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ATRA Responds to HCFA Request for MDS 3.0 Comments

September 13, 2000

Pauline Belleville-Taylor, RN, MS
Hebrew Rehabilitation Center for Aged (HRCA)
Research and Training Institute
1200 Centre Street
Boston, MA 02131

Dear Pauline,

Thank you for the opportunity to provide comments to the Minimum Data Set (MDS) 2.0 during your revision process. I know Linda Hutchinson-Troyer has been in contact with you about our comments specific to Section T.1.a. that was not included in the response form. We have solicited comments from national leaders working in skilled nursing facilities that represent our national association's response.

As we have indicated in our previous correspondence with you, we are very pleased with the Section T.1.a. data collection regarding recreational therapy as a rehabilitation therapy. Therefore we have three specific recommendations and requests for the revision process:

1. Move Section T.1.a. data from the demonstration section to section P.1.b.f. The move of Section T.1.a data would then allow recreational therapy treatment minutes to be included in the rehabilitation treatment projections for the first 15 days under the MDS section T.1.b. Recreational therapy should be included in determining a complete picture of a resident's rehabilitation potential during the first RUG assessment period.

2. Revise the qualified recreational therapy provider language to "a state licensed or nationally certified therapeutic recreation specialist and a therapeutic recreation assistant as defined by the ATRA Standards of Practice, working under the supervision of a qualified therapeutic recreation specialist." This revision would reflect current practice of therapeutic recreation assistants and clarify potentially confusing definitions that are administered inaccurately.

We sincerely appreciate the opportunity to respond to this review and look forward to providing additional comments and feedback during the review process. Please ensure that my name and office is added to your list for further review. Please do not hesitate to contact me if you require further information or have questions regarding our comments. Thank you.

Sincerely,

Ann D. Huston, MPA, CTRS
Executive Director

Cc: Powers, Pyles, Sutter & Verville, PC
ATRA Board of Directors