Inspection on 28/06/05 for Kent House

This inspection was carried out on 28th June 2005.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Poor. 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 but made no statutory requirements on the home.

Other inspections for this house

Kent House 31/03/08

Kent House 19/06/07

Kent House 18/12/06

Kent House 11/05/06

Kent House 27/11/05

Kent House 10/04/05

Kent House 02/12/04

Kent House 22/06/04

Kent House 22/02/04

Similar services:

Fairfields Country Rest Home

Poldhu

Queensmount

Trevaylor Manor

Didsbury Court Rest Home

Belma

Hunters Care Centre

Manor Lodge

Extracts from inspection reports are licensed from CQC, this page was updated on 09/07/2008.

CARE HOMES FOR OLDER PEOPLE Kent House George Street Okehampton Devon EX20 1HR Lead Inspector Helen Tworkowski Announced 28 and 29 June 2005 th th 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 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 Older People. 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. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 3 SERVICE INFORMATION Name of service Kent House Address Greorge Street, Okehampton, Devon. EX20 1HR Telephone number Fax number Email address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) 01837 52568 01837 52580 Stonehaven (Healthcare) Ltd Vacant Care Home 25 Category(ies) of Dementia - over 65 years of age (25), Old age, registration, with number not falling within any other category (25), of places Physical disability over 65 years of age (25) Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 10/4/05 Brief Description of the Service: Kent House is a large detached Victorian House located in the centre of Okehampton. The Home is registered for 25 older people who may have dementia, or a physical disability. There are 21 single bedrooms, nine with en suite facilities, and two double bedrooms. There is a shaft lift, although there are steps to 9 of the 21 bedrooms. These rooms are only suitable for service users who are able to negotiate steps. On the ground floor there are three lounges, a dining room, kitchen, two toilets, adapted bathroom, and 5 bedrooms. On the first floor there are 13 bedrooms and 2 bathrooms. On the second floor there are 5 bedrooms and 2 bathrooms. The Home has a front garden with seating and a small patio at the side of the home. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This Announced Inspection took place on the 28th and 29th June 05, between 9am and 5pm. The homes representative was Ms Sallyann Roach, Acting Manager. The inspection included a tour of the building, inspection of records, discussions with staff, service users and visitors. What the service does well: What has improved since the last inspection? What they could do better: The ongoing Service User needs assessment and Service User Plans need to be improved so that they accurately reflect the needs of people being cared for. The lack of assessments and up to date Service User Plans, and the fact that they are not read by staff means that care staff have to make their own judgement about what is needed. Needs may be missed or met in different ways. This is of serious concern, particularly where Service Users may not be able to explain what their needs are because of illness or dementia. The lack of accurate assessments also means that individual risk assessments are likely to be inaccurate, potentially placing Service Users at risk. The food provided in the home remains of concern and Service Users had mixed views about it. Fresh fruit and fruit juice are now provided. The home continues to provide only reconstituted skimmed dried milk for all requirements including in tea and on breakfast cereals. The food provided does not reflect dietary needs or provide sufficient choice. For example service users who are underweight are given reduced fat yoghurts and skimmed milk. The registered person has been required to offer a variety of wholesome food and Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 6 drink. This must take into account people’s individual preferences and choices, dietary and care needs. Staffing levels remain low and of concern. Staff do not receive thorough induction training that will allow them to function as part of the team providing competent care. Records of training in the home indicate that there are significant gaps- including in relation to falls and protection from abuse. Enforcement Notices: Four enforcement notices were service following the last inspection and a follow up visit was made to the home on 19 May 05. The notices were in relation to: 1. Fire Training and wedging doors. This notice has now been complied with. 2. Assessments: Concerns remain regarding the ongoing assessments of Service Users who’s needs change. 3. Induction Training: Concerns remain regarding the level of induction training provided to new staff. 4. Service User Plans: this is to be reviewed in August 05. 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. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 7 DETAILS OF INSPECTOR 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) Scoring of Standards Statutory Requirements Identified During the Inspection Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 8 Choice of Home The intended outcomes for Standards 1 – 6 are: 1. 2. 3. 4. 5. 6. Prospective service users have the information they need to make an informed choice about where to live. Each service user has a written contract/ statement of terms and conditions with the home. No service user moves into the home without having had his/her needs assessed and been assured that these will be met. Service users and their representatives know that the home they enter will meet their needs. Prospective service users and their relatives and friends have an opportunity to visit and assess the quality, facilities and suitability of the home. Service users assessed and referred solely for intermediate care are helped to maximise their independence and return home. The Commission considers Standards 3 and 6 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 1 and 3 The current system for assessing new service users is appropriate in identifying the needs of more independent Service Users. However concerns remain that service users with more complex needs may not be properly assessed. EVIDENCE: The Responsible Individual has developed a Statement of Purpose and Service Users Guide, documents which should provide people thinking about moving to the home, with information. These documents are in the process of being reviewed and amended. People who have recently stayed at the home have been assessed, so that their needs were known. These people had moved for a “short stay”, and were relatively independent, and this was reflected in the assessment. No one has moved to the home, permanently, in recent months. However the pre-admission assessment for an individual, with more complex needs, who had moved to the home earlier in the year was missing. