VIRGINIA DEPARTMENT OF SOCIAL SERVICES

Bickford of Virginia Beach
2629 Princess Anne Road
Virginia beach, VA 23456
(757) 821-0198

Current Inspector: Willie Barnes (757) 439-6815

Inspection Date: Aug. 18, 2022 , Aug. 22, 2022 , Aug. 29, 2022 and Sept. 2, 2022

Complaint Related: No

Areas Reviewed:

22VAC40-73 PERSONNEL 22VAC40-73 STAFFING AND SUPERVISION 22VAC40-73 ADMISSION, RETENTION AND DISCHARGE OF RESIDENTS 22VAC40-73 RESIDENT CARE AND RELATED SERVICES 22VAC40-73 EMERGENCY PREPAREDNESS 22VAC40-73 ADDITIONAL REQUIREMENTS FOR FACILITIES THAT CARE FOR ADULTS WITH SERIOUS COGNITIVE IMPAIRMENTS 22VAC40-90 THE CRIMINAL HISTORY RECORD REPORT

Comments:

Type of inspection: Complaint On-site renewal inspection conducted two days, 8-18-18 (two inspectors from ERO/PLO) (Ar 08:10 /dep 6:25 p.m.) Day 2 on 8-22-22 one inspector (Ar 10:20 a.m./dep 6:00 p.m.)The facility census was 62, a tour of the facility was conducted, medication pass observation, activity, emergency preparedness/ first aid kit check, resident and staff records and interviews conducted. A preliminary exit conducted with administrator and two other staff members. The Acknowledgement Form was signed and dated. Requested documents requested and received via email. Preliminary exit and review conducted on 8-22-22 with administrator and staff member. Acknowledgement Form signed and dated. Request for additional documents requested and received via email. Third preliminary meeting conducted virtually on 8-29-22 with administrator and Nursing Services Director. Final exit interview will be conducted. The Acknowledgement of Inspection form was sent to the Administrator following each exit meeting and receipt of documents. The evidence gathered during the inspection determined non-compliance with applicable standard(s) or law, and violation(s) were documented on the violation notice issued to the facility. The licensee has the opportunity to submit a plan of correction to indicate how the cited violation(s) will be addressed in order to return the facility to compliance and maintain future compliance with applicable standard(s) or law. If the licensee wishes to provide a plan of correction: (i) type the plan on a separate Word document, (ii) identify the standard violation number being addressed, (iii) include the date the violation will be corrected, (IV) do not include any names or confidential information, and (V) return to the licensing inspector by email within five (5) business days of the exit interview. Compliance with all applicable regulations and law shall be maintained and any areas of noncompliance must be corrected. Within 15 calendar days of your receipt of the inspection findings (inspection summary, violation notice, and supplemental information), you may request a review and discussion of these findings with the inspector's immediate supervisor. To make a request for review and discussion, you must contact the licensing supervisor at the regional licensing office that serves your geographical area. Regardless of whether a supervisory review has been requested, the results of the inspection will be posted to the DSS public website within 5 business days of your receipt of the Inspection Summary and/ or Violation Notice. The department's inspection findings are subject to public disclosure. Please Note: A copy of the findings of the most recent inspection are required to be posted on the premises of the facility. The department's inspection findings are subject to public disclosure. Please Note: A copy of the findings of the most recent inspection are required to be posted on the premises of the facility. For more information about the VDSS Licensing Programs, please visit: www.dss.virginia.gov Should you have any questions, please contact (Willie Barnes), Licensing Inspector at (757-439-6815) or by email at willie.barnes@dss.virginia.gov

Violations:

Standard #:	22VAC40-73-1180-B
Description:	Based on observation and staff interviewed, the facility failed to ensure that ordinary materials or objects may be harmful to a resident, these materials or objects shall be inaccessible to the resident?s on the safe, secure unit, except under staff supervision. Evidence: 1. On 8-18-22 during a tour of the safe, secure unit with staff #5, two air blowing machines were observed in two chairs in the hallway. There was no supervision of these electrical items. 2. Staff #5 acknowledged the items should not have been left unsupervised on the safe, secure unit.
