See information on the Change Healthcare response

Beginning July 1, 2024, claims submitted by fee-for-service providers that include a referring, ordering, or attending provider who is NOT registered with AHCCCS will be denied.

Fee-for-service claims that include an unregistered prescribing provider are not subject to this deadline.

Referring, Ordering, Prescribing, Attending (ROPA) Providers Required to Register with AHCCCS

The Patient Protection and Affordable Care Act (ACA) and the 21st Century Cures Act (Cures) require that all health care providers who refer AHCCCS members for an item or service, who order non-physician services for members, who prescribe medications to members, and who attend/certify medical necessity for services and/or who take primary responsibility for members’ medical care must be registered as AHCCCS providers. AHCCCS calls this initiative, and these providers, "ROPA.”

Until these acts passed, referring, ordering, prescribing, and attending providers were required to obtain and maintain a National Provider Identifier (NPI), but were not required to be registered as an AHCCCS provider, but with the implementation of ROPA requirements any registrable healthcare provider who is not already registered as an active AHCCCS provider must register or be identified as an Exception non-registerable provider*, if applicable.

To make the ROPA registration process as simple as possible, AHCCCS developed a streamlined application for ROPA providers who meet all of the following criteria:

  • Have a National Provider Identifier (NPI) from the National Plan and Provider Enumeration System (NPPES),
  • Already fully enrolled in Medicare or another state’s Medicaid program, and
  • Do not intend to bill AHCCCS for services.

ROPA Provider Listings

All health care providers who refer AHCCCS members for an item or service, who order non-physician services for members, who prescribe medications to members, and who attend/certify medical necessity for services and/or who take primary responsibility for members’ medical care must be registered as AHCCCS providers or be listed as an allowed not registered Exception provider.

To validate providers who meet these requirements, AHCCCS publishes two listings as follows on a regular basis:

AHCCCS Active, Registered Providers by NPI who may Refer, Order, Prescribe, or Attend

ROPA Excepted Providers List (Residents, Interns, Pharmacists)

*There are limited types of providers who can refer, order, prescribe or attend who are not registerable provider types with AHCCCS, including pharmacists, residents, and interns. The providers in the above list will not be required to formally register with AHCCCS but will be tracked for validity through an alternative tracking system.

Steps To Comply with ROPA

If you are a provider who refers, orders, or acts as an attending provider for AHCCCS members, and you are not represented on either of the above lists, you must begin the registration or exception provider designation process.

If you are a provider who receives a referral or order from a provider who is not on either of these lists (as appropriate), your fee-for-service claim will not be paid as of July 1, 2024.

ROPA Flier

View or print the "Don't Be the Weak Link in the Claim" ROPA flier

To begin the enrollment process, visit AHCCCS Provider Enrollment.

Frequently Asked Questions (FAQs) for Referring, Ordering, Prescribing, Attending (ROPA) Providers

  • Q1: What types of providers are affected?

    A1: As required by the federal government, all medical providers (who are a registerable provider type) must be enrolled with the State Medicaidprogram in order for Medicaid to pay for services that they attend, prescribe, order or refer. The rule applies even if the provider does not accept Medicaid payment for the provider's own services or wishes to otherwise participate as a Medicaid provider. See Medical Policy Manual Chapter 601, Attachment A for a list of registerable provider types.

  • Q2: Which Medicaid programs are affected?

    A2: This rule applies to all AHCCCS programs regardless of managed care or fee-for-service delivery.

  • Q3: What services are affected?

    A3: The provider should enroll before ordering, prescribing, or referring services. The service must continue to be within the provider’s scope of practice to order, prescribe, or refer and all other program rules for seeking coverage apply. Services affected by this new rule include, but are not limited to, home care services, lab testing, durable medical equipment, and prescription drugs.

    EXAMPLE: If an AHCCCS member uses a Medicaid card at the pharmacy counter because she has fee-for-service prescription coverage, the prescriptions will not be paid for by Medicaid unless the provider who prescribed the drugs is an AHCCCS registered provider or is identified as a non-registerable provider type.

  • Q4: As a rendering/service provider, how can I find out if my ROPA provider is registered with AHCCCS?

    A4: Rendering/service providers reporting applicable prescribing, ordering, referring, or attending providers on their claims submissions to all AHCCCS programs must verify that these providers have appropriate registration. If they are a registerable provider type, use the online AHCCCS provider listing web page to verify enrollment.

