Inspection on 16/05/07 for Fearnley House

This inspection was carried out on 16th May 2007.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Excellent. 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 made no statutory requirements on the home as a result of this inspection and there were no outstanding actions from the previous inspection report.

Other inspections for this house

Fearnley House 12/12/05

Fearnley House 08/07/05

Fearnley House 17/02/05

Fearnley House 12/10/04

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Hillview Farm

Dalewood Respite Care

Orchard,The

REACH Upton Court Road

Fairways

Treloar College

Kestrel House, St Anne`s Opportunity Centre,

Pinta

Extracts from inspection reports are licensed from CQC, this page was updated on 08/07/2008.

CARE HOME ADULTS 18-65 Fearnley House 86 Straight Road Old Windsor Berks SL4 2RX Lead Inspector Robert Dawes Unannounced Inspection 16th May 2007 11:15 DS0000052919.V335821.R01.S.doc Version 5.2 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 DS0000052919.V335821.R01.S.doc Version 5.2 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. DS0000052919.V335821.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Fearnley House Address 86 Straight Road Old Windsor Berks SL4 2RX 01753 863752 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) Choice Limited Mrs Dionne Catherine McGlinchey Care Home 4 Category(ies) of Learning disability (4) registration, with number of places DS0000052919.V335821.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 12th December 2005 Brief Description of the Service: The home is owned and run by CHOICE Ltd and provides care for people with multiple needs. This is a new home that opened a little over 18 months ago, to provide care for four young residents with learning and physical disabilities. The home is in a bungalow on a main road, with shops nearby. The house is set in a medium size garden with a tarmac car park in the front. The rear is a grassed area with an annexe for an office. There is a summerhouse for use as an educational facility. The house comprises a spacious L-shaped lounge and dining room and kitchen, with four bedrooms and bathrooms and toilets. Fees £1800-£2200 per week. DS0000052919.V335821.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This was a routine unannounced site visit, which took place during the day on the 16 May 2007. The pre-inspection questionnaire and one relative’s questionnaire were returned to the inspector before the site visit. These, together with the site visit, were the main sources of information for the key inspection. During the site visit the inspector interviewed the manager and three members of staff; toured the premises; looked at records; case tracked; and observed the interaction between clients and staff. No service users were spoken with because of communication difficulties. Twenty three standards were assessed during the site visit of which thirteen were met and ten were exceeded. One recommendation was made. What the service does well: Fearnley House provides an excellent standard of personal and health care support for the service users that live there. A large variety of different communication methods are used together within the home to maximise service users choice and involvement. This includes exploring feelings and emotions. The staff team are very knowledgeable about the service users and are able to observe behaviour and interpret its meaning. The team were observed to be relaxed, friendly and professional with service users at all times. Each service user is supported in addition by an effective key worker system. The person centred care plans are detailed and comprehensive. Service users have the opportunity to participate in a wide range of activities. These include a good use of all local facilities in the local community and more specialist courses at local colleges and activities in specialist centres. There is a competent registered manager who supports an experienced staff team that have received a good program of training to ensure a good knowledge and understanding of service users needs. Clients are treated equally and their diverse needs are catered for. A relative commented in the survey, ‘they have a very positive approach and I really believe my son has never been happier. Fearnley House should be considered a model of good practice’. DS0000052919.V335821.R01.S.doc Version 5.2 Page 6 What has improved since the last inspection? What they could do better: 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. The summary of this inspection report can be made available in other formats on request. DS0000052919.V335821.R01.S.doc Version 5.2 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 DS0000052919.V335821.R01.S.doc Version 5.2 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. JUDGEMENT – we looked at outcomes for the following standard(s): Number 2. People who use the service experience good quality outcomes in this area. Prospective clients’ individual aspirations and needs are assessed. This judgement has been made using available evidence including a visit to this service. EVIDENCE: No service user has been admitted to the home in the last three years. There is a detailed admission policy and procedure within the home and the statement of purpose. DS0000052919.V335821.R01.S.doc Version 5.2 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. JUDGEMENT – we looked at outcomes for the following standard(s): Numbers 6, 7 and 9. People who use the service experience excellent quality outcomes in this area. The home works hard to enable service users lead as independent a life as possible and make decisions about what they do and how they are cared for. The care plan is person centred, reflects their diverse needs and focuses on the individual’s strengths and personal preferences. A variety of communication tools and techniques are used to enable service users contribute to their care plan. This judgement has been made using available evidence including a visit to this service. EVIDENCE: