Arizona HCBS Needs Tool

What the HNT Is

The HCBS Needs Tool (HNT) is Arizona's standardized assessment for determining how many direct care and habilitation hours a DDD member receives through their Person-Centered Service Plan (PCSP). AHCCCS directed DDD and the managed care plans to implement the HNT as a replacement for the previous assessment methods, which varied between plans and support coordinators.

The tool evaluates the individual's functional needs across daily living activities — bathing, dressing, feeding, toileting, mobility, communication, behavior management, and community access — and generates an authorized hour range based on clinical scoring. The goal is consistency: two members with similar functional profiles should receive comparable service hours regardless of which DDD health plan they're enrolled in or which support coordinator conducts the assessment.

The Rollout Timeline

The HNT implementation has been anything but smooth:

October 1, 2025 — AHCCCS launched the HNT for minor members (under 18). Almost immediately, families reported that the tool was generating significantly fewer authorized hours than their children had previously received, particularly for in-home habilitation and direct care.

October 16, 2025 — Governor Katie Hobbs directed AHCCCS to pause the HNT for minor children, revert to the previous assessment tools, and develop an exception process for families whose hours were reduced.

Late 2025 – Early 2026 — AHCCCS initiated emergency rulemaking to create the Extraordinary Care Review (ECR) process and revised the HNT to address the age-based scoring limitations that were undercounting service needs for younger children.

April – May 2026 — The emergency rule was renewed for an additional 180 days. AHCCCS opened a 30-day public comment period and hosted hearings to gather input from families, providers, and advocacy organizations.

June – August 2026 — The Arizona Legislature passed Laws 2026, Chapter 132, Section 19, exempting the revised HNT and ECR rules from standard Administrative Procedure Act (APA) requirements for the 2026–2027 fiscal year, allowing adoption through an exempt rulemaking process with community forums held in July and August.

December 1, 2026 — Target date for permanent, statewide implementation of the revised HNT and ECR policies. The updated HNT adjusts age limits for certain assessments — clinical evaluations for specialty feeding and bathing now start at age 5 instead of age 8.

How the HNT Affects Adults Turning 18

For transition-age youth turning 18, the HNT dynamics are different from the childhood controversy. The standard adult HNT guidelines apply without the childhood age exclusions that caused the October 2025 problems. This means:

• An 18-year-old is evaluated on their raw functional limitations in all areas, including housekeeping, meal preparation, and grooming — categories that were age-restricted for minors (a 10-year-old wouldn't be scored on meal preparation under the childhood tool because that's not age-appropriate)
• The adult assessment can actually produce higher hour authorizations than the childhood tool for individuals with significant daily living needs, because none of the "normal for their age" exclusions apply

However, the transition from the childhood assessment to the adult HNT happens at the same time as the DDD redetermination, ALTCS screening, and health plan enrollment — so families are managing multiple new evaluations simultaneously.

The Extraordinary Care Review Process

The ECR described in the research is a clinician-led exception process for minor members who believe their HNT-generated hours don't reflect their actual care needs. The key elements:

Who can request it: The research describes ECR as a clinician-led process for minor DDD members (or their family/representative) who disagree with the hours authorized through the standard HNT assessment. For an adult member, ask DDD which current review or appeal process applies rather than assuming ECR is available.

What it involves: A licensed clinician — separate from the regular support coordinator — conducts an independent review of the member's medical records, functional assessments, behavioral data, and current service utilization to determine whether the standard HNT result accurately captures the member's needs.

Possible outcomes: The clinician may confirm the HNT result, increase authorized hours above the standard range, or recommend alternative service configurations (such as shifting hours between service categories) that better match the member's care profile.

How to request: For a minor member, contact the DDD Customer Service Center at 844-770-9500 and ask about the current Extraordinary Care Review request route. For an adult member, ask DDD which review or appeal route applies. Document the specific functional needs you believe the HNT under-scored and have supporting medical or behavioral evidence ready.

Preparing for the Assessment

Whether the assessment uses the standard HNT or triggers an ECR, families can prepare by:

• Documenting the individual's worst-day functioning, not their best-day capabilities. Assessors often see the individual in a controlled environment where they appear more capable than they are during unstructured daily routines
• Collecting behavioral incident logs — frequency, duration, and intensity of challenging behaviors that require direct intervention
• Getting provider letters from therapists, physicians, and behavioral health professionals describing the level of support needed for each daily activity
• Preparing a 24-hour care diary showing exactly what the caregiver does throughout a typical day, including overnight supervision needs

The Arizona SSI at 18 & Adult Disability Benefits Guide includes a PAS preparation worksheet that doubles as HNT preparation — many of the functional domains overlap, so evidence gathered for one assessment supports the other.

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