Documentation Index
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Version: 1.0.0
Last Updated: 2026-02-27
Status: Active
Module: RH (Recovery Housing)
Cross-References:
Overview
This document tracks regulatory compliance obligations for recovery housing operations in Arizona. Recovery residences (sober living homes) are subject to Arizona DHS licensure, NARR quality standards, Fair Housing Act protections, fire/safety codes, and data privacy requirements (HIPAA / 42 CFR Part 2) when handling resident SUD records.
1. Arizona DHS Licensure (ARS 36-2061 through 36-2068, AAC Title 9 Chapter 12)
| # | Requirement | Responsible Spec | Status | Notes |
|---|
| DHS-01 | Licensure before operation — Obtain DHS sober living home license before accepting residents | RH-06 | ⏳ Not Started | Application: 500+100/bed; floor plans, zoning attestation required |
| DHS-02 | Minimum standards (AAC R9-12-201 through R9-12-207) — Comply with administration, residency agreements, resident rights, records, services, emergency/safety, and physical plant | RH-01, RH-06 | 🟡 Partial | RH-01 tracks property and bed inventory; RH-06 tracks inspections |
| DHS-03 | Substance-free environment — Maintain alcohol-free and drug-free housing; mandatory resident abstinence | RH-04 | 🟡 Partial | Drug testing tracking in RH-04; policy enforcement |
| DHS-04 | Medication-assisted treatment (MAT) — Cannot prohibit residents from continuing MAT per ARS 36-2062 | RH-01 | 📋 Policy | Organizational policy; system must not flag MAT as violation |
| DHS-05 | Residency agreements — Written agreement covering house rules, fees, discharge conditions | RH-02 | 🟡 Partial | Resident agreement templates in RH-02 |
| DHS-06 | Resident records — Maintain intake records, emergency contacts, discharge information | RH-02 | 🟡 Partial | Resident profile data in RH-02 |
| DHS-07 | DHS inspections — Submit to routine and complaint-driven inspections | RH-06 | 🟡 Partial | Inspection tracking in RH-06; license renewal workflow |
| DHS-08 | Civil penalties — Up to $500/day per violation for noncompliance; license suspension/revocation | RH-06 | 📋 Awareness | Track inspection findings and corrective actions |
2. NARR Quality Standards (National Alliance for Recovery Residences)
| # | Requirement | Responsible Spec | Status | Notes |
|---|
| NARR-01 | Level classification (I–IV) — Self-classify home per NARR National Standard 3.0 based on staffing, governance, and services | RH-01, RH-11 | ⏳ Not Started | Store NARR level in property record; affects compliance requirements — see RH-11 |
| NARR-02 | AzRHA certification — Optional Arizona Recovery Housing Association certification (expedites DHS licensing) | RH-06, RH-11 | ⏳ Not Started | Track AzRHA certification status and renewal — see RH-11 |
| NARR-03 | Peer-operated governance — Resident participation in house governance (Levels I-II); professional management (Levels III-IV) | RH-01 | 📋 Operational | Document governance structure per level |
| NARR-04 | Recovery support — Provide or facilitate access to recovery support services per level | RH-05 | 🟡 Partial | Recovery program tracking in RH-05 |
| NARR-05 | Administrative standards — Policies for admission, discharge, grievance, safety | RH-01, RH-02 | 🟡 Partial | Policies managed in system; ensure NARR alignment |
3. Fair Housing Act / ADA
| # | Requirement | Responsible Spec | Status | Notes |
|---|
| FH-01 | Non-discrimination — Cannot deny housing based on disability (including SUD recovery status) | RH-02 | 📋 Policy | Organizational policy; system must not discriminate in waitlist/placement |
| FH-02 | Reasonable accommodations — Modify policies/practices to accommodate disabled residents | RH-02 | 📋 Policy | Track accommodation requests and outcomes |
| FH-03 | Zoning protection — Local governments cannot apply zoning to exclude group homes for disabled persons | RH-01 | 📋 Awareness | Document zoning compliance per property; track any challenges |
| FH-04 | ADA physical accessibility — Common areas and a proportion of units must be accessible per ADA | RH-01 | ⏳ Not Started | Track accessibility features per property in RH-01 |
4. Fire and Life Safety
| # | Requirement | Responsible Spec | Status | Notes |
|---|
| FS-01 | Local fire codes — Comply with municipal fire codes; submit floor plans showing egress | RH-01, RH-06, RH-10 | ⏳ Not Started | Track fire inspection dates and findings per property — see RH-10 |
| FS-02 | Smoke/CO detectors — Install and maintain per Arizona building code | RH-01 | 📋 Operational | Maintenance tracking in RH-01 |
| FS-03 | Emergency evacuation plan — Posted evacuation plan; periodic fire drills | RH-06 | ⏳ Not Started | Track drill dates; inspection readiness |