All the four service users’ files contained comprehensive and very detailed individual care plans. They are reviewed annually with the service user, relatives and professionals and when required. The plans contain behavioural management guidelines; play session guidelines; risk assessments; a person centred ‘my profile’ covering the individuals’ personal needs; action plans which are reviewed every six months; monthly summaries of daily notes using DS0000052919.V335821.R01.S.doc Version 5.2 Page 10 key headings such as health, activities and goals from review; and very detailed guidelines covering all aspects of the service users’ personal care and behaviour such as toileting, making loud noises, contact seeking behaviour, inappropriate greetings and agitated behaviour. All staff sign to indicate that they have read the plans. The regular service users’ meeting records and individual files showed that service users are involved in making decisions about their daily lives, i.e. what they would like to do on holiday, menus, staff who they want to go on holiday with them and colour of rooms. In reply to the question in the relatives’ survey ‘does the care service support people to live the life they choose?’ the relative replied ‘yes’. Service users meet with their key workers at regular intervals to express their views about their care. All of the service users have significant difficulties in communication. The manager and staff use a range of communication techniques to ensure the service users communicate their views and make decisions about their lives. A service user with little contact with his relatives has been found an advocate. The service users capabilities are very limited but are encouraged and enabled to be as independent as possible i.e. two service users make cups of tea with support form staff. Appropriate risk assessments are in place. DS0000052919.V335821.R01.S.doc Version 5.2 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. JUDGEMENT – we looked at outcomes for the following standard(s): Numbers 12, 13, 15, 16 and 17. People who use the service experience excellent quality outcomes in this area. People who use the service take part in a wide range of appropriate activities which reflect their diverse needs; they participate in the local community and are enabled to keep in touch with their families and friends; their rights are respected and responsibilities recognised in their daily lives; and are offered a healthy diet and enjoy their meals. This judgement has been made using available evidence including a visit to this service. EVIDENCE: Each service user has an individual schedule of weekly events. The activity program is very varied both in the local community and in house. Activities include using local colleges for courses such as cooking and makaton; leisure centres for swimming and trampolining; outdoor activities such as horse riding; more specialist centres for hydrotherapy, drama therapy and sensory activities; and going shopping and to pubs, cinemas and cafes. There is a DS0000052919.V335821.R01.S.doc Version 5.2 Page 12 range of activities for service users in house including reading, art and craft, daily living skills, aromatherapy, reflexology, sensory sessions and music sessions. Two service users have a tutor for two hours a week. Activities are reviewed regularly and during service users review as evidenced in recent records. Staff support two service users using their communication boards in the lounge each day so they are fully aware of what activities have been organised. On the day of the inspection two staff took two service users bowling, the manager undertook sensory work with another service user and the other service user was with the tutor. The home has a mini bus for outings. Service users are encouraged and enabled to keep in regular contact with relatives. The home has a sexuality and relationships policy. Staff receive sexuality and personal relationships training. In response to the questions in the relatives’ survey, ‘does the home help you keep in touch with your relative?’ and ‘are you kept up to date with important issues affecting your relative?’ the relative replied ‘yes’. Service users were observed to have unrestricted movement around the home, except other people’s bedrooms. Service users can choose to be alone. Service users help with simple tasks around the house such as putting the laundry away and washing cups. A very positive and respectful interaction between staff and service users was observed. Staff on duty at lunchtime demonstrated a good awareness of each individual’s support needs. A risk assessment was seen, for one service user who has difficulty swallowing, describing how the food should be prepared and how he should be fed. The staff use cards with the service user to sequence the events during the meal. The three other service users were supported and offered as much choice and independence as possible. The menus are varied over a three-week cycle with the main meal being prepared and provided during the evening by the cook, who is experienced and has worked at the home for some time. The relatives of a service user who is a Muslim were asked if they wanted the preparation and serving of her food to follow their cultural and religious requirements. DS0000052919.V335821.R01.S.doc Version 5.2 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. JUDGEMENT – we looked at outcomes for the following standard(s): Numbers 18, 19 and 20. People who use the service experience excellent quality outcomes in this area. People who use the service receive personal support in the way they prefer and require; and their physical and emotional health needs are well met. Service users are protected by the home’s medication procedures. This judgement has been made using available evidence including a visit to this service. EVIDENCE: The service users have very complex needs and staff provide a high level of support. Detailed guidelines covering all aspects of the service users’ personal support needs were seen, i.e.toileting. Staff assist service users undertake tasks, such as making a cup of tea and getting undressed, by using communication aids to take them through each stage. To enable service users to understand what is happening during the day various communication aids, such as timetable boards, objects of reference and makaton, are used. The inspector observed staff respond to service users in a caring, respectful and professional manner. DS0000052919.V335821.R01.S.doc Version 5.2 Page 14 In response to the question in the relatives’ questionnaire ‘does the care home give the support or care to your relative that you expect or agreed?’ the relative replied ‘yes’. The diverse needs of the service users are addressed on an individual basis. Specialist support is provided as required i.e. speech therapy, physiotherapy and occupational therapy. All the files contained records, such as weight, behavioural observation, seizure and pressure sore charts, which showed the service users’ physical and emotional health is being well monitored, responded to appropriately and any problems are being promptly addressed. All the service users have health action plans. Service users attend for regular health checks including vision, teeth and medication. Where required service users have behavioural guidelines which are regularly reviewed by the organisations’ psychologist. None of the service users self-administer their medication. No controlled drugs are on the premises. The medication administration records were in order. All the staff have received medication training. Appropriate medication policies and procedures are in place, including for the administration of PRN medication and for administering medication covertly. Agreement was sought from the GP for covert administration of medication. The manager has requested a pharmacist visits the home once a year to inspect the storage, administration, recording and disposal of the medication. DS0000052919.V335821.R01.S.doc Version 5.2 Page 15 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. JUDGEMENT – we looked at outcomes for the following standard(s): Numbers 22 and 23. People who use the service experience excellent quality outcomes in this area. People who use the service feel their views are listened to and acted on; and are protected from abuse. This judgement has been made using available evidence including a visit to this service. EVIDENCE: There is a comprehensive complaints procedure as well as a pictorial complaints process aimed at service users contained in the service users guide. The service users have very limited verbal skills and would find it difficult to complain directly. Staff are clear on observing behaviour and interpreting its meaning and this is reinforced by an effective key worker system. The use of emotion picture cards to explore feelings is used for two of the service users. No complaints to the home or the Commission have been made since the last inspection. In response to the question in the relatives’ survey ‘do you know how to make a complaint?’ the relative replied ‘yes’. Staff have received training in protection of adults as well as to assist with behaviour that may challenge the service. Staff spoken to were clear about protection issues and dealing with behaviours ensuring respect and dignity. There are comprehensive behavioural guidelines in place designed to protect service users from harm, which are regularly reviewed by the psychologist DS0000052919.V335821.R01.S.doc Version 5.2 Page 16 team within the company. Records showed in the case of one service user who exhibited numerous incidents of challenging behaviour over a six month period he was only ‘escorted to his room’ on one occasion. No allegations of abuse have been made to the Commission since the last inspection. A safeguarding younger adults’ policy is in place. Each service user has a bank account. The manager and deputy manager are authorised to withdraw money. No service user manages his or her own finances. Service users’ personal money is kept in individual wallets in a secure facility in the manager’s office. Records of all transaction are kept and audited by a person from outside of the home annually. The home has appropriate policy and procedures for handling clients’ personal money. DS0000052919.V335821.R01.S.doc Version 5.2 Page 17 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. JUDGEMENT – we looked at outcomes for the following standard(s): Numbers 24 and 30. People who use the service experience good quality outcomes in this area. The home is comfortable, safe and well maintained. The home is clean and hygienic. This judgement has been made using available evidence including a visit to this service. EVIDENCE: The home is spacious, light and airy. It is well furnished, decorated and maintained. The bathing facilities meet the needs of the service users, aids and adaptations have been fitted to enable service users with physical disabilities to move independently around the home, bedrooms were personalised and the garden is pleasant and accessible. In the garden there is a summerhouse used for recreational activities including a computer. The home is clean and hygienic. DS0000052919.V335821.R01.S.doc Version 5.2 Page 18 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. JUDGEMENT – we looked at outcomes for the following standard(s): Numbers 32, 33, 34 and 35. People who use the service experience excellent quality outcomes in this area. An effective, competent and qualified staff team who receive a broad range of training support the people who use the service fairly, without discrimination and in a caring manner. The home is working hard to recruit a full staff team which would raise the level of care even more. The home operates a thorough recruitment procedure. This judgement has been made using available evidence including a visit to this service. EVIDENCE: Staff interviewed demonstrated a good understanding of the conditions and needs of the service users. One support worker said he was proud to be a member of staff in the home. In response to the questions