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Inspection on 27/09/05 for Lennox Lodge

Also see our care home review for Lennox Lodge for more information

This inspection was carried out on 27th September 2005.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Adequate. 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.

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

All of the residents spoken with spoke positively of the care that they receive at the home. Comments included: `I`m cared for very well here` and `I wouldn`t wish to live anywhere else`. The staff team have a good understanding of when to contact specialist services as necessary such as the Community Mental Health Team and there is clear evidence of multidisciplinary working. One of the CPN`s spoken with said that the staff team are `approachable`. Residents are offered a varied and nutritious diet and the home has good systems in place to ensure that all complaints are dealt with appropriately.

What has improved since the last inspection?

Since the last inspection the home has updated it`s Statement of Purpose and Service Users` Guide to incorporate residents` and relatives views, details of the CSCI and the home`s complaints procedure. Some minor repairs have been carried out such as the replacement of some lampshades and the retiling of one bathroom. After some considerable time, staff have received training in working with people with mental health needs and more recently manual handling training and risk assessment.

What the care home could do better:

This inspection highlighted some serious concerns and resulted in four immediate requirements being made. Very few of the previous requirements made have been achieved. The Inspector is especially concerned to note that the home has repeatedly failed to meet the required National Minimum Standards in respect of the administration of prescribed medication (despite receiving advice from a Pharmacy inspector), maintaining an adequate level of staff and ensuring that staff are only employed following satisfactory Criminal Record Bureau Checks being obtained and in ensuring that all hazardous substances are stored securely. The Commission for Social Care Inspection will be meeting with the owner to express their concerns and to ensure that appropriate action is taken within an agreed timescale to address these issues. Due to the number of serious concerns that were raised during this inspection not all of the requirements from the previous report and outstanding National Minimum Standards for Older People were assessed on this occasion. They will be prioritised and inspected at the next inspection.