Plan of Correction:	*The two carpet drying enclosed fan units observed in the chairs on the safe, secure unit were put away. *The Maintenance Coordinator was instructed to put all carpet care equipment away when not in use. *ACC and care staff instructed to always be on the lookout for any items that could pose potential harm on a safe, secure unit and to report any observations to the Maintenance Coordinator and/or Director. Person Responsible: Maintenance Coord./ACC/Care Staff
Standard #:	22VAC40-73-40-B-8
Description:	Based on observation and staff interviewed, the facility failed to current license was posted in the facility. Evidence: 1. On 8-18-22, during a tour of the facility, the current license was posted. The license posted expired May 11, 2022. 2. On 8-18-22, staff #1 acknowledged the current license was not posted in the facility.
Plan of Correction:	*The expired license, dated 5/11/22, was re-issued by DSS on 8/9/22 and emailed to the licensee on 8/10/22. *The electronic copy was printed and then photocopied onto cardstock and hung at the entryway of the Branch on the morning of 8/18/22 prior to the exit of this monitoring inspection. *The posted license will be checked, during daily rounds, to assure that the most current copy is hanging and on display. Person Responsible: Dir/ Admin. Asst
Standard #:	22VAC40-73-220-A
Description:	Based on documents reviewed and staff interviewed, the facility failed to ensure before direct care or companion services are initiated, the facility shall obtain, in writing, information on the type and frequency of the services to be delivered to the residents by the private duty personnel, review the information to determine if it is acceptable, and provide notification to home care organization or whomever is hired regarding any needed changes. The services should be reflected on the resident?s individualized service plan. The facility shall provide orientation and training to private duty personnel regarding facility policies and procedures related to private duty personnel and documentation of resident care required ismaintained. Evidence: 1. On 8-22-22, a review of CS-1?s record did not have documentation of the required information for private duty personnel. There was no documentation of orientation, description of services and frequency and no documentation of facility policies and procedures relating to private duty personnel. 2. On 8-22-22, staff #1 stated private sitter provides services for residents #12 and #13. Individual hired by the family. 3. On 8-22-22, staff #1 stated CS-2 also provided sitter duties in the facility, but staff did not know which resident received the services. Individual hired by a private agency. 4. On. 8-22-22, staff #1 acknowledged private duty personnel were providing services in the facility and the facility did not have the required documentations.
Plan of Correction:	*CS-1 was a former nursing staff member of Bickford of Virginia Beach and completed orientation at the time of hire on 10/07/2019 and again on 1/11/22 as a private duty companion. CS-2 is employed by a licensed and JCAHO accredited staffing agency in the state of VA. She received orientation on 9-14-22 *Both CS-1 and CS-2 provided their frequency and description of companion-only services on 8/22/22. *Both agencies providing the services of CS-1 and CS-2 were provided with a copy of Standard 22VAC73-220 for ongoing compliance purposes. *All resident and family members will receive, at the time of move in, written guidelines of the requirement to provide notification to the Branch, in advance, of the desire to employee the services of a private duty companion to assure that all regulatory requirements are met. Person Responsible: Dir./CRD/Admin. Asst.
Standard #:	22VAC40-73-250-D
Description:	Based on document reviewed and staff interviewed, the facility failed to ensure each staff person on or within seven days prior to the first day of work at the facility shall submit the results of a risk assessment, documenting the absence of tuberculosis (TB) in a communicable form as evidences by the completion of the current screening form published by the Virginia Department of Health or a form consistent with it. Evidence: 1. On 8-22-22, CS-1 and CS-2 record did not have documentation of the results of a risk assessment, documenting the absence of tuberculosis (TB) 2 .On 8-22-22, staff #3?s TB was dated 6-4-22. Staff?s date of hire was documented as 5-31-22. 3. On 8-29-22, staff #1 acknowledged the TB information were not completed as required per the requirements.
Plan of Correction:	*CS-1 completed TB testing on 9/26/19, 8/4/21, and again on 8/27/22 and was negative. CS-2 completed a TB screening on 6/28/22 and was negative. *All resident and family members will receive, at the time of move in, written guidelines of the requirement to provide notification to the Branch, in advance, of the desire to employee the services of a private duty companion to assure that all regulatory requirements are met. *Staff #3 completed TB testing on 6/4/22 during her scheduled orientation and prior to assuming responsibility for her position. *All applicants will complete TB testing or a TB Risk Assessment within 7 days prior to their actual ?start date? in the Branch and will not participate in any orientation activities ?on-site? in the Branch until negative TB/Risk Assessment results are received. *All staff records will be audited to assure that each contains a current negative TB Risk Assessment/Screening or negative TB results. Person Responsible: Dir./Admin. Asst.
