Major Regulatory Overhaul Coming July 1, 2025

Arizona is implementing the most significant assisted living regulatory changes in years. If your facility provides memory care services—or plans to—you need to understand these new rules now.

The Arizona Department of Health Services (ADHS) has finalized new administrative rules under Title 9, Chapter 10 (R9-10) that create a new memory care licensing subclass with extensive training, documentation, and safety requirements.

This isn't optional. Compliance is mandatory by July 1, 2025.

What's Changing: The Big Picture

New Memory Care Licensing Category

Arizona now has three assisted living license classifications:

1. Standard — Basic assisted living services

2. Directed Care — Enhanced services for residents needing more assistance

3. Memory Care — NEW: Specialized license for dementia and Alzheimer's care

If you currently provide memory care services, you'll need to update your license application. If you're considering adding memory care, you'll need this new subclass.

Why These Changes?

These rules stem from Laws 2024, Chapter 100 (HB2764), which mandated ADHS establish formal memory care standards by June 30, 2025. The goal: better protection for Arizona's most vulnerable residents—those with dementia and cognitive impairments.

New Training Requirements

This is where most facilities will feel the impact. The training requirements are substantial and non-negotiable.

For All Memory Care Staff

Every caregiver, contractor, and direct care worker in a memory care facility must complete:

* 8 hours of initial training from an ADHS-approved program

* 4 hours of annual continuing education

* In-person demonstration of skills and knowledge (online-only training won't count)

For Managers

Facility managers have additional requirements:

* All standard manager training

* Additional 4 hours specific to memory care services

* Demonstrated competency in memory care supervision

Rehired Staff

If a staff member leaves and returns after a 12-month gap, they must complete the full 8-hour initial training again within 30 days of rehire.

What Training Must Cover

ADHS has specified required topics:

* Understanding cognitive impairments and their impact on residents

* Communication techniques for cognitively impaired residents

* Managing challenging behaviors (aggression, wandering, agitation)

* Safety protocols specific to memory care

* Elopement prevention strategies

* Person-centered care approaches

Registry Check Requirements

Starting January 1, 2025, Arizona requires all assisted living facilities to verify staff against the Adult Protective Services (APS) Registry.

Key Deadlines

* January 1, 2025: New requirement takes effect

* March 31, 2025: All existing staff must be verified

What This Means

* Check every employee, contractor, and volunteer against the APS Registry

* Anyone with a substantiated report of abuse, neglect, or exploitation cannot work in your facility

* Document every registry check in personnel files

* Perform checks on all new hires before they start

Don't Forget Fingerprint Clearance

Every staff member must also have a valid Fingerprint Clearance Card per A.R.S. § 36-411:

* Cards must be current (not expired)

* Copies filed in personnel records

* Background check must be clear

Environmental and Safety Requirements

Memory care facilities must meet enhanced physical environment standards:

Elopement Prevention

* Secured entry/exit points

* Alarm systems on doors

* Documented elopement prevention protocols

* Staff training on elopement response

Signage and Visual Cues

* Clear wayfinding signage appropriate for cognitively impaired residents

* Visual cues to support orientation

* Accommodations for residents at varying stages of impairment

Additional Documentation

* Bi-annual certification by a medical practitioner confirming appropriate placement

* Enhanced intake paperwork for memory care residents

* Incident documentation specific to cognitive impairment behaviors

Increased Penalties for Non-Compliance

As covered in our previous article, HB2764 also doubled violation fines from $500 to $1,000 per resident, per day.

For memory care violations, this could mean:

* Untrained staff providing memory care: $1,000 × number of residents × days

* Missing registry documentation: Penalties plus potential license issues

* Elopement due to inadequate safety measures: "Immediate Jeopardy" classification

What is "Immediate Jeopardy"?

This is a new concept in Arizona assisted living regulations, borrowed from CMS skilled nursing standards. It means:

> "A situation in which a patient or resident has suffered or is likely to suffer serious injury, serious harm, serious impairment, or death as a result of a licensee's noncompliance."

