Arizona home health agency license: ADHS rules, fees and the Medicare freeze
An Arizona business that sends nurses, therapists or home health aides into patients' homes under a physician's plan needs a home health agency license from the Arizona Department of Health Services (ADHS), Bureau of Medical Facilities Licensing. The license never expires as long as you pay the annual fee. Since May 13, 2026, though, a new agency cannot enroll in Medicare.
Contents14 sections
Key takeaways
- ADHS licenses home health agencies under A.R.S. 36-425.01 and A.A.C. R9-10 Article 12. The health care institution classes list no separate license for a private-pay companion or personal care agency; confirm that with ADHS.237
- Every owner with a 10% or greater stake must send ADHS a copy of a valid Arizona fingerprint clearance card with the application.3
- You need a home health services director (a physician with 24 months of home health experience, or an RN with 3 years of nursing that includes 24 months in home health) and an advisory group of at least four members.3
- Fees as published on October 12, 2026: a $50 application fee plus a $365 licensing fee, then $365 every year. The license itself does not expire.36
- CMS has refused new home health agency enrollments in Medicare since May 13, 2026. An Arizona license can still be issued, but it does not get you Medicare billing.1012
Quick facts
| Agency | ADHS, Bureau of Medical Facilities Licensing, Phoenix |
|---|---|
| Law | A.R.S. 36-151, 36-411, 36-425.01; A.A.C. R9-10 Articles 1 and 12 |
| Fees | $50 application + $365 licensing fee, then $365 a year (as published on 2026-10-12) |
| License term | Does not expire; void if the annual fee goes unpaid |
| Building approval | No architectural plan, site plan or floor plan submission for home health agencies |
| Certificate of need | None in the ADHS home health rules |
| Medicare | New enrollments frozen nationwide since May 13, 2026 |
Fees are from A.A.C. R9-10-106, read October 12, 2026. A home health agency has no licensed capacity, so it pays the flat "no licensed capacity" licensing fee.
What Arizona counts as a home health agency
Arizona’s definition comes from A.R.S. 36-151. It describes an organization “primarily engaged in providing skilled nursing services and other therapeutic services.” The agency’s policies must be set by a group of professionals that includes at least one physician and one registered nurse, and it must keep clinical records on every patient.1 The services are delivered “on a visiting basis” in the patient’s home, under a plan a physician sets up and reviews. They consist of part-time or intermittent nursing by or under the supervision of a registered nurse, plus either physical, occupational or speech therapy or, to the extent ADHS rules permit, part-time or intermittent home health aide services.1 Home health agencies are a named class of health care institution in A.R.S. 36-401 and in A.A.C. R9-10-102, and ADHS must license them by rule under A.R.S. 36-425.01.732
Three nearby business models are easy to confuse with this one:
- Personal care or companion agencies without nursing. A.R.S. 36-151 treats homemaker, meal, transportation and similar help as “supportive services,” which are separate from home health services.1 The health care institution classes in A.R.S. 36-401 and R9-10-102 include no class for a private-pay non-medical home care agency.73 ADHS does not say this outright on its own pages, so confirm it with the Bureau before you open. If you contract with AHCCCS or another state program, its contract rules apply on top.
- A licensed agency that adds personal care. A licensed home health agency may list supportive services, including personal care, in its scope of services. The administrator may allow supportive services without a physician order and may let staff who are not home health aides provide personal care. A registered nurse must still assess the patient’s need, assign tasks in writing, direct the services and include them in each reassessment.3
- Hospice and facility-based care. A hospice service agency is a separate ADHS class with its own rules. Residential and day programs need their own licenses: see the assisted living facility guide and the adult day health care facility guide.
The Medicare freeze in effect since May 13, 2026
Before you commit money to a skilled agency, plan around the federal moratorium. Effective May 13, 2026, CMS stopped enrolling new home health agencies, branches and practice locations in Medicare anywhere in the country, unless a Medicare contractor received the application before that date.10 The CMS moratoria page says the freeze also covers non-exempt changes in majority ownership under 42 CFR 424.550(b), so buying a recently enrolled agency is not a way around it.12 CMS’s survey memo to state agencies adds three more points:11
- Initial enrollment applications filed during the moratorium are denied.
- CMS regulations allow no exceptions.
- Accreditation from a CMS-approved accrediting organization will not give a new agency deemed status while the moratorium lasts.
