Arizona Assisted Living Emergency Preparedness and Evacuation Drill Requirements: 2026 Guide

This guide covers the emergency and safety standards for licensed assisted living facilities in Arizona: assisted living homes (ten or fewer residents) and assisted living centers (eleven or more). It is written for the manager who has to schedule the drills, keep the records, and answer the surveyor's questions.

Quick reference

The recurring items, all from R9-10-819. Frequencies are the rule minimums.

The rule changed numbers in 2025

For more than a decade, Arizona's assisted living emergency standards lived at R9-10-818. In 2025 the Department of Health Services added a new section for memory care services, and the sections after it moved down one number. The historical note in the current compilation records it directly: R9-10-819 was renumbered to R9-10-820, and a new R9-10-819 was "renumbered from R9-10-818 and amended by final rulemaking at 31 A.A.R. 2085 (June 27, 2025), with a delayed effective date of June 30, 2025."

The renumbered Article 8 now reads: R9-10-815 Directed Care Services, R9-10-816 Memory Care Services, R9-10-817 Medication Services, R9-10-818 Food Services, R9-10-819 Emergency and Safety Standards, R9-10-820 Environmental Standards, and R9-10-821 Physical Plant Standards.

What must be in the disaster plan

R9-10-819(A)(1) requires a disaster plan that is developed, documented, kept where caregivers and assistant caregivers can get to it, and put into action when needed. "Disaster" is defined in R9-10-101 as an unexpected occurrence that adversely affects the facility's ability to provide services, which is broader than a fire or a storm. As an example tied to that definition, a long power outage that adversely affects the facility's ability to provide services can qualify.

The plan must include four things, in plain terms:

• Relocation. When residents would be moved, how they would get there, and where they would go.
• Medical records. How each resident's medical record will be available to the people providing services during the disaster.
• Medications. A plan to make sure each resident's medications will be available to administer.
• Food and water. How the facility will obtain food and water for the people present, at the facility or at the relocation site.

Sources: R9-10-819(A)(1)(a) to (d); R9-10-101 (definition of disaster).

Annual disaster-plan review

R9-10-819(A)(2) requires the plan to be reviewed at least once every 12 months. The review has its own documentation requirement in (A)(3):

• the date and time of the review;
• the name of each employee or volunteer who took part;
• a critique of the review; and
• recommendations for improvement, if there are any.

The critique is easy to overlook. A signed line that says "reviewed, no changes" records that a review happened but does not show that anyone evaluated whether the plan would work. Two or three sentences on what was tested against reality, and what was found, satisfy the rule and are more useful.

Employee disaster drills

R9-10-819(A)(4) requires a disaster drill for employees, conducted on each shift, at least once every three months, and documented. Three points follow from the wording.

• It is a drill for employees. Residents are not required participants. The drill exercises the plan: who does what, where the records and medications go, how relocation would start.
• Each shift means each shift. A facility with day, evening, and night shifts needs a drill on each of them at least every three months. One drill on the day shift does not cover the night crew.
• It must be documented, but the rule does not list what the documentation must contain. Recording the date, time, shift, scenario, and who participated is a reasonable way to show the requirement was met.

Evacuation drills with residents

The evacuation drill is a separate requirement, and the rules do not merge it with the disaster drill. R9-10-819(A)(5) requires an evacuation drill for employees and residents at least once every six months that includes all individuals on the premises, with two exceptions:

• a resident whose medical record contains documentation that evacuation from the facility would cause harm to the resident; and
• sufficient caregivers to ensure the health and safety of the residents who are not evacuated.

The exception is specific. It is not "residents who would rather not," and it is not a blanket exemption for everyone in a memory care wing. It rests on documentation in that resident's medical record that evacuation would cause harm. If a resident is left in place, enough caregivers stay with them, and the drill record names them (see the next section).

Unlike the disaster drill and the elopement drill, the current evacuation-drill text does not say "on each shift." Some older Arizona materials quote an earlier version that did. Under the current rule the minimum is every six months. Nothing prevents a facility from drilling more often or on more than one shift, and many do.

Sources: R9-10-819(A)(5)(a) and (A)(5)(b)(i) to (ii).

What must be documented after an evacuation drill

R9-10-819(A)(6) requires a record of each evacuation drill, kept for at least 12 months after the date of the drill. The record must include:

• the date and time of the drill;
• the amount of time it took employees and residents to evacuate;
• if applicable, which residents needed assistance to evacuate;
• if applicable, which residents were not evacuated;
• any problems encountered in conducting the drill; and
• recommendations for improvement, if applicable.

Do not leave the evacuation time blank; it is a required field. It is also the one that makes the record useful: a drill that took four minutes in March and nine minutes in September, with a note explaining why, tells the manager and the surveyor something. Use a clock, not an estimate.

Directed care and elopement drills

If the facility is authorized to provide directed care services, R9-10-819(A)(7) adds a third drill. "Elopement" is defined in R9-10-801: a resident who is cognitively, physically, mentally, emotionally, or chemically impaired wanders, walks, or runs away, or otherwise leaves the premises unsupervised or unnoticed, without the knowledge of the facility's personnel.

Two duties sit in this subsection, and they are different in kind:

• The drill. An elopement drill for employees every six months on each shift, documented with the date, time, and a description of each drill. (A)(7)(a)
• The real event. Any actual elopement is investigated immediately, and the designated family member or members, legal guardian, or other responsible person is notified within 24 hours. (A)(7)(b)

A real elopement also triggers a separate duty outside this section: R9-10-803(K)(3) requires written notification to the Department within 24 hours of the elopement being discovered. Facilities providing memory care services also carry policy requirements in R9-10-816(A)(1)(f) and (g): evacuation and emergency procedures specific to memory-care residents that include the R9-10-819(A)(5) evacuation requirements, and elopement prevention and response. Our incident reporting guide covers the reporting side in detail.

