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Inspection on 29/11/05 for Conquest House

Also see our care home review for Conquest House for more information

This inspection was carried out on 29th November 2005.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Good. The way we rate inspection reports is consistent for all houses, though please be aware that this may be different from an official CSCI judgement.

The inspector found there to be outstanding requirements from the previous inspection report. These are things the inspector asked to be changed, but found they had not done. The inspector also made 8 statutory requirements (actions the home must comply with) as a result of this inspection.

What follows are excerpts from this inspection report. For more information read the full report on the next tab.

What the care home does well

Care plans show clearly the help and support that residents need and how staff should go about the task of providing such help. The plans have been reviewed to ensure that they remain up to date though the home`s procedures dictate that they should be reviewed every month, which is not always happening. Assessments of risk around individual needs and the environment of the home have been carried out and reviewed as necessary. Recruitment procedures are rigorous, and the procedures to ensure the protection of vulnerable adults are well known and acted upon. Staff members` relationships with residents are friendly and professional and interventions, including the management of challenging behaviour, are based on good practice.

What has improved since the last inspection?

A member of staff has been appointed specifically to organise activities both within the home and in the community, and to develop links with colleges and other educational organisations. Floor covering in the communal areas has been replaced and efforts have been made to make the service more homely including the purchase of new communal furniture. Two deputy manager posts have been created to work alongside, and assist, the acting manager. Arrangements for the storage of medication have been improved.

What the care home could do better:

The home`s location, in an isolated area of the Fens, means that it cannot be considered to be part of a local community, and accessing ordinary facilitiessuch as shops, pubs, libraries can only be achieved using a vehicle or after a long walk to a bus stop and subsequent bus journey. The home`s bathing and toilet facilities are large, impersonal and poorly maintained, though new baths and showers have been delivered and are due to be fitted shortly. Many areas of the home are not properly heated, and a number of fire doors do not have self-closing devices. Systems need to be improved ensure staff are regularly supervised, however, the creation of two deputy posts should help this. The home`s registered manager has been on maternity leave for approximately 12 months and, whilst the home is generally being managed adequately, more permanent management arrangements need to be made.