CARE HOMES FOR OLDER PEOPLE Lennox Lodge 37 The Highlands Bexhill-on-sea East Sussex TN39 5HL Lead Inspector Niki Palmer Unannounced Inspection 27th September 2005 10:30 X10015.doc Version 1.40 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 Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 2 This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for 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. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 3 SERVICE INFORMATION Name of service Lennox Lodge Address 37 The Highlands Bexhill-on-sea East Sussex TN39 5HL 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) 01424 222966 Mr Guy Haddow Vacant Care Home 19 Category(ies) of Mental disorder, excluding learning disability or registration, with number dementia (19) of places Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 4 SERVICE INFORMATION Conditions of registration: 1. 2. 3. 4. 5. The maximum number of residents to be accommodated is nineteen (19). Residents must be aged over fifty five (55) years on admission. Residents with a past or present mental disorder only to be accommodated. The home provides placement for one named resident with a learning disability. The home provides placement for one named resident with a dementia type illness. 8th April 2005 Date of last inspection Brief Description of the Service: Lennox Lodge is a care home registered to provide accommodation for up to 19 residents aged 55 or over or admission who have a mental disorder. The home is a large detached property situated in a quiet residential area of The Highlands, approximately three and a half miles north of Bexhill on Sea. Accommodation is provided over three floors with level access only to the front of the building. The home consists of 11 single bedrooms, five of which have en-suite facilities and four double rooms. A planning application has been submitted to the Council in order to create two additional bedrooms on the first floor and four additional bedrooms to the top floor. The village Sidley is approximately half a mile away, which can be accessed via the local bus service. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The reader should be aware that the Care Standards Act 2000 and Care Homes Regulation Act 2001, uses the term ‘service user’ to describe those living in care home settings. For the purpose of this report, those living at Lennox Lodge will be referred to as ‘residents’. This unannounced inspection took place between on a Tuesday between 10.30am and 4pm. The inspection began having discussions with the Deputy Manager of the home in the absence of the Acting Manager in respect of progress made since the last inspection, followed by the examination of three care plans, the home’s recruitment procedures, medication practices and a variety of administration systems. The Registered Provider facilitated the latter part of the inspection. In order to gather evidence on how the home is performing, individual discussions took place with three residents, whilst others commented on their care during lunchtime, the Inspector having been invited to join them for a meal. In addition two care staff and two visiting Community Psychiatric Nurses (CPN’s) were spoken with during the inspection. Eighteen residents were accommodated at the time of the inspection. What the service does well: What has improved since the last inspection? Since the last inspection the home has updated it’s Statement of Purpose and Service Users’ Guide to incorporate residents’ and relatives views, details of the CSCI and the home’s complaints procedure. Some minor repairs have been carried out such as the replacement of some lampshades and the retiling of one bathroom. After some considerable time, staff have received training in Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 6 working with people with mental health needs and more recently manual handling training and risk assessment. 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. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 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 Outcomes Statutory Requirements Identified During the Inspection Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 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 the following standard(s): 1 and 3. Residents are provided with sufficient information to help them judge if the home is appropriate for them. The pre-admission assessment process needs to be developed to ensure that the home can meet assessed needs. EVIDENCE: Since the last inspection the home has updated it’s Statement of Purpose and Service Users’ Guide, which are kept on display in the entrance area of the home. Both were found to be very detailed and contain specific information in relation to the home’s aims, staffing levels, details of the services that are provided, the home’s complaints procedure and residents’ and relatives’ views of the home. Although copies of previous inspection reports are kept within the home, the most recent was not included within the Service Users’ Guide and therefore not accessible to residents or visitors. A requirement has been made in respect of this. Two pre-admission assessment forms were viewed during the inspection. Both had been completed by the acting manager, however it was not clear from the documentation who was present at the time of the assessment, where the Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 9 assessment took place and in one instance the date of the assessment. It was particularly concerning to note that minimal details had been recorded regarding individuals’ mental health details (past or present) as required in the previous inspection report. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 10 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 the following standard(s): 8, 9 and 10. Residents’ healthcare needs are met well by the home, however the systems in place for the administration of medication remain poor and potentially place residents at risk. EVIDENCE: All residents are registered with a local General Practitioner shortly after admission and there was clear evidence that specialist advice and support is sought from the home on an individual basis from the local Community Mental Health Team. One of the visiting CPN’s spoke very positively of the way in which the care staff collected and provided information to them in relation to one resident at the time of referral. Some details of healthcare appointments were recorded in two of the care plans inspected, however it was concerning to note that there were no details recorded of a recent GP appointment, which led to a referral being made to the local hospital for a scan of the brain. In addition, one of the residents has recently been seen by a District Nurse with regard to maintaining continence, however the care plan had not been updated to provide details to staff of the action that is to be taken to support the individual. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 11 Following concerns raised in the previous inspection report regarding the home’s medication practices, a Pharmacy Inspector visited the home in June 2005. A number of requirements were made in relation to the home’s medication administration records (MAR), a dosage error and the home’s lack of written policies regarding homely remedies and record keeping. Since this time new policies have been implemented and a suitable cupboard purchased for the storage of controlled drugs. However it was particularly concerning to note that a number of gaps were evident on the MAR sheets where either a signature or a reason for non-administration should appear. In addition, one of the residents who chooses to lie in, in the mornings, is sometimes not offered her medication when she gets up, and therefore misses some doses. These concerns were raised directly with the Registered Provider and an Immediate Requirement issued. Residents confirmed that staff respect their right to privacy and dignity. It was noted on the day of inspection that all residents are addressed by their preferred term, staff knock on bedroom doors before entering and that screening is provided in shared rooms. The visiting Community Nurses also stated that a private room is always available for them to meet with residents on a one to one basis. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 12 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 the following standard(s): 13 and 15. All residents are supported to maintain contact with family and friends. A varied, wholesome and nutritious diet is provided by the home. EVIDENCE: The arrangements in place for maintaining contact with friends and relatives are detailed within the home’s Statement of Purpose and Service Users’ Guide. All of the residents spoken with said that they are able to receive visitors at anytime. Staff and the two visiting CPN’s also confirmed this. A cook is employed on a full-time basis to prepare breakfast and the lunchtime meal. The menus are rotated on a four weekly basis and changed seasonally. Residents said that a variety of cereals, porridge, toast and eggs are offered at breakfast and that they are able to choose an alternative lunch should they wish to do so. All of the residents are encouraged to dine in the dining area. The tables were well presented with tablecloths and serviettes. A vegetarian option was eaten on the day of inspection, followed by a hot pudding. Both were found to be well presented, hot and flavoursome. Low sugar diets are also catered for. It was noted that the menu was not on display anywhere in the home for residents to see, however the majority of residents spoken with said that they preferred the ‘element of surprise’. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 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 the following standard(s): 16. This home has adequate systems in place to ensure that complaints are dealt with appropriately. EVIDENCE: The home has a clear complaints procedure in place, which is included within the home’s Statement of Purpose. It has been amended to include details of how the CSCI can be contacted in the event of any concerns raised in respect of the home, however this has yet to be copied in to the complaints folder. Residents spoken with said that in the first instance they would raise their concerns with the acting manager of the home. A record of all complaints is stored within the home. No complaints have been received by either the home or the CSCI since the last inspection. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 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 the following standard(s): 19 and 25. Further maintenance work is needed for the home to present throughout as an attractive and comfortable place to live. EVIDENCE: It was pleasing to note that since the last inspection the ground floor bathroom has been retiled and lampshades in some areas of the home have been replaced. All communal toilets are now in use, however walls within the home are in need redecoration as wallpaper is noticeably peeling. Although the boiler and pipe work on the top floor has been covered, on the day of inspection it was not secure. This was addressed with the Registered Provider. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 15 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 consider all the above are key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 27, 28, 29 and 30. Extremely poor judgements are being made regarding the manner in which staff are deployed to work in the home. These continue to place residents at a high level of risk. EVIDENCE: Since the last inspection the home has continued to experience difficulties in recruiting sufficient numbers of staff to meet the assessed needs of the residents accommodated. Care staff are still continuing to carry out cleaning duties within the home, which one staff member said was ‘frustrating’. Eleven care staff are currently employed to work at the home, none of which are trained to NVQ level 2 in care. Staffing rotas were examined, which raised some serious concerns. One member of staff deployed to work in the home worked a total of 84 hours the previous week and was rostered to work 72 hours the following week. These hours comprised of working late duties followed by a night shift and night shifts followed by an early shift. An immediate requirement was issued on the day of inspection. In addition to the above, it was very concerning to note that two of the care staff employed to work the night prior to the inspection were found to be asleep at 05:00am. This was discussed in detail with the Registered Provider who is required to take immediate action. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 16 Serious concerns were raised in the previous inspection report regarding the home’s practices for recruiting new staff. On the day of the inspection it was of major concern to find that one newly appointed member of staff had been employed by the home without any proof of identification, written references, a thorough knowledge of their previous employment history, Criminal Record Bureau Check or POVA First. Indeed there was no evidence to show that these had been applied for. In addition, a self-employed hairdresser who visits the home regularly was not in possession of a CRB or POVA First Check. An immediate requirement was issued. Since the last inspection many of the staff team have received specific training relating to working with people who have mental health needs. Staff spoken with said that they found this to be ‘useful’ and ‘worthwhile’. In addition another study day is booked for October 2005 with regards to working with people with learning disabilities and epilepsy. This is acknowledged by the CSCI as good working practice for the one resident accommodated. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 17 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 31, 33, 35 and 38 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 31 and 38. Albeit that residents express satisfaction with the quality of their lives at Lennox Lodge, there is little evidence that their interests are safeguarded in respect of the management of the administration of medication, the recruitment of staff, and in the absence of a Registered Manager. EVIDENCE: Lennox Lodge has been without a Registered Manager in post for over one year. Despite this being raised in previous inspection reports and more recently in writing to the Registered Provider no application has been received by the CSCI. This was discussed in detail on the day of inspection. It was pleasing to note that on the day of the inspection no doors were found to be wedged open, however it was of particular concern to find two hair treatment chemicals stored in one of the bathrooms, one of which had been prescribed for a resident no longer living at the home. The storage of Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 18 potentially hazardous chemicals was raised as an immediate cause for concern at the previous inspection. A sample of the home’s health and safety records were examined. All fire extinguishers had recently been checked and certified and evidence was seen to confirm that regular fire drills are carried out, however it was noted that fire alarms and emergency lighting testing is overdue. A requirement was made in respect of this. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 19 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 Standard No Score 1 2 3 4 5 6 ENVIRONMENT Standard No Score 19 20 21 22 23 24 25 26 2 X 1 X X N/A HEALTH AND PERSONAL CARE Standard No Score 7 X 8 2 9 1 10 3 11 X DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 X 13 3 14 X 15 3 COMPLAINTS AND PROTECTION Standard No Score 16 3 17 X 18 X 2 X X X X X 2 X STAFFING Standard No Score 27 1 28 1 29 1 30 3 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score 2 X X X X X X 1 Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 20 Are there any outstanding requirements from the last inspection? Yes 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(1)(d) Requirement It is required that a copy of the home’s most recent inspection report is included within the Service Users’ Guide. It is required that residents are only admitted to the home following a detailed preadmission assessment of their past and present mental health needs [OUTSTANDING FROM PREVIOUS INSPECTION]. It is required that appropriate consultation takes place with prospective residents and/or their representatives during the pre-admission assessment process. The date, place and those present at the time of the assessment must be recorded. It is required that all specialist advice and input for residents is recorded within their plans of care. Care plans must be updated as necessary. It is required that MAR sheets must contain a signature or a reason for non-administration [OUTSTANDING FROM PREVIOUS INSPECTION – DS0000021407.V253283.R01.S.doc Timescale for action 27/10/05 2. OP3 14(1)(a) 27/09/05 3. OP3 14(1)(c) 27/09/05 4. OP8 15(1)(2) (a-d) 27/09/05 5. OP9 13(2) 27/09/05 Lennox Lodge Version 5.0 Page 21 6. OP9 13(2) 7. OP19 23(2)(d) 8. OP25 13(4)(a) (c) 18(1)(a) 9. OP27 10. OP29 19 & Schedule 2 11. OP31 9(2) 12. OP38 13(4)(a) (c) 13. OP38 23(4) IMMEDIATE REQUIREMENT]. It is required that advice is sought from the GP regarding the latest time a morning dose of medication can be given for the one individual who chooses to lie in bed. This must be recorded. It is required that wallpaper is replaced in certain areas of the home [OUTSTANDING FROM PREVIOUS INSPECTION]. It is required that the boiler on the top floor is covered securely [OUTSTANDING FROM THREE PREVIOUS INSPECTIONS]. It is required that urgent and appropriate action is taken to ensure that residents’ welfare and safety is not compromised by staff working additional hours [IMMEDIATE REQUIREMENT]. It is required that no person is employed to work at the home prior to thorough recruitment checks being carried out [OUTSTANDING FROM TWO PREVIOUS INSPECTIONS – IMMEDIATE REQUIREMENT]. It is required that an application is submitted to the CSCI for a Registered Manager [OUTSTANDING FROM TWO PREVIOUS INSPECTIONS]. It is required that all hazardous materials are stored in a locked cupboard [OUTSTANDING FROM PREVIOUS INSPECTION – IMMEDIATE REQUIREMENT]. It is required that adequate arrangements are made to have the overdue tests carried out for fire alarms and emergency lighting. 11/10/05 27/11/05 27/10/05 27/09/05 27/09/05 27/09/05 27/09/05 11/10/05 Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 22 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. 2. 3. 4. Refer to Standard OP9 OP15 OP16 OP28 Good Practice Recommendations It is recommended that a more recent medicines book be obtained [OUTSTANDING FROM 29th June 2005]. It is recommended that residents be consulted regarding the display of weekly menus. It is recommended that the amended complaints procedure be copied in to the complaints folder. It is recommended that at least 50 of care staff are trained to NVQ Level 2 in care by December 2005. Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 23 Commission for Social Care Inspection East Sussex Area Office Ivy House 3 Ivy Terrace Eastbourne East Sussex BN21 4QT 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 Lennox Lodge DS0000021407.V253283.R01.S.doc Version 5.0 Page 24 - Please note that this information is included on www.bestcarehome.co.uk under license from the regulator. Re-publishing this information is in breach of the terms of use of that website. Discrete codes and changes have been inserted throughout the textual data shown on the site that will provide incontrovertable proof of copying in the event this information is re-published on other websites. 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