This guide turns the personnel rules into a hiring and file-review process. It covers the assisted living licensing record. Payroll, employment eligibility, benefits, and other employment-law records need their own processes.
How to read this guide
Sources checked September 12, 2026. The administrative rules cited below are from the official Supplement 26-1 compilation. Requirements are identified by their rule or statute. Suggestions for organizing the work are labeled management practice and are not additional legal obligations.
1. Start with the person's role and actual duties
R9-10-806(C) requires a personnel record for every employee and volunteer. Some contents apply to everyone. Others depend on duties, credentials, resident contact, facility services, or the facility's written policies.
Before collecting documents, identify the person's role and the services they will provide.
| Role or circumstance | What changes in the review |
|---|---|
| Manager | Verify written designation, age 21 or older, and the required manager certificate or temporary certificate. R9-10-803(A)(3) includes an adult foster care home exception to the certificate requirement. |
| Caregiver | Verify age 18 or older and an approved caregiver-training qualification, or a documented alternative allowed by R9-10-806(A)(1)(b). Verify skills for the actual duties. |
| Assistant caregiver | Verify age 16 or older. Resident interactions must be supervised by a manager or caregiver. Orientation and documented skills verification still matter. |
| Other employee or volunteer | Identify qualifications and training required by the job and policies. For TB, assess whether direct resident interaction exceeds, or is expected to exceed, eight hours per week. |
| Staff or contractor at a facility licensed for directed care | Review the memory-care training and certificate requirements described below. The facility's license matters; a job title alone does not settle applicability. |
| Contractor or agency worker | Assess the contracted-services requirements and applicable fingerprinting and training obligations. An agency arrangement is not a reason to skip the facility's review. |
Sources: R9-10-803(A)(3), R9-10-805, R9-10-806(A) and (C); A.R.S. § 36-405.03.
For caregiver qualifications, keep evidence of the specific route being used. A résumé saying "experienced caregiver" does not establish completion of an approved program or an alternative qualification. The rule lists particular alternative pathways; do not assume every healthcare credential is interchangeable.
Put the role, assigned duties, service level, and supervisor on the file cover sheet. If an item does not apply, record why. This makes the decision understandable when someone else reviews the file.
2. Know what must happen before work or care begins
There is no single grace period for an incomplete personnel file. Different requirements have different triggers.
| Requirement | Timing and scope |
|---|---|
| APS Registry check | Check potential employees before hiring; do not hire a person confirmed to be on the registry. Reverify each employee annually. A.R.S. § 36-411(C). |
| Applicant's APS certification | Before employment in a position providing direct services to vulnerable adults or children, obtain the certification required by A.R.S. § 46-459(J). |
| Required TB evidence | On or before the person begins providing services at or on behalf of the facility. Applies to managers, caregivers, assistant caregivers, and other employees or volunteers meeting the resident-interaction threshold. R9-10-806(A)(8). |
| Duty-specific orientation | Before a caregiver or assistant caregiver provides assisted living services to a resident. R9-10-806(A)(9). |
| Skills and knowledge verification | Before a caregiver or assistant caregiver provides physical or behavioral health services; document it according to facility policies. R9-10-806(A)(4). |
| Adult CPR and first aid | Managers and caregivers must provide current documentation before providing assisted living services to a resident. Other personnel may be covered by the article or facility policies. R9-10-806(A)(10), (C)(1)(c)(vii-viii). |
| Fingerprint clearance | Follow the applicable card, application, exemption, and status rules in A.R.S. § 36-411. The application provisions are explained below; they do not extend the separate deadlines above. |
Use a documented readiness review before assigning care. A missing pre-service requirement should be resolved before the affected services begin. A later training deadline should have a named owner and due date, rather than being marked complete in advance.
3. Keep the required personnel-record contents together
R9-10-806(C)(1) supplies the core inventory. Each employee or volunteer record includes:
- Name, date of birth, and contact telephone number.
- Starting date of employment or volunteer service, and the ending date when applicable.
- Qualifications, including skills and knowledge relevant to assigned duties.
- Relevant education and experience.
- Completed orientation and in-service education required by facility policies.
- A license or certification when required by Article 8 or facility policies.
