We are urging our members and partners to actively support the Arizona Department of Health Services’ proposed rulemaking to update licensing fees for health-care institutions.
The proposal (published last Friday in the Arizona Administrative Register) is the first proposed fee adjustment since 2010. For 15 years, ADHS has been asked to regulate and oversee a growing and increasingly complex health system without a fee structure that keeps pace.
See the Licensing Fee Rulemaking Text Starting on Page 2705
9 A.A.C. 10 HCI Fees Economic Impact Evaluation
- Patient Safety and Oversight Are at Stake
Licensing fees fund the critical work of ensuring healthcare facilities meet standards for safety, quality, and accountability. Without an update, ADHS lacks the resources it needs to protect patients and communities. - Some Institutions May Oppose
While many providers understand the need, we expect opposition from some healthcare institutions reluctant to pay higher fees. That’s why it’s especially important for public health voices like ours to speak out in support. - Equity and Community Health Depend on It
Strong licensing programs ensure that care in Arizona is delivered fairly, safely, and consistently—especially for vulnerable populations.
Timeline and Participation
- Oral Proceeding: Monday, September 22, 2025
- Public Comment Deadline: September 22, 2025
The rules can be reviewed in the Arizona Administrative Register (page 2705).
We support ADHS’s fee adjustment because it:
- Provides sustainable funding for inspections and oversight.
- Strengthens protections for patients and residents.
- Ensures ADHS can keep pace with emerging public health challenges.
This is a commonsense update that reflects 15 years of inflation, rising operational costs, and expanded responsibilities.
AzPHA’s Letter of Support for ADHS’ Licensing Fees for Healthcare Institutions Rulemaking
Call to Action: Make Your Voice Heard
- Submit written comments before September 22.
- Speak at the oral proceeding in support of the rulemaking.
- Share AZPHA’s position with colleagues and networks.
With healthcare institutions expected to push back, ADHS needs the backing of stakeholders who put community health first. By adding our voice to the choir, we can help ensure that ADHS has the tools it needs to safeguard patient safety, support healthcare quality, and protect all Arizonans.
Sample Comment
I am writing in strong support of the Arizona Department of Health Services’ proposed rulemaking to update licensing fees for healthcare institutions. These fees have not changed since 2010, while the Department’s responsibilities and costs have grown significantly.
Updating fees are essential to ensure ADHS has the resources to conduct thorough inspections, uphold safety standards, and protect patients and communities across Arizona.
Without this adjustment, oversight ability will continue to erode, putting vulnerable populations at risk.
I urge ADHS to adopt the proposed rule and thank the Department for its careful, evidence-based approach.
Submit comments to:
Stacie Gravito Office Chief, Administrative Counsel and Rules
150 N. 18th Ave., Suite 200
Phoenix, AZ 85007