in the relatives survey ‘do you feel the care home meets the needs of your relative?’; ‘does the home give the support and care to your relative that you expect?’; ‘do the care staff have the right skills and experience to look after people properly?’; and ‘does the care service meet the different needs of people?’, the relative replied ‘yes’. DS0000052919.V335821.R01.S.doc Version 5.2 Page 19 The relative commented ‘the home has helped my son develop his skills, thoroughly enjoy his life, and explore the environment. As a result his timetable is flexible, supportive and encouraging of his abilities. His progress is a joy to us and to him. I cannot praise the care enough. They have a very positive approach and I really believe my son has never been happier and Fearnley House should be considered a model of good practice. The home has maintained a stable staff team and only one member of staff has left in the last year. However recruitment is a problem and the home is managing with one full and one part time support worker vacancies. The staff team and bank staff cover the vacant support hours but because the home does not like to use agency staff, given the complex needs of the service users, on occasions there are only two support workers on duty. This occurs the minority of times but when it does occur service users can become more demanding and are restricted from going out. Records showed the organisation complies with the recruitment regulations. All new staff undertake an induction and foundation training programme which incorporates LDAF. All staff have received basic training and training in key areas of their work such as safeguarding younger adults, values and attitudes, anti discriminatory practice, SCIP, autism and apergers, effective communication and epilepsy. Only one support worker had received training in the mental health problems that service users with a learning disability can suffer from. Refresher training of key areas of work takes place. Staff said they considered training equipped them to undertake their work but would like the opportunity for a speech therapist to teach them how to communicate with the service users using makaton. 33 of the support staff have a NVQ2 or above in care. All staff had training profiles. DS0000052919.V335821.R01.S.doc Version 5.2 Page 20 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. JUDGEMENT – we looked at outcomes for the following standard(s): Numbers 37, 39 and 42. People who use the service experience excellent quality outcomes in this area. People who use the service benefit from a well run home; their views underpin all self-monitoring, review and development by the home; and their health, safety and welfare are promoted and protected. This judgement has been made using available evidence including a visit to this service. EVIDENCE: The registered manager is qualified, competent and experienced to run the home. She has been the manager since the home opened in November 2003. The manager undertakes periodic training to maintain and update her knowledge and skills. Staff described the manager as very supportive, approachable, clear in how she wants the clients cared for and operates a person centred approach to how the home is run. DS0000052919.V335821.R01.S.doc Version 5.2 Page 21 The organisation ensures an effective quality assurance and monitoring system operates in the home through regular staff and service users’ meetings (using communication aids such as pictures and photos) taking place; a representative of the organisation visiting the home every month to undertake a detailed inspection of the quality of care being delivered; the service users, relatives and care managers completing an annual satisfaction questionnaire (the service users’ questionnaire is in a format to suite their level of understanding and communication); and key workers meeting with service users to discuss their care at regular intervals. A development plan is produced annually. In the relatives’ survey the relative commented ‘the home asks me at the reviews how the home could be improved’. The organisation has a commitment to keep improving the quality of care. Records showed all health and safety checks and inspections are up to date and completed as required. Necessary health and safety policies and procedures are in place. The home’s fire risk assessment has been reviewed. All the service users’ files contained appropriate risk assessments and had been reviewed regularly. All the staff have received the necessary health and safety training including first aid. DS0000052919.V335821.R01.S.doc Version 5.2 Page 22 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 Standard No Score 1 X 2 3 3 X 4 X 5 X INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score CONCERNS AND COMPLAINTS Standard No Score 22 4 23 3 ENVIRONMENT Standard No Score 24 3 25 X 26 X 27 X 28 X 29 X 30 3 STAFFING Standard No Score 31 X 32 4 33 3 34 3 35 3 36 X CONDUCT AND MANAGEMENT OF THE HOME Standard No 37 38 39 40 41 42 43 Score 4 4 X 3 X LIFESTYLES Standard No Score 11 X 12 4 13 4 14 X 15 3 16 3 17 3 PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Score 4 4 3 X 4 X 4 X X 3 X DS0000052919.V335821.R01.S.doc Version 5.2 Page 23 No 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. Standard Regulation Requirement Timescale for action RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. 1 Refer to Standard YA35 Good Practice Recommendations Provide all staff with training in makaton and the mental health conditions that people with learning disabilities can suffer from. DS0000052919.V335821.R01.S.doc Version 5.2 Page 24 Commission for Social Care Inspection Oxford Office Burgner House 4630 Kingsgate Oxford Business Park South Cowley, Oxford OX4 2SU National Enquiry Line: Telephone: 0845 015 0120 or 0191 233 3323 Textphone: 0845 015 2255 or 0191 233 3588 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 DS0000052919.V335821.R01.S.doc Version 5.2 Page 25 - 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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