- Clinical-oversight documentation under R9-10-115 if the individual is a behavioral health technician.
- Evidence of freedom from infectious TB when R9-10-806(A)(8) applies.
- CPR and first-aid documentation when required by the article or policies.
- Documentation of compliance with A.R.S. § 36-411(A) and (C).
- The memory-care certificate of completion under R9-10-126; review its directed-care context with A.R.S. § 36-405.03 and R9-10-816.
A signed checklist helps someone review these records. It does not replace the certificates, results, verification records, or training evidence behind the checkmarks.
Record the evidence location, completion date, reviewer, and next action for each item. Store sensitive records with appropriate access restrictions; the review index can point to their controlled location.
4. Treat fingerprinting, references, and APS checks as separate tasks
Fingerprint clearance and current status
A.R.S. § 36-411 covers specified employees, owners, contractors, and volunteers providing the services listed in the statute. Its definition of direct supportive services includes services such as housekeeping in a resident's room and transportation. Coverage can extend beyond hands-on caregivers.
The statute also recognizes a health-professional fingerprinting pathway: a professional who has met the fingerprinting requirements of the relevant Title 32 regulatory board is not required to submit another set under this section. Document the actual basis for the exception.
For covered people, retain evidence supporting the valid card or applicable application pathway, together with the facility's documented good-faith effort to verify current card status. Use the Arizona DPS fingerprint-clearance resources for the official status and application process. A card copy by itself does not establish its current status.
A timing detail worth preserving
Subsection (A) uses 20 working days for applying after employment or the start of volunteer or contracted work. Subsection (D) separately says a completed application must be submitted within 20 days after work or volunteer service begins. This guide does not combine those provisions into a blanket permission to work uncleared. Resolve an application-in-progress case against the actual statutory provisions and agency guidance.
Other provisions matter too. Denied, suspended, or revoked cards are subject to the restrictions in subsection (E). Subsection (F) contains a specific, documented pending-good-cause-exception pathway with direct visual supervision; supervision alone is not a general substitute. Subsection (G) requires a new application and fingerprints when the employment record includes six months or more without employment by any employer.
Previous-employer contacts
The facility must make documented, good-faith efforts to contact previous employers for information relevant to the person's fitness to work. A.R.S. § 36-411(C)(1) does not specify a universal number of reference letters.
Record whom you contacted, when, the method, and the response or lack of response. That documents the effort even when a former employer does not reply.
APS Registry checks and the applicant's certification
The APS check is separate from fingerprint clearance. A.R.S. § 36-411(C) requires checking potential employees and annual reverification of each employee. It prohibits hiring a potential employee found on the registry and requires action to terminate an existing employee found on it. Verify that a possible registry match is the same person before treating it as a confirmed result.
Separately, A.R.S. § 46-459(J) requires prospective direct-service employees to certify, under penalty of perjury, whether an allegation of vulnerable-adult abuse, neglect, or exploitation was made against them and substantiated. DES provides Form AAA-1355A. The applicant's statement does not replace the employer's registry check.
Keep the dated check result, the identity match used, the reviewer, and the next annual check date. Track APS reverification independently of the fingerprint-card date.
5. Build TB documentation around the person's circumstances
For covered personnel, R9-10-806(A)(8) requires evidence of freedom from infectious TB on or before services begin. Managers, caregivers, and assistant caregivers are expressly named. The more-than-eight-hours-per-week threshold applies to the other employee or volunteer category.
R9-10-113 requires a baseline screening process and the appropriate evidence. A negative-test pathway includes a qualifying test administered within the preceding 12 months and documentation of its date and type. People with prior TB, latent infection, or a positive result follow the applicable alternative evaluation and documentation provisions. A test result should not be used to bypass the baseline risk and symptom assessment.
The ongoing requirements also deserve a place in the file-review calendar:
- Annual education for employees and volunteers about recognizing TB signs and symptoms.
- The facility's annual TB exposure-risk assessment.
- As part of that annual assessment, documentation for each person required to be screened indicating freedom from infectious-TB symptoms, signed by a medical practitioner, occupational health provider, or local health agency. This is expressly required by R9-10-113(B)(2).
- Any additional evaluation and follow-up indicated by TB history, symptoms, or exposure.