New resident evacuation orientation

R9-10-819(B) requires that each resident receive orientation to the exits from the facility and the route to use when evacuating, within 24 hours after the resident's acceptance, and that the orientation be documented.

The clock runs from acceptance, which for most facilities is move-in day. The rule requires documentation but does not prescribe a form or a signature. One practical way to document the requirement is to add a dated line to the admission checklist identifying that the evacuation orientation was completed and who provided it. For a resident who cannot follow the orientation, document that it was given and how. Whether that resident is later listed as needing assistance on an evacuation drill record depends on whether assistance was actually needed during the drill.

Evacuation maps and exit postings

R9-10-819(A)(8) requires an evacuation path to be conspicuously posted in each hallway of each floor. A single map by the front door does not meet "each hallway of each floor." Post one where people actually are, at a height and size that can be read in a hurry, and update it when a room changes use.

First-aid kit

R9-10-819(C) requires a first-aid kit to be maintained in the assisted living facility in a location accessible to caregivers and assistant caregivers. That is the whole requirement: the rule does not prescribe the kit's contents, a brand, an inspection schedule, or a log. "Maintained" is the operative word. A kit that has been emptied of bandages, or one locked in an office the night caregiver cannot open, does not meet it.

When a resident is hurt: what R9-10-819 requires

R9-10-819(D) applies when a resident has an accident, emergency, or injury that results in the resident needing medical services. The caregiver or assistant caregiver must:

• Immediately notify the resident's emergency contact and primary care provider; and
• Document the date and time; a description of what happened; the names of individuals who observed it; the actions the caregiver took; the individuals notified; and any action taken to prevent it from happening again.

Note what this subsection does not say. It does not require a report to ADHS. Department notification is governed by R9-10-803(K), which requires written notice for three specific events: a resident's death when it is reportable under A.R.S. § 11-593 (within one working day), a self-injury that requires immediate intervention by an emergency services provider (within two working days), and an elopement (within 24 hours of discovery). A fall that sends a resident to urgent care is documented under R9-10-819(D) and evaluated through the quality-management program in R9-10-804; it is not, by itself, an ADHS-reportable event. Do not tell staff that "every emergency goes to the state." Tell them which ones do.

Fire safety for assisted living homes

R9-10-819(F) sets the physical fire-safety items for an assisted living home. These are the things a surveyor can see and touch on the first walk-through.

Fire safety for assisted living centers

R9-10-819(E) sets a different list for an assisted living center. The home rules above do not apply to centers as written, and the center rules do not apply to homes except through the alternative in (G).

• Fire alarm and sprinklers. In the areas of the center providing personal care services or directed care services, a fire alarm system installed according to NFPA 72 and a sprinkler system installed according to NFPA 13 (both incorporated by reference in R9-10-104.01), each in working order. The rule preserves an exception only for a center that has documentation of an exception received from the Department before October 1, 2013. (E)(1)
• Supervisory-care-only areas. Either the same alarm and sprinkler systems, or compliance with the home requirements in subsection (F). (E)(2)
• Fire inspection. Conducted by a local fire department or the State Fire Marshal before licensing, and then according to the time-frame that fire authority establishes. The rule does not set the interval; the fire authority does. (E)(3)
• Corrections and records. Any repairs or corrections stated on the inspection report are made, and documentation of a current fire inspection is maintained. (E)(4), (E)(5)

What to have ready for a surveyor

ADHS does not require a physical "survey binder," and nothing in R9-10-819 says how records must be organized. What the rule does require is that the documents exist, and R9-10-803(E)(1) requires documentation required by Article 8 to be provided to the Department within two hours after a Department request. Keeping these items in one place, paper or electronic, is how most operators meet that two-hour expectation without a scramble.

• the current disaster plan, in the location caregivers know;
• the most recent annual review record with its critique;
• disaster drill records, per shift, covering at least the last several quarters;
• evacuation drill records for at least the last 12 months;
• elopement drill records if the facility provides directed care;
• resident exit-orientation documentation, usually on the admission checklist;
• for homes, 12 months of smoke-detector test records and the extinguisher service tag or replacement date;
• for centers, the current fire inspection report and evidence that any listed corrections were made.

The current ADHS initial checklists for homes and centers (Version 25-4, June 17, 2025) list these R9-10-819 items in the order a surveyor works through them, and they are a reasonable self-audit tool between surveys. Our survey readiness guide covers the rest of the visit.

Common mistakes

Each of these follows directly from the rule text above. The ADHS top-ten deficiency lists published for 2019 and 2020 placed disaster drills and evacuation drills among the most frequently cited items for assisted living facilities; those lists cite the old R9-10-818 number, but the underlying requirements are the same ones described here.

• Citing R9-10-818 in current policies. The emergency standards have been R9-10-819 since June 30, 2025.
• Doing drills without documenting them. Every drill in R9-10-819 carries a documentation requirement; an undocumented drill cannot be shown to a surveyor.
• Covering one shift and calling it done. Disaster drills and elopement drills are per shift. Night shift needs its own.
• Leaving the evacuation time blank. It is a required element of the evacuation drill record.
• An annual review with no critique. The rule requires a critique and, where applicable, recommendations, not just a date and signatures.
• No record that new residents were shown the exits. The 24-hour orientation must be documented.
• Testing smoke detectors without a log. The monthly test must be documented and kept for 12 months.
• Treating the medical exception as optional participation. A resident sits out an evacuation drill only on documentation in the medical record that evacuation would cause harm.