· Applaud CMS for moving Recreational Therapy from Section T 1.a to Section P. as an identified therapy service to be consistent with the industry of rehabilitation and other accrediting agencies.

· Recommend CMS utilization of Recreational Therapy treatment minutes in determining in the rehabilitation RUG classification as other rehabilitation therapies identified in Section P.

· Recommend CMS promote the utilization of the most cost effective mix of rehabilitation therapies as identified in Section P.

· Recommend the definitions for all therapies identified in P. 2 retain definitions that rehabilitation therapies are physician supervised, include in the physician’s order the frequency, intensity and duration of the ordered therapy and the therapy is provided by a qualified therapist.

· Request that CMS identify Recreational Therapy as an ordered therapy in Section T


1. to remain consistent with the listing of therapies in Section P2

· Recommend CMS include observable, non-verbal, or non-expressed indicators for the quality of life indicates in Section F.

· In Section G and K, the use of FIM related language and seven point scale is excellent for consistency and follow up with patients through the spectrum of care, however the change from four point scale in other parts of this MDS may be confusing and lead to inaccurate ratings.

· In Section N, the incorporation of MDS 2.0 Sections F and E are positive to reflect involvement patterns, however without access to the interpretative instructions, Section N5 on Pursuit and Engagement may be very difficult to distinguish between the statements.

· Section P1 Special Treatments r. Training in skills required to return to the community is a significant area that may be impacted by the interventions of a qualified recreational therapist and the interpretive instructions should be revised to reflect qualified therapists.

· The current interpretive instructions for Section P will require minor revisions to reflect the inclusion of qualified therapists, including the references to licensed therapist as not all states recognize therapists as licensed providers.