whole on Monday with an amendment to SB1710 that strips out 100% of the language that built more accountability and governance. He then inserts language that would allow some physician assistants to help psychiatrists with certain kinds of assessments – something totally unrelated to the original bill.

The amended version – which does nothing to reform ASH or ADHS – then passes the full House on Tuesday, passes the Senate again in its new trivial form, and is sent to the governor for her certain signature. The title of the bill that she’ll be signing is still called SB1710 State Hospital; Governing Board; Governance… but the bill has absolutely NOTHING to do with the State Hospital or ADHS.

Editorial Note: As a result of the sad turn of events this week, the fox will continue to watch the henhouse. Under some administrations, the fox (the ADHS Director) can be trusted. In other administrations they absolutely cannot, as we observed during the Ducey administration. Whether we’ll be able to trust ADHS to honestly regulate ASH during this administration remains to be seen.

We won’t know the answer until ADHS finally has a permanent agency director and we observe how she or he behaves vis a vis their responsibilities to honestly regulate the Arizona State Hospital. In the mean-time, patients and their families will need to continue to wait for meaningful structural reform.

See: AZ Capitol Times YELLOW SHEET REPORT June 13

Will Humble Affordable Care Act, Public Health Law, Wills Blog

ACA’s Preventive Services Requirements are the Next Target for Opponents of the Affordable Care Act: Braidwood Management v. Becerra

One of the pillars of the Affordable Care Act is the requirement that most private insurance plans cover preventive health services without any patient cost-sharing. The Act is specific about what preventive health services include (e.g., a range of services including screening tests, immunizations, behavioral counseling, and certain medications).

The ACA started with the preventive health services that were recommended in 2010 (when the law passed). As new preventive services are added by the U.S. Preventive Services Task Force (USPSTF), Advisory Committee on Immunization Practices (ACIP), or (HRSA), private health plans need to add them w no cost sharing. As previous recommendations change or are modified, private health plans need to cover those services in the next plan year.

The Plaintiffs in the Braidwood v. Bererra case are trying to get rid of no co-pay coverage for preventive services. Their argument is that  those task forces and committees don’t have the ability to make policies like that because they violate the Appointments Clause of the US Constitution.

Specifically, they’re arguing that only “officers of the United States” can make decisions and they must be appointed by the president and senate confirmed. The judge U.S District Judge Reed O’Connor in Texas (the go-to judge to file challenges to the ACA & women’s reproductive rights) agreed with the Plaintiffs that members of USPSTF, ACIP and HRSA are “officers of the United States”, weren’t appointed by the President (they’re appointed by the HHS Secretary) and therefore their decisions can’t be implemented as policy under the ACA.

Plaintiffs make another argument that the USPHTF recommendation for certain populations to prevent HIV violates their religious freedom. The judge took that bait too.

On March 30, 2023, District Court Judge O’Connor issued a ruling, striking down the ACA’s coverage requirement for preventive services. That ruling blocks the federal government from requiring health plans to cover services recommended or updated by the U.S. Preventive Services Task Force (USPSTF) on or after March 2010.

There are 53 Preventive Health Services with an A or B rating by the USPHTF (A & B Recommendations). All but two of these recommendations have been updated or are new since 2010.

See: Mayes: Ruling dropping preventive drugs from insurance would be devastating | Arizona Capitol Times

HHS appealed the ruling to the United States Court of Appeals for the 5th Circuit. A couple of weeks ago the Circuit Court of Appeals stayed the district court’s ruling, meaning HHS can continue enforcing the preventive services requirement while the case proceeds through the courts.

What If the Courts Ultimately Uphold O’Connor’s Decision?

If the Texas District Court ruling ultimately holds, private health plans would still have to cover no cost-share coverage of preventive health services as they existed in 2010. Private health plans would no longer be required to cover any preventive service identified after 2010 (for example screening for major depressive disorder in adolescents 12-18 y.o.). Basically, it would stop the clinical practice clock in 2010.

For services recommended before 2010, HHS could only hold health plans accountable for covering services as they existed in 2010. For example, prior to 2010 colorectal screening was recommended for people 50 – 75 years old. Based on clinical evidence, that has since been changed to 45-75 y.o.

That would mean required coverage would be limited to clinical practice standards as they existed 13 years ago.

Medicine and public health are iterative disciplines. Best practice standards shift over time as we learn more from evidence and studies. Freezing clinical and public health practice in the year 2010 makes no sense.

In any event, it will be several months if not years before we know the fate of preventive health services coverage in the ACA. The decision will most likely be made by the U.S. Supreme Court.