The moratorium runs for six months and can be extended in six-month increments.12 When the CMS page was checked on October 12, 2026 (last updated August 27, 2026), it showed no extension. That puts the end of the first period at about November 13, 2026. ADHS links the CMS notice from the top of its Medical Facilities Licensing page.8
The freeze does not stop ADHS from licensing you. Arizona’s license is a state requirement, separate from Medicare certification. A private-pay agency, or one serving AHCCCS members, can be licensed and operate. CMS left it to each state to decide whether to restrict Medicaid enrollment of home health providers.10 AHCCCS’s moratorium page lists only a behavioral health provider moratorium, which ended December 9, 2024. It names no home health moratorium (checked October 12, 2026).14
No building review, but you must define where you serve
Facility-based institutions in Arizona submit architectural plans, local building and zoning sign-off, site plans and floor plans. R9-10-105 exempts home health agencies from all of these, and from the question about agricultural land within a quarter mile.3
What the rules require instead is geography. Your application must give the name and address of each proposed branch office and the geographic region served by the administrative office and by each branch.3 A branch office operates under your license and under your administrator’s control.3 Once licensed, you must notify ADHS in writing at least 30 calendar days before you change the geographic region you serve, with supporting documents.3 Under the federal freeze, a new branch also cannot be added to a Medicare enrollment.10
Owners and staff: fingerprint clearance cards and the APS registry
Arizona puts the background check ahead of the application. Under R9-10-1202, you must submit a copy of a valid fingerprint clearance card (issued by the Department of Public Safety under A.R.S. Title 41, Chapter 12, Article 3.1). The card is required for the applicant if you apply as an individual, and for each person who owns 10% or more if you apply as a business.3 The application also asks whether the owner, or anyone with a 10% or larger interest, has had a health care institution license or a health professional license denied, revoked or suspended.3
For staff, A.R.S. 36-411 applies to employees, owners, contractors and volunteers who provide nursing, home health or direct supportive services. Each must hold a valid fingerprint clearance card or apply for one within twenty working days of starting.4 The exception is anyone already fingerprinted by their Title 32 licensing board, such as a nursing license holder.4 The agency must also make documented, good-faith efforts to do the following:4
- contact previous employers;
- verify the current status of each card;
- check the adult protective services registry before hiring, a duty that began January 1, 2025. Anyone listed on the registry may not be hired, and existing employees had to be checked by March 31, 2025, with action to end the employment of anyone found on it, and re-verified annually from March 31, 2025.
R9-10-1206 adds evidence of freedom from infectious tuberculosis for each personnel member, employee, volunteer or student who has, or is expected to have, direct patient interaction, on or before the day services begin and as specified in R9-10-113.3 Each personnel record must be kept for 24 months after the person leaves.3
The people Article 12 requires
The rules name four roles and groups. ADHS will ask about the chief administrative officer’s highest degree and related work experience on the application.3
| Role | What the rule requires |
|---|---|
| Governing authority | One or more people responsible for the agency. Sets the scope of services and the administrator’s qualifications in writing, and reviews the quality management program at least every 12 months.3 |
| Administrator | Meets the qualifications the governing authority wrote. An acting administrator must be designated in writing if the administrator is, or is expected to be, away from the office for more than 30 days. ADHS must be told in writing immediately when the chief administrative officer changes.36 |
| Home health services director | A physician with at least 24 months of experience working for or with a home health agency, or an RN with at least three years of nursing that includes 24 months providing home health services.3 |
| Advisory group | At least four members: a physician, an RN with at least one year of home health experience, and two or more people from medical, nursing or health-related professions. Meets at least every 12 months, keeps minutes, and helps set and evaluate policies. Minutes are kept for 24 months.3 |
Arizona also specifies who may deliver each discipline. Speech therapy must come from a speech-language pathologist or assistant licensed under A.R.S. Title 36, and occupational and physical therapy from an occupational or physical therapist or assistant. Nutritional services must come from a registered dietitian, and pharmacy services from a pharmacist. Respiratory care may come from a respiratory therapist or technician, or from a practical or registered nurse. Medical social services must come from a person your policies qualify to coordinate them, and any service that is the practice of social work must come from a social worker licensed under A.R.S. Title 32, Chapter 33, Article 5. Each of these services needs an order from the patient’s physician, registered nurse practitioner or podiatrist.3
Policies and the quality program ADHS expects
R9-10-1203 lists the subjects your written policies must cover:3
- job descriptions and qualifications;
- orientation and in-service education;
- how staff submit complaints about patient care, and the steps for a patient to file a complaint and for you to respond;
- the fingerprinting requirements of A.R.S. Title 36, Chapter 4, Article 11;
- patient rights, including help for patients who do not speak English or have a disability;
- health care directives;
- medical records, including electronic records;
- the quality management program and incident reports;
- contracted services;
- which staff must hold CPR and first aid training;
- admission, discharge planning and discharge;
- general and informed consent;
- responding to out-of-control behavior;
- medication procurement and administration;
- infection control.
