In September 2019, the Arizona Auditor General (AZAG) published the Performance Audit and Sunset Review (2019 Report) for the Arizona Department of Health Services (ADHS). The 2019 Report included the AZAG’s findings related to how ADHS handled complaints for long-term care (LTC) facilities in 2017 and 2018, and five recommendations to improve the complaint process.

In May 2022, the AZAG published the Arizona Department of Health Services Long-Term Care Complaints and Self-Reports 30-Month Follow-Up Report (2022 Report), based on a review of data from July 1, 2019 through April 21, 2021. The 2022 report found that ADHS failed to implement the five recommendations from the 2019 Report and added four additional recommendations.

There were significant changes to the ADHS Division of Licensing leadership team prior to the release of the 2022 Report. Our current leadership team agrees with the AZAG that no excuses can justify the additional findings in the 2022 Report, and the failure to implement the recommendations from the 2019 Report. We recognize the importance of correcting these issues to help ensure the health and safety of the vulnerable populations that reside in Arizona’s LTC facilities. 

Since the last report was published in May 2022, ADHS has made significant progress towards implementing the nine recommendations from the AZAG. Immediately following receipt of the 2022 Report, ADHS convened a task force from across the agency to oversee the implementation of the AZAG’s recommendations, and to ensure compliance with policies from the Centers for Medicare & Medicaid Services (CMS). By July 2022, ADHS changed leadership within the Bureau of Long-Term Care Facilities Licensing (BLTC) and hired a Quality Control Administrator for the Division of Licensing.  

Under new leadership, the BLTC team immediately ceased the most concerning practices identified in the 2022 Report. The team stopped closing self-reports from facilities without an onsite inspection when required, and implemented a new reprioritization policy. As a result of implementing that policy, the percentage of complaints reprioritized dropped from 42.1% in the first half of 2022 to 1.4% in the second half of the year.

Evidence of these changes, as well as other efforts ADHS has made towards implementing the nine recommendations can be found in the AZAG’s 36-Month Follow-Up Report (2023 Report), which was released in May 2023. While the 2023 Report focuses on data from April 22, 2021 through October 20, 2022, some sections do point out the observable differences in the data from July 2022 through October 2022, when ADHS made significant changes after the 2022 Report’s release. 

Although we are proud of the progress our team has made since the 2022 Report was released, we know we have a lot more work to do. We are appreciative that the state legislature understands that fully implementing all nine of the AZAG’s recommendations will require a significant increase in staffing. Due to that understanding, the legislature allocated an additional 16 positions and approximately $1.6 million in funding to ADHS to help improve our ability to respond to LTC complaints. We are thankful to the legislature for the budgetary increase; however historically, we have struggled to recruit and retain qualified compliance officers for BLTC.

It is also important to note that it takes 6-12 months for a new compliance officer to become fully trained and pass the Surveyor Minimum Qualifications Test (SMQT) administered and required by CMS, which means the progress made in the second half of 2022 was based on the extraordinary efforts of the existing team members. While most BLTC team members were eager to help address the issues raised by the AZAG, continually working with an increased workload in the field while also helping train new hires proved stressful.

To address both the historical difficulties in recruiting and retaining staff, as well as the new challenges related to the audit, ADHS implemented the following initiatives in 2022:

  • Created a career track for compliance officers, which includes:
    • Increased base salary
    • Incentives for education and licensure as a registered nurse
    • Advancement opportunities
  • Implemented new recruitment techniques, including:
    • Posting positions in additional locations and attending job fairs
    • Offering hiring incentives for new hires
    • Offering referral incentives to existing staff

In response to a recommendation made by the state legislature, we have also been exploring how contracting with private companies may help improve our ability to investigate complaints more timely. ADHS followed the procurement process to contract with a private company that is equipped to complete complaint investigations for LTC facilities. The company has several SMQT-certified staff members who have begun working with our team to investigate some complaints. Like ADHS, they are also working to ramp-up their staffing levels.

All of these changes and improvements have not been made in a vacuum. ADHS is grateful to the AZAG for agreeing to our request to meet with us monthly since the 2022 Report was published. During these meetings, AZAG staff has been able to continuously observe the changes being made, and provide ADHS with invaluable feedback along the way. We recognize  that this collaborative approach is beyond the scope of the AZAG’s normal process, and believe it clearly demonstrates the shared commitment from both agencies to ensure the health and safety of the residents in Arizona’s LTC facilities.

This ongoing audit experience has inspired ADHS to examine all of our licensing processes more closely. We are committed to fully implementing all nine recommendations for BLTC, as well as monitoring all of the licensing bureaus to ensure these areas do not become problematic in any of our other licensing programs. 

If you are interested in becoming a part of our highly dedicated team, please check out this job posting for BLTC compliance officers, our Open Jobs page, as well as the other open ADHS positions currently posted on