The State should not be making unreasonable requirements on adult day care centers.  Specifically, adding a requirement for a “designated” activity staff will put a financial hardship on small and rural day care centers.  Recreational Specialists and/or Occupational  Therapists are are expensive options for cash strapped day care centers that rely on publicly funded Medicaid reimbursement which is already well below the cost of daily care of these participants.  I also question whether studies have shown these specialists provide better quality activities than is available with current staffs of caring nursing and administrative personnel.

Proposed regulation 22VAC10-61-330 should be eliminated or revised to be a minimal standard that does not create a financial hardship for small centers.  While everyone wants the excellent daycare, it can be achieved without excessive requirements that may lead to closing of small centers that are providing an important service to the participants and the community.