Under the current framework, the important question for an assisted living operator is no longer simply, does this employee have a TB test? It is: do we have the correct baseline screening and evidence, was it obtained at the right time, have we addressed any positive or prior-positive history correctly, and are we completing the ongoing facility and individual requirements that apply?
Arizona Administrative Code R9-10-113 was amended to align Arizona healthcare-institution TB infection-control activities with the 2019 recommendations of the National Tuberculosis Controllers Association (NTCA) and CDC. Those recommendations replaced routine serial testing of healthcare personnel with a risk-based approach in the absence of a known exposure or ongoing transmission. That does not, however, mean TB compliance became a one-time paperwork exercise.
The three Arizona rules that matter
Three provisions are particularly important for Arizona assisted living facilities. They cover facility-level infection control, personnel timing, and resident timing respectively.
R9-10-113
Tuberculosis screening (facility framework)
The general TB infection-control rule for covered healthcare institutions. Requires establishing, documenting, and implementing TB infection-control activities consistent with the 2019 NTCA/CDC recommendations incorporated by reference.
R9-10-806(A)(8)
Assisted living personnel
Covered personnel must provide evidence of freedom from infectious TB on or before the date the individual begins providing services at or on behalf of the facility, as specified in R9-10-113.
R9-10-807(A)
Residents
Except for the respite exception, a resident must provide evidence of freedom from infectious TB before or within seven calendar days after the resident's date of occupancy, as specified in R9-10-113.
Operator takeaway
Personnel and residents are on different timelines.
Personnel: on or before beginning services. Residents: before or within seven calendar days after occupancy, subject to the respite exception. Mixing those deadlines up is an avoidable compliance mistake.
An important legal detail on the framework rule: Arizona incorporated that specific 2019 publication without future editions or amendments. Newer CDC webpages are useful implementation resources, but later federal guidance does not automatically amend the Arizona Administrative Code.
What baseline TB screening actually includes
A common mistake is treating TB screening and TB test as interchangeable terms. They are not.
Under the framework incorporated by Arizona, baseline screening is broader than simply obtaining a lab result or skin-test card. The 2019 NTCA/CDC recommendations define baseline screening to include an individual risk assessment and a symptom evaluation, along with TB testing for personnel without documented prior TB disease or latent TB infection, and additional evaluation when indicated. Arizona's current TB resource packet identifies baseline documentation similarly, and calls out a baseline screening form addressing risk factors, TB history, and symptoms, plus baseline testing with an IGRA or TST for individuals without a documented history of LTBI or TB disease.
Practical takeaway
A personnel file containing only “TB test, negative” may not demonstrate the complete baseline process.
Operators should be looking for the screening / risk / symptom documentation as well as the appropriate testing or other evidence required for the person's circumstances.
What counts as evidence of freedom from infectious TB
R9-10-113 establishes different pathways depending on an individual's history. For an individual without a history requiring the special positive or prior-positive pathway, the rule allows documentation of a negative Mantoux skin test or another CDC-recommended TB screening test that meets the rule's timing and documentation requirements.
ADHS summarizes the baseline testing options as:
- IGRA blood testing, such as QuantiFERON or T-SPOT, or
- TST, the Mantoux tuberculin skin test.
The test documentation should not be treated as a generic checkbox. Dates, test type, results, baseline screening documentation, and the person's history all matter.
IGRA blood test vs. TB skin test
Both TB blood testing and tuberculin skin testing can be used in appropriate circumstances, but they are not operationally identical.
IGRA blood test
When baseline testing is performed with an IGRA blood test, two-step testing is not required. CDC also identifies TB blood testing as the preferred method for people who have received the BCG vaccine. From an assisted living onboarding perspective, an IGRA can therefore be simpler because it does not require the multiple visits associated with two-step skin testing.
Mantoux (TST) skin test
If a Mantoux TST is used for baseline testing of healthcare personnel, CDC guidance calls for two-step baseline testing.
Important assisted living compliance issue
A single negative skin test should not automatically be assumed to constitute a completed baseline two-step TST process for healthcare personnel. The individual's documented prior testing history matters for how the baseline is completed.
