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Connection Newsletter
By AzHHA Communications● March 6, 2025
Smart Brevity® count: 7.5 mins...1989 words
This week, read about:
- An update on some of our priority legislation.
- How an HHS policy rescinds public notice and comment requirements for certain rules.
- AzHHA submitting a comment letter on Differential Adjusted Payments.
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Legislative update: The hurry up and wait game

We’re now 53 days into the legislative session, with a staggering 1,677 bills introduced. Yet, only one bill has made it through both chambers—and as we previously covered, that bill was quickly vetoed.
This week has been filled with marathon floor sessions as legislators push their bills forward.
- One of our key priorities, SB1291, which aims to improve healthcare provider credentialing for commercial plans, was up for its third and final vote in the Senate on Wednesday, March 5, 2025, and passed unanimously!
Our interfacility transportation bill, HB2124, was amended with changes that unfortunately worsen the existing Certificate of Necessity process rather than solve the transportation challenges hospitals face.
- As a result, we’ve moved to oppose the bill.
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Check out Representative Bliss’s remarks during Tuesday afternoon’s Committee of the Whole if you'd like to hear more about how other stakeholders responded.
What’s next: Committee agendas were relatively light this week, but we all know that won’t last.
- As the session progresses, we anticipate longer committee hearings and intense debates.
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Stay tuned: We’ll keep you informed as we advocate for the bills that still have a fighting chance.
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HHS policy rescinds public notice and comment requirements for certain rules

On Monday, March 3, 2025, the U.S. Department of Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. issued a policy effective immediately.
- It rescinds the 1971 regulation commonly referred to as the Richardson Waiver (36FR 2532 (Feb. 5, 1971)).
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This regulation required HHS to follow the Administrative Procedure Act’s (APA) notice and comment rulemaking procedures for rules and regulations relating to agency management/personnel, public property, loans, grants, benefits or contracts.
Why it matters: HHS is no longer required to publish a notice of proposed rulemaking, give interested persons an opportunity to submit comments or publish a final rule that is accompanied by a statement of the rule’s basis and purpose for rulemakings relating to these topics.
- Additionally, the policy gives HHS more latitude to invoke a “good cause” exemption to the APA requirements, allowing the agency more opportunities to bypass the traditional rulemaking processes.
The big picture: The Richardson Waiver had the effect of requiring APA notice and comment requirements to apply to rulemakings regarding those topics.
- HHS’s reasoning for rescinding the Richardson Waiver includes that it “impose[d] costs on the Department and the public, [was] contrary to the efficient operation of the Department, and impede[d] the Department’s flexibility to adapt quickly to legal and policy mandates.”
What’s next: This policy is expected to have ramifications for any HHS program that is considered a “benefit” program or a “grant” program.
- For example, HHS likely will forgo public comment for policies relating to National Institutes of Health research funding and may also implement changes to certain types of Medicaid policies, such as those relating to benefits, without seeking public comment.
- However, it is expected that many Medicare regulations will continue to undergo notice-and-comment rulemaking due to specific statutory requirements.
- Additional analysis is available in this memo released by the American Hospital Association on Tuesday.
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AzHHA submits comment letter on Differential Adjusted Payments

Last week, AzHHA submitted comments on the Contract Year Ending (CYE) 2026 (Oct. 1, 2025-Sept. 30, 2026) Differential Adjusted Payments (DAP).
- The Arizona Health Care Cost Containment System (AHCCCS) preliminary public notice can be found here.
- A final notice is expected later this month.
Why it matters: Hospitals and other providers may receive an additional increase of 0.25-10.5% on all AHCCCS inpatient and outpatient payments if they participate in certain DAP initiatives. The amount for DAP payments and what needs to be completed to obtain the increase is updated annually.
What they're saying: AzHHA provided suggested improvements to AHCCCS’ current proposal including:
- AHCCCS should continue to fund DAP payments for the Naloxone Distribution Program for hospitals which participated in the program in CYE 2024 and 2025. AHCCCS is currently limiting it to those who did not participate in the last two years.
- A second Naloxone Distribution Program DAP with an increased payment should be considered for pregnant and postpartum women with a substance use disorder who visit the hospital but do not go to the emergency department.
- AzHHA encourages AHCCCS to limit the Maternal Syphilis Program DAP to individuals who are already pregnant or those who have expressed a desire to become pregnant.
- If AHCCCS is unwilling to set a more flexible goal for the Social Determinants of Health Closed Loop Referral Platform for smaller hospitals, AHCCCS and Contexture should continue to be extremely lenient with hospitals that are trying to screen/refer individuals but do not meet goals of screening/referring 15 patients per month.
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The potential consequences of failing to extend enhanced premium tax credits

