This week’s CMSCG Blog “Ftag of the Week” is F680 Qualifications of Activity Professional. F680 is a regulation that hasn’t traditionally been widely cited, but there are multiple citations throughout the country and given the industry’s staffing shortages, it’s important to be aware of the requirements for the individual responsible for your activities program. It is also worth mentioning that surveyors are directed to review the activities director’s qualifications if they identify issues with F679 Activities Meet Interest/Needs of Each Resident. Don’t forget – COVID-19 related restrictions on group activities and social distancing requirements have largely been eliminated, so your activities program should be back in full swing.
Qualifications
The regulation at F680 states that a facility’s activities program must be directed by a “qualified professional” who is either:
- A qualified therapeutic recreation specialist or
- An activities professional with one of several qualifications
Per the regulation, acceptable qualifications for the activities professional include licensure or registration by the State in which the individual is practicing, if applicable and:
- Eligibility for certification as a therapeutic recreation specialist or activities professional by a recognized accrediting body (on/after 10/1/1990) or
- 2 years of experience in a full-time, therapeutic program (social or recreational) within the last 5 years or
- The individual is a qualified Occupational Therapist (OT) or OT assistant or
- Has completed a State-approved training course
Now that we have reviewed what types of qualifications an activities director needs, let’s look at what the person directing the activities program is responsible for.
Responsibilities of the Activities Director
The activities director:
- Completes and/or directs or delegates the completion of the activities component of the comprehensive assessment
- Contributes to and/or directs or delegates the implementation of activities programming
- Monitors, reviews and evaluates each resident’s response to the programs to determine if the resident’s needs are being met
- Makes revisions to programming as necessary
How F680 is Cited
The Interpretive Guidance in Appendix PP of the State Operations Manual (SOM) states that F680 is an “absolute” tag. This means that the facility is required to have a qualified activities professional, and there does not need to be a negative outcome for a resident in order for this regulation to be cited. Concerns that have been identified at F679 will be considered by the surveyor when determining scope/severity for a citation at F680. That factor lends itself to not one, but two potential deficiencies if issues are identified with the facilities therapeutic recreation program and then attributed to the lack of qualification of the person overseeing the program.
Let’s look at a couple of actual survey citations to see how this occurs.
Recertification Survey Citation – F680 S/S: F
A facility was cited at F679 S/S: E for its activities program when it was observed that all activities in the facilities ended at 3:30 PM. During the Resident Council meeting, the residents stated that there were not enough activities, especially in the evenings. The activities director was interviewed and stated that all activities end at 3:30 and there are no activities in the evening, so the facility was not meeting the needs of its residents.
The surveyor reviewed the activities director’s personnel file and cited the facility at F680 S/S: F because the facility did not ensure the director had completed a State-approved program and was not qualified to be the department director.
Standard/Complaint Survey Citation – F680 S/S: E
As part of a complaint investigation related to a resident exhibiting physical and verbal behaviors, it was determined during record review that the resident’s behavior care plan did not include interventions implemented to address the behaviors. The facility, which was set up in smaller households, made CNAs responsible for providing recreation on the resident’s unit. On interview, the CNA stated that she was responsible for completing activity assessments and implementing activities for residents on her assigned unit. She had received dementia care training, but no formal training or education about therapeutic recreation and was not aware of any qualified recreation specialist/ activity professional in the facility. The surveyor interviewed the Administrator who stated that there was a specialist working in the community, but that person was not involved in the assessment, planning or implementation of any of the LTC activity programs and no one had been in that role for more than two years.
Recertification Survey Citation – F680 S/S: F
During the survey, a surveyor conducted a resident meeting, and it was determined that that the facility had not had a Director of Recreation for approximately six months, and it was affecting the residents. The residents told the surveyor that there were not enough activities, and no activities in the evenings or on the weekend. They also stated that there had been no outside trips since the pandemic. Resident Council members stated they were concerned about what kind of activities were being provided to cognitively impaired residents since minimal activities were being provided to the alert and oriented residents. All the residents in the group agreed with these statements. The surveyor interviewed the OT who was the Activity Director who stated she had not received specialized training. She stated the activities staff completed the calendars and activities assessments and she was not involved in that. The surveyor interviewed an activities staff member who stated that she was responsible for passing out mail, doing one-to-one visits and providing entertainment. When asked how she knew what the residents liked to do, she stated that the alert residents mostly liked arts and crafts and they did coloring with the residents with dementia.
Not surprisingly, the facility was also cited at F679 S/S: F for failure to provide meaningful and individualized activity programs for severely cognitively impaired residents and ensure that activities, social events and schedules were developed that accounted for residents’ interests and needs.
As you can see from the scenarios above, there are many ways that a provider can find itself looking at a citation at F680. This is a good time to remind everyone – ensure your activities program is back to “usual” – and don’t forget about the need to have evening and weekend programming for engagement. Do yourself a favor, take a walk down the facility’s halls with a focus on assessing resident engagement. If everywhere you look residents are parked in front of a TV in their rooms or a public area or are at a table with a coloring book and are sound asleep, you might want to consider taking a hard look at your activities department. While you are taking that walk, talk to a few residents about what they do on Sundays. The answer has a high likelihood of being “there is nothing to do” or “there is a televised religious service in the morning” and that is not going to be an answer you want to hear.
Do yourself a favor, take a walk down the facility’s halls with a focus on assessing resident engagement. If everywhere you look residents are parked in front of a TV in their rooms or a public area or are at a table with a coloring book and are sound asleep, you might want to consider taking a hard look at your activities department.
What you also might want to do is re-look at the S/S of the survey citations referenced in this Ftag of the Week. We are looking at pattern and widespread and I don’t think that anyone wants to see that on their 2567.