Note: (Credit to KFF): “Overturning the preventive services requirement broadly would have significant implications for coverage of a broad range of clinical preventive services. Should the final decision for this case be found in favor of the plaintiffs, and applied nationwide, then millions of people may be vulnerable to loss of guaranteed coverage of preventive services without cost sharing. It will again be at the discretion of plans and employers to determine what preventive services will be covered and whether they will charge cost-sharing, lowering premiums in some cases, but likely creating a patchwork of coverage for these services.”

The Secretary of HHS has the authority to determine coverage for preventive services for Medicare beneficiaries. The ACA eliminated Medicare cost sharing, including coinsurance and deductibles, for most preventive benefits that are rated A or B by the USPSTF, beginning in 2011, and authorized the Secretary of HHS to add coverage for new preventive services.

Coverage under Medicare for several preventive services, including some rated A or B by the USPSTF, predated the ACA and is specified in statute, and therefore would not be affected by any ruling on the current litigation.

See: Mayes: Ruling dropping preventive drugs from insurance would be devastating | Arizona Capitol Times

Will Humble Assurance & Licensure, Behavioral Health, Emergency Management, Wills Blog

Legislative Session Update: Week of June 12

Both the House & Senate will be back in session for a couple days or so this week. Two important bills will be debated in the Committees of the Whole this week. Both may roll over to Third Read votes (final floor voting).

The House is considering SB1710 – an effort to correct the governance flaw at our Arizona State Hospital. Since 1974 ADHS has been responsible for both running & regulating ASH, obviously a conflict-of-interest reminiscent of the old saying: “The fox is watching the henhouse.”

Under some ADHS directors the system worked OK and ADHS’ licensing division did an honest job regulating ASH. 

However, as we observed during the Ducey administration, sometimes that’s not the case and the lack of independent regulation & oversight results in unchecked substandard care because ADHS leadership (the Director) soft-pedals regulatory oversight to give the appearance that the facilities are providing care that meets standards to ‘keep things quiet’.

See: Fixing the Governance Flaw at Our Arizona State Hospital: A Primer

SB1710 would provide checks and balances in the system by having the Superintendent of ASH report to an independent 5-member Board beginning 1/1/25. The ADHS licensing division would then be able to regulate the hospitals without a conflict of interest – reducing the chances that what happened during the Ducey administration would be repeated. See: SB1710 Fact Sheet

Senate COW will debate HCR2039 – a resolution that would limit all emergency declarations to just 30 days. The legislature would need to approve 30-day extensions.

Because this would change the constitution, it would need to be approved by the voters. If it passes the Senate this week, it’ll go directly to the 2024 ballot. If the voters end up approving it, the Recovery phase of emergencies would evaporate.

2023 AZ’s 2023 Legislative Session: The Good, The Bad, The Close Calls, & The Missed Opportunities
View Our Webinar Summarizing the 2023 Legislative Session: https://us06web.zoom.us/rec/share/vEOWDWlR3BW1D3gaJBRsH4AhduOLA83IuSD_byKYHmBPMulwKmLQJN3D3D7z_4Ed.Ih7vqw7INNyYNtTI Passcode: 5=5FjjNC
Passcode: 5=5FjjNC
See: Ballot Referral Could Dismantle Arizona’s Emergency Management System
Will Humble Professional Development, Wills Blog

What’s the Solution to AZ’s Doctor Shortage? More Medical Students or More Residencies?

It’s no secret that Arizona has a physician shortage that’s getting worse, not better. The shortage is most acute in rural Arizona and worse in the key specialty areas that do the most to improve community health: primary care, family medicine and a very few specialties like obstetrics. According to research by the UA Center for Rural Health, Arizona has a shortage of 560 primary care physicians right now and 1,941 more will be needed by 2030 because of retirements, population increases, higher rates of chronic disease and an aging population.

At first glance most folks might think the solution is simple… just expand the number of medical schools and the sizes of the enrollment per school in Arizona. Makes intuitive sense, right?

Mostly wrong.

The bottleneck in getting more physicians practicing in the field in AZ isn’t the number of medical school students in the pipeline…  it’s mostly the number of residency slots that are available in AZ & geographic and specialty distribution of those residencies.

Nationally, about 42,000 students finish allopathic (MD) medical school each year (2022 data) but the number of residencies available for medical school graduates hasn’t kept pace with the increase in students, meaning that a bit over 20% (8,400) of medical school graduates are left out – unable to get the residency slot they need to complete their training so they can practice.

In 2022 about 80% of the total 42,549 applicants were matched with a residency program. Match rates weren’t equal across the board. 93% of U.S. allopathic (MD) medical students were matched but only 61% of international medical graduates 58% of non-U.S. citizens matched. Doctors of osteopathy (DO) had lower match rates than MD students.

