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Dedicated to helping Activity Professionals
with the daily operation of their department.
Potential Changes to Interpretive Guidelines
for Nursing Homes
By Debbie Hommel, BA, CRA, ACC
Executive Director of
DH Special Services

The Federal Government (CMS or Center for Medicaid and Medicare Services) has been working on
amendments and expansions of selected interpretive guidelines.     Since they are focusing on regulations
which have significant impact upon quality of life, F-Tag 248 is one of the regulations having revised interpretive
guidelines.   These changes were created with guidance from an Expert Panel which included several
experienced Activity Professionals.  At the recent NAAP (National Association of Activity Professionals)
convention in April, it was said that projected time for implementation of these new interpretive guidelines
ranged anywhere from two months to a year from now.  Regardless of their implementation date, all activity
professionals should be aware of the pending changes and how they will impact our work with elders in
nursing homes.  Hopefully, your State association is keeping you informed, as is our National association.  
Once the changes are approved, there is a thirty-day implementation period.  It is after that thirty-day transition
period that surveyors will expect the changes to be implemented.    It is important to note that revisions to the
proposed draft, which may currently be circulating amongst professionals, could continue.  It is never final till
the Final Rule.    

Personally, I think many of the changes are for the better.  They will push our profession forward and challenge
us to provide the best care for the elders living in our communities.  The pending changes signify strong
validation from CMS regarding the significant impact that involvement in therapeutic activities can have upon
quality of life.   

Summary of Key Changes

There are very specific references to the types of activities and the therapeutic value of each.  There is more
emphasis on activities being scheduled and implemented to meet specific needs and introduced to each
resident based on the individual’s comprehensive assessment.
•Although this is pretty standard within most activity programs, the therapeutic process is being stressed.  
Activities to enhance overall resident well being, self-esteem and success are being emphasized.   Activities is
no longer being seen as a diversion to simply occupy time, but seen as a means for the resident to live life fully
within the long term care setting.  

There are many references to age appropriateness of programming and appropriateness of supplies and
equipment.  There are specific descriptions of using adult oriented adaptive equipment from the resident’s
generation rather than toys.  
•Most activity departments have eliminated use of toys.  Many companies now offer developmentally and age
appropriate equipment for use with elders.  Activity departments will need to ensure their budget allows for
purchase of such equipment.  

There are numerous references to the use of adaptive equipment for specific losses and limitations.  Specifics
such as use of amplifiers for the hearing impaired, magnifying equipment for visually impaired, use of vises,
grips and adaptive holders for task oriented activities as well as procedural changes to our approach within
specific activities for the cognitively impaired are listed throughout the changes.  
•This is an area where some activity departments will need to expand their services and approach.  Funding
will need to be acquired to allow purchase of adaptive equipment.    Please refer to last months article as it
focused on the adaptation process.  There are many catalogs and web sites listed which will assist your
department in meeting this requirement.  

Activity care planning is discussed at length in the proposed changes with an increased emphasis on the
importance of activities and how each resident should have activity needs and interests addressed within the
interdisciplinary care plan.
•This change will have significant impact in New Jersey, where I reside and practice activities. We have
adopted a true interdisciplinary approach to care planning.  Many activity professionals integrate most activity
needs into primary issues of cognitive loss, behaviors and mood and do not have an “activity care plan” in
place.  If your State has adopted this integrated method of care planning, you may have to revise your care
planning technique, as we will in NJ.  To prepare for this change, strengthening and expanding our input into
overall interventions is a first step.  When the changes become final and if they remain as written, specific
activity based care plans (problem, goal and interventions) can be easily added.  

Finally, there is much discussion and emphasis on interdisciplinary responsibility in promoting and engaging
the resident in activities.  There are several references to activities being “everyone’s responsibility”.  
•This is not a new idea but the way the revisions are written, this idea is emphasized throughout with several
examples.  Now is the time to in-service staff and take a stronger role in care planning.  Once the revisions are
implemented, we can use them as a frame of reference for support.

We all respond differently to change.  Some like to wait till it actually happens before adjusting.   Others panic
long before it happens, creating unnecessary unrest.  Having experienced a few regulatory changes in the
past, it would be wise for our profession to be aware of what is coming and start preparing now.     A good book
about change is “Who Moved My Cheese?” by Spencer Johnson, MD.  One quote in the book is “Change
happens” and it is that simple.  With or without us, change will happen.  How we decide to deal with the change
will define our future.
About Debbie

Debbie Hommel, BA, CRA, ACC, is
the Executive Director of DH
Special Services. She is a
Certified Activity Consultant on
State and National level, with over
twenty-seven years of experience
in providing direct care and
consultation to long term care,
medical day care, assisted living,
and ICF/MR facilities throughout
New Jersey, New York, Maryland,
and Pennsylvania. She is an
experienced trainer and workshop
presenter, conducting a variety of
seminars throughout the Tri-State
area for the Activity Professional,
Administrator, and allied
healthcare professional. Debbie
Hommel is an active member of
Activity Professional Associations
on State and National levels. She
is ACC certified through the
NCCAP. She is a founding
member of the New Jersey Activity
Professionals' Association, serving
terms as Vice President and
President. She received the
Weidner Lifetime Achievement
Award in 1994 and the Monmouth
& Ocean County Activity
Professionals Life Achievement
Award in 1999.
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