Standard #:	22VAC40-73-260-C
Description:	Based on observation and staff interviewed, the facility failed to ensure the listing of all staff certified in current first aid and CPR was kept up to date. Evidence: 1. On 8-18-22, staff #4 was asked where the facility?s first aid/CPR listing was posting. A check of the listing on the wall in the medication room, determined the list was not current. A more current listing was located in staff information binder at the nursing station. Review of the document revealed there staff names with expired certification (6-9-22 and 1- 2022). 2. Staff #4 acknowledged the first aid/CPR listing was not updated.
Plan of Correction:	*All staff records were audited to determine current CPR/First Aid training status. *A revised current list of those staff with current CPR/First Aid training was posted on the AL Nurses Station bulletin board, in the Communication Binder at the AL Nurses Station and in the Main Office on the Training Bulletin Board. *CPR/First Aid training was conducted on 9/7/22 and is also scheduled for 9/30/22. The list will be updated following that training. *The Admin. Asst. has scheduled that the list be updated every month, on/around the 15th, to assure that only those with current certification are posted Person Responsible: Dir./Admin. Asst./Designee
Standard #:	22VAC40-73-290-B
Description:	Based on observation and staff interviewed, the facility failed to ensure it posted the name of the current on-site person in charge. Evidence: 1. On 8-18-22, the name of the current on-site person in charge was not posted in the facility. There was also no posting of the previous shifts (11p- 7a). This inspector had on previous inspection reminded staff #1 of the requirement for posting the staff person in charge (4-7-22 and 2-7-22). 2. Staff #1 acknowledged the facility did not post the name of the current on-site person in charge.
Plan of Correction:	*A framed sign, with the names and titles of the 4 members of the Directing Family Group, will be conspicuously displayed to the residents and the public on the table at the entry way in the Branch and will include the name and title of the current on-site person in charge, on each shift. *This will be scheduled to be updated weekly, and any changes will be notated. *These signs will be kept on file with the corresponding schedule that also indicates whomever is in charge at any given time. Person Responsible: Dir./Admin. Asst./Designee
Standard #:	22VAC40-73-440-H
Description:	Based on record review and staff interviewed, the facility failed to ensure an annual reassessment, using the uniformed assessment instrument (UAI), shall be utilized to determine whether a resident?s needs can continue to be met by the facility and whether continued placement in the facility is in the best interest of the resident. Evidence: 1. On 8-18-22, resident #3?s record?s uniformed assessment instrument (UAI) was dated 10-2- 20 and 10-26-20. The resident?s date of admit was documented as 10-12-20. 2. On 8-18-22, resident #5?s record did not have a copy of the UAI, resident?s date of admit documented as 8-26-21. 3. On 8-18-22, staff #1 acknowledged the aforementioned resident did not have an annual reassessment using the UAI.
Plan of Correction:	*Resident #3 UAI dated 9/22/21 reassessment was retrieved from the thinned chart and placed in the medical record. *Resident #5 UAI dated 8/10/21 assessment and 9/1/21 reassessment was retrieved from the thinned chart and placed in the medical record. *Resident #1 was admitted on 11/1/21. UAI dated 10/21/21 assessment was retrieved from the thinned chart and placed in the medical record. *100% audit of all resident records will be conducted to assure that the initial UAI assessment and most current UAI reassessment are located on the medical record. *Nursing Core Checks to be conducted, as a part of our Quality Assurance process, to assure that all original UAI assessments and most current UAI reassessments remain in the medical record. Person Responsible: NCC/ACC/Dir./Divisional Nurse
Standard #:	22VAC40-73-450-C
