Why it matters: The report details AzHHA’s 2026 advocacy efforts including:
Increasing transparency in health insurance practices.
Streamlining state regulatory oversight.
Strengthening behavioral health operations.
Preserving access to rural cancer treatment.
Clarifying Arizona’s Safe Haven law.
Safeguarding critical funding and preparing the state’s Medicaid program for federal policy changes.
The big picture: These legislative victories are a direct result of AzHHA members’ bold advocacy and steadfast partnership.
The voices of our members strengthen our collective impact and help ensure Arizona hospitals can continue to deliver high-quality care to the communities that depend on us.
Registration and room block information: 2026 Arizona Hospital Leadership Conference
This educational event is dedicated to supporting a vibrant healthcare delivery system, including a robust network of acute care, critical access, specialty, behavioral health and post-acute care hospitals.
What you need to know: Take advantage of our buy five – get one free offer for teams.
📢A little over a month left to register! The deadline to register is Thursday, Oct. 8, 2026. Register today!
⌛Time is running out to reserve your room at a discounted rate. The deadline is Thursday, Sept. 24, 2026. Book now.
CMS state-directed payment rule draws broad opposition
A wide-ranging coalition of hospitals, physicians, health plans and state Medicaid leaders is urging the Centers for Medicare and Medicaid Services (CMS) to pull back its proposed Medicaid state-directed payment rule, arguing the agency is going far beyond what Congress required.
Why it matters: Congress capped certain state-directed payments at 100% of Medicare in Medicaid expansion states like Arizona.
But CMS is proposing to extend similar limits to virtually all Medicaid services and providers by 2029.
That difference is enormous. CMS estimates its rule would reduce federal Medicaid spending by $510 billion over 10 years — more than three times the $149 billion reduction previously attributed to the statutory changes.
The concern: Hospitals and other providers argue the proposal could destabilize Medicaid financing, reduce provider participation and threaten access to care, particularly for rural, behavioral health and other financially vulnerable providers.
The American Hospital Association, the American Medical Association, AHIP and the National Association of Medicaid Directors are among those telling CMS that Congress set specific limits — and the agency should not use regulation to expand them.
AzHHA’s view: Arizona hospitals already face significant Medicaid reimbursement pressures.
CMS should implement the law Congress passed, not use it as a vehicle for hundreds of billions of dollars in additional Medicaid cuts.
What we’re watching: Whether CMS narrows the final rule or moves forward with the broader policy, which could trigger significant legal challenges.
No Surprises Act ruling could boost provider payments
A federal appeals court has ordered the government to revise how insurers calculate a key No Surprises Act payment benchmark, handing providers another important legal victory.
Why it matters: The qualifying payment amount, or QPA, helps determine out-of-network reimbursement and patient cost-sharing.
The court found that insurers cannot include certain “ghost rates” for services providers do not actually furnish and must account for some bonus and incentive payments.
That could push QPAs higher.
The impact: Insurers will have to recalculate payment amounts once federal agencies issue new guidance — a potentially costly and complex process.
For providers, the ruling is generally favorable. Higher QPAs could increase out-of-network reimbursement and may reduce the number of claims that end up in Independent Dispute Resolution.
The big picture: Providers continue to win the large majority of No Surprises Act arbitration cases, while courts have repeatedly rejected parts of the federal government’s implementation of the law.
What we’re watching: How quickly the Centers for Medicare and Medicaid Services and other federal agencies revise the methodology — and whether higher QPAs meaningfully change provider payments, arbitration volumes or patient cost-sharing.
Rural health program faces calls for greater transparency
Healthcare groups are pressing the Centers for Medicare and Medicaid Services (CMS) and states to provide more detail about where the $50 billion Rural Health Transformation Program (RHTP) is actually sending money — and whether it is reaching rural hospitals and communities.
Why it matters: Rural hospitals were a central justification for creating the program as communities prepare for significant Medicaid funding reductions.
But reporting varies widely by state, making it difficult to determine who is receiving funding, how dollars are being spent and whether investments are improving rural access.
What they're saying: The American Hospital Association is urging CMS to disclose the “final destinations” of RHTP funding, particularly when states make awards to large health systems, universities or other organizations that then distribute funds to additional recipients.
The concern: Without clear reporting on subrecipients, contractors and vendors, policymakers may not know how much of the $50 billion ultimately reaches rural hospitals and frontline providers.
What's next: CMS plans to publish an annual national progress report, but individual state reports will generally be available only upon request rather than proactively posted.
What we’re watching: Whether CMS creates greater visibility into award recipients, downstream spending and outcomes — and whether the program can demonstrate that its investments are strengthening.
New HRSA requirement will change how ventilated patient referrals are reported
Starting Thursday, Oct. 1, 2026, the Health Resources and Services Administration (HRSA) requires all organ procurement organizations (OPO) to begin using a new Ventilated Patient Form (VPF) to track every ventilated patient referral, not just those resulting in donation.
Why it matters: This includes the Donor Network of Arizona, Arizona’s federally designated OPO.
