Proposed Revisions to the Federal Nursing Home Regulations now Published and Open for Comment

July 21, 2015

Dear Fellow NAAP Members:

As most of you are aware, the Centers for Medicare and Medicaid Services, CMS, has published proposed revisions to current regulations  for skilled nursing facilities participating in the Medicare and/or Medicaid programs. All Recreation/Activity Professionals are encouraged to review the proposed revisions, which may be viewed on the Federal Register website; www.regulations.gov.

Each of us, on the NAAP Board, would like to encourage all Recreation/Activity Professionals to submit personal comments on this ruling. Individuals may begin submitting their reflections and comments through September 14, 2015, and please don’t forget to use the above-listed website when submitting your comments.  The National Association of Activity Professionals’ Board will also carefully review the proposed revisions to the Requirements of Participation and respond to CMS in a timely manner.

Specifically, the section we are most concerned with regarding the qualifications of an Activity Professional is as follows:

“We received stakeholder input on the requirements for the director of a facility activities program and considered, but did not modify the requirements for the director of the activities program. However, we are soliciting comments on the current requirements to determine if they remain appropriate and, if not, what the evidence is for changing the current requirements for this position and what stakeholders would recommend as minimum requirements for this position.”

Only one certifying organization has been listed as the stakeholder. As Activity Professionals we are the stakeholders that CMS needs to hear from. We have multiple states that have state approved courses and state licensure. If we allow one organization to dictate what is best for an entire nation this would be extremely detrimental to states and other credentialing organizations. We at NAAP, urge you to make your voice heard and give comment in regards to the proposed changes.

The Requirements of Participation, set forth by CMS, clearly establishes key and essential measures for Quality of Life and Care for our residents. Each NAAP member is urged to provide personal feedback on the proposed revisions. Our goal is to promote high standards of excellence for the Activity Professional and we need your voice more than ever!
When writing your comments, refer to file code CMS-3260-P and use the below-listed information:

*Electronic – submit electronic comments to http://www.regulations.gov. Follow the “Submit a Comment” instructions.

*U.S. Mail – send all correspondence to the following address: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-3260-P, P.O. Box 8010, Baltimore, MD 21244

*Express/Overnight Mail – send your comments to the following address: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-3260-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850

Thank you for your immediate attention to this very important federal proposal regarding our profession. We appreciate your efforts and thank you for what you do every day.

Respectfully,

The National Association of Activity Professionals’ Board

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