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Inspection on 28/11/08 for Howard House Nursing Home

Also see our care home review for Howard House Nursing Home for more information

This inspection was carried out on 28th November 2008.

CSCI found this care home to be providing an Excellent service.

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.

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

There is information available for prospective residents and their needs are assessed before they move to the home to ensure that they can be met. The assessment document identifies prospective residents` faith and cultural needs as well as their care and emotional needs. A trial visit can be arranged and prospective residents and their families are encouraged to visit the home before moving. Residents` personal, healthcare and medication needs are met to a high standard. There are good staffing levels and close collaboration with the local general practitioner, who visits regularly. There is a programme of activities to bring interest and diversion to the day. Residents are encouraged to remain in contact with friends and family. Meals are good and meet residents` nutritional and social needs. There are complaints policies and procedures in place to address residents` concerns and to protect them from potential harm. Residents feel that they are listened to and that their views are respected. The home is clean and well maintained and is a safe and accessible home for residents. Residents are encouraged to personalise their own rooms to make them more homely and to reflect their own tastes and memories. There are sufficient staff, who have received relevant training, to meet residents` needs in a timely way. The recruitment procedures are thorough and the required checks are undertaken to protect residents from unsuitable staff. The home is well managed by an experienced manager and there are quality assurance systems in place to ensure that the care residents receive improves and that action is taken when deficits in care are noted. Residents and their family`s views are taken into account in the running of the home.

What has improved since the last inspection?

The information available to prospective residents has been updated. There has been a programme of ongoing redecoration and improvements to the environment.

What the care home could do better:

The Trustees and responsible individual must review the categories of registration of the home. The home is currently registered for twenty residents who require nursing care and ten who require personal (residential) care only. On the day of the unannounced visit it was felt that most residents required nursing care. The trustees must apply for a variation to their registration categories if they wish to take more than twenty residents who require nursing care, if they are to operate legally within the legal requirements of the Care Standards Act 2000. A recommendation to do this was made at the last inspection but has not yet been undertaken.