How a two-step TB skin test works
For baseline healthcare-personnel testing using the Mantoux TST:
If the first TST is negative and a second test is required, the second TST is generally administered one to three weeks after the first test result is read. If the second TST is also negative, the baseline two-step process is complete. If positive, further evaluation is required based on the individual's risk assessment and applicable clinical guidance.
Why are there two tests?
The second test is not simply checking twice. In some people infected long ago, the first TST can stimulate, or boost, the immune system's ability to react. Without the two-step baseline, a later positive test could be incorrectly interpreted as a recent conversion when it actually represents an old infection.
The important prior-test exception
CDC states that if the person has a documented TST result from within the previous 12 months, a second baseline skin test may not be necessary in the usual two-new-test sequence. For someone with a documented negative TST during the previous 12 months, one additional TST can serve as the second stage of the two-step process.
That is why managers should avoid reducing TB compliance to blanket rules such as “everyone needs two brand-new skin tests”. The individual's documented history matters.
Do employees need a TB test every year?
Generally, no. This is probably the most important misconception to correct.
The 2019 NTCA/CDC recommendations incorporated into Arizona's rule state that healthcare personnel without latent TB infection should not undergo routine serial TB testing after baseline in the absence of a known exposure or ongoing transmission. Current CDC implementation guidance says the same thing: annual testing is not generally recommended unless there is a known exposure or ongoing transmission.
“No annual test” does not mean “nothing annually.”
A facility can stop unnecessarily repeating annual tests and still be deficient because it failed to perform the annual responsibilities that actually apply.
Continuing annual TB responsibilities
ADHS's current documentation checklist identifies ongoing items including annual symptom screening for individuals with untreated LTBI, annual TB education, and the facility TB risk assessment. Annual testing and annual TB compliance are not the same thing.
Annual symptom-free documentation for everyone who must be screened
As part of the facility's annual TB exposure-risk assessment, R9-10-113(B)(2) requires documentation for each individual required to be screened that indicates freedom from symptoms of infectious tuberculosis. It must be signed by a medical practitioner, occupational health provider, or local health agency. This annual documentation requirement is separate from whether repeat TB testing is clinically indicated.
Read it alongside the narrower provision for latent infection. The annual symptom documentation under R9-10-113(A)(2)(b)(ii) applies to an individual who may have a latent tuberculosis infection, while R9-10-113(B)(2) reaches every individual the Section requires to be screened. Neither provision turns into an instruction to repeat a routine test on an annual date.
Annual TB education
The Arizona framework requires annual training and education related to recognizing TB signs and symptoms for employees and volunteers subject to the rule. CDC's current implementation guidance describes annual TB education as including information about TB risk factors, signs and symptoms of TB disease, and TB infection-control policies and procedures.
A practical facility process should document that the education occurred rather than relying on staff recollection during an inspection.
Annual facility TB risk assessment
TB compliance also exists at the facility level, not just inside personnel files. The incorporated framework continues facility TB risk assessments to guide infection-control policies and procedures. ADHS's current resource packet includes the facility risk assessment in its annual documentation checklist and provides example material for facilities to use.
This is easy to overlook because it is not attached to one employee or resident. A good compliance calendar should therefore track the facility's annual TB risk assessment as its own compliance obligation, separate from individual TB records.
Prior positive tests and LTBI
Do not simply order another routine TST because the employee's annual date arrived. Healthcare personnel with a documented prior positive TB test should receive the appropriate baseline risk assessment and symptom screening, but CDC does not require repeating the TB infection test itself. Individuals with prior positive results or a history of TB or LTBI follow a different documentation pathway.
For example, the 2019 recommendations state that healthcare personnel with a prior positive test and a documented normal chest radiograph generally do not need repeat chest radiographs unless they develop symptoms or are being evaluated before beginning LTBI treatment. Arizona's TB resource packet reflects the same principle.
Operational lesson
Do not build a compliance system that simply says “TB expires every 365 days, order another test.” That is too simplistic for the current framework. The correct follow-up depends on the individual's TB history and circumstances.
Untreated latent TB infection
The incorporated 2019 recommendations strongly encourage treatment of healthcare personnel with untreated LTBI unless treatment is contraindicated. For healthcare personnel who do not complete LTBI treatment, the recommendations call for annual symptom evaluation and reevaluation of the risks and benefits of treatment. ADHS specifically includes annual symptom screening for individuals with untreated LTBI in its annual documentation checklist.