Description:	Based on record reviewed and staff interviewed, the facility failed to ensure the individualized service plan (ISP) included all assessed needs for six residents? record. Evidence: 1. On 8-18-22, resident #1?s record documented resident?s allergy to some chocolate and not to others. The physical dated 10-28-21documented resident?s hearing loss. The uniformed assessment instrument (UAI) noted resident?s use of eye glasses, resident also observed with eye glasses. The UAI transferring need assessed as ?mechanical help?. The record included a physician signed and dated (10-28-21) Do Not Resuscitate (DNR) document. These were not documented on resident?s ISP dated 1-19-22. 2. On 8-18-22, resident #2?s UAI dated 6-30-22, toileting need assessed as `human help/supervision?, the ISP documented use of grab-bar, walker and raised toilet seat. Mobility need assessed as ?mechanical help? use of walker. This need was not documented on the ISP dated 6-30-22. 3. On 8-18-22, resident 3?s ISP dated 2-16-22 did not include resident mental health services being provided by a local agency. 4. On 8-18-22 and 8-22-22, resident #4?s UAI dated 6-30-22, stairclimbing need assessed as ?mechanical help?. Resident assessed as ?disoriented sometime? to time. The record also documented mental health services being provided by a local agency (7-5-22). Occupational therapy, physical therapy and speech therapy (start 5-26-22 to 7-24-22) documented in record. Resident also observed wearing eyeglasses. These needs were not documented on the ISP dated 6-30-22. The ISP documented resident code as ?Do Not Resuscitate?, the record did not include a signed and dated physician?s DNR order. 5. On 8-22-22, resident #8?s record documented physical therapy services for cellulitis, right lower limb (5-28-22 to 7-26-22, recertification 7-26-22 to 9-24-22). This need was not documented on the ISP dated 6-30-22. 6. On 8-22-22, resident #9?s UAI dated 1-12-22, transferring assessed as not help needed. The ISP dated 2-8-22 documented need as ?mechanical help needed?, use of walker and arm rest. Stairclimbing need assessed as ?not performed?, however, the ISP did not document how and need would be provided. The signed physician?s orders (POS) documented allergy to Codeine, Gabapentin, Hydrocodone, Oxycodone and stimulant laxative. Physical therapy services notes dated 2-16-22 to 5-19-22 (discharged note 5-19-22), skilled nursing order (1-20-22 to 3-20-22) and mental health services (notes 3-22-22 to 8-16- 22) from a local agency. These needs were not documented on the ISP dated 2-28-22. 7. On 8-18-22 and 8-22-22, staff #1 acknowledged the aforementioned residents? UAI and ISP did not include all assessed/identified needs.
Plan of Correction:	Not available online. Contact Inspector for more information.
Standard #:	22VAC40-73-450-E
Description:	Based on record reviewed and staff interviewed, the facility failed to ensure the individualized service plan was signed and dated by the resident and/or legal representative. Evidence: 1. On 8-22-22, resident #11?s comprehensive service plan (ISP) dated 7-29-22 was not signed and dated by the resident and/or his legal representative. 2. On 8-22-22, staff #1 acknowledged the aforementioned resident?s service plan was not signed.
Plan of Correction:	*Resident #11 Service Plan, completed on 7/29/22, emailed to the daughter on 9/14/22 for signature. *100% audit of all resident records to be conducted to assure that either a signature or email confirmation of receipt is received for all resident service plans. *NCC/ACC, upon completion of the ISP, is to give it to the Admin. Asst. to obtain the Director?s signature and then obtain residents signature and/or email to POA for signature. Also to schedule a care plan meeting, when requested. Upon receiving the signed copy, the original is to be filed in the medical record, and a copy is to be filed in the Life Song Binder *Nursing Core Checks and routine audits to be conducted, as a part of our Quality Assurance process, to assure that all services plans have the required signatures or documentation of receipt. Person Responsible: NCC/ACC/Dir./Divisional Nurse
Standard #:	22VAC40-73-470-A
Description:	Based on record reviewed and staff interviewed, the facility failed to ensure directly or indirectly, that the health care service needs of a resident was met. Evidence: 1. On 8-22-22, resident #11?s record included a signed physician?s order dated 7-1-22 for speech therapy to evaluate for dysphagia. 2. Staff acknowledged the order for the aforementioned resident?s speech services was not conducted.