Inspecting for better lives Key inspection report Care homes for older people Name: Address: Howard House Nursing Home Vicarage Way Gerrards Cross Buckinghamshire SL9 8AT     The quality rating for this care home is:   three star excellent service A quality rating is our assessment of how well a care home, agency or scheme is meeting the needs of the people who use it. We give a quality rating following a full assessment of the service. We call this a ‘key’ inspection. Lead inspector: Chris Sidwell     Date: 2 8 1 1 2 0 0 8 This is a report of an inspection where we looked at how well this care home is meeting the needs of people who use it. There is a summary of what we think this service does well, what they have improved on and, where it applies, what they need to do better. We use the national minimum standards to describe the outcomes that people should experience. National minimum standards are written by the Department of Health for each type of care service. After the summary there is more detail about our findings. The following table explains what you will see under each outcome area. Outcome area (for example Choice of home) These are the outcomes that people staying in care homes should experience. the things that people have said are important to them: They reflect This box tells you the outcomes that we will always inspect against when we do a key inspection. This box tells you any additional outcomes that we may inspect against when we do a key inspection. This is what people staying in this care home experience: Judgement: This box tells you our opinion of what we have looked at in this outcome area. We will say whether it is excellent, good, adequate or poor. Evidence: This box describes the information we used to come to our judgement. Copies of the National Minimum Standards – Care Homes for Older People can be found at www.dh.gov.uk or bought from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering from the Stationery Office is also available: www.tso.co.uk/bookshop 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 Our duty to regulate social care services is set out in the Care Standards Act 2000. Care Homes for Older People Page 2 of 26 Reader Information Document Purpose Author Audience Further copies from Copyright Inspection report CSCI General public 0870 240 7535 (telephone order line) Copyright © (2008) Commission for Social Care Inspection (CSCI). This publication may be reproduced in whole or in part, free of charge, in any format or medium provided that it is not used for commercial gain. This consent is subject to the material being reproduced accurately and on proviso that it is not used in a derogatory manner or misleading context. The material should be acknowledged as CSCI copyright, with the title and date of publication of the document specified. www.csci.org.uk Internet address Care Homes for Older People Page 3 of 26 Information about the care home Name of care home: Address: Howard House Nursing Home Vicarage Way Gerrards Cross Buckinghamshire SL9 8AT 01753885258 01753887574 Telephone number: Fax number: Email address: Provider web address: Name of registered provider(s): Name of registered manager (if applicable): The Perseverance Trust The registered provider is responsible for running the service Name of registered manager (if applicable) vacant post Type of registration: Number of places registered: care home 30 Conditions of registration: Category(ies) : Number of places (if applicable): Under 65 old age, not falling within any other category Additional conditions: 10 service users receiving personal care. 20 service users receiving general nursing care. Admission of a specific service user. That from 12th April 2006- the home`s registration is varied to enable the continued accommodation of a specific service user with a demntia type illness. This is to be a temporary variation to the home`s existing registration categories and will revert to the original registration when the named resident is no longer accommodated at the home. Dementia Care Training. For as long as residents with a dementia type illness are accommodated at Howard House- training in the care of people with dementia type illness is to be mandatory for all current and future staff. This condition is to be effective immediately. Care Homes for Older People Page 4 of 26 Over 65 30 0 Date of last inspection Brief description of the care home Howard House is located in a quiet residential area of Gerrards Cross a short distance for the town centre. The village is served by local bus services and has a mainline railway station. The home provides accommodation for up to 30 residents, 20 of whom may receive nursing care. The home is comprised of both old and modern buildings, and has a large, attractive and well-maintained garden. All rooms are single and two have en-suite facilities. There is a lift to the first floor. The home has been adapted to meet the needs of the elderly. The communal space is attractively decorated. Residents are able to take meals in their rooms, in an attractively decorated dining room, or in the summer months on the patio. The home has quiet areas, including a small library, where residents may receive guests in private. A team of qualified nurses, carers, catering, housekeeping and maintenance staff supports the homes manager. A qualified nurse is on duty 24 hours a day. Allied healthcare professionals are accessible through direct contact or by General Practitioner referral. Information about the home can be obtained by contacting or visiting the home. Care Homes for Older People Page 5 of 26 Summary This is an overview of what we found during the inspection. The quality rating for this care home is: Our judgement for each outcome: three star excellent service Choice of home Health and personal care Daily life and social activities Complaints and protection Environment Staffing Management and administration peterchart Poor Adequate Good Excellent How we did our inspection: The inspection was conducted over the course of three days and included an unannounced visit to the home. The key standards