This is another reason a simple “negative test expiration date” is an inadequate way to manage TB compliance.
After a known TB exposure
The no-routine-annual-testing rule should never be interpreted as never test again. After a known exposure to potentially infectious TB disease, personnel should receive timely symptom evaluation and additional testing when indicated.
For personnel without documented prior LTBI or TB disease, the incorporated recommendations call for an IGRA or TST after exposure. If the initial test is negative, retesting generally occurs 8 to 10 weeks after the last exposure, preferably using the same type of test.
Personnel with documented prior LTBI or TB disease generally do not need another infection test after exposure, but they still require symptom evaluation and further evaluation if TB disease is suspected.
ADHS also advises facilities to coordinate with the local health department regarding contact investigations and to follow the health department's recommendations. If TB disease is suspected, this is no longer merely a personnel-file issue; appropriate clinical and public-health involvement is necessary.
Who needs TB documentation
For assisted living facilities, R9-10-806(A)(8) covers:
- Managers
- Caregivers
- Assistant caregivers
- Employees or volunteers who have or are expected to have more than eight hours per week of direct interaction with residents
Notice an important distinction. The “more than eight hours” qualifier applies to the employee or volunteer category. Managers, caregivers, and assistant caregivers are expressly named. A facility should therefore be cautious about applying an oversimplified “under eight hours means no TB requirement” rule to everyone.
Non-resident household members
Arizona has an easily overlooked requirement for assisted living homes. Under R9-10-806(B), an individual residing in the assisted living home who is not a resident, manager, caregiver, or assistant caregiver must meet specified requirements. If that individual is 12 years of age or older, the person must provide evidence of freedom from infectious tuberculosis as specified in R9-10-113.
This can matter in small residential settings where family members or other individuals live at the property. It is a different population from the facility's residents and employees, but it should not be forgotten during a compliance audit.
Resident TB requirements
Residents have their own timing rule. Under R9-10-807(A), except for the respite exception, a resident must provide evidence of freedom from infectious TB before or within seven calendar days after the resident's date of occupancy. This differs from personnel, who must provide the required evidence on or before beginning services.
Personnel: on or before beginning services. Residents: before or within 7 calendar days after occupancy.
A useful onboarding control
For every new resident, a facility's admission checklist should make the seven-day TB deadline highly visible. Waiting until a routine chart audit weeks later can turn a correctable admission task into a regulatory deficiency.
The respite-care exception
Arizona provides a specific exception for short respite stays. Under R9-10-808(B)(2), if a resident receiving respite care is not expected to be present in the assisted living facility for more than seven calendar days, the resident is not required to comply with R9-10-807(A).
The wording matters: not expected to be present for more than seven calendar days. Operators should document the respite arrangement appropriately rather than assuming every person categorized informally as “respite” is automatically exempt.
What the personnel file should show
The exact documentation will vary depending on the individual's history, but a strong baseline file should allow an inspector to determine what happened without reconstructing the process from memory.
For an individual without a prior TB or LTBI history, that will commonly include:
- Baseline TB risk assessment
- Baseline TB symptom evaluation
- Appropriate TB test documentation, including:
- Test type
- Test date
- Result
- If TST was used, documentation supporting completion of the appropriate baseline two-step process
- Any additional evaluation required because of a positive result
For someone with prior positive testing, TB disease, or LTBI, the file should contain the appropriate alternative evidence and follow-up documentation applicable to that person's circumstances. ADHS's current resource packet provides a useful baseline and annual documentation checklist and example forms.
Personnel-record retention matters too
TB compliance documentation is part of a broader personnel-record obligation. Arizona's assisted living personnel rules require personnel records to be maintained throughout the individual's period of service and generally for at least 24 months after the last date the individual provided services. An employee leaving the facility does not mean their TB documentation should immediately disappear from the compliance record.
Common TB compliance mistakes in Arizona assisted living
The rules become easier to manage when translated into operational failure points.
- Letting an employee start before baseline TB requirements are complete. For covered personnel, the deadline is on or before the date services begin. “We'll get it next week” can already be too late.
