Rick Scott Governor Barbara Palmer Director 3 a State Office a 4030 Bapianade Way Suite 380 Ta?ahassee Fiorida 32399?0950 a (850} 488-425? Fm: (850)922-6456 'Toii Free: (866) (866-273-2273) agency for persns with disabilities Store of Florida April 22, 2014 Mr. Keliy McCr'ann. Chief Executive Officer Advoserv, Inc. I 28334 Churchill Smith Lane Mount Dora, Florida 32757 Dear Mr. McCrann: As a follow-up to the face-to?face meetings you have had with several of my staff members, I have reviewed the proposed improvements intended to address previously-identified issues of concern. In order to formalize our mutual understandings and agreements in this matter, below are the final expectations our Agency has agreed upon for your facility. Unless otherwise indicated, all of these actions must be completed and fully implemented prior to the end of this calendar year. 1. Technology Upgrade and Expansion - Video Image Quality The quality of the video images captured must be improved. Designated APD staff shall be afforded the opportunity to review the proposed enhancements and make a determination as to whether or not the captured images are of acceptable quality. The video storage duration must remain at 30 days. 0 Audio With Video Audio recording capability must be provided with all existing video camera locations and retained for the same 30-day period as required for video images. Designated APD staff shall be afforded the opportunity to listen to sample audio recordings in order to make a determination as to whether or not those recordings are of acceptable quality. 0 Video Back?up uMaintain a back-up storage system (at an off?site location if possible) for all video and audio recordings. a Remote Video Monitoring - Modify or enhance the video/audio monitoring system in order to enable authorized APD staff to access the system (in real-time) from an off~site location. 2. Medical Case Management - Deveiop and implement medical protocols to specifically address assessment and treatment of medical issues, upon admission and on an ongoing basis, that clearly delineate those conditions which may be treated by facility staff as Well as those conditions for which it will be required to seek and obtain outside medical treatment as needed. 3. Communication improvements Develop and implement a revised policy on health~reiated issues for the purposes of addressing the communication failures that have been identified. This policy should address communication protocols between direct care staff and medical personnel as well as between nursing staff and physicians. 4. Additional Monitoring - Administrative Presence - implement a schedule of administrative coverage during all evenings, nights, and weekends. Add Program Administrator positions that would have authority over Program Supervisors within the Table of Organization and would be speci?cally scheduled to work evenings, nights, and weekends. Supervisory Training - Modify existing training for supervisory staff (to address preViOUSIy-identitied issues of concern) and submit to APD for approval. Upon approval, reutrain all supervisory staff using the new curriculum. Technology Changes Modify existing video monitoring systems in order to ensure that monitoring may occur without detection or knowledge by staff in those areas. a Evaluate, and update as necessary, the forms, function, and efficacy of current monitoring systems. Update such systems as necessary to better utilize the data in shaping staff performance and identifying trends/issues of concern across program locations. 5. Quarterly Meetings On an ongoing basis, participate in quarterly meetings with APD and other stakeholders (such as DCF and/or Disability Rights Florida) wherein summaries of incident reports, abuse reports, employee disciplinary actions, and other issues of concern will be discussed. Such meetings shall include at least one representative from your corporate office. 6. Communication to Senior Management - All incident reports involving residents of the facility shall be immediately forwarded to management staff within the licensee's. corporate office. Corporate staff shall work with on-site facility management to ensure that all incidents are preperly addressed. 7. Restraint Policies - Provide APD with the facility?s policy on the utilization of mechanical and physical restraints and conduct re~ training of all direct care staff on the use of such actions. 8. Compliance with New CMS Guidelines Develop and submit a plan to APO for achieving compliance with the CMS requirements related to the provision of community?based waiver services. 9. Staff Disciplinary Actions - Develop and implement a policy which prohibits the facility from continuing to employ any licensed medical professional whom the Florida Department of Health has suspended or revoked the license(s) of such employees. Also, as my staff previously discussed with you, the Agency is willing to forego the imposition of administrative fines at this juncture and allow your facility to apply those resources instead to complying with the . expectations outlined herein. Our staff members will continue to monitor the operations of your facility and are prepared to initiate formal disciplinary actions if the aforementioned provisions are not fulfilled or if subsequent or additional issues of concern are identified. That being said. i appreciate your willingness to work cooperatively with the Agency in helping us to achieve our mutual goal of ensuring the health and safety of the people we serve. Sincerely, (gm. .QW Barbara Palmer, Director