The lowest hanging fruit for getting more of the right kinds of doctors into the field (and in the right places) is building more residency slots in Arizona (especially in things like family medicine, primary care, and obstetrics etc.)… not necessarily graduating more AZ medical students. Placing those primary care residency slots in rural community-based settings is crucial.

Why? Because physicians are likely to practice near where they complete their residency (not where they finish medical school).

We need to expand the number of medical residency training programs in rural areas to fill gaps in care – doctors tend to settle within 100 miles of where they do their residency (especially family medicine specialists).

What Are Some Solutions?

Building teaching health centers at rural federally qualified health centers in collaboration with a rural hospital is a terrific tool for building and retaining a primary care workforce like the Teaching Health Centers at North Country Healthcare and El Rio Community Health Center:

El Rio Health is helping to create a new model of medical education in what is known as a Teaching Health Center. This concept emphasizes multidisciplinary, inter-professional educational opportunities within community health centers. This allows students and residents with a passion for community medicine to obtain their training directly within the community health center environment.

Dr. Doug Spegman, El Rio’s Chief Clinical Officer:

These residencies provide traditional, clinical training in acute and chronic care management and also emphasize preventive care and wellness. This includes a comprehensive approach to understanding healthcare disparities and social determinants of health that are often overlooked barriers to care and patient wellness.

Arizona’s budget agreement this year allocated $5M to the AZ AHEC program to specifically get the pieces together for more teaching health center collaborations like El Rio and North Country going.

“One-Two” residency programs—one year in an urban, academic hospital followed by two years in a rural area are effective in rural recruitment, while providing the amenities of academic residency programs centered around large, academic hospitals.

Other effective strategies are loan repayment programs like Arizona has, and the National Health Service Corps (NHSC says 81% of recent participants remained in rural areas after completion of their service agreements).

There are several pieces that need to come together to get more residency sites up and running. Among the most important are funding the startup costs at new clinical training sites and recruiting qualified primary care and key specialty preceptors.

Focusing solely on getting more medical students to study in AZ and thinking that alone will build more in-state practitioners is off target. Let’s hope public resources go to residency development and not just more medical students.

Arizona State University announces plans to create medical school

What does a new medical school mean for Arizona State University?

ASU will open its first medical school to address health care shortage

What ASU’s new medical school means for Arizona’s health care industry | KJZZ

Will Humble Assurance & Licensure, Wills Blog

ADHS’ Regulation of Nursing Homes Shows Some Improvement After Years of Scandal

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 (azauditor.gov)

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 (azdhs.gov)

“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 (azcentral.com)

Will Humble State Legislature, Wills Blog

Chad Campbell Tapped as Hobbs’ New Chief of Staff

Former Democratic lawmaker Chad Campbell will begin his job as Governor Hobbs’ chief of staff tomorrow. The move came as no surprise. Pretty much everybody expected Campbell to be asked to serve in the post – in large part because he brings precisely the right skill set to the job – and has the right personality for the post.

Campbell served four terms in the House from 2007 to 2014, including two terms as minority leader. After that he was at Strategies 360 and then Lumen Strategies (both consulting companies).

He has a reputation of working well with both Republicans and Democrats and has a no-nonsense style that many politicians – and agency directors – will appreciate. He was a key reason why Governor Brewer was able to get the deal to restore and expand AHCCCS back in the day.

Good call

Will Humble Air Quality, Climate Change, Wills Blog

AzPHA Urges Corporation Commission to Deny APS’ 13.6% Rate Increase: Proposal Doubles Down on Coal

Arizona Public Service has filed for a rate increase with the Arizona Corporation Commission that would result in an annual net rate increase of $460 million, which would result in a net 13.6% bill increase for ratepayers. APS is asking captive ratepayers to pay for the continued operation of their Four Corners and Cholla coal-fired plants through 2031. The also have removed their original plan to have the Four Corners plan go seasonal starting this year.

For these reasons and others, AzPHA submitted the letter below to the Commission urging them to oppose the rate request and urge the utility to return to the Commission with a request that includes more investment in renewable sources and energy efficiency and relies less on coal.

See AzPHA’s APS Rate Increase Opposition Letter

The Commission is having a Public Comment session on June 7 from 6 – 8:30pm.  To attend in person, go to 1200 West Washington Street, Phoenix, Arizona 85007 and enter from the back or north side of the building. You will need to go through security to enter. To speak in person, either complete a “Request to Speak” form on one of the kiosks in the lobby at the ACC or fill out a paper slip or use your computer or mobile device ahead of time and request to speak via the ACC Portal here https://efiling.azcc.gov/cases. To provide telephonic comments, phone 1-877-309-3457, then enter the passcode 801972877#.

