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State Issues

One of AzHHA’s core functions is its continuous involvement with issues of state policy that have the potential to impact hospitals and health systems as well as the health and healthcare of the people, patients and communities of Arizona.

View AzHHA's 2024 Legislative Agenda

Our in-house staff is intimately engaged in healthcare policies under consideration by the State Legislature, the Office of the Governor, and other state and local policymakers. AzHHA also performs research, analysis and development of new policies to positively impact healthcare in Arizona. The advocacy and policy team works closely with coalitions of healthcare providers to amplify support or opposition of issues.

Make a contribution to the AzHHA PAC Download the 2023 Legislative Report


Below are a selection of AzHHA’s letters, court filings, and issue briefs related to issues of state policy. To view COVID-19 related waiver requests and letters visit our COVID-19 waivers page.

Comment Letters

AzHHA comments on hospital assessment and HEALTHII payments – March 2024

AzHHA Comments on AHCCCS Administration's CYE 2025 Differential Adjusted Payment proposal - March 2024

AzHHA comments on AHCCCS HEALTHII Quality Metrics – December 2023

AzHHA comments on ground ambulance NOPR - October 2023

AzHHA's additional comments on August draft revisions to Article 9 of the ground ambulance rules - August 2023

AzHHA comments on ADHS draft revisions to Article 9 of the ground ambulance rules - June 2023

AzHHA Comments on AHCCCS Administration's CYE 2024 Differential Adjusted Payment proposal - March 2023

AzHHA Comments on AHCCCS Administration's policy on Credentialing and Recredentialing Processes - January 2023 

AzHHA comment letter to ADOSH - December 2, 2021

AzHHA Comments on AHCCCS Administration’s CYE 2022 Differential Adjusted Payment Preliminary Public Notice - February 2021

AzHHA Comments on DHS Notice of Proposed Rulemaking, Re: Radiation Control Fees - July 2020

AzHHA Comments on AHCCCS Administration’s CYE 2021 Differential Adjusted Payment proposal - April 2020

AzHHA Responds to AHCCCS Differential Adjusted Payment Strategies Request for Information - December 2019

AzHHA Comments on AHCCCS Administration’s CYE 2020 Differential Adjusted Payment proposal - March 2019

AzHHA Comments on DHS Notice of Proposed Rule Making RE: Opioid Prescribing and Treatment - December 2017

AzHHA Comments on Draft ADHS Opioid Prescribing and Treatment Rules - October 2017

AzHHA Comments on ADHS Emergency Rules - August 2017

AzHHA Comments on AHCCCS Free-standing ED Rulemaking - September 2016

AzHHA Comments on AHCCCS CYE 2017 Value-Based Purchasing Proposal - December 2015

AzHHA Comments on AHCCCS Medicaid Waiver - September 2015

AzHHA Comments on AHCCCS Provider Rate Reductions - May 2015

AzHHA Comments on AHCCCS Waiver SB1092


Court Filings

Arizona School Boards Association Inc. v. State of Arizona Amicus Brief - October 2021 

Arizona School Board Association case: Prohibitions on schools and universities from imposing mask mandates - September 2021

Governor’s Use of Executive Power in Closing Bars Amicus Brief - February 2021

CVS Pharmacy v. Tucson Medical Center Amicus Brief - November 2020

Biggs v. Betlach- AZ Supreme Court Amicus Brief - October 2017

Biggs v. Betlach Amicus Brief - April 22, 2016

Biggs v. Betlach- Court of Appeals Ruling


Issue Briefs

Data Report - ED Behavioral Health Wait Times 2012-2014 - March 2016

Psychiatric Boarding Issue Paper - July 2015

2015 State Budget Issue Paper - February 2015

2014 AHCCCS Rate Restoration Issue Paper - November 2014

Medicare Cuts-Enough is Enough - January 2014

Provider Assessment Issue Paper- January 2014

Medicaid Restoration and Expansion - October 2013


Additional Documents

ADHS Emergency Rule on Opioid Reporting

Historical Impact of AHCCCS Rate Cuts on Hospitals

Hospital Compensation Act Overview 

Statement for Voter's Pamphlet regarding Hospital Compensation