Arizona repealed its CON program—but it now has a “certificate of necessity” program that applies only to ground ambulances. For this reason, some have deemed Arizona a “quasi-CON” state. Despite the fact that Arizona maintains only one certificate of necessity requirement, the application process is the longest in the nation, lasting 450 days. Ariz. Admin. Code § R9-25-1201(A), Tbl. 12.1. During the 450-day application process, every existing ground ambulance service provider in the affected region must be notified and given the opportunity to object to the application. See Ariz. Rev. Stat. § 36-2234.

COVID-19 Response

As of May 15, 2020, Arizona had not suspended its certificate of necessity requirement in response to COVID-19.

Application Process

In Arizona, the certificate of necessity application process takes 450 days. Ariz. Admin. Code § R9-25-1201(A), Tbl. 12.1. Applications can be submitted at any time. The filing fee is $100 for the application and an additional $200 per ambulance. Ariz. Rev. Stat. § 36-2240(1), (3). Competitors can intervene in the application process and can offer evidence or argument as to why an application should be denied. Ariz. Rev. Stat. §§ 36-2234(B); 41-1092.03 et seq.

CON? Number of Certificates Moratoria Temporary COVID-19 response:
Hospital Beds No
Beds Outside Hospitals No
Equipment No
Facilities/ Buildings No
Services No
Emergency Medical Transport Yes 1 No action