CARE HOME ADULTS 18-65 Conquest House Straight Drove Farcet, Cambridgeshire PE7 3DY Lead Inspector Matthew Bentley Unannounced Inspection 29th November 2005 11:30 Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 1 The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 2 This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Adults 18-65. They can be found at www.dh.gov.uk or obtained from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering: www.tso.co.uk/bookshop This report is a public document. Extracts may not be used or reproduced without the prior permission of the Commission for Social Care Inspection. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 3 SERVICE INFORMATION Name of service Conquest House Address Straight Drove Farcet, Cambridgeshire PE7 3DY Telephone number Fax number Email address Provider Web address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) 01733 244623 01733 245845 Conquest Care Homes (Peterborough) Limited Marie Brown Care Home 20 Category(ies) of Learning disability (20), Mental disorder, registration, with number excluding learning disability or dementia (20) of places Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 4 SERVICE INFORMATION Conditions of registration: 1. MD only in association with LD Date of last inspection 22nd June 2005 Brief Description of the Service: Conquest House provides support and accommodation for up to 20 younger adults with a learning disability which may be coupled with a mental disorder. Some service users have complex needs including behaviours which challenge the service. The home is in a converted vicarage near to the Fenland village of Farcet. An additional bungalow on the same site provides care and support for up to six permanent residents, however, at the time of the inspection it was empty and the building was being decorated in preparation for the admission of new residents. In addition to day support staff there is one waking night staff with another staff member sleeping in the building to assist residents if necessary. A maintenance person is also employed, though there is a vacancy for a cleaner, and a cook, the later of who has taken on the post of support worker. The home is owned Craegmoor Group Ltd; Conquest Care Homes (Peterborough) Limited is a subsidiary of the organisation, and continues as the registered provider. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This was the second inspection of Conquest House, for the period 2005/6. The unannounced inspection took 2.5 hours and took place between 11.30 and 14.00. On the day of inspection a number of service users were at home and the inspector spoke to six individuals. The inspection also included reading care plans and other documents, speaking to staff and the acting manager (the registered manager being on maternity leave) and a tour of the communal parts of the home and some bedrooms. What the service does well: What has improved since the last inspection? What they could do better: The home’s location, in an isolated area of the Fens, means that it cannot be considered to be part of a local community, and accessing ordinary facilities Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 6 such as shops, pubs, libraries can only be achieved using a vehicle or after a long walk to a bus stop and subsequent bus journey. The home’s bathing and toilet facilities are large, impersonal and poorly maintained, though new baths and showers have been delivered and are due to be fitted shortly. Many areas of the home are not properly heated, and a number of fire doors do not have self-closing devices. Systems need to be improved ensure staff are regularly supervised, however, the creation of two deputy posts should help this. The home’s registered manager has been on maternity leave for approximately 12 months and, whilst the home is generally being managed adequately, more permanent management arrangements need to be made. Please contact the provider for advice of actions taken in response to this inspection. The report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–5) Individual Needs and Choices (Standards 6-10) Lifestyle (Standards 11-17) Personal and Healthcare Support (Standards 18-21) Concerns, Complaints and Protection (Standards 22-23) Environment (Standards 24-30) Staffing (Standards 31-36) Conduct and Management of the Home (Standards 37 – 43) Scoring of Outcomes Statutory Requirements Identified During the Inspection Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 8 Choice of Home The intended outcomes for Standards 1 – 5 are: 1. 2. 3. 4. 5. Prospective service users have the information they need to make an informed choice about where to live. Prospective users’ individual aspirations and needs are assessed. Prospective service users know that the home that they will choose will meet their needs and aspirations. Prospective service users have an opportunity to visit and to “test drive” the home. Each service user has an individual written contract or statement of terms and conditions with the home. The Commission consider Standard 2 the key standard to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 2, 5 Sufficient arrangements are in place to ensure that the service is suitable for individuals who are considering moving to the home so that no one is admitted inappropriately. There is effectively no contract between residents and the home so they will not be fully aware of their rights and responsibilities. EVIDENCE: A full assessment of each person’s needs, and the help that they are likely to need takes place before admission. Since the last inspection two new residents have moved in; the needs of the people concerned were assessed by care managers and the acting manager of the home, and also involved healthcare professionals, and the individuals themselves. When appropriate, families are involved in the assessment process and are invited to be part of the reviews of the placement. Since the last inspection a contract between the home and residents has been devised, however, it is yet to be implemented. A requirement has been made about this. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 9 Individual Needs and Choices The intended outcomes for Standards 6 – 10 are: 6. 7. 8. 9. 