  • Q5: Can a provider retroactively enroll?

    A5: Yes for all provider types listed except the new OR provider type (the new provider type is prescribing or ordering providers that will allow for use as a prescribing/ordering authority only) for which retroactive registration will be effective no earlier than 10/1/2020. AHCCCS will pay retroactive claims and encounters involving registered, eligible providers subject to timeliness rules.

  • Q6: How long does the enrollment process take?

    A6: Provider enrollment applications are typically processed within an average of six (6) business days, but may take a maximum of 45 days from the date the application is received.

  • Q7: Does this affect practitioners who are actively enrolled in Medicaid?

    A7: Providers who are already registered with AHCCCS and are attending, prescribing, ordering or referring do not need to re-enroll.

  • Q8: Are ROPA providers mandated to accept Medicaid patients?

    A8: No. All providers have the choice of whether or not to accept Medicaid patients.

  • Q9: Do attending providers need to register?

    A9: Yes, attending providers should be registered if they are a registerable provider type.

  • Q10: Will ROPA providers be required to re-validate their registration?

    A10: Yes, all providers, including ROPA providers, must re-validate their AHCCCS enrollment every four (4) years.

  • Q11: What if I’m a prescribing provider who is not an AHCCCS registerable provider type (i.e. Pharmacist, Naturopath who treat adults only, etc.)?

    A11: AHCCCS has identified an alternative exception process for prescribing or ordering providers (who are not registerable provider types) that will allow for participation as a provider with referring, ordering, prescribing, or attending authority only.

  • Q12: How can I enroll as an ROPA provider?

    A12: Providers who:

    • do not want to bill Medicaid for covered services, and
    • only want to prescribe, order, attend, or make referrals for Medicaid recipients, and
    • are a registable provider type

    can enroll with AHCCCS. New providers can enroll here. Currently enrolled providers can login to AHCCCS Online.

  • Q13: How should MCOs handle rejects at point of sale for pharmacies? Will there be exceptions for lifesaving prescriptions (such as inhalers) and hospital discharges?

    A13: AHCCCS members are not financially responsible for any out of pocket expenses, with the exception of member copayments, for an emergency service or lifesaving prescription that is ordered and or rendered by a non AHCCCS registered provider. The financial responsibility will remain with the Managed Care Organization if the member needs a lifesaving prescription and/or has an emergency. Emergency is defined in 42 C.F.R. 438.114. as a medical service provided for a non-FES member for the treatment of an emergency medical condition that manifests itself by acute symptoms of sufficient severity, including severe pain, such that a prudent layperson who possesses an average knowledge of health and medicine, could reasonably expect the absence of immediate medical attention to result in any of the following:

    • Place the member’s health in serious jeopardy,
    • Serious impairment to bodily functions, or
    • Serious dysfunction of any bodily organ or part.
  • Q14: If AHCCCS is the secondary insurance for a member, will all providers on their claim have to comply with the ROPA requirements by the deadline as well?

    A14: Yes, the requirement applies whether AHCCCS is a member’s primary or secondary insurance.

  • Q15: If I am a resident, intern or pharmacist and I don't see my NPI listed on the ROPA excepted Provider List, how do I get added to the list?

    A15: If I am a resident, intern or pharmacist and I don't see my NPI listed on the ROPA excepted Provider List, how do I get added to the list?

    To have missing residents, interns or pharmacists added to the ROPA excepted Provider List, please email the following information to the address listed below:

    • NPI,
    • Provider Name,
    • Indication of whether the NPI is associated with a Resident, an Intern or a Pharmacists and
    • the beginning date associated with this association.


  • Q16: (Revised 10/20/2021) How should providers handle the situation when AHCCCS members present, or the provider receives, a referral or order that originated from a non-enrolled AHCCCS provider?

    A16: (Revised 10/20/2021) During the ROPA registration deadline extension, inform the provider of these requirements and/or inform AHCCCS or the member’s managed care health plan so that we can contact the provider to begin the registration process or the exception process. After the ROPA registration deadline, providers should be aware that if they accept the referral or order from a non-enrolled AHCCCS provider/non-exception provider their claim will not be paid.

  • Q17: If I am already an AHCCCS registered provider, do I need to complete additional ROPA registration?

    A17: No, if you are already an AHCCCS registered provider, you do not need to take any further action to be recognized for ROPA purposes.

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