for older peoples services were covered. Information received about the home since the last inspection was taken into account in the planning of the visit. Prior to the visit, the manager completed an annual quality assurance self-assessment and questionnaires were distributed to residents, visiting health and social care professionals and staff. Fifteen residents, five healthcare professionals and eight members of staff returned the questionnaires. Residents and families were also spoken to on the days of the unannounced visit. Discussions took place with the manager, nursing, care and ancillary staff. Care practice was observed. A tour of the premises and examination of some of the required records was also undertaken. The homes approach to equality and diversity was considered throughout. Care Homes for Older People Page 6 of 26 The last inspection was carried out on 1st December 2006. What the care home does well: What has improved since the last inspection? What they could do better: The Trustees and responsible individual must review the categories of registration of the home. The home is currently registered for twenty residents who require nursing care and ten who require personal (residential) care only. On the day of the unannounced visit it was felt that most residents required nursing care. The trustees must apply for a variation to their registration categories if they wish to take more than twenty residents who require nursing care, if they are to operate legally within the legal requirements of the Care Standards Act 2000. A recommendation to do this was made at the last inspection but has not yet been undertaken. Care Homes for Older People Page 8 of 26 If you want to know what action the person responsible for this care home is taking following this report, you can contact them using the details set out on page 4. The report of this inspection is available from our website www.csci.org.uk. You can get printed copies from enquiries@csci.gsi.gov.uk or by telephoning our order line –0870 240 7535. Care Homes for Older People Page 9 of 26 Details of our findings Contents Choice of home (standards 1 - 6) Health and personal care (standards 7 - 11) Daily life and social activities (standards 12 - 15) Complaints and protection (standards 16 - 18) Environment (standards 19 - 26) Staffing (standards 27 - 30) Management and administration (standards 31 - 38) Outstanding statutory requirements Requirements and recommendations from this inspection Care Homes for Older People Page 10 of 26 Choice of home These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People are confident that the care home can support them. This is because there is an accurate assessment of their needs that they, or people close to them, have been involved in. This tells the home all about them and the support they need. People who stay at the home only for intermediate care, have a clear assessment that includes a plan on what they hope for and want to achieve when they return home. People can decide whether the care home can meet their support and accommodation needs. This is because they, or people close to them, have been able to visit the home and have got full, clear, accurate and up to date information about the home. If they decide to stay in the home they know about their rights and responsibilities because there is an easy to understand contract or statement of terms and conditions between them and the care home that includes how much they will pay and what the home provides for the money. This is what people staying in this care home experience: Judgement: People using this service experience adequate quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. There is information available for prospective residents and their needs are assessed before they move to the home to ensure that they can be met. The trustees must review the homes categories of registration to ensure that home is operating legally. Evidence: The home has information available to prospective residents in the form of a statement of purpose, service users guide and coloured brochure. These are displayed in the front entrance of the home and are sent to prospective residents on request. The home is currently registered for twenty residents who require nursing care and ten residents who need personal (residential) care. The manager and the responsible individual felt that most residents now needed nursing care as some who had moved to the home when the care needs were less now required more care. They also stated in the annual quality assurance assessment that thirteen residents had dementia. They felt that some had developed this as they aged in the home. They also felt that they Care Homes for Older People Page 11 of 26 Evidence: could meet their needs and that none had challenging behaviour. The responsible individual must apply for a variation to the homes registration categories if they wish to take more than twenty residents who require nursing care, to ensure they are to be operating legally within the requirements of the Care Standards Act 2000 and Care Homes Regulations 2003. The manager said that she visits prospective residents before they move to the home to meet them and to assess their needs with them. The assessment documentation is comprehensive and had been completed in full. Respite care can also be offered if a room is available. All residents have contracts or statements of their terms and conditions, if they are supported by the local authority. The home does not offer intermediate care for those in need of rehabilitation. Care Homes for Older People Page 12 of 26 Health and personal care These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People’s health, personal and social care needs are met. The home has a plan of care that the person, or someone close to them, has been involved in making. If they take medicine, they manage it themselves if they can. If they cannot manage their medicine, the care home supports them with it, in a safe way. People’s right to privacy is respected and the support they get from staff is given in a way that maintains