For testing options and prior-positive circumstances, see Tendera's Arizona assisted living TB guide.
6. Connect orientation and training to the work being assigned
Facility policies must cover job duties, qualifications, orientation, in-service education, CPR, and first aid. The personnel record needs evidence of the training required by those policies. Caregiver and assistant-caregiver orientation and skills verification have the pre-service deadlines described above. R9-10-803(C) and R9-10-806(A), (C).
Make the orientation record specific enough to show what was taught and checked: the person, date, topics, trainer, applicable policies, and demonstration of relevant duties. A generic acknowledgment that orientation occurred may leave the actual skills verification unclear.
Apply additional requirements to the services and role:
| Area | Evidence to review |
|---|---|
| Adult CPR | Current required documentation. Facility CPR policies generally must include demonstration of the person's ability, trainer qualifications, renewal timing, and verification documentation; R9-10-803(C)(1)(e) expressly references an exception in subsection (M). |
| Fall prevention and recovery | Initial and continued-competency training for all staff under A.R.S. § 36-420.01. This statute does not prescribe a universal annual hour total. |
| Medication duties | Relevant skills and orientation, plus the documented authorization process where medication administration under a medical practitioner's direction applies. Review R9-10-817(B); a caregiver-training certificate alone does not describe every authorization needed for the assigned task. |
| Behavioral health technician | The required clinical oversight under R9-10-115, documented in the personnel record. |
| Licensed or certified role | The required credential and applicable renewal evidence. See the manager requirements guide for manager-specific detail. |
Sources: R9-10-803, R9-10-806 and R9-10-817; A.R.S. § 36-420.01.
Directed-care facilities: keep memory-care training visible
A.R.S. § 36-405.03 ties the training framework to staff and contractors working at facilities licensed to provide directed care. It specifies at least eight hours of initial memory-care training and four hours of annual continuing education, with an additional four hours of training specifically for managers.
R9-10-816(B) requires the staff certificate, including the minimum initial training within the first 30 days of hire, or a qualifying certificate obtained within the preceding 12 months. A 12-month lapse from working at a directed-care facility triggers initial retraining within 30 days of hire, rehire, or return.
Use a Department-approved program and review the certificate against R9-10-126, including provider, completion and issuance dates, hours, topics, trainer signature, and its completion and examination provisions. R9-10-126(G) expressly addresses initial training, annual continuing education, and the passing examination score before certificate issuance. An informal attendance note is not the same as that certificate.
Track initial training, annual continuing education, manager-specific training, and any lapse-triggered retraining as distinct items. Avoid assuming a directed-care facility is exempt because it does not market a separate memory-care unit.
7. Keep records available after someone leaves
R9-10-806(C)(2) requires personnel records throughout the person's service and for at least 24 months after the last date of services. That is the Article 8 personnel-record minimum, not a universal destruction date for all employment documents.
Daily documentation of caregivers and assistant caregivers working, including their hours, has a separate minimum: 12 months after the last date on that documentation under R9-10-806(A)(7).
Availability has its own deadlines:
- General rule: Article 8 documentation must be provided to ADHS within two hours of a request, unless another provision states otherwise. R9-10-803(E)(1).
- Specific personnel exception: R9-10-806(C)(3) allows 72 hours for the record of a manager, caregiver, or assistant caregiver who has not provided physical or behavioral health services at or for the facility during the previous 12 months. It is not a general 72-hour window for every former employee.
Keep an accessible archive and give a backup reviewer the necessary access. Test whether someone other than the usual file owner can retrieve a complete record. The broader survey readiness guide connects personnel files to the rest of a facility review.
8. Use a small, repeatable review process
The following is a suggested management routine, not an additional statutory schedule:
- At hiring Identify the role, duties, applicable requirements, and evidence needed. Complete the pre-employment checks before the hiring decision.
- Before assigning services Verify the applicable pre-service requirements. Record any limits on assigned duties and any later training deadline.
- Each month Review upcoming credential renewals, annual checks, training, and open documentation gaps. Assign each gap an owner and date.
- When duties change Reassess qualifications, skills, supervision, and training before the new services are assigned.
- At departure Record the last service date, preserve the required record, and set the applicable retention and archive-review dates.