Policies must be reviewed at least every three years.3 The quality management plan must describe how you identify incidents, collect and evaluate data, act on concerns and check whether the actions worked. Reports go to the governing authority and are kept for 12 months.3 Article 12 expects documentation to reach ADHS within two hours of a request.3
Filing the application, in order
Get the fingerprint clearance cards first
You need cards for the individual applicant or for every 10% owner before the packet is complete.3
Set up the business records
Have the formation documents, statutory agent, governing authority and a lease (if the office is leased) ready. R9-10-105 asks for copies of each.3
Write the scope of services and the service area
The application must include your proposed scope of services, the geographic region and any branch offices.3
Apply in the Licensing Management System
ADHS says all applications and renewals must be filed electronically through its LMS portal and that paper forms are no longer accepted.8 Pay the $50 application fee with the application.3
Declare that you are ready for inspection
The application asks whether you are ready for a licensing inspection. ADHS does not treat the packet as complete until you give written notice that you are ready.3 If ADHS sends a notice that the packet is incomplete, you have 60 calendar days to supply the missing items, or the application is treated as withdrawn.3
Licensing inspection
The director inspects and investigates the applicant’s character and qualifications.5 During the substantive review, ADHS may make one comprehensive written request for more information. Not answering within 120 calendar days leads to denial.3 By statute, ADHS must approve or deny a complete initial application within 90 days of receiving it.6 ADHS’s 2014 filed version of R9-10-108 Table 1.1 listed 120 calendar days overall, 30 for the administrative completeness review and 90 for the substantive review.3 The Secretary of State’s current table could not be opened on October 12, 2026, so ask the Bureau which time-frames apply to your application.
Pay the licensing fee after approval
Once you receive the written notice of approval, you have 60 calendar days to pay the $365 licensing fee. You can pay within 90 days instead if you add a $250 late fee. ADHS issues the license after it receives payment.3 A denial can be appealed within 30 calendar days.3
If an inspection finds you are not in substantial compliance, and the director believes patients are best served by a chance to correct them, the director issues a provisional license for no more than one year. You must agree to carry out a plan that eliminates the deficiencies.6
Fees as published
| Fee | Amount | When |
|---|---|---|
| Application fee | $50 | With the application3 |
| Licensing fee (no licensed capacity) | $365 | Within 60 days of the approval notice, then every year3 |
| Late payment fee | $250 | If the initial or annual licensing fee is paid late3 |
Fees are nonrefundable except as A.R.S. 41-1077 allows.3 Medicaid enrollment has its own fee, covered below.
Clinical rules that shape daily operations
Several Article 12 deadlines affect how you staff and schedule, so build them into your systems before the licensing inspection:3
- Admission requires an order from a physician, registered nurse practitioner, physician assistant or podiatrist.
- Initial assessment. A registered nurse must assess the patient within 48 hours after services start. The assessment covers needs, resources, the home and family environment, goals, medications and equipment. If only therapy is ordered, the therapist does the assessment.
- Care plan. The care plan must be in place within five days of the start of care, with input from the ordering practitioner and an RN. It is updated at least every 60 calendar days and reviewed with the patient or their representative at least every 30 calendar days. The practitioner must sign it within 30 calendar days. Referrals must be documented and answered within 48 hours.
- Aide supervision. Aide tasks are assigned in writing by an RN, or by the therapist for therapy-related tasks. The RN visits to assess aide services at least every two weeks if the patient also receives nursing or therapy, and at least every 60 calendar days if the patient receives aide services only.
- RN reassessment happens at least every 60 calendar days, with a summary sent to the practitioner. Verbal orders must be signed within 30 calendar days.