their dignity. If people are approaching the end of their life, the care home will respect their choices and help them feel comfortable and secure. They, and people close to them, are reassured that their death will be handled with sensitivity, dignity and respect, and take account of their spiritual and cultural wishes. This is what people staying in this care home experience: Judgement: People using this service experience excellent quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. Residents personal, health care and medication needs are met to a high standard. Evidence: The care of three residents was followed through. All had care plans, which had been updated regularly. Residents personal and healthcare needs were identified, risk assessments were undertaken and a plan to address these was documented. Residents had had a nutritional assessment, had been weighed regularly and those who had more that one weight recorded had maintained their weight since moving to the home. One resident whose care was followed through was shown to be at risk nutritionally. This had been recognised and she had been seen by the dietitian and her weight had been maintained. One had appeared to lose weight suddenly. This had also been recognised and she had been seen by the doctor, who adjusted her diuretics. Residents risk of developing pressure damage was assessed and documented. Two of the residents whose care was followed through were at risk and had the appropriate Care Homes for Older People Page 13 of 26 Evidence: pressure relieving mattress and chair cushion. Nobody had developed pressure damage in the home. There was evidence in the care plans that the general practitioner visits regularly. Five healthcare professionals returned the questionnaires and were complementary about the care offered at the home, saying a caring and attentive environment for residents and provides a comfortable home combined with skilled nursing care. There are medication policies and procedures in place. Storage facilities are satisfactory and were spotlessly clean. Records are kept of medication entering and leaving the home. There were no gaps on the medication administration records. The general practitioner signs the medication administration chart for new medicines although residents may bring in medication if they come for respite care. The nursing staff transcribe this medication to the medication administration charts. These transcriptions should be signed by two members of staff. The staff said that no one was self medicating at present, although there were policies and procedures in place to support this, if a resident wished. The staff were aware of what to do if a resident did not wish to take their medication and said that medication was never given covertly. Controlled drugs were stored in a satisfactory manner and all entries to the controlled register were signed. Controlled drugs are checked when they are given to residents and at each shift handover. There was evidence that medication can be obtained promptly if a residents medication is changed following a visit from the doctor. Residents were well groomed and their clothing was in a good state of repair. Staff were observed to be courteous and to respond to their wishes promptly. One health care professional said staff always help residents to dress well and add jewelry to finish an outfit off . The residents spoken to said that they did not have to wait long for a response to their call bell. Residents said that their care is given in their rooms and that they always see the doctor in their rooms. They appreciated being addressed by their full name and one said I am happy here, they have old fashioned values . Care Homes for Older People Page 14 of 26 Daily life and social activities These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: Each person is treated as an individual and the care home is responsive to his or her race, culture, religion, age, disability, gender and sexual orientation. They are part of their local community. The care home supports people to follow personal interests and activities. People are able to keep in touch with family, friends and representatives. They are as independent as they can be, lead their chosen lifestyle and have the opportunity to make the most of their abilities. People have nutritious and attractive meals and snacks, at a time and place to suit them. There are no additional outcomes. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. There is a programme of activities to bring interest and diversion to the day. Residents are encouraged to remain in contact with friends and family. Meals are good and meet residents nutritional and social needs. Evidence: The residents spoken to said that they had a choice as to how they spent their day. Those who returned the questionnaires said that the staff listened to them and acted upon what they said. There is an activities coordinator in post who offers a range of activities, including games, art/craft, bingo, quizzes, musical, discussion, board/parlour games and reminiscence. There are some outside trips and a garden party was held in the summer. An active Christmas programme of carol singing by local groups and other Christmas events is planned. A physiotherapist leads an armchair exercise. Church services are held regularly for those who wish to attend. There is also a bible study group with communion for those who wish to attend. There is a varied menu with more than one choice of dish at all meal times. Residents said that they enjoyed their meals and that the chef would prepare special dishes for them. The menus were varied and home cooked. Residents had a choice as to Care Homes for Older People Page 15 of 26 Evidence: whether they ate in the dining room or whether they ate in their rooms. The tables in the dining room were laid well and mealtimes were observed to be a sociable occasion. Those who needed help eating were being helped sensitively and unhurriedly, with staff sitting with them. Residents were complimentary about the food saying I am fussy about my food, they (the meals) are very good really and the food is very good, I have a choice. The home is very welcoming and residents said that their visitors were welcome at any time. They were always offered tea or coffee Care Homes for Older People Page 16 of 26 Complaints and protection These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: If people have concerns with their care, they or people close to them know how to complain. Any concern is looked into and action taken to put things right. The care home safeguards people from abuse and neglect and takes action to follow up any allegations. People’s legal rights are protected, including being able to vote in elections. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. There are complaints policies and procedures in place to address residents concerns and to protect them from potential harm. Residents feel that they are listened to and that their views are respected. Evidence: There are complaints policies and procedures in place. A complaints record is kept. All the residents who returned the questionnaires said that they knew who to speak to if they were unhappy. One resident said she had never had to make a formal complaint and that if she was unhappy with any aspect of the service it would usually be dealt with immediately, saying they are very good here and always listen to what I say The home has an up to date copy of the local multi agency strategy for safeguarding vulnerable adults. Most staff have had safeguarding training and those spoken to said that they would have no hesitation in reporting any concerns about residents welfare. There are whistle blowing policies and procedures in place. The Commission for Social Care Inspection has not received any complaints about the service since the last inspection and has not been told of any safeguarding concerns reported by the home to the local authority, which is the lead agency in these matters. Care Homes for Older People Page 17 of 26 Environment These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People stay in a safe and well-maintained home that is homely, clean, pleasant and hygienic. People stay in a home that has enough space and facilities for them to lead the life they choose and to meet their needs. The home makes sure they have the right specialist equipment that encourages and promotes their independence. Their room feels like their own, it is comfortable and they feel safe when they use it. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. The home is clean and well maintained and is a safe and accessible home for residents. Residents are encouraged to personalise their own rooms to make them more homely and to reflect their own tastes and memories. Evidence: The home comprises and Edwardian building with modern annex. The ambience is welcoming and communal areas are well decorated comfortable. There has been an ongoing programme of maintenance and a new shower room has been installed upstairs. The Environmental Health Officer visited in October 2008 and has recommended that the kitchens be improved and some cabinets and surfaces replaced. This is being addressed. The Fire and Safety officer inspected in September 2008 and made some recommendations which have been implemented. The number of night staff has been increased to four to enable evacuation of residents if necessary. All residents have their own room. They are encouraged to bring items of furniture and ornaments and pictures. Many had chosen to do so and their rooms were personalised and homely. There are infection control policies and procedures in place. The home was clean and tidy on the day of the unannounced visit. There were no offensive odours. Protective clothing and gloves are available for staff to help minimise the risk of cross infection. Care Homes for Older People Page 18 of 26 Evidence: Staff were observed to wash their hands frequently. Alcohol hand gel is available. The laundry was clean and well organised. The washing machines had suitable programmes to sluice soiled linen and to wash at high temperatures if necessary. Care Homes for Older People Page 19 of 26 Staffing These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People have safe and appropriate support as there are enough competent staff on duty at all times. They have confidence in the staff at the home because checks have been done to make sure that they are suitable to care for them. Their needs are met and they are cared for by staff who get the relevant training and support from their managers. There are no additional outcomes. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. There are sufficient staff, who have received relevant training, to meet residents needs in a timely way. The recruitment procedures are thorough and the required checks are undertaken to protect residents from unsuitable staff. Evidence: A staff rota is kept and showed that there are two qualified nurses and six care staff on duty in the morning, one qualified nurse and five care staff in the afternoon and evening and 1 qualified nurse and 3 care staff at night. The residents and families who returned the questionnaires said that their needs were met in a timely way. All residents, who were getting up, were up by mid morning on the day of the unannounced visit. The manager said that there were additional staff on duty at busy times of the day. She also said that she had a regular staff team and did not need to use many agency staff. In addition to the nursing and care staff employed to cover the 24 hour rota there are additional staff providing housekeeping, maintenance and catering support to residents. Residents were complementary about the staff team commenting that the carers are marvellous and they do their job well. There is a training programme available for staff. The manager said in the annual quality assurance assessment that seven of the seventeen care staff hold the National Vocational Qualifications in Care at Level 2 or above. The home does not yet meet the Care Homes for Older People Page 20 of 26 Evidence: standard that fifty percent of staff hold this qualification. The training matrix