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 9 Health and Personal Care The intended outcomes for Standards 7 – 11 are: 7. 8. 9. 10. 11. The service user’s health, personal and social care needs are set out in an individual plan of care. Service users’ health care needs are fully met. Service users, where appropriate, are responsible for their own medication, and are protected by the home’s policies and procedures for dealing with medicines. Service users feel they are treated with respect and their right to privacy is upheld. Service users are assured that at the time of their death, staff will treat them and their family with care, sensitivity and respect. The Commission considers Standards 7, 8, 9 and 10 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 7,8,9, and 10. Service User needs are not reassessed and personal and health care needs are not fully met. Service Users generally felt that they were treated with respect, however at times privacy was not respected, There is a safe system for the management of medication of medication, which benefit service users well-being. EVIDENCE: Each Service User had a Service User Plan, this document should detail, based on an assessment, how needs are met by staff. From discussions with staff it was clear that critical information was being omitted. Where Service Users needs had changed because of ill health, there was no record of a reassessment, or of how these needs would be met. Some needs were omitted from written records altogether. Discussions with staff indicated that they had discussed Service User needs and how they would be met, but did not read any Service User Plans. The day care staff did not know night care needs, as these were verbally handed over between night staff. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 10 There are risk assessments however these do not reflect all risks as the assessments are incomplete. Risk Assessments should help care staff to manage and reduce risk. A “bubble- pack” medication system is used, there were accurate records of administration, and a safe system for administering medication was used. Service users said that they were treated with respect and kindness, and staff were observed to knock on doors. However one person said that not every one knocked before entering. During the Inspection the visiting chiropodist saw Service Users in one of the lounges, rather than in private. Service Users should be provided with health care in private. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 11 Daily Life and Social Activities The intended outcomes for Standards 12 - 15 are: 12. 13. 14. 15. Service users find the lifestyle experienced in the home matches their expectations and preferences, and satisfies their social, cultural, religious and recreational interests and needs. Service users maintain contact with family/ friends/ representatives and the local community as they wish. Service users are helped to exercise choice and control over their lives. Service users receive a wholesome appealing balanced diet in pleasing surroundings at times convenient to them. The Commission considers all of the above key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 12,13, and 15 Activities are provided and some Service Users enjoyed taking part in them. However these need to better reflect the interests of service users, including people with dementia. Improvements have been made in the choice of food at Kent House, however the meals still do not reflect the dietary needs of Service Users. Service Users had mixed views about the food. EVIDENCE: Service User Plans include some information about interests and hobbies. There is a plan of activities for the week that includes bingo, skittles, colouring, exercises and singing. However these activities do not always happen, being dependant on the in put of one member of care staff. These activities are organised with great enthusiasm, however they need to better reflect the needs and interests of Service Users, and to include people with dementia. The televisions were often on and not watched, Service Users confirmed that they would rather not have the TV on when no one was watching it, particularly when there were children’s programmes on. Throughout two days of inspection Service Users visitors were coming and going, and confirmed that they were made welcome. There are some references to diets in the Service User Plans, and improvements have been made in relation to the food provided including providing fresh fruit. Some choice and variety has also been provided by the Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 12 provision of a choice of jams and tinned soups. However dietary needs are not always reflected in the food provided. People who need to gain weight were being given low fat-products. The only milk provided is reconstituted dried skimmed milk. Service User views on the food were mixed: some thought the food was very good, others that it was not. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 13 Complaints and Protection The intended outcomes for Standards 16 - 18 are: 16. 17. 18. Service users and their relatives and friends are confident that their complaints will be listened to, taken seriously and acted upon. Service users’ legal rights are protected. Service users are protected from abuse. The Commission considers Standards 16 and 18 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 16 and 18 Protection of service users is not assured. EVIDENCE: The complaints procedure is available for use by Service Users and visitors to the home; no complaints have been made in the last 12 months. Some of the staff have received training in relation to adult protection, however it was not clear from the certificate who had provided the training. This training did not include all senior staff in the home. Staff induction is minimal. Induction is part of the process where staff learn what their responsibilities are and is part of the process of protecting Service Users. The Registered person has not reported incidents of concern to the Commission, as is required by regulation. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 14 Environment The intended outcomes for Standards 19 – 26 are: 19. 