Enhanced Affordable Care Act premium tax credits that assist low- and middle-income individuals with purchasing insurance on the health insurance marketplaces will expire at the end of 2025 without Congressional action.
Why it matters: If Congress does not extend the enhanced subsidies, many Americans will face higher premiums, which would result in coverage losses and increased uncompensated care.
- According to a Commonwealth Fund report, the federal tax credits that individuals (and ultimately health insurers and healthcare providers) receive would fall by $26.1 billion in 2026.
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Additionally, the report estimated that failure to extend the subsidies would lead to 286,000 job losses nationwide, nearly half of which would occur in hospitals, physicians’ offices and pharmacies.
Furthermore, low-income individuals and those living in rural areas would be disproportionally affected by a failure to extend the enhanced premium tax credits.
- Rural populations are more likely to face higher health insurance premiums and to have more complex health needs.
- Similarly, low-income individuals have more financial barriers to receiving care and tend to suffer higher rates of chronic conditions.
- This American Hospital Association blog contains additional information on potential impacts.
What’s next: Begin incorporating this important information when you speak to your representatives and senators about potential cuts to healthcare funding.
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Arizona Transition to Practice Program participates in AzNA Day at the Capitol
On Thursday, Feb. 27, 2025, 11 individuals representing the Arizona Transition to Practice Program participated in the Arizona Nurses Association (AzNA) Day at the Capitol.
- This group included new graduate nurses, a site champion and representatives from AzHHA’s Care Improvement team.
Why it matters: They attended the floor session for the House and the Senate and received a tour by Senator Selina Bliss (R-Dist. 1).
What they’re saying:
It was great to see so many nurses and students engage in this important day. I loved seeing Kristin Grimes, MSN, RN, CIC, site champion from Mt. Graham Regional Medical Center, engage and talk about how our program is needed for critical access hospitals.
-Karen Ofafa, EdD, MPH, BSN, RN, director, Transition to Practice Program at AzHHA
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CSR Spring 2025 Conference: Joint Commission update, infection control and post-survey guidance
Hospitals that have active contracts with Joint Commission Resources are eligible to participate in the upcoming Continuous Service Readiness™ (CSR) Conference.
- This one-and-a-half-day CSR event will be held at the AzHHA office in central Phoenix April 1-2, 2025.
Why it matters: The agenda is focused on accreditation updates for 2025, infection control standards and post-survey guidance on completion of the Evidence of Standard Compliance.
In accordance with each hospital’s CSR contract, three representatives per facility can participate without charge, with each additional representative incurring a fee of $100.
What’s next: Register here.
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Patient Safety Awareness Week is March 9-15, 2025
Each year, Patient Safety Awareness Week recognizes and celebrates patient safety improvements.
- This year’s theme is “Moving the Needle.”
Why it matters: Take time to celebrate how your organization has contributed to the patient safety movement, engage in conversations about patient safety and plan for a safer future.
What’s next: Download a free toolkit with posters, banners and more from the Center for Patient Safety.
The big picture: At AzHHA, we prioritize quality and patient safety, and we have been involved in a number of national quality initiatives.
- Additionally, to celebrate and recognize Arizona’s leaders committed to advancing healthcare through exceptional quality performance, community engagement and a culture of continuous improvement, we present the annual Quality Awards.
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Attend the AHA Annual Membership Meeting in Washington, D.C.
The American Hospital Association (AHA) Annual Membership Meeting will be held from May 4-6, 2025 in Washington, D.C.
Why it matters: Join AzHHA at the event and on our Arizona delegation Hill visits. This is an important way we can make sure our collective voice is heard at the federal level.
The big picture: The meeting will feature insightful conversations with policymakers, legislators and thought leaders on our most pressing issues.
- You’ll connect with decision makers who create, shape and implement healthcare policy and influence the political landscape.
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Member spotlight: Copper Springs East ribbon cutting
Copper Springs East will celebrate the addition of a new 24 bed unit with a ribbon cutting event from 2 to 3 p.m. on Thursday, March 13, 2025.
- The event will feature a ceremony and tours of the expansion.
Why it matters: These additional beds will help increase access for adults seeking inpatient behavioral health treatment.
What’s next: If you are interested in attending the event, please RSVP to Ashley Orlovich at [email protected].
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Monday, March 10 - AHCCCS Provider Enrollment Portal changes webinar The Arizona Health Care Cost Containment System (AHCCCS) Provider Enrollment team is hosting a session to discuss the new Provider Directory scheduled to go live in June 2025, as well as related changes in the AHCCCS Provider Enrollment Portal. Register here.
Tuesday, March 11 - Health Equity Roadmap Workshop: The Waypoint The Institute for Diversity and Health Equity (IFDHE) will convene hospitals and health systems engaged in the Health Equity Roadmap. Attendees may earn one or two ACHE Qualified Education Hours toward initial certification or recertification of the Fellow of the American College of Healthcare Executives (FACHE) designation. Learn more and register.
Wednesday March 12 - Member webinar: ADHS presents its 2024 State Health Assessment This webinar provides members a rare opportunity to gain firsthand insights into the strategic directions of Arizona’s health initiatives. You’ll hear about key achievements and challenges faced by the Arizona Department of Health Services (ADHS) and learn about the future plans for the Arizona Health Improvement Plan. Interested in attending? Email [email protected].
Thursday, April 3 - AzPHA Annual Conference This year’s conference theme is “building an innovative and inclusive infrastructure for the public health of the future” and will feature topics such as using AI to enhance public health practice and population outcomes, data infrastructure and informatics, public health workforce and engaging public health professionals. Register now.
April 15-16 - 2025 Arizona Immunization Conference This one-of-a-kind event provides education and resources so you can better understand the challenges around vaccine confidence and leave the conference encouraged by the success stories from around the state. Join over 500 attendees at the 2025 conference. Register here.
Wednesday, May 28 - Introduction to POLST Join physician orders for life-sustaining treatment (POLST) paradigm for their one-hour virtual workshops equipping healthcare professionals with knowledge and resources to begin using POLST in Arizona. Register here.
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