The CNA had been serving as the facility's activities director for four to five weeks when federal inspectors arrived in November. She told inspectors she had no training and wasn't enrolled in any certification program required by federal regulations.
"She stated she was not an OT or OTA, and she did not have any prior experience," inspectors wrote. "She stated she was doing a little trial run to see if she was interested in the position."
Federal law requires nursing homes to employ qualified therapeutic recreation specialists or state-licensed activities professionals to direct resident programming. The woman running activities at Avir met none of these requirements.
During her interview, the activities director said she "wanted to make sure she could take the job seriously and do the position justice and do it right." She told inspectors she loved the job and had communicated to the administrator within her first week that she wanted to do it full time.
The HR director confirmed the personnel file contained no proof of education for the activities director. He said it was his understanding that she had a year to complete training, but the administrator had not yet enrolled her in any certification program.
When inspectors interviewed the administrator, he acknowledged the woman "was hired as an assistant because she worked as a CNA." He said the facility was working on getting her certified and planning to enroll her in training courses, but admitted she wasn't currently registered for any program.
The administrator told inspectors he didn't have anyone else who met the activity director requirements. He recognized the importance of having a qualified activities director "to assist with cognition, so residents had the opportunity to express themselves and so they could flourish in their home."
Federal regulations exist because activities programming directly affects residents' physical, mental and psychosocial well-being. Without proper training, activities staff cannot provide individualized approaches that match residents' skills, abilities and personal interests.
The facility's own policy, dated June 2018, states that "activity programs are designed to meet the interests of and support the physical, mental and psychosocial well-being of each resident." However, inspectors found the policy failed to address qualifications for the activities director position.
A job description for "Activity Coordinator" found during the inspection listed only preferences for office experience, nursing home experience, and supervisory experience. None of the qualifications mentioned the federal requirements for therapeutic recreation specialists or state-licensed activities professionals.
The violation affected all 72 residents at the facility. Inspectors classified it as having potential for actual harm, noting that residents were at risk of not receiving individualized activities approaches tailored to their specific needs and capabilities.
Activities programming in nursing homes serves multiple therapeutic purposes beyond entertainment. Qualified professionals assess residents' cognitive abilities, physical limitations, and personal interests to design interventions that can slow cognitive decline, maintain physical function, and provide meaningful social engagement.
For residents with dementia, properly designed activities can reduce agitation and improve mood. For those recovering from strokes or injuries, therapeutic recreation can support rehabilitation goals. Social activities help combat isolation and depression common in institutional settings.
The inspection occurred in response to a complaint, though the specific nature of the complaint was not detailed in the report. Federal inspectors found the facility failed to ensure its activities program was directed by a qualified professional, a violation that impacts the foundation of therapeutic programming for vulnerable residents.
The administrator's acknowledgment that qualified activities direction helps residents "flourish in their home" highlights the disconnect between understanding the importance of proper staffing and actually implementing it. While the facility expressed intentions to provide training, no concrete steps had been taken during the woman's month-long tenure in the position.
The case illustrates a broader challenge in nursing home staffing, where facilities struggle to find qualified professionals but continue operating programs with unqualified staff rather than addressing the underlying staffing crisis. Residents continue receiving services from untrained personnel while administrators make plans that remain unfulfilled.
Federal regulations don't allow for "trial runs" with resident care. The 72 residents at Avir at Kerrville spent weeks under the direction of someone learning whether she was interested in the job, rather than receiving activities programming from a qualified professional trained to support their complex needs.
Full Inspection Report
The details above represent a summary of key findings. View the complete inspection report for Avir At Kerrville from 2025-11-21 including all violations, facility responses, and corrective action plans.