Arizona Medical Record Reproduction Fees, A.R.S. § 12-2295

Arizona medical record reproduction fees are governed by A.R.S. § 12-2295, which lets a healthcare provider charge a “reasonable fee” for copies but also requires the provider to hand records over at no cost in several common situations, including when you need them for ongoing care. Federal HIPAA rules add a separate cap on what you can be billed when the records are your own. Between the two, most patients pay far less than a provider’s initial quote suggests, and sometimes nothing at all.

When Arizona Law Requires Free Records

Subsection B of A.R.S. § 12-2295 lists the situations where a provider cannot charge you anything for pertinent information in your medical records and payment records:¹

Records sent to another healthcare provider who is treating you.
Records you request for the demonstrated purpose of obtaining healthcare.
Records your authorized health care decision maker requests on your behalf for healthcare purposes.
Records requested by the Arizona Medical Board, the Board of Osteopathic Examiners, or officers of the Department of Health Services or local health departments.
Records you or your legal representative need to appeal a denial of benefits under the Social Security Act. A legal representative must present a completed SSA-1696 appointment of representative form to receive records at no cost.

For Social Security appeals, only the first request per calendar year is free. Later requests in the same year, or a second copy of records already provided, are subject to a reasonable fee. If the provider searches and finds no responsive records, no fee may be charged regardless of whether it is a first or later request.¹

If your request falls into any of these categories, say so in writing. A request that states its purpose — “for the purpose of obtaining health care,” for example — puts the provider on notice that no fee applies.

What “Reasonable Fee” Actually Means

Outside the free-records categories, A.R.S. § 12-2295(A) allows a “reasonable fee” for reproducing medical records and payment records. The statute does not set a dollar amount or a per-page rate for general requests. It relies on a reasonableness standard, which means fees should reflect the actual cost of producing the copies rather than function as a revenue source.¹

Providers may require payment in advance before releasing copies. The one exception: they cannot withhold records needed for continuity of care pending payment. If you are transferring to a new provider and need your records for ongoing treatment, the current provider must release them regardless of any outstanding balance.¹

Because there is no published fee schedule under this statute, prices vary from one provider to the next. Ask for a written estimate before authorizing a large reproduction. If the quote seems high, HIPAA gives you separate leverage.

How HIPAA Caps What You Pay for Your Own Records

When you are the one requesting your records, federal law is stricter than Arizona’s general “reasonable fee” language. Under the HIPAA Privacy Rule, a provider may only charge a “reasonable, cost-based fee” that covers the labor of copying the records, the supplies used to make the copy, and postage if you ask for mailing.²

Several charges that show up on provider invoices are specifically prohibited:

Search and retrieval fees — the time spent locating your file, pulling it from storage, or reviewing which pages are responsive.³
IT maintenance or storage costs — electronic record system expenses, data storage, software updates.
Compliance labor — time spent verifying your identity, confirming the right records are included, or otherwise complying with HIPAA itself.³

If an invoice for your own records includes a line for “search,” “retrieval,” or “records management,” that charge likely violates federal law.

Which Law Wins When They Conflict

Whichever law gives you cheaper access controls. Arizona’s rule that healthcare-purpose requests are free is more protective than HIPAA, so it applies in that scenario. Where subsection B doesn’t apply, HIPAA’s cost-based fee limits may be lower than what a provider would call “reasonable” under Arizona law, and HIPAA’s cap governs.

The $6.50 Ceiling for Electronic Records

When you request electronic copies of records already stored electronically, HIPAA gives providers three ways to calculate the fee. The simplest option is a flat fee of up to $6.50, which covers labor, supplies, and postage combined.⁴

Providers aren’t required to use the flat fee. They may calculate actual costs for each request or build an average-cost schedule instead. The $6.50 figure is a ceiling for those that choose the simple route, not a mandated price.⁵

One key restriction: the federal Office for Civil Rights does not consider per-page fees reasonable for records stored electronically. Per-page pricing is only acceptable when the originals are on paper and you request either a paper copy or a scan of those paper records.⁶ A per-page quote for records pulled straight from an electronic health record system conflicts with federal guidance.

