Current regulations have no requirement for a "designated staff person" responsible for activities.  Adding the requirement for a "designated" activity staff will create an extreme hardship on smaller centers. It is not necessary to have a distinct person, especially at the pay rate of an Occupational Therapist, as all of our staff, for instance, serve as "activity" staff.

This regulation also offers no opportunity to hire and train quality people without the “correct” educational background.

Recommendation:

The proposed regulation 22VAC40-61-330 Activities, Part D should either be eliminated in its entirety or changed to be a minimal standard that does not create a financial hardship, especially for small centers or those in rural areas. 

The proposed regulation should either be eliminated or revised to include any current or future training program offered through National Certification Council for Activity Professionals. 

The proposed regulation should either be eliminated or revised to include 1-year experience in an adult day setting or long-term care setting.