Starting a Hospice Agency in Arizona: A Step-by-Step Guide and Overview of Pertinent Laws

Opening a hospice agency in Arizona can be both a fulfilling and complex process, requiring a deep understanding of licensing, healthcare regulations, and compliance with state and federal laws. The Arizona Department of Health Services (ADHS) regulates hospice agencies within the state, and strict adherence to their requirements is essential for successful licensure and ongoing operations.

This article outlines how to start a hospice agency in Arizona and the key laws and rules you must know to remain in compliance.

What Is a Hospice Agency?

A hospice agency provides palliative and supportive services to terminally ill patients and their families, typically in the patient’s home or residential facility. Services include medical, nursing, social, emotional, and spiritual care focused on comfort rather than cure.

In Arizona, hospice agencies must be licensed by the Arizona Department of Health Services (ADHS) under Arizona Administrative Code (A.A.C.) Title 9, Chapter 11.

Step-by-Step: How to Start a Hospice in Arizona

1. Determine Your Business Structure

Choose a legal business structure (e.g., LLC, Corporation) and register with:

• Arizona Corporation Commission (ACC)

• Arizona Department of Revenue (ADOR) for applicable tax registration

You may also need an Employer Identification Number (EIN) from the IRS and appropriate business insurance.

2. Secure a Physical Office Location

Arizona requires hospice agencies to have a physical business location that meets state regulations for administration and service delivery. The office must:

• Be accessible to staff and state surveyors

• House patient records and administrative documentation

• Serve as the operational headquarters

3. Apply for a Hospice License through ADHS

Complete and submit the hospice license application via the ADHS Division of Licensing Services. You must provide:

• Ownership and organizational details

• Floor plans of the business location

• Staffing structure and qualifications

• Policies and procedures compliant with A.A.C. R9-11

• Proof of liability insurance

• Payment of applicable fees

Important: Review the Arizona Administrative Code R9-11-101 through R9-11-1205 for detailed licensing requirements.

4. Pass Initial Survey/Inspection

Before your license is issued, the ADHS will conduct an initial compliance survey (onsite inspection) to ensure your agency:

• Meets building and safety standards

• Has staff properly credentialed and trained

• Has operational policies, clinical procedures, and documentation systems ready

• Is prepared to begin patient care immediately after licensure

5. Enroll in Medicare and Medicaid (Optional, but Recommended)

If you plan to serve Medicare or Medicaid beneficiaries:

• Apply for Medicare Certification via CMS Form 855A

• Prepare for a CMS certification survey

• Meet federal Conditions of Participation (42 CFR Part 418)

Arizona's AHCCCS (Arizona Health Care Cost Containment System) is the state Medicaid agency, and you may also apply to become a Medicaid provider through them.

6. Maintain Ongoing Compliance

Once licensed and certified, your hospice agency must:

• Maintain clinical and administrative records per ADHS rules

• Submit to routine and unannounced surveys

• Report incidents and complaints to ADHS as required

• Renew your license as scheduled and notify ADHS of changes (e.g., ownership, location, administrator)

Pertinent Laws and Regulations

Arizona Administrative Code (A.A.C.) Title 9, Chapter 11

This chapter governs licensing of health care institutions, including hospice agencies. Key sections include:

• R9-11-201 to R9-11-208 – Hospice-specific provisions

• R9-11-301 to R9-11-323 – Administrative requirements

• R9-11-404 – Medical Director requirements

• R9-11-502 to R9-11-519 – Plan of care, staffing, quality management

These rules specify requirements for:

• Medical director oversight

• Nursing and counseling services

• Volunteer involvement

• Spiritual and bereavement care

• Recordkeeping and patient rights

Arizona Revised Statutes (A.R.S.) Title 36, Chapter 4

This statute outlines state oversight and enforcement powers over healthcare institutions and includes the legal authority for licensure, enforcement, and penalties.

Additional Considerations

Staffing

Hospice agencies in Arizona must employ:

• A licensed physician or medical director

• Registered nurses for direct patient care

• A social worker

• A spiritual or bereavement counselor

• Trained volunteers, per CMS requirements

Policies and Procedures

Your agency must have written, state-compliant policies covering:

• Admission and discharge

• Medication administration

• Infection control

• Emergency preparedness

• Abuse prevention

• Quality improvement

Final Thoughts

Starting a hospice agency in Arizona involves more than a good business idea—it requires legal, clinical, and operational readiness. From compliance with ADHS licensing requirements to adherence to federal Medicare CoPs, your agency must be structured for regulatory success.

By preparing thoroughly, working with experienced consultants, and investing in strong clinical systems and training, you can lay the foundation for a hospice that is compliant, compassionate, and sustainable.