Plan of Correction:	*Resident #11 medical record contains the SP initial evaluation and therapy notes ordered by the provider on 7/1/2022. *In-house rehab provider to generate documentation for all residents currently receiving therapy services that will be kept in a separate file that is easily assessable by Bickford staff. *The weekly rehab caseload report will be used for audit purposes to assure that documentation for all services is on site and available. Person Responsible: NCC/ACC/Dir./Divisional Nurse
Standard #:	22VAC40-73-550-G
Description:	Based on record reviewed and staff interviewed, the facility failed to ensure the rights and responsibilities of residents in assisted living facilities shall be reviewed annually with each resident or his legal representative or responsible individual. Evidence of this review shall be in the resident?s, his legal representative?s or responsible individual?s written acknowledgement of having been so informed, which shall include the date of the review and shall be filed in the resident?s record. Evidence: 1.On 8-18-22 and 8-22-22, the following residents? record did not have documentation of an annual review of the resident?s rights and responsibilities: residents? #2, #3, #4, #5, #6, #7, #8 and #10. 2. On 8-22-22, staff #7, acknowledged the residents? rights and responsibilities were not signed and dated and place in residents? record.
Plan of Correction:	*Residents #2, #3, #4, #5, #6, #7, #8, & #10 will have their annual resident rights review completed and documented with them, or their POA when indicated, prior to 9/30/2022. *All remaining residents will also have their annual resident rights review completed and documented with them, or their POA when indicated, prior to 9/30/2022. *The annual resident rights review will be scheduled yearly in September to assure that it is conducted annually. *The documentation will be maintained in the Admin. office in the Resident Rights Annual Review binder. Person Responsible: LEC/LEA/Designee
Standard #:	22VAC40-73-580-D
Description:	Based on record review and staff interviewed, the facility failed to ensure when the uniformed assessment instrument (UAI) assessed resident as dependent in eating/feeding, the individualized service plan (SIP) shall indicate an approximate amount of time needed for meals to ensure needs are met. Evidence: 1. On 8-22-22, resident #10?s uniformed assessment instrument (UAI) dated 4-28-22 documented resident is fed by others. The individualized service plan (ISP) 5-22-22 did not document an approximate amount of time needed for meals to ensure resident?s needs are met. 2. On 8-22-22 and 8-29-22, staff #1 acknowledged the aforementioned resident?s record did not document amount of time need to assist resident with meals.
Plan of Correction:	*Resident #10 to be evaluated during mealtime to determine the approximate amount of time required to consume meals to ensure that resident needs are met. Input will also be obtained from those staff members who assist this resident at mealtime. This information will be added to the service plan *Any other residents identified as needing to be fed will also be assessed to determine the approximate time required to eat during mealtimes. That information will be added to their service plans. *SP therapy will also be consulted when any identified residents are receiving those ser * Nursing Core Checks and ISP audits to be conducted, as a part of our Quality Assurance process, to assure that all residents identified as needing feeding assistance have the approximate amount of time needed to eat during meals documented on their service plans.
Standard #:	22VAC40-73-660-A
Description:	Based on observation and staff interviewed, the facility failed to ensure medications were stored in a manner consistent with current standards of practice. Evidence: 1. On 8-18-22, during a tour of the facility, resident #7 and #8?s medications on the safe, secure unit were observed unsecured on a desk in the common area. Staff #3, the medication person, was present and the inspectors spoke with staff regarding what was observed. Staff then went into the medication room but did not take the two containers of multiple medication cards into the medication room. 2. On 8-18-22, staff #3 acknowledged the medications on the safe, secure unit for two residents assigned to the 300 hallway were not properly stored on the morning of 8-18-22.
Plan of Correction:	*Staff #3 to receive additional education on the proper storage procedures for all medications in an Assisted Living Community with emphasis on the additional safety concerns on a safe, secure unit. *This occurrence will be documented. *Staff #3 to receive a med pass observation to ensure that all proper procedures are being followed with regards to proper medication administration procedures. Person Responsible: NCC/Divisional Nurse/appropriate designee
Standard #:	22VAC40-73-680-B
Description:	Based on observation and staff interviewed, the facility failed to ensure medications was remained in the pharmacy issued container, with the prescription label or direction attached, until administered to the resident. Evidence: 1. On 8-18-22, upon approaching the medication cart on the safe, secure unit, the inspectors observed four medication cups with medications on top of the medication cart. Staff #3 was inquired regarding the medications and stated the medications were for four residents on the 300 hallway who do not reside on the safe, secure unit. The medication staff on the safe, secure unit is responsible for administering medication on the 300 hallway located off the unit. The medications that were pre-poured were for residents #1, #5, #7 and #8. On 8-18--22 staff #3 acknowledged preparing the medications beforehand to administer later to the residents located on the 300 hallway.