If you ask for records on a USB drive or CD rather than by email or patient portal, the provider may add the cost of the physical media. The total still cannot include search, retrieval, or system-maintenance expenses.

Imaging Studies and Other Non-Paper Materials

X-rays, MRIs, CT scans, and similar diagnostic images don’t fit a per-page framework. Reproducing them involves specialized media and sometimes technician time. Arizona’s workers’ compensation fee schedule, which applies specifically to work-injury claims, sets reproduction at $0.25 per page and $10.00 per hour for clerical labor involved in locating and reproducing documents.⁷

That schedule is for workers’ compensation cases. Outside that context, providers generally charge the actual cost of duplicating imaging media, and there is no single capped rate under A.R.S. § 12-2295’s general reasonableness standard. For imaging copies, ask for an itemized estimate before authorizing the work.

Postage

Both Arizona law and HIPAA allow a provider to pass along actual postage costs when you ask for records to be mailed. Postage is one of the few permissible components of the fee for patient access under federal rules.² The charge should match what the provider actually paid the carrier. A separate handling or administrative surcharge on top of postage isn’t allowed.

Requesting Records and What the Provider Owes You

Under A.R.S. § 12-2293, a healthcare provider must give you access to or copies of your medical records and payment records when you submit a written request. Your authorized health care decision maker can submit the request on your behalf. The provider must release any records for which there is no valid basis for denial.⁸

Specify the date range and the types of records you want (office visit notes, lab results, imaging, billing records) so you don’t get either too little or an unmanageable volume. If your purpose fits a subsection B category, state that purpose in the request so the provider applies the correct fee, or no fee.

Under HIPAA, the provider must act on your request within 30 calendar days of receiving it. If the provider cannot meet that deadline, it may extend by another 30 days, but only by sending you a written explanation and a specific date certain within the original 30-day window.⁹ These are outer limits, not targets.

If You’re Overcharged or Ignored

If a provider charges more than the law allows, refuses to release records without justification, or ignores your request, you have options at both the federal and state level.

For HIPAA violations, including excessive fees for your own records or missed deadlines, you can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights. Complaints can be submitted through the OCR Complaint Portal, by email to OCRComplaint@hhs.gov, or by mail. You must file within 180 days of when you became aware of the violation, though OCR may extend that deadline for good cause.¹⁰

At the state level, complaints about hospitals go to the Arizona Department of Health Services, Division of Licensing. For other provider types, contact the state board or regulatory agency that licenses the provider.¹¹

1
Arizona Legislature. Arizona Revised Statutes Title 12-2295 – Charges
2
eCFR. 45 CFR 164.524 – Access of Individuals to Protected Health Information
3
U.S. Department of Health & Human Services. May a Covered Entity Charge Individuals a Fee for Providing the Individuals With a Copy of Their PHI
4
U.S. Department of Health & Human Services. Clarification of Permissible Fees for HIPAA Right of Access – Flat Rate Option
5
U.S. Department of Health & Human Services. Is $6.50 the Maximum Amount That Can Be Charged to Provide Individuals With a Copy of Their PHI
6
U.S. Department of Health & Human Services. How Can Covered Entities Calculate the Limited Fee That Can Be Charged
7
Arizona Industrial Commission. Arizona Physicians and Pharmaceutical Fee Schedule 2025/2026
8
Arizona Legislature. Arizona Revised Statutes 12-2293 – Release of Medical Records and Payment Records to Patients
9
U.S. Department of Health & Human Services. How Timely Must a Covered Entity Be in Responding to Individuals Requests for Access to Their PHI
10
U.S. Department of Health & Human Services. How to File a Health Information Privacy or Security Complaint
11
Georgetown University Health Policy Institute. Your Medical Record Rights in Arizona