RECEIVED FROM:Charlie Dixon
DATE:7-11-08RESPONSE MUST BE MADE BY JULY 18, 2008
Hi Everyone:West Virginia recreation therapists need your help.
Bureau for Public Health Office of Health Care Facility Licensure and Certification in West Virginia is proposing a new Nursing Home Licensure Rule which removes therapeutic recreation specialist as a qualified individual to work as an activity director in nursing homes.
A copy of the proposed rule and a copy of the current rule are available on the home page at http://www.wvtra.org.
This rule, although impacting only WV TRs, may be the beginning of changes that might happen in your state.
Although you may not be from WV, the rules committee is seeking comments from any interested persons.
The deadline for receipt of comments is July 18, 2008. Please send your response to:
Bureau for Public Health
Office of Health Care Facility Licensure and Certification
1 Davis Square, Suite 101
Charleston, WV 25301-1799
ATTN: Deanna Kramer, RN, MS, NHA
Aimee Silva Jackson, Paralegal – Legal Division
This rule will have a significant impact on recreation therapists wanting work in nursing homes in the state of West Virginia. RT’s won’t be able to get work as an activity director based on their RT education. RT’s will have to take the 90 hour course in order to be eligible to work.
WVTRA Past President
The following response was written by Thomas K. Skalko. You may want to use all or part of his response in your personal letter….
7.8.a. The administrator shall enjoy a full-time qualified professional to direct the activities program who:
7.8.a.1. Is certified by the national certification council for activity professionals (NCCAP), through any of the NCCAP’s approved certification tracks, as an activity director certified (ADC); or …
RESPONSE: Certified Therapeutic Recreational Specialists are required to possess a minimum of a baccalaureate degree in recreational therapy or therapeutic recreation, complete a minimum of a 12 week internship (480 hours of direct supervision) in the practice of recreational therapy, and must pass a national examination developed and administered by the Educational Testing Service (ETS). It is also important to note that 76 % of CTRS work with adults and older adults in acute and long-term settings.
Currently, a person can become an activity director certified (ADC) with 12 semester credits in college as noted below:
A. ACADEMIC EDUCATION
1. 90-Hour Modular Education Program for Activity Professionals Part 1 (C.C.1-11) and the 90-Hour Practicum (Basic Education Course). * 2. 90-Hour Modular Education Program for Activity Professionals Part 2 (C.C.12-20) and 90-Hour Practicum (Advanced Management Course). * 3. 12 semester college credits (cannot include #1 and #2 (must include an English PLUS 1 other required coursework area)). ...AND...
B. ACTIVITY EXPERIENCE
4. 6,000 hours activity experience within the past 5 years. ...AND...
C. CONTINUING EDUCATION
30 clock hours (Body of Knowledge) within past 5 years.
The proposed language, as written, would eliminate a CTRS with a baccalaureate degree and all of the above.
Also note that in October 2009 the MDS 3.0 will be introduced nationally. Recreational therapy is listed in Section O. and will be a viable option for nursing home residents with special needs. For decades, recreational therapists have worked as Activity Directors and are also be available for Medicare eligible residents. Removing them from your state public health language will limit access to such services by the skilled nursing home residents. The CTRS is professionally trained to reduce behaviors in dementia, treat depression, and to help integrate residents back into the community. The elimination of the therapeutic recreation specialist/recreational therapist would effectively deny skilled nursing home residents of these valuable services.
RESPONSE MUST BE MADE BY JULY 18, 2008