- Keeping only a negative test result. Baseline screening involves more than the test itself. Risk assessment and symptom evaluation are part of the baseline process.
- Accepting one TST as a completed baseline without checking history. If TST is used for healthcare-personnel baseline testing, the two-step process generally applies unless prior documented testing satisfies the applicable exception.
- Automatically ordering another TB test every year. Routine annual testing is no longer the general post-baseline approach absent exposure or ongoing transmission.
- Interpreting “no annual testing” as “no annual TB work.” Annual education, facility risk assessment, and applicable annual symptom screening still matter.
- Re-testing someone with a documented prior positive without considering the proper pathway. Prior-positive and LTBI cases have different evaluation and documentation requirements.
- Missing the resident's seven-day deadline. Resident evidence generally must be obtained before or within seven calendar days after occupancy.
- Forgetting the short-respite exception, or applying it too broadly. The exception is tied to a respite resident not expected to be present for more than seven calendar days.
- Forgetting non-resident individuals living in an assisted living home. Certain individuals age 12 or older residing in the home are separately covered by R9-10-806(B).
- Forgetting the facility-level annual risk assessment. Not every TB compliance item lives inside an employee file.
ADHS does cite facilities for TB documentation failures.
This is not merely a theoretical paperwork issue. Published ADHS Top-10 Deficiency lists for Assisted Living Homes have included R9-10-806(A)(8)(a-b), the personnel TB requirement, among frequently cited deficiencies. Recent inspection material has described caregiver files containing only one negative TST and lacking both a second skin test and baseline risk / symptom screening documentation.
Having “something TB-related” in the personnel file is not necessarily the same as demonstrating compliance. The documentation needs to show that the applicable process was completed correctly and on time.
A practical Arizona assisted living TB audit
Managers can use the following as a starting point for an internal review. Not every item applies in every facility; scope each section to what applies at your home.
Personnel
- Every manager has appropriate baseline TB documentation
- Every caregiver has appropriate baseline TB documentation
- Every assistant caregiver has appropriate baseline TB documentation
- Employees and volunteers expected to have more than 8 hours per week of direct resident interaction are identified and appropriately screened
- Required personnel evidence was obtained on or before the individual began providing services
- Baseline files include the applicable risk assessment and symptom evaluation
- Testing documentation identifies the test type, date, and result
- If TST was used for baseline healthcare-personnel testing, the file demonstrates the appropriate two-step process or applicable prior-test exception
- Prior-positive, TB, and LTBI cases follow the appropriate alternative pathway rather than simply receiving repeated routine testing
- Personnel with untreated LTBI receive applicable annual symptom screening
Residents
- Each non-exempt resident has appropriate evidence of freedom from infectious TB
- Documentation was obtained before or within 7 calendar days after occupancy
- Short-stay respite exceptions are appropriately identified and documented
Assisted living home household members
- Individuals living in the home who are not residents, managers, caregivers, or assistant caregivers have been evaluated for the requirements of R9-10-806(B)
- Required TB documentation exists for covered individuals age 12 or older
Facility-level responsibilities
- Annual TB education is completed and documented
- Annual facility TB risk assessment is completed and documented
- As part of that annual assessment, signed documentation of freedom from symptoms of infectious TB is obtained for each individual required to be screened (R9-10-113(B)(2))
- The facility has a process for recognizing and responding to possible TB exposure
- Local public-health / contact-investigation recommendations are followed and documented when applicable
- TB records are retained for the required period
The current framework in four layers
For day-to-day operations, Arizona assisted living managers can think about TB compliance in four layers. That is much more accurate than treating TB compliance as a single annual expiration date.
-
Baseline.
Before a covered employee begins work (or within the applicable resident deadline), complete the appropriate screening, testing or other evidence, and documentation.
-
Exceptions and special histories.
Recognize that prior-positive, TB, and LTBI histories require different handling from a routine negative baseline.
-
Ongoing compliance.
Complete the annual activities that actually apply instead of automatically repeating the same TB test every year.
-
Exposure response.
Have a process for symptom evaluation, testing when indicated, and coordination with public-health authorities following a known exposure.