10. Service users know their assessed and changing needs and personal goals are reflected in their individual Plan. Service users make decisions about their lives with assistance as needed. Service users are consulted on, and participate in, all aspects of life in the home. Service users are supported to take risks as part of an independent lifestyle. Service users know that information about them is handled appropriately, and that their confidences are kept. The Commission considers Standards 6, 7 and 9 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 6, 7, 8, 9, 10 Systems of care planning are clear and well laid out and contain information to guide staff about how to support those living in the home, though the daily recording of each person’s circumstances needs to be improved. Residents are involved in making decisions about their lives to the best of their abilities with help and guidance from staff when necessary. Systems for assessing risk are effective so that any unnecessary or unacceptable risks can be eliminated. EVIDENCE: The care plans relating to four of the people living in the home were seen and contained good quality information about what help each person needed and how it should be given. The home’s procedures dictate that reviews of care plans should take place every month to make sure they are up to date. Some of the plans had been reviewed when they were due, however, reviews of some were overdue. Each resident is allocated a member of staff to act as ‘keyworker’, with another named staff member taking over if the main keyworker is not around. The recording of the activities in which residents have been involved and other aspects of their care does not show enough detail, and there are numerous entries such as ‘been fine’, which does not tell the reader anything of use and cannot be used to develop or inform the system of care planning. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 10 Participation in the running of the home is promoted by offering choice and encouraging comments from those living in the home, both on a day-to-day basis, and through regular residents’ meetings. Residents are encouraged to do jobs abound the house that they enjoy, and are able to do. Discussions with the acting manager and staff members indicate that they have a good understanding of residents’ right to make decisions and to take acceptable risks. An assessment of the risk that might exist in a number of areas relevant to each resident has been carried out; methods by which the risk might be avoided or lessened have been recorded and appropriate action has been taken to avoid unnecessary risk. The home has a policy to guide staff regarding what information should be shared, and with whom; records containing personal information are kept securely in a filing cabinet in the office. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 11 Lifestyle The intended outcomes for Standards 11 - 17 are: 11. 12. 13. 14. 15. 16. 17. Service users have opportunities for personal development. Service users are able to take part in age, peer and culturally appropriate activities. Service users are part of the local community. Service users engage in appropriate leisure activities. Service users have appropriate personal, family and sexual relationships. Service users’ rights are respected and responsibilities recognised in their daily lives. Service users are offered a healthy diet and enjoy their meals and mealtimes. The Commission considers Standards 12, 13, 15, 16 and 17 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 11, 12, 13, 14, 16, 17 Staff provide appropriate support to facilitate contact with family and friends, and service users have access to leisure activities in the community, that are appropriate to their needs and abilities. The home’s location means that contact with the community has to be planned and necessitates the use of a vehicle. Service users are provided with an adequate diet. EVIDENCE: The majority of residents take part in a range of activities to suit their individual needs and interests including leisure activities and educational courses at local colleges; however, the home’s location means that informal contact with the wider community is difficult to develop or maintain. A new activities co-ordinator has been appointed; the person concerned hopes to develop and expand the range and frequency of the activities provided, including horse-riding, swimming, and a range of sports, part of the aim of which is to improve residents’ fitness and health. Some activities are provided by specialist day services, others involve going out with staff members; a number of residents are enrolled on courses at the adult education colleges in Peterborough; concerns have been expressed, by one of the authorities who Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 12 purchase the service, that residents are sometimes not able to go to their courses due to a shortage of staff, however, the acting manager said that the problem has now been rectified. The home has a range of vehicles to allow residents to go out singly with a member of staff, or as a group. Residents meetings take place regularly to give each person the opportunity to say what they think about the service and make suggestions about things such as food or outings that they would like to happen. For safety reasons the kitchen is not usually accessible to residents, however, hot and cold drinks are always available and residents said that the food is good. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 13 Personal and Healthcare Support The intended outcomes for Standards 18 - 21 are: 18. 19. 20. 21. Service users receive personal support in the way they prefer and require. Service users’ physical and emotional health needs are met. Service users retain, administer and control their own medication where appropriate, and are protected by the home’s policies and procedures for dealing with medicines. The ageing, illness and death of a service user are handled with respect and as the individual would wish. The Commission considers Standards 18, 19, and 20 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 18, 19, 20 Care is provided in a manner that suits those living in the home, and service users physical, emotional and health needs are being met. Arrangements for the administration and storage of medication are appropriate and the home’s procedures were being followed ensuring that service users were not put at risk. EVIDENCE: Staff were helping people appropriately with a range of tasks and those spoken to appeared knowledgeable about individuals’ needs and how they should provide help and support. The home is supported by specialist learning disability professionals including psychiatrists, occupational therapists, care managers, nurses, and speech and language therapists; advice has also been gained from a dietician regarding the needs of one particular resident. Medication records were inspected and were satisfactory. Since the last inspection a suitable fridge has been purchased to store medication that needs to be kept cool. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 14 Concerns, Complaints and Protection The intended outcomes for Standards 22 – 23 are: 22. 23. Service users feel their views are listened to and acted on. Service users are protected from abuse, neglect and self-harm. The Commission considers Standards 22, and 23 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 22 The home’s systems for dealing with complaints are satisfactory so that residents and relatives can be sure their concerns are taken seriously and are acted upon within an appropriate timescale. EVIDENCE: The home has a policy and procedure to follow if a person wishes to make a complaint about the service; the procedures are displayed on the wall in the entrance hall. A complaint about issues relating to activities over the summer period has been made, but the manager said that the issue has since been properly resolved. Residents said that they would speak to staff members if they were unhappy about the service. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 15 Environment The intended outcomes for Standards 24 – 30 are: 24. 25. 26. 27. 28. 29. 30. Service users live in a homely, comfortable and safe environment. Service users’ bedrooms suit their needs and lifestyles. Service users’ bedrooms promote their independence. Service users’ toilets and bathrooms provide sufficient privacy and meet their individual needs. Shared spaces complement and supplement service users’ individual rooms. Service users have the specialist equipment they require to maximise their independence. The home is clean and hygienic. The Commission considers Standards 24, and 30 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 24, 27, 28, 30 The home is clean and generally adequately maintained, however, the isolated location of the building means that it cannot be considered to be part of a community. One area of cleanliness was causing a risk of cross-infection. EVIDENCE: The home is situated in a large building in an area of fenland. Though it is just within walking distance of a small village, it is could not be seen to be part of the local community, and service users are dependant on staff to transport them to local amenities. The communal areas of the House are maintained and decorated to an acceptable level, and work has continued to improve the environment generally, including new floor covering in the hall, new carpets in the lounge, and new chairs in the dining room. The home has an adjacent bungalow called Alpine Lodge, which is part of the same registration. At present it is not being used and is being re-decorated; the acting manager said that if it is to be used in the future it will have its own staff group who will be directly supervised by a deputy manager. Thermostatic valves have been fitted to sinks and baths to ensure that hot water is delivered at a safe temperature. The large bathroom has a separate shower that has been out of use for many months and which has no curtain round the tray; there are also a number of tiles that are cracked or broken. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 16 The bath in the small downstairs bathroom is chipped and worn and needs replacing. Requirements were made about these matters following previous inspections; these have not been met. Failure to comply with these requirements may result in legal action being taken against the service, however, a replacement suite and shower have been delivered and the acting manager reported that the work was scheduled to start the following week. The lock on the door to one of the bathrooms is broken and the door doesn’t close properly, which compromises residents’ privacy; a requirement has been made about this, however the acting manager has since said that the lock was replaced later that afternoon. Many parts of the home, including some bedrooms and the bathrooms were cold. The acting manager said that the heating system is due to be renewed, and a requirement has been made to this effect with (considering the onset of winter) has a relatively short timescale for action. On the day of inspection the home as a whole was clean and hygienic and there were no unpleasant smells, however, there was what looked like faeces on the door and the handle in one of the bathrooms. A requirement has been made about this, however, the acting manager said that the door handle would be cleaned immediately. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 17 Staffing The intended outcomes for Standards 31 – 36 are: 31. 32. 33. 34. 35. 36. Service users benefit from clarity of staff roles and responsibilities. Service users are supported by competent and qualified staff. Service users are supported by an effective staff team. Service users are supported and protected by the home’s recruitment policy and practices. Service users’ individual and joint needs are met by appropriately trained staff. Service users benefit from well supported and supervised staff. The Commission considers Standards 32, 34 and 35 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 31, 32, 33, 34, 35, 36 Staff are clear about their roles and are properly trained, and appropriate checks are being made prior to the appointment of new staff, however, formal one-to-one supervision is not taking place as regularly as is required. EVIDENCE: Arrangements are in place to ensure that new staff are given a proper induction to the home so that they are aware of the work that they have to do and can watch how established staff interact with residents. Health and safety topics are also covered during this period, as are the service’s values and ethos. A range of training has taken place, including specialist training in managing challenging behaviour. The majority of the staff team either have, or are doing, a National Vocational Qualification (NVQ) in care at level 2 and one of the newly appointed deputy managers has the NVQ at level 3. Staff spoken to said that there are sufficient staff in the team, though there have been occasions when, due to vacancies, they have had to cover shifts. The acting manager said that recently 2 new staff have been appointed, which has made covering shifts easier. Files relating to the 2 new members of staff contain references, Criminal records Bureau (CRB) checks, and other necessary documents which have been obtained before the people concerned start work. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 18 Due to circumstances outside the control of the acting manager the formal supervision of staff has fallen behind; a requirement that staff receive formal supervision at least 6 times a year has been made, but the acting manager said that, as a suitably qualified deputy manager has recently been appointed, he would soon be achieving this goal. A new format for supervision is being put in place; the effectiveness of this, and the frequency of supervisions will be looked at as part of future inspections. Staff meetings are held regulary and include an update on each of the service users’ needs, matters of health and safety, and any other areas of concern; the staff meetings are classed in part, as group supervision. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 19 Conduct and Management of the Home The intended outcomes for Standards 37 – 43 are: 37. 38. 39. 40. 41. 42. 43. Service users benefit from a well run home. Service users benefit from the ethos, leadership and management approach of the home. Service users are confident their views underpin all self-monitoring, review and development by the home. Service users’ rights and best interests are safeguarded by the home’s policies and procedures. Service users’ rights and best interests are safeguarded by the home’s record keeping policies and procedures. The health, safety and welfare of service users are promoted and protected. Service users benefit from competent and accountable management of the service. The Commission considers Standards 37, 39, and 42 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 37, 42 The home is properly managed and in the absence of the registered manager, the acting manager is providing effective leadership and guidance to staff. One area of health and safety needs attention, without it, residents would not be properly protected in the event of a fire. EVIDENCE: The registered manager is on maternity leave, however, the acting manager is running the home competently and effectively in her absence and is working towards gaining the Registered Manager’s Award (RMA). Since the last inspection management arrangements at the home have been altered and two deputy posts have recently been created to assist the manager and to take on the supervision of some staff. A recent inspection by the fire safety officer has been carried out, two requirements were made, one being that one of the bedroom doors has its self-closing device replaced. The door to another bedroom also has a faulty device and a requirement that they are both replaced, has been made in this report. Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 20 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Adults 18-65 have been met and uses the following scale. The scale ranges from: 4 Standard Exceeded 2 Standard Almost Met (Commendable) (Minor Shortfalls) 3 Standard Met 1 Standard Not Met (No Shortfalls) (Major Shortfalls) “X” in the standard met box denotes standard not assessed on this occasion “N/A” in the standard met box denotes standard not applicable CHOICE OF HOME CONCERNS AND COMPLAINTS Standard No 1 2 3 4 5 Score X 2 X X 2 Standard No 22 23 Score 3 X ENVIRONMENT INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score 3 3 3 3 3 Standard No 24 25 26 27 28 29 30 STAFFING Score 2 X X 1 3 X 2 LIFESTYLES Standard No Score 11 3 12 3 13 3 14 3 15 X 16 3 17 Standard No 31 32 33 34 35 36 Score 3 3 3 3 3 2 CONDUCT AND MANAGEMENT OF THE HOME 3 PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Conquest House Score 3 3 3 X Standard No 37 38 39 40 41 42 43 Score 3 X X X X 2 X DS0000015146.V260463.R01.S.doc Version 5.0 Page 21 Yes Are there any outstanding requirements from the last inspection? STATUTORY REQUIREMENTS This section sets out the actions, which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard YA5 Regulation 5(1)(b)(c) Requirement Timescale for action 15/08/05 2. YA24 23(2)(p) 3. YA27 23(2)(j) 4. YA27 23(2)(j) Each service user must be provided with a written contract/statement of terms and conditions containing the information required to meet this standard and associated regulations This was a requirement resulting from the last inspection; failure to comply with this requirement may result in legal action being taken against the service. The heating system must be 15/12/05 repaired or replaced and all parts if the home must be adequately heated. The bathroom suite referred to 31/08/05 must be replaced and effective heating must be provided. This was a requirement resulting from the last inspection; failure to comply with this requirement may result in legal action being taken against the service. The shower in the large 31/08/05 bathroom in the house must be repaired or replaced and suitable screens or curtains must be provided. This was a requirement resulting from the DS0000015146.V260463.R01.S.doc Version 5.0 Conquest House Page 22 5. YA27 6. 7. 8. YA30 YA36 YA42 last inspection; failure to comply with this requirement may result in legal action being taken against the service. 23(2)(b) The lock referred to must be replaced, and all bathrooms and toilets must be fitted with locks so that service users’ privacy is maintained 16(2)(j) All parts of the home must be kept hygienic 18(2) Staff must receive formal supervision at least six times a year 23(4)(c)(i) The fire doors referred to must be fitted with automatic closers 15/12/05 29/11/05 29/11/05 31/12/06 RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. Refer to Standard Good Practice Recommendations Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 23 Commission for Social Care Inspection Cambridgeshire & Peterborough Area Office CPC1 Capital Park Fulbourn Cambridge CB1 5XE National Enquiry Line: 0845 015 0120 Email: enquiries@csci.gsi.gov.uk Web: www.csci.org.uk © This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI Conquest House DS0000015146.V260463.R01.S.doc Version 5.0 Page 24 - Please note that this information is included on www.bestcarehome.co.uk under license from the regulator. Re-publishing this information is in breach of the terms of use of that website. Discrete codes and changes have been inserted throughout the textual data shown on the site that will provide incontrovertable proof of copying in the event this information is re-published on other websites. 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