22 VAC 40-61-330 D 3  Allows a qualified occupational therapist or an occupational therapy assistant to be the activity director.  Both of those must be licensed by the Board of Medicine to practice in Virginia and the COTA (occupational therapy assistant) must be supervised by the OTR (qualified occupational therapist).  If a COTA was the Activity Director there would need to be an OTR supervisor.  This might need to be explored with the Licensing Board as to how much supervision.  It does not seem to be much of a solution for those in smaller towns where health care employees are scarce anyway to allow own that is already in demand.  Compensation is also an issue as noted in other comments.

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