22VAC 40-61-330 Part D: Activities. 

*The proposed regulation is inclusive to cover Adult Daytime Centers for future regulations that will be engaged on a federal level. Not all Adult Daytime Centers are Medicaid reimbursed, or Medicare covered such as PACE. Some are smaller and rely on private pay and long term care insurance for funding. I do believe that there should be a standard for activities but in a practical essence. Our direct care staff are PCA/Activity Assistants or CNA/Activity Assistants. A more well rounded approach would be to train all direct care staff to be both a Care Aide and an Activity assistant. This would be better accomplished by adding a requirement for all PCA/Activity Assistants that are direct caregivers of at least obtaining the training within 6 months such as MEPAP 1 course and/or Engagement Course on the NCCAP website or other credentialing sectors that are approved. This could be supervised and coordinated through a professional healthcare (RN or LPN), (that is already staffed),Director/Assistant Director, Rec. Therapist, Occ. Therapist if had on board already. But to require this for all centers as the proposed regulations state this would be a hardship. I think by having just one person designated would not be a good fit for the overall health of the program. All direct care staff needs activity training as such.