showed that most staff have had mandatory training in safe working practices and that staff undertake an induction programme on appointment to the home. Registered nurses have also undertaken refresher update courses in practical skills and the care of people with specific conditions for instance diabetes. The recruitment files of four recently recruited members of staff were reviewed. All had the required documentation to show that checks as to the potential staff members identity and suitability to work with vulnerable people had been undertaken. All had submitted an application from, which showed their work history. Interview records had been kept. Two references had been sought and Criminal Records Bureau checks had been undertaken before the staff member commenced work. Care Homes for Older People Page 21 of 26 Management and administration These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People have confidence in the care home because it is led and managed appropriately. People control their own money and choose how they spend it. If they or someone close to them cannot manage their money, it is managed by the care home in their best interests. The environment is safe for people and staff because appropriate health and safety practices are carried out. People get the right support from the care home because the manager runs it appropriately with an open approach that makes them feel valued and respected. The people staying at the home are safeguarded because it follows clear financial and accounting procedures, keeps records appropriately and ensures their staff understand the way things should be done. They get the right care because the staff are supervised and supported by their managers. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. The home is managed by an experienced manager and there are quality assurance systems in place to ensure that the care residents receive improves and that action is taken when deficits in care are noted. Residents and their familys views are taken into account in the running of the home. Evidence: The manager is an experienced registered nurse. The lines of accountability within the organisation are clear. The residents spoken to say that the management team were approachable and responsive to their needs. Families and staff spoke highly of the manager and said that she was approachable, worked alongside them and listened to their views. The home has a quality assurance system in place. Regular resident, family and staff meetings are held. The Manager and Secretary to the Trustees regularly audit processes in the home. The organisation also monitors the quality of care by means of Care Homes for Older People Page 22 of 26 Evidence: regular visits. Residents are spoken to and reports of these visits, with action points are kept. The home does not manage residents financial affairs although residents may keep a small amount of personal allowance in the home safe for safe keeping. Receipts are given and the amounts are checked regularly by the Secretary to the Trustees. There are health and safety policies and procedures in place. The information sent prior to the visit showed that service and maintenance records are up to date. Most staff have had moving and handling training, health and safety, food hygiene, infection control and fire safety training. Fire safety records are kept and were up to date. The staff spoken to were aware of the fire evacuation procedures. Risk assessments for safe working practices have also been undertaken. Records are kept of safety checks of hot water temperatures, particularly baths and showers. Care Homes for Older People Page 23 of 26 Are there any outstanding requirements from the last inspection? Yes £ No R Outstanding statutory requirements These are requirements that were set at the previous inspection, but have still not been met. They say what the registered person had to do to meet the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards No. Standard Regulation Requirement Timescale for action Care Homes for Older People Page 24 of 26 Requirements and recommendations from this inspection: Immediate requirements: These are immediate requirements that were set on the day we visited this care home. The registered person had to meet these within 48 hours. No. Standard Regulation Requirement Timescale for action 1 1 4 The responsible individual 27/02/2009 must review the homes categories of registration and apply for a variation if they wish to take more than twenty residents who require nursing care. To ensure that they are operating legally within the requirements of the Care Standards Act 2000 and the Care Homes Regulations 2003. Statutory requirements These requirements set out what the registered person must do to meet the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The registered person(s) must do this within the timescales we have set. No. Standard Regulation Requirement Timescale for action Recommendations These recommendations are taken from the best practice described in the National Minimum Standards and the registered person(s) should consider them as a way of improving their service. No. Refer to Standard Good Practice Recommendations Care Homes for Older People Page 25 of 26 Helpline: 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 We want people to be able to access this information. If you would like a summary in a different format or language please contact our helpline or go to our website. Copyright © (2008) Commission for Social Care Inspection (CSCI). This publication may be reproduced in whole or in part, free of charge, in any format or medium provided that it is not used for commercial gain. This consent is subject to the material being reproduced accurately and on proviso that it is not used in a derogatory manner or misleading context. The material should be acknowledged as CSCI copyright, with the title and date of publication of the document specified. Care Homes for Older People Page 26 of 26 - 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. 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