Plan of Correction:	* Staff #3 to receive additional education on the proper administration of medications with emphasis on the importance of not pre-pouring medications. *This occurrence will be documented. *Staff #3 to receive a med pass observation to ensure that all proper procedures are being followed with regards to proper medication administration procedures. Person Responsible: NCC/Divisional Nurse/appropriate designee
Standard #:	22VAC40-73-680-K
Description:	Based on observation and staff interviewed, the facility failed to ensure medications order shall have the exact dosage. Evidence: 1. On 8-18-22 during the medication pass observation with staff #4, the following resident?s medication label and August 2022 medication administration record (MAR) documented medications without exact dosages: (1) resident #4?s Metamucil noted 4 ounces of fluid, the label noted at least 8 ounces and (2) resident #9?s Miralax noted give 4 to 8 ounces fluid. 2. Staff #1 acknowledged the aforementioned residents? medication did not have the exact dosage of liquid, but was noted to have a range of fluid ounces for the mixtures.
Plan of Correction:	*Resident #4 to receive a clarification order with regards to the fluid ounces to be used while administering Metamucil. *Resident #9 to receive a clarification order with regards to the exact amount of fluid ounces to be used while administering Miralax. *100% audit of all residents taking Metamucil, Miralax or other medications to be mixed with fluids to assure that each set of instructions include the exact amount of fluid ounces to be used while administering those medications. *All new orders for medications to be administered with fluids to be reviewed by the NCC/ACC to assure that the instructions are clear with the proper and exact amount of fluid ounces to be used. *Ongoing monitoring during weekly medication variance audits and MAR/POS audits. Person Responsible: NCC/ACC/designee
Standard #:	22VAC40-73-680-M
Description:	Based on observation and staff interviewed, the facility failed to ensure medications ordered for PRN administration shall be available, properly labeled for the specific resident, and properly stored at the facility. Evidence: 1. On 8-18-22 during the medication pass observation with staff #4, the following resident's PRN medications were not available in the facility: resident #4?s Bisacodyl and Glucagon kit. 2. Staff #4 acknowledged the aforementioned residents? PRN medications were not available on 8-18-22.
Plan of Correction:	*Resident #4 Glucagon kit and Bisacodyl refill requested on 8/18/2022 *100% audit of all residents with PRN medication orders to assure that all of the medications are on hand and able to be given if requested. *Ongoing monitoring during weekly medication variance audits and MAR/POS audits. Person Responsible: NCC/ACC/designee
Standard #:	22VAC40-73-960-C
Description:	Based on observation and staff interviewed, the facility failed to ensure the emergency telephone numbers for poison control center shall be posted by each telephone shown on the fire and emergency evacuation plan. Evidence: 1. On 8-18-22, the emergency telephone numbers were not observed posted near the telephones and not in the facility?s binder of telephones numbers to call in the event of an emergency. 2. Staff #1 acknowledged the emergency telephone numbers required to be posted or near the telephones were not available on the day the inspectors were present.
Plan of Correction:	*Required emergency telephone numbers were posted on each of the new telephones received and installed in April 2022 on 9/12/2022 *Any new or additional telephone equipment, identified on the fire and emergency evacuation plan, will have the emergency telephone numbers posted on/near them, as required. Person Responsible: Admin. Asst./designee
Standard #:	22VAC40-90-40-B
Description:	Based on record reviewed and staff interviewed, the facility failed to ensure that private duty personnel had an original criminal history record report issued by the Virginia Department of State Police, Central Criminal Records Exchange for each private duty personnel. Evidence: 1. On 8-22-22 a review of the private duty staff #11 and #12?s records with staff #1, there was no documentation of a criminal history report reviewed and /or in the record. 2. Staff #1 acknowledged not having a criminal history record for the aforementioned private duty staff.
Plan of Correction:	*CS-1 had a Criminal Background Check completed on 8/23/22. There was no conviction data. *CS-2 had a Criminal Background Check completed on 8/22/22. There was no conviction data. *Both agencies providing the services of CS-1 and CS-2 were provided with a copy of Standard 22VAC73-220 for ongoing compliance purposes. *All resident and family members will receive, at the time of move in, written guidelines of the requirement to provide notification to the Branch, in advance, of the desire to employee the services of a private duty companion to assure that all regulatory requirements are met. Person Responsible: Dir./Admin. Asst.