For a quick audit, select one current caregiver file and one departed worker's file. Can another manager find the evidence, explain what applies, and identify the next action without asking the original file owner?
Make the next file review easier
Start with the Employee File Checklist accompanying this guide. Use one copy per person, record where the evidence lives, and give each unresolved item a clear next action.
Employee File Checklist
Where Tendera fits
Tendera keeps each employee's personnel file in one view, with the documents an Arizona file is expected to hold, their signed dates and expirations, and what is missing or coming due. The facility still performs the checks and the training; Tendera keeps the record of them visible.
It does not run DPS fingerprint or APS Registry checks for you, and it does not certify that a file meets a requirement.
Explore TenderaFAQ
Does every employee need exactly the same documents?
No. Every employee and volunteer needs the personnel record required by R9-10-806(C), but several components are expressly conditional. Role, duties, resident contact, facility license, and policies determine the supporting evidence.
Is an APS check the same as a fingerprint-clearance check?
No. A.R.S. § 36-411(C) lists separate duties for fingerprint-card status and APS Registry verification. Keep evidence for both as applicable.
Can we collect the TB paperwork during the first week?
For personnel covered by R9-10-806(A)(8), the deadline is on or before the person begins providing services. The separate resident-admission timeline is not an employee onboarding allowance.
Does someone need a new caregiver certificate every year?
Do not treat every training document as an annual renewal. R9-10-806(A)(1) addresses the caregiver qualification; memory-care continuing education, professional credentials, CPR, and policy-based in-service training have their own requirements. Track the actual obligation instead of assigning one expiration rule to everything.
Does a completed checklist prove the facility is compliant?
The checklist helps organize a review. The underlying records, the person's qualifications, the timing of the work, and the facility's actual practices still need to meet the applicable requirements.
Primary authority & further reading
Arizona Administrative Code
- Arizona Administrative Code, Title 9, Chapter 10, Health Care Institutions: Licensing, reviewed against Supplement 26-1. Printed pages: R9-10-113 p. 29; R9-10-126 p. 42; R9-10-803 pp. 167-169; R9-10-805 pp. 169-170; R9-10-806 pp. 170-171; R9-10-816 pp. 178-179; R9-10-817 pp. 179-181. Printed page numbers differ from PDF viewer page numbers.
- R9-10-113 - Tuberculosis screening
- R9-10-126 - Memory-care certificate of completion
- R9-10-803 - Administration and document availability
- R9-10-805 - Contracted services
- R9-10-806 - Personnel
- R9-10-816 - Memory care
- R9-10-817 - Medication services
Arizona Revised Statutes
- A.R.S. § 36-411 - fingerprinting coverage, application provisions, status checks, previous-employer contacts, APS verification, exceptions, and the employment-gap provision
- A.R.S. § 46-459(J) - prospective direct-service employee certification
- A.R.S. § 36-420.01 - initial and continued-competency fall-prevention and recovery training
- A.R.S. § 36-405.03 - memory-care training framework for directed-care facilities
Agency resources
- Arizona DES employer resources - background-check resources and employer information
- Arizona DES APS Registry and Form AAA-1355A - registry access, identity-match guidance, and the applicant certification form
- Arizona DPS fingerprint-clearance resources - official application and status resources
Companion Tendera resources
- Arizona Assisted Living TB Requirements - testing pathways, prior positives, and annual responsibilities
- Arizona Assisted Living Manager Requirements - certification, responsibilities, and records availability
- The Complete Arizona Assisted Living Survey Readiness Guide - how personnel files are examined during a survey
Regulatory history: Arizona's assisted living rules were substantially amended in 2025. This guide is reviewed against Arizona Administrative Code, Title 9, Chapter 10, Supplement 26-1. Personnel checklists, hiring packets, and training materials that predate the current rule text should be reviewed against it.
Sources checked: September 12, 2026.
This is an educational operator resource, not an ADHS form and not a substitute for the applicable rules. It is not legal, medical, or professional advice, and a completed checklist is not a guarantee of compliance. Requirements can depend on the person's role, duties, the facility's license, and facility policies, and they can change. Use the linked primary sources for individual circumstances and check for changes after the stated source-review date.