A spreadsheet may tell you “Employee TB due August 15,” but it may not tell you whether the original baseline was complete, whether a two-step TST was required, whether a prior test satisfies part of the baseline process, whether the employee has a prior positive, whether annual testing is even appropriate, whether an annual symptom screen is required instead, whether annual education was completed, or whether the facility's own annual TB risk assessment is due.
Compliance is often less about remembering a date and more about understanding what requirement applies to whom and why.
Medication management and service planning are companion topics that shape the same personnel and resident files. For more on those, see Arizona Assisted Living Medication Management Requirements → and Arizona Assisted Living Service Plan Requirements →.
Compliance software should help you know what needs attention next.
Tendera is built for small assisted living operators who need to keep operational and compliance responsibilities visible without relying on memory, disconnected spreadsheets, paper calendars, and last-minute chart audits.
The goal is not to replace a manager's judgment or interpret regulations for the facility. It is to help make sure that the things a facility has determined it needs to track are visible before they become survey problems.
Tendera surfaces expiring and missing items as they age so renewals happen before deficiencies do. TB documentation lives alongside the other personnel and resident records the same audit would open.
Frequently asked questions
Do Arizona assisted living caregivers need a TB test before they start working?
Covered assisted living personnel must provide the required evidence of freedom from infectious TB on or before the date they begin providing services. The complete baseline process may involve more than merely possessing a negative test result.
Do Arizona assisted living employees need a TB test every year?
Routine annual TB testing is generally not recommended after baseline in the absence of a known exposure or ongoing transmission. Annual TB responsibilities still exist, including education, facility risk assessment, and annual symptom screening for applicable individuals with untreated LTBI.
Is a one-step TB skin test enough for a new caregiver?
When TST is used for baseline healthcare-personnel testing, CDC guidance calls for a two-step process, subject to exceptions based on documented prior testing. An IGRA blood test does not require two-step testing.
How soon does a new assisted living resident need TB documentation?
Except for the applicable short-respite exception, Arizona requires evidence of freedom from infectious TB before or within seven calendar days after occupancy.
Does a resident staying for respite care need TB documentation?
R9-10-808(B)(2) provides an exception when the respite resident is not expected to be present for more than seven calendar days.
Does someone with a prior positive TB test need another TB test every year?
Not simply because another year has passed. Prior-positive and LTBI cases follow different screening, evaluation, documentation, and follow-up pathways. Repeat chest radiographs also generally are not required for healthcare personnel with a prior positive and a documented normal chest radiograph unless symptoms develop or another specified clinical reason applies.
Sources and further reading
- Arizona Administrative Code, Title 9, Chapter 10 (Health Care Institutions Licensure), current codification, published by the Arizona Secretary of State. Includes R9-10-113, R9-10-806, R9-10-807, and R9-10-808.
- Arizona Department of Health Services: Residential Facilities Licensing, the licensing agency for Arizona assisted living facilities. Publisher of the TB Screening Requirements resource packet for health care institutions and the Tuberculosis Screening Regulation Summary for R9-10-113.
- Centers for Disease Control and Prevention: Tuberculosis (TB), including the current CDC implementation pages on baseline TB screening and testing for health care personnel and the frequency of TB screening and testing for health care personnel.
- CDC / NTCA: Tuberculosis Screening, Testing, and Treatment of U.S. Health Care Personnel: Recommendations from the National Tuberculosis Controllers Association and CDC, 2019. This is the publication incorporated by reference in R9-10-113. Arizona incorporates this specific 2019 publication without future editions or amendments; later CDC guidance may inform implementation but does not automatically amend Arizona law.
Regulatory history: Arizona amended R9-10-113 to align with the 2019 NTCA/CDC recommendations, replacing routine serial annual TB testing for most healthcare personnel with a risk-based approach in the absence of a known exposure or ongoing transmission. Facility-level annual responsibilities, annual education, and the different rules for prior-positive and LTBI cases remain in place. Operators should verify that older TB policies, checklists, and training materials still align with the current framework.
Last reviewed: August 2026.
This resource provides general educational information for Arizona assisted living operators and is not legal, medical, public-health, or professional advice. Regulations and agency guidance may change. Operators should verify current requirements with ADHS, the appropriate local public-health authority, and other qualified professionals as appropriate to their facility and residents.