| FS-04 | NFPA compliance — National Fire Protection Association standards for residential occupancies | RH-01 | 📋 Operational | Existing building compliance; document per property |
5. Arizona Title 36 (Public Health and Safety)
| # | Requirement | Responsible Spec | Status | Notes |
|---|
| T36-01 | Patient rights (ARS 36-504 et seq.) — Rights to privacy, dignity, least restrictive treatment | RH-02 | 📋 Policy | Applies when housing intersects with behavioral health treatment |
| T36-02 | Voluntary vs involuntary status — Residents are voluntary; cannot restrict departure | RH-02 | 📋 Policy | System must not enforce involuntary retention |
| T36-03 | Grievance procedures — Residents have right to file grievances without retaliation | RH-09 | ⏳ Not Started | Implement grievance tracking workflow — see RH-09 |
| T36-04 | Personal property rights — Residents retain rights to personal property and financial management | RH-02 | 📋 Policy | Fee structure transparency; no property seizure |
6. Data Privacy (HIPAA / 42 CFR Part 2)
| # | Requirement | Responsible Spec | Status | Notes |
|---|
| DP-01 | HIPAA applicability — If housing entity is a covered entity or business associate, HIPAA applies to resident health data | RH-02, PF-44 | 📋 Depends | Determined by organizational structure; pure housing without clinical services may not be covered |
| DP-02 | 42 CFR Part 2 — SUD treatment records require specific consent for disclosure; redisclosure prohibited | CL-11, RH-02 | 🟡 Partial | CL-11 consent management implements Part 2; RH must respect consent boundaries |
| DP-03 | Resident SUD data — Drug test results and SUD treatment status are Part 2 protected | RH-04 | ⏳ Not Started | Implement access controls on drug test data; audit trail |
| DP-04 | Minimum necessary — Share only minimum necessary resident information for housing operations | RH-02 | 📋 Policy | Organizational policy; system enforces role-based access |
7. Zoning and Land Use
| # | Requirement | Responsible Spec | Status | Notes |
|---|
| ZN-01 | Local zoning compliance — Attestation of zoning compliance required for DHS licensure | RH-01 | ⏳ Not Started | Track zoning status per property; store attestation documents |
| ZN-02 | Municipal group home limits — Some municipalities limit number of unrelated persons; Fair Housing may override | RH-01 | 📋 Awareness | Track applicable municipal ordinances per property location |
| ZN-03 | Neighborhood notification — Some municipalities require notification for group home operations | RH-01 | 📋 Awareness | Document notification status per property if applicable |
8. Authoritative External References
| Source | URL | Used By |
|---|
| Arizona DHS: Sober Living Home Licensing | https://www.azdhs.gov/licensing/special/sober-living-homes/index.php | RH-06, RH-01 |
| Arizona DHS: Behavioral Health Facilities Licensing | https://www.azdhs.gov/licensing/bbbl-facilities/index.php | RH-06, RH-03 |
| Arizona DHS: Residential Facilities Licensing | https://www.azdhs.gov/licensing/residential-facilities/ | RH-01, RH-06 |
| ARS 36-2061 through 36-2068 (Sober Living Homes) | https://www.azleg.gov/arsDetail/?title=36 | RH-06 |
| AAC Title 9, Chapter 12 (Sober Living Home Rules) | https://apps.azsos.gov/public_services/Title_09/9-12.htm | RH-01, RH-06 |
| NARR: National Standard for Recovery Residences 3.0 | https://narronline.org/standards/ | RH-01, RH-06 |
| Arizona Recovery Housing Association (AzRHA) | https://www.myazrha.org/ | RH-06 |
| HUD/DOJ: Fair Housing Act — Group Homes for Persons with Disabilities | https://www.justice.gov/opa/file/912366/dl | RH-01, RH-02 |
| Fair Housing Act | https://www.hud.gov/program_offices/fair_housing_equal_opp/fair_housing_act_overview | RH-01, RH-02 |
| Arizona Title 36 (Public Health and Safety) | https://www.azleg.gov/arsDetail/?title=36 | RH-02 |
| NFPA: Life Safety Code | https://www.nfpa.org/codes-and-standards/nfpa-101-standard-development/101 | RH-01 |
9. Periodic Review Schedule
| Review | Frequency | Next Due | Owner |
|---|
| DHS license renewal | Per license term | YYYY-MM-DD | Operations Director |
| AzRHA certification renewal | Annually | YYYY-MM-DD | Operations Director |
| Fire inspection compliance | Annually | YYYY-MM-DD | Property Manager |
| NARR level reassessment | Annually | YYYY-MM-DD | Program Director |
| Fair Housing policy review | Annually | YYYY-MM-DD | Compliance Officer |
| Drug testing data access audit | Quarterly | YYYY-MM-DD | Privacy Officer |
Version History
1.0.0 (2026-02-27)
- Initial comprehensive RH recovery housing compliance document
- Covers Arizona DHS licensure, NARR standards, Fair Housing, fire/safety, Arizona Title 36, data privacy, zoning
- 35+ compliance requirements tracked across 7 categories
Last Updated: 2026-02-27
Next Review: 2026-05-27