Immediate Jeopardy triggers the most severe enforcement response, including potential emergency license action.

Timeline: Critical Dates

| Date | Requirement |

|------|-------------|

| January 1, 2025 | APS Registry checks mandatory for new hires |

| March 31, 2025 | All existing staff verified against APS Registry |

| April 8, 2025 | Public comment period ends |

| July 1, 2025 | Memory care licensing rules take effect |

| July 1, 2025 | 8-hour training requirement for all memory care staff |

What Existing Memory Care Providers Should Do Now

If you already provide memory care services, don't wait until July:

1. Audit Your Current Training

* Do all staff have documented dementia care training?

* Is training from an ADHS-approved provider?

* Can you prove in-person skill demonstration?

2. Complete Registry Checks

* Run APS Registry checks on all current staff by March 31

* Document results in personnel files

* Verify all Fingerprint Clearance Cards are current

3. Review Your Physical Environment

* Are elopement prevention measures documented?

* Is signage appropriate for cognitively impaired residents?

* Do you have incident protocols for wandering/elopement?

4. Prepare for License Update

* Contact ADHS about documentation requirements for existing licensees

* Gather required paperwork before the July deadline

* Budget for any application fees

5. Set Up Tracking Systems

* 4-hour annual continuing education for all memory care staff

* Bi-annual medical practitioner certifications for residents

* Training certificate expirations

* Registry check renewal schedules

How CareDash Pro Helps

These new requirements create significant documentation and tracking burdens. CareDash Pro helps you stay compliant:

Training Tracking

* Track initial 8-hour training completion for every staff member

* Monitor annual 4-hour CE requirements

* Set alerts before certifications expire

* Document in-person vs. online training components

Staff Compliance Dashboard

* See all registry check dates at a glance

* Track Fingerprint Clearance Card expirations

* Get alerts when staff certifications are due

* Generate audit-ready compliance reports

Resident Documentation

* Track bi-annual medical certifications

* Document assessments and care plan updates

* Maintain incident logs for cognitive-related behaviors

Deadline Alerts

* Automated reminders for March 31 registry deadline

* Training expiration warnings at 90, 60, 30, and 7 days

* License renewal tracking

The Bottom Line

Arizona's 2025 memory care rules aren't suggestions—they're mandatory. Facilities that fail to comply face:

* $1,000/resident/day fines

* "Immediate Jeopardy" classification for safety failures

* License suspension or revocation

* Inability to operate memory care services

The time to prepare is now. Don't wait until June to scramble for training providers or discover documentation gaps.

Need help tracking memory care compliance? [Contact CareDash Pro](/contact) to see how we can help you meet the July 2025 deadline.

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Sources:

* [Arizona HB2764 - Senate Fact Sheet](https://www.azleg.gov/legtext/56leg/2R/summary/S.2764HHS.DOCX.htm)

* [ADHS Notice of Final Rulemaking - Memory Care](https://www.azdhs.gov/documents/policy-intergovernmental-affairs/administrative-counsel-rules/rules/rulemaking/hci-and-memory-care/notice-of-final-rulemaking.pdf)

* [Arizona Assisted Living Compliance: 2025 Provider Guide](https://synkwise.com/news/arizona-assisted-living-compliance/)

* [New Memory Care Legislation - Davis Miles](https://www.davismiles.com/lawyer-speak/new-memory-care-legislation-will-take-effect-in-arizona-on-july-1-2025-survey-open-now/)

* [Significant Rule Changes - Snell & Wilmer](https://www.swlaw.com/publication/significant-rule-changes-ahead-for-arizona-assisted-living-facilities-providing-memory-care-and-directed-care-services/)

* [AZ Assisted Living Regulations 2025](https://meyland-smith.com/assisted-living/az-assisted-living-regulations/)

Arizona Memory Care Rules 2025: Complete Guide to New ADHS Requirements