This replaces the OPO's prior, more limited reporting of certain hospital deaths.
For hospitals, this means more standardized, system-wide data on how patients move through the referral and donation process, including specific hospital-side process measures like referral timeliness and clinical support provided.
It's a meaningful shift toward shared accountability between hospitals and OPOs, and an opportunity to strengthen this work together.
Get to know them: Hospitals and providers face increasing pressure to deliver exceptional care while managing reimbursement uncertainty, rising operating costs, workforce risk and changing employer expectations.
The Mahoney Group helps healthcare organizations make even better decisions across employee benefits and property & casualty.
Through CASE: Clarity, Alignment, Strategy and Execution, The Mahoney Group brings a structured approach to complex risk decisions.
They help leaders clarify exposures, align stakeholders, develop practical strategies and execute with accountability.
The result: Even better benefits that support and retain employees; stronger protection for property, liability and workforce risks; and greater confidence in decisions that affect the organization’s financial and operational future.
The Mahoney Group brings Arizona roots, healthcare perspective and disciplined execution to help providers protect what matters most: their people, their mission and their ability to serve.
In relationship with DataGen, AzHHA distributes reports to hospitals based on information submitted to the Centers for Medicare and Medicaid Services. DataGen generates hospital-specific reports which are sent to AzHHA hospital members as part of their membership.
Why it matters: This data helps hospitals understand the financial impact of proposed changes and annual updates.
The reports can also assist in preparing budgets or benchmarking results with other similar organizations.
The below reports were recently sent to members:
CY2027 Home Health Prospective Payment Proposed Rule (sent Monday, Aug. 3, 2026)
FFY 2027 Inpatient Prospective Payment System Final Rule Analysis (sent Monday, Aug. 24, 2026)
UPCOMING EVENTS
Friday, Sept. 4, 2026 – Deadline for AzPHA Public Health Awards nominations The Arizona Public Health Association (AzPHA) is accepting nominations for its 2026 Public Health Awards to recognize the people and organizations whose dedication, leadership, service and impact deserve to be celebrated. The awards ceremony will be held on Thursday, Oct. 29, 2026, at The Social Hall in Tempe. Submit your nomination today.
Wednesday, Sept. 9, 2026 - Inpatient Diabetes Care Learning Collaborative Join the American Diabetes Association for a free learning opportunity that will provide a practical overview of a comprehensive inpatient diabetes care program, with targeted approaches for high-risk patient populations. The featured speaker for this session is Lahey Clinic. Register now.
Friday, Sept. 11, 2026 and Saturday, Sept. 12, 2026 – Alzheimer’s and Dementia in Practice: Bridging the Gap Between Diagnosis and Treatment Yavapai County Community Health Services is hosting two free, three-hour professional development classes in Cottonwood and Prescott to learn from medical experts in the field of Alzheimer’s and dementia on how to bridge the gap between early diagnosis and effective treatment by improving screening practices and connecting patients and caregivers with valuable resources. Register here for the Cottonwood session on Sept. 11 and register here for the Prescott session on Sept. 12.
Sept. 12, Sept. 19 and Oct. 3, 2026 – AzNA Regional Townhalls Join the Arizona Nurses Association (AzNA) for its regional townhalls in September and October. Townhalls will be held in Phoenix, Flagstaff and Yuma. Board reports and networking will take place at all three events, and the full business meeting (including the induction of new board members) will occur in Phoenix. Learn more and register.
Monday, Sept. 14, 2026 – Arizona summit on workforce resilience Registration is now openfor “Resilient Together: Arizona Summit on Behavioral Health Workforce Well-being,” which will take place in Tucson, AZ. In partnership with the Opioid Response Network, La Frontera Center and the ASU School of Social Work, this full-day summit will focus on supporting the resilience of our behavioral health workforce. Continuing education credit is available.
Friday, Sept. 18, 2026 – AzONL 2026 Summit The Arizona Organization of Nurse Leaders (AzONL) will hold it’s 2026 summit at Mayo Clinic from 10 a.m. to 3 p.m. on Friday, Sept. 18, 2026. The event’s theme is “Bridging Generations, Building Leaders” and will also include naming the 2026 AzONL Nursing Leadership in Action Award winners. Register today.
Oct. 21-23 – 2026 Arizona Hospital Leadership Conference The 2026 Arizona Hospital Leadership Conference will be held at the El Conquistador Tucson, a Hilton Resort on Oct. 21-23. This will be an inspirational gathering of more than 200 hospital and healthcare executives seeking opportunities for continuing education, meaningful discussion and relationship building. Registerby Thursday, Oct. 8, 2026.
Save the date: Jan. 8-9, 2027 – 3rd National Pediatric Disaster Conference The conference, which will be held in Scottsdale, Ariz., will focus on pediatric mass casualty incidents and innovative approaches to strengthening preparedness, response and recovery efforts for children. AzCHER encourages members to save the date and take advantage of this opportunity to learn, connect and strengthen pediatric readiness. Registration details coming soon.