SUBMIT WRITTEN COMMENTS TO THE DOCKET

To submit a public comment, go to https://efiling.azcc.gov/cases, Click on “Make A Public Comment in a Docket.” Complete your information and click “Submit.”  Be sure to include the docket number at the top of your comments – Docket NumberE-01345A-22-0144

Action kit for APS Rate Case 2023

____________

May 31, 2023

RE: APS 13.6% Rate Increase Request: Docket E-01345A-22-0144

Dear Commissioners,

The Arizona Public Health Association respectfully urges the Arizona Corporation Commission to deny Arizona Public Services’ $460M rate increase – which would result in a net 13.6% bill increase for ratepayers. As an alternative, we request you urge the utility to return to the Commission with a request that includes more investment in renewable sources and energy efficiency and relies less on coal.

AZPHA understands that public utilities like APS have capital needs and variable costs that periodically require rate increases to ensure a reliable supply of energy and meet anticipated peak demands. However, we believe this request (Docket E-01345A-22-0144) is unreasonable and excessive as it focuses investments on expensive energy sources (coal) rather than cheaper and cleaner renewable sources and underleverages energy efficiency.

If implemented as requested, this rate increase would pose an avoidable burden on vulnerable and low-income Arizonans. Why do I use the word avoidable? Because with better planning, the utility could acquire cleaner energy sources with lower operating costs that would moderate this excessive rate increase request.

For example, APS’ request rests on an existing strategy to continue operation of their outdated coal-fired power plants, even though those plants are no longer economical to operate and are more costly than clean energy alternatives.

Since the last rate case, APS has spent hundreds of millions of dollars in capital expenses and operations and maintenance costs at the coal fired Four Corners Generating Station and Cholla Power Plant. The rate increase before you rest on APS’ plan to spend hundreds of millions more to keep Four Corners operating until 2031. We think this is short-sighted and harmful to Ratepayers.

If APS were asking Ratepayers for an increase to cover capital costs to increase renewable capacity (solar) while quickly phasing out coal, we could understand the Commission’s decision to approve the rate increase. However, that is not the request before you.

This request doubles down on inefficient and expensive energy production by continuing to run the costly (and dirty) Four Corners and Cholla Power Plants through 2031 while under-investing in renewable sources and energy efficiency.

APS could save ratepayers money, reduce pollution, and moderate their rate increase request by retiring the Four Corners Power Plant before 2031 and replacing it with lower-cost renewable energy. At a minimum, their plan should have switched Four Corners to seasonal operations this year as originally planned.

In addition to over-committing to coal sources (rather than less expensive renewable sources of energy), APS’ request fails to increase resources to incentivize energy efficiency – the lowest cost energy option for meeting peak demands.

APS’ rate increase should have included increased investments in energy efficiency, which can reduce customer bills. Investing in energy efficiency helps keep electric bills lower and as noted above can lower energy burden on those with low incomes. Investments

in efficiency result in all electricity customers paying less than it would cost to generate that same power from more expensive alternatives.

In short, we understand that utilities like APS require periodic rate increases to plan for growth, meet customer needs, and accommodate peak loads. However, we believe the request (as submitted) focuses too much of APS’ resources on expensive energy sources (coal) rather than pressing forward with cheaper renewable sources and leveraging energy efficiency – strategies that are better mid-term approaches to serving and protecting Ratepayers.

As a final note, we commend APS for including $10M/year in coal community transition funding (over 9 years) for communities that would be impacted by their belated plan to close coal-fired plants in 2031. A final proposal should accelerate the use of those funds over a shorter time period to accommodate a more rapid decommission of those plants.

Sincerely,

Will Humble, MPH

Executive Director, Arizona Public Health Association

Will Humble Behavioral Health, Wills Blog

How Does ADHS Regulate Sober Living and Residential Behavioral Health Facilities

How ADHS regulates sober living homes and behavioral health residential facilities

In Part 1 of ADHS’ Licensing blog series, they covered what a sober living home (SLH) actually is and  explained other types of homes that are often confused for sober living homes, including behavioral health residential facilities (BHRF), which are also licensed by the Arizona Department of Health Services (ADHS).

This week ADHS posted more information about ADHS’ role in regulating homes that require licensure as a sober living home or behavioral health residential facility.

They also posted a  fact sheet to help clarify some of these differences. See How ADHS regulates sober living homes and behavioral health residential facilities.

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