Arizona rules also mention the licensed health aide. This is a parent, guardian or family member of an Arizona Long Term Care System (ALTCS) member who is licensed by the Board of Nursing to provide care only to that member under the member’s plan of care. The scope matches a licensed nursing assistant, plus medication administration, tracheostomy care, enteral care and routine ventilator care.15 Article 12 lets an agency assign tasks to licensed health aides under the same RN supervision rules that apply to home health aides.3
Inspections, accreditation and keeping the license
An Arizona health care institution license does not expire. It stays valid unless ADHS revokes or suspends it, or it becomes void because you did not pay the licensing fee.6 A.R.S. 36-425.01 allows a licensure period of up to two years, but in practice you pay the licensing fee every year.23 ADHS sends notice at least 90 days before the fee is due. You file the fee and confirm your records no earlier than 60 days before the license anniversary date.3
ADHS must inspect each institution for compliance at least once a year. A deficiency-free compliance survey earns 24 months without a routine survey.6 Accreditation gives you two more ways to reduce inspections:
- Accreditation report. If your agency is accredited by a nationally recognized organization approved by the U.S. Secretary of Health and Human Services, you may send ADHS the accreditation report. ADHS may then accept it in place of compliance inspections. This does not apply if you faced an enforcement action in the year before your fee anniversary date.53
- Medicare-certified agencies. Once you have been licensed for at least a year and are certified by Medicare, ADHS issues the license on application, without a state licensure survey. ADHS keeps full enforcement authority.2
Other notices: give ADHS 30 days’ written notice of a name change, a change in office hours, or a change in your service region.3 Give 30 days’ notice before you close, along with where the medical records will be kept.3 ADHS runs a hotline for home health agency complaints and questions at 602-364-3350 or 1-800-221-9968 (handout version June 5, 2026).9
AHCCCS (Medicaid) enrollment
Arizona’s Medicaid agency, AHCCCS, enrolls providers through the AHCCCS Provider Enrollment Portal (APEP). AHCCCS screens each applicant by risk level. At the high level that means license verification, database checks, a site visit and a fingerprint-based criminal background check.13 Institutional providers pay an enrollment fee that matches the Medicare fee. For calendar year 2026 it is $750, effective January 1 through December 31, 2026.13 AHCCCS publishes a screening glossary (PEP-903) listing the risk level and enrollment fee for each provider type. The glossary (version posted August 2026) lists two home health types, Home Health Agency and Non-Medicare Certified Home Health Agencies. Each is high risk, requires the enrollment fee, a site visit and a fingerprint-based background check, and is verified against the ADHS license.16 AHCCCS therefore has a separate provider type for agencies without Medicare certification; ask AHCCCS whether it is open to new agencies during the federal freeze.
Rule changes since 2025
- April 6, 2025: ADHS amended R9-10-1201, 1203, 1207, 1209 and 1210 (31 A.A.R. 651).3 The amended text includes the three-year policy review cycle, the 30-day care plan review with the patient, the 48-hour referral response, and the licensed health aide provisions.
- January 1 and March 31, 2025: the adult protective services registry check for new hires and for existing employees took effect under A.R.S. 36-411.4
- May 13, 2026: the CMS Medicare enrollment moratorium for home health agencies took effect, for six months unless extended.1012
- Licensing Management System: ADHS now accepts applications and renewals only through the LMS.8
The child care licenses in Arizona come from a different ADHS bureau. See the child care facility guide and the child care group home guide, or the Arizona state page for every care license in the state.
Sources
- 1
- 2 Arizona State Legislature, A.R.S. 36-425.01, Home health agencies; licensure Checked 12 Oct 2026 · Back to text ↑
- 3
- 4
- 5
- 6
- 7
- 8 Arizona Department of Health Services, Bureau of Medical Facilities Licensing Checked 12 Oct 2026 · Back to text ↑
- 9
- 10
- 11
- 12 Centers for Medicare & Medicaid Services, Provider Enrollment Moratoria Checked 12 Oct 2026 · Back to text ↑
- 13
- 14 Arizona Health Care Cost Containment System, Enrollment Moratoriums Checked 12 Oct 2026 · Back to text ↑
- 15 Arizona State Legislature, A.R.S. 32-1601, Definitions (licensed health aide) Checked 12 Oct 2026 · Back to text ↑
- 16
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Arizona and neighboring states
Compare all 51| State | License | Who needs it | State fee |
|---|---|---|---|
| Arizona (this guide) | Home Health Agency license | Sending your own nurses, therapists or aides into homes | $50 application + $365 licensing fee, then $365 a year |
| California | Home Health Agency license | Skilled nursing in homes; new licenses frozen since June 29, 2026 | $2,946 per main office or branch; +$2,103 in Los Angeles County |
| Nevada | Agency to Provide Nursing in the Home license (home health agency) | Skilled nursing and related help provided in clients' homes | $5,530 home office, $5,733 branch (R071-26, as published on 2026-10-12) |
| Utah | Home Health Agency License | Agency with 2+ staff giving nursing, therapy or aide visits in homes | $2,138.52 home health fee + $743.83 two-year base fee; $1,069.26 new-provider application (FY2027 fee brief, as published on 2026-10-12) |
| New Mexico | Home Health Agency license | Provides at least one medically directed service in clients' homes | $300 per year; $300 per amended license |
| Colorado | Home Care Agency license, Class A | Agency providing skilled nursing or therapy in homes; may add personal care | $3,709.49 |
Shortened from each state's guide and our 51-state table, as of each guide's last review. Fees are the state's own; local permits and background checks cost extra.