20. 21. 22. 23. 24. 25. 26. Service users live in a safe, well-maintained environment. Service users have access to safe and comfortable indoor and outdoor communal facilities. Service users have sufficient and suitable lavatories and washing facilities. Service users have the specialist equipment they require to maximise their independence. Service users’ own rooms suit their needs. Service users live in safe, comfortable bedrooms with their own possessions around them. Service users live in safe, comfortable surroundings. The home is clean, pleasant and hygienic. The Commission considers Standards 19 and 26 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 19, 22, and 26. Kent House is a comfortable and reasonably decorated care home, however not all the checks and systems, to ensure service users safety and privacy, are in place. EVIDENCE: Kent House is reasonably well decorated, clean, tidy and comfortable. All of the rooms were seen as part of a tour of building, some of the Service Users had chosen to bring items of their own furniture and to individualise their own rooms. Garden furniture has recently been purchased so that Service Users can better use the garden. The home has a “nurse-call” system that Service Users can use to call for assistance. However this system has additional features, which potentially allows staff to listen in, in what is happening in bedrooms without the consent of a Service Users. This system must be adjusted so that Service Users privacy is assured. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 15 “Door guards” have been purchased by Stonehaven (Healthcare Ltd) so that Service Users can choose to have their bedroom doors open, this is particularly important for people on the second floor (under the roof) in hot weather. Not all of the bedrooms have doors that can lock and provide service users with additional privacy if they wish. The Registered Provider must provide appropriate bedroom door locks for all service users, unless the home can show that this would not be appropriate for that individual, a record of this must be kept. Staff are provided with disposable gloves to use to avoid spreading infections however these gloves were not being used appropriately at the time of the inspection. There are concerns regarding safety in the home and these have been identified later in the report. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 16 Staffing The intended outcomes for Standards 27 – 30 are: 27. 28. 29. 30. Service users needs are met by the numbers and skill mix of staff. Service users are in safe hands at all times. Service users are supported and protected by the home’s recruitment policy and practices. Staff are trained and competent to do their jobs. The Commission considers Standards 27, 29, and 30 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 27, 29 and 30 Staffing levels are insufficient given that not all care staff were appropriately inducted. Staff are not fully trained in a number of aspects of the work, potentially placing Service User at risk. EVIDENCE: The level of staff is lower at weekends than during the week, staff said that there were sufficient staff, if they were able competent and prepared to get on with the work. On a weekend at the end of June a new member of staff was included as part of the staffing. The individual had recently arrived in Britain and had one night of induction. It is likely that after such a short period they would have difficulty in contributing fully to the care work, particularly where the other staff might not be able to provide appropriate training and support because they are busy caring for Service Users. The most recent member of staff had been employed through an agency who had carried out relevant checks. The Registered Person is also required to complete a Criminal Records Bureau check, there was no record in the home that this had been initiated. The home must also ensure that until the check has been completed that the person is under the supervision of a named person. There was no awareness of this amongst senior staff. The home has set up a system for inducting new staff, and this had been used for the most recent member of staff. All areas of the induction had been completed during a waking night. An induction is a process that should provide a planned introduction to the home and the service users. It would not be Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 17 possible to provide or receive this over on night. Staff must be provided with appropriate inductions to the work that they are to do. Staff files showed that some training had been received in relation to adult protection, food hygiene and moving and handling. However it was not possible to tell if the person carrying out the training was competent to do so. There was no training in falls prevention- although 14 Service Users had fallen since the beginning of May 05. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 18 Management and Administration The intended outcomes for Standards 31 – 38 are: 31. 32. 33. 34. 35. 36. 37. 38. Service users live in a home which is run and managed by a person who is fit to be in charge, of good character and able to discharge his or her responsibilities fully. Service users benefit from the ethos, leadership and management approach of the home. The home is run in the best interests of service users. Service users are safeguarded by the accounting and financial procedures of the home. Service users’ financial interests are safeguarded. Staff are appropriately supervised. 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 and staff are promoted and protected. The Commission considers Standards 33, 35 and 38 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 31, 32, 33, 34, 38 There is no proper process of management resulting in inconsistent care and unsafe working practices and systems. EVIDENCE: There is no registered manager at Kent House, however the Commission has received and is processing an application. An acting manager, who is supervised by the Responsible Individual (Mrs Dawn Stone), currently manages Kent House. The acting manager had not been provided with a copy of the most recent inspection report until shortly before this inspection, and so was unaware of the contents. Many of the requirements made at pervious inspections remain outstanding. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 19 There is a quality assurance system, however the Commission has not received a copy of any review of the quality of care in the home that has been conducted in the home. A Statutory Requirement notice had been issued that required the Registered Person to ensure that no fire doors are wedged open, this has happened. The Registered Provider was also required to establish a policy and plan that will ensure that all staff receive fire instruction in accordance with the frequencies specified, and that all newly employed staff receive fire instruction in accordance with the frequencies specified in the policy and plan. All staff, including new staff, had received training as specified in guidance provided by Devon Fire and Rescue, and a plan had been drawn up indicating when future training and checks would take place. No Fire Risk Assessment has been completed; this is an essential part of ensuring service users are kept safe. There is no Legionella risk assessment and no checks on the temperature of bathwater have been completed to avoid incidents of scalding. No thermometer could be found in the home. The accident book is completed, however there is no system for monitoring accidents and for looking at how they can be avoided. This is of particular importance in relation to falls by Service Users. The acting manager holds money on behalf of Service Users, There are records of transactions, however no one signs to take responsibility for withdrawing or depositing money, this must be remedied. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 20 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Older People 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 ENVIRONMENT Standard No 1 2 3 4 5 6 Score Standard No 19 20 21 22 23 24 25 26 Score 2 x 3 x x x HEALTH AND PERSONAL CARE Standard No Score 7 1 8 1 9 3 10 1 11 x DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 2 13 3 14 x 15 1 COMPLAINTS AND PROTECTION 1 x x 1 x x x 2 STAFFING Standard No Score 27 2 28 x 29 1 30 1 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score Standard No 16 17 18 Score 3 x 1 1 1 2 1 2 x x 1 Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 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 OP1 Regulation 5 Requirement The Statement of Purpose and Service User Guide must be revised so that it reflects both regulations and national minimum standards. (This requirement was made at the last three inspections). Service Users must be assessed prior to addmission and reassessed when needs change. The registered person must ensure that all Service Users have up to date and comprehensive assessment of needs which is drawn up with each Service User (or their representative) and provides the basis for the care to be delivered. Service Users Plans must set out in detail the actions which needs to be taken by care staff to ensure that all aspects of the health, personal and social care needs of the Service User are met. Service User must be reviewed every month, or sooner if necessary, and updated to reflect changing needs. All significant individual risks must be assessed and appropriate actions taken to D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Timescale for action 1 August 05 2. 3. OP7 OP7, OP8 14 15 1 August 05 22 August 05 4. OP7 13 1 August 05 Page 22 Kent House Version 1.40 minimise risks. 5. 6. OP8 OP15, OP8 12 16 All health care needs, including chiropody should be given in private. Service Users must receive a varied, appealing, wholesome and nutritious diet, which is suited to the individual, assessed and recorded requirements. This or similar requirements have been made at every inspection for over three years. Service Users must be given regular opportunities for stimulation through leisure and recreational activiites suited to their needs, preferences and capacites. These should be clearly traced from the assessment to the service users plan. (This requirement was made at previous insepctions and has not been met). The registered manager and senior staff attend the multiagency adult protection training. This requirement was made at previous inspections. All new staff must receive induction training that ensures that staff are able to fulfil the aims of the home and meet the changing needs of service users. The care home environment must be risk assessed and checks to maintain safety carried out. These risk assessment must include: Legionnella, fire, scalds from hot water. The nurse call system must not allow for anyone to listen on service users, unless specific agreement has been gained under specific circumstances. Control of infection practices in the home must be reviewed, this must include the inappropriate 1 August 05 1 August 05 7. OP12 16 1 September 05 8. OP18 23 1 September 05 1 August 05 9. OP18, OP30 18 10. OP19, OP38 13, 23 1 September 05 11. OP22 12 1 September 05 1 September 05 Page 23 12. OP26 13 Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 use of disposable glove. 13. 14. OP27 OP29 18 19 Staffing levels must be reviewed and to take account of staff experience and competence. The registered provider must ensure that there is evidence that Criminal Records Bureau checks have initiated for all new staff, and that such staff have an named supervisor to oversee their work. (Similar requirements have been made at previous inspections). All financial transactions involving Service Users money must be appropriately signed for. Staff training records must contain information regarding the competence of the trainer to provide that training. Kent House must be properly managed to ensure the safety and well being of Service Users. The registered manager and senior staff must attend the mult-agency training in relation to the protection of vulnerable adults. This requirement was made at the inspections on 2/12/05, 2/4/05 and 10/4/05. The registered person must ensure that all incidents detailed in regulation 37 are reported to CSCI. The registered person must ensure that there is a proper system for the monitoring and prevention of accidents, including falls. 1 September 05 1 August 05 15. 16. OP34 OP30 17 18 1 August 05 1 August O5 1 August 05 1 October 05 17. 18. OP31, OP32 OP32 12 13 19. OP32 37 28 June 05 20. OP38, OP7 13 1 August 05 21. Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 24 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 Good Practice Recommendations Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 25 Commission for Social Care Inspection Unit D1 Linhay Business Park Ashburton TQ13 7UP 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 Kent House D54-D07 S32744 Kent House V223496 280605 Stage 4.doc Version 1.40 Page 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. 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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