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Advocacy letters

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Amplifying our collective voice

Another important strategy to ensure that we take a stand on behalf of our members is through our work with advocacy letters to Congress, the State Legislature and health plans, and combining our collective voice through comment letters on state and federal regulatory issues, as well as signing on to amicus briefs.

State regulatory letters 

To the Arizona Health Care Cost Containment System (AHCCCS): 

  • Raised concerns regarding AHCCCS’ ambiguous language and conflicting timelines for the incident, accident and death reporting policy (October 2025 letter) 
  • Urged AHCCCS to retain payment parity for behavioral health telehealth services (June 2025 letter) 
  • Submitted feedback on HEALTHII payments (March 2025 letter) and provided input on HEALTHII quality metrics (May 2025 letter) 
  • Expressed concerns about proposed Medicaid work requirements, lifetime benefit limits and emergency department cost-sharing (March 2025 letter) 
  • Provided feedback on the proposed Contract Year Ending 2026 differential adjusted payments (February 2025 letter) 
  • Expressed concerns on Arizona’s Pre-Admission and Screening Resident Review Program self-service portal (November 2024 letter) 

To the Arizona Department of Health Services (ADHS): 

  • Expressed concerns over shifting the licensing costs to providers (September 2025 letter) 
  • Required clarification and revisions to ADHS’ health care institution/memory care rules (January 2025 letter) 

To the Arizona Department of Insurance and Financial Institutions (DIFI): 

  • Urged DIFI to revise the definition of “contracted” in R20-6-1902 to include Letters of Agreement (August 2025 letter)

AzHHA continues to communicate with health plans regarding:

  • Downcoding policies, which financially harm hospitals and create unnecessary administrative burden.
  • Medicare Advantage policies that directly conflict with CMS regulations and financially harm hospitals. 

Federal regulatory letters 

To Centers for Medicare and Medicaid Services (CMS): 

To other federal agencies: 

  • Expressed concerns to the Health Resources and Services Administration on the impact to hospitals for proposed 340B Rebate Model Pilot Program and its legality, and recommended safeguards to protect covered entities and patients (August 2025 letter) 
  • Addressed concerns to the Department of Health and Human Services, Office of Management and Budget and CMS on burdensome healthcare regulation that detracts from patient care and increases cost (May 2025 letter)

Amicus briefs 

  • Supported the enforcement of state Affidavit/Certificate of Merit laws to protect against frivolous malpractice lawsuits in Berk v. Choy (U.S. argued Oct. 6, 2025 brief)
  •  Defended hospitals is six federal court and regulatory proceedings against drug manufacturers’ push to replace up-front 340B discounts and rebate models: 
  • Urged the Arizona Supreme Court to grant immunity to healthcare providers from civil liability during the COVID-19 public health emergency in Roebuck v. Mayo Clinic (Ariz. Sept. 12, 2025 brief) 

Looking for a document that isn’t listed on this page? Please contact communications@azhha.org for assistance.