Arizona families have another opportunity to weigh in on changes to how home and community-based service needs are assessed for people enrolled in the Arizona Long Term Care System (ALTCS).
The Arizona Health Care Cost Containment System (AHCCCS) opened a formal 30-day public comment period Sept. 12 on proposed rules governing the Home and Community Based Services Needs Tool (HNT) and Extraordinary Care Review (ECR).
Comments will be accepted through Oct. 12.
The changes are particularly important for families of children with disabilities who receive direct care or habilitation services through ALTCS, including children served by the Division of Developmental Disabilities (DDD).
What Are the HNT and ECR?
The HNT is a standardized assessment used to determine a person’s need for direct care and habilitation services. It considers support needed with activities such as bathing, dressing, eating and mobility, as well as tasks including meal preparation, household activities and community participation.
The ECR is a separate clinician-based review process for ALTCS members under age 18. It is intended for situations in which a child’s assessed direct care or habilitation hours may not reflect their needs because of age-related limitations in the HNT or habilitation service-hour caps.
In other words, the HNT helps determine assessed service needs, while the ECR provides an additional review process for some children when those assessed hours are disputed.
How Did We Get Here?
AHCCCS initially launched a new HNT in October 2025 but paused its use for children under 18 after concerns were raised by families and other stakeholders.
Since then, AHCCCS has revised the HNT and developed the ECR process. Thousands of public comments, along with feedback from families, providers, advocates, health plans and other stakeholders, have contributed to revisions.
Families also had an informal opportunity to review and comment on draft policies this summer.
The current comment period is different. It is the formal 30-day public comment period on the proposed exempt rulemaking that will establish requirements for the HNT and ECR as AHCCCS moves toward implementation.
Why This Comment Period Matters
The proposed rules address how the HNT and ECR processes will operate, including requirements for health plans and training for clinicians conducting Extraordinary Care Reviews.
For families, the practical issue is how the assessment and review processes work for people who rely on home and community-based services.
Families do not have to agree or disagree with the proposal as a whole to participate. Comments can address a particular provision, explain how a proposed process might work for an individual with significant support needs, identify an area that is unclear or describe an experience that could help AHCCCS understand how the rule may work in practice.
AHCCCS says comments received during this 30-day period will help inform the final exempt rulemaking.
What Happens Next?
The formal comment period ends Oct. 12.
AHCCCS expects the exempt rulemaking process to conclude in October, with HNT and ECR policies finalized in October or November.
The current AHCCCS timeline calls for the new HNT/ECR policies to take effect in December 2026.
Families whose children receive ALTCS services may want to review the proposed rule and related HNT/ECR materials before the comment period closes.
Resources
AHCCCS HNT/ECR Proposed Rule and Public Comment: Review the proposed exempt rulemaking and find instructions for submitting comments.
AHCCCS HNT/ECR Information for Members and Families: Find background information, FAQs, previous presentations and the implementation timeline.
