Inspection on 20/06/07 for Palm Care

This inspection was carried out on 20th June 2007.

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

The inspector found no outstanding requirements from the previous inspection report, but made 2 statutory requirements (actions the home must comply with) as a result of this inspection.

Other inspections for this house

Palm Care 23/04/08

Palm Care 17/06/06

Palm Care 29/11/05

Palm Care 15/06/05

Palm Care 07/09/04

Palm Care 07/06/04

Palm Care 17/02/04

Similar services:

Thorndene

Insight - Eastchurch

Southfields

Magenta

Seabourne House

33 St John`s Church Road

Dovedale Court

Lyncol House

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

CARE HOME ADULTS 18-65 Palm Care Limited 12 Hardy Road Greatstone New Romney Kent Lead Inspector Michele Etherton Key Unannounced Inspection 20th June 2007 09:30 Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 1 The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 2 This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Adults 18-65. They can be found at www.dh.gov.uk or obtained from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering: www.tso.co.uk/bookshop This report is a public document. Extracts may not be used or reproduced without the prior permission of the Commission for Social Care Inspection. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Palm Care Limited Address 12 Hardy Road Greatstone New Romney Kent 01797 367006 01797 367006 palm@beaconcaregroup.co.uk 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) Beacon Care Holdings PLC Ms Regina Magigi Care Home 6 Category(ies) of Learning disability (6) registration, with number of places Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 17th June 2006 Brief Description of the Service: Palmcare, Hardy Road is registered as a Care Home for up to six adults with a learning disability. Palmcare Ltd is the registered provider. Ms. G. Magigi is the Manager in day-to-day control of the functioning of the home. The home is a detached property set in a residential area of the seaside village of Greatstone. The accommodation comprises six single bedrooms for the service users. There is a lounge to the front of the house and a larger lounge/dining room with access to the enclosed rear garden. Car parking is available to the front of the property. Local facilities (shop, church, pub, post office and GP) are all within walking distance. The reported fees for this service are between £1200-1470 per week dependent on assessed need. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. An inspection of this service has been undertaken, this has involved a review of information received about the service since the last inspection, information provided by the home for the purposes of inspection and review and an unannounced site visit. The purpose of the visit was to assess progress made by the home in addressing outstanding requirements and recommendations issued at the last inspection and to establish that standards of care are being maintained. The site visit took place on 20/6/07 between 9:30 am- 2:40 pm, and involved a tour of the premises, a review of some documentation, discussion with the manager and staff, observation of and conversations with people living in the home, although the level of functioning of some people limited their opportunity to voice their experiences and opinions. One relative was also spoken with during the site visit, and gave positive feedback of their experiences of the home and the support provided to their relative. Feedback from other relatives and care professionals has been sought subsequently through telephone surveys and has been very positive. All key standards have been assessed, and some additional standards where outcomes were established during the site visit. What the service does well: The home offers a bright, comfortable and homely environment in which the manager and staff promote a friendly, relaxed and welcoming atmosphere. Staff demonstrate patience, an understanding of the needs and support of people in their care, and a willingness to support in an enabling manner; they are encouraging of the individual development of personal and daily living skills, within the social and educational activity programme. The home enables and facilitates contact with families and friends, relatives reported the home to be responsive to changes in visiting arrangements. Feedback from social care professionals is positive, the home manager and staff are viewed as having a good understanding of the needs of people with challenging or complex behaviour and to manage this effectively. One person living at the home said that they loved their room and loved the home. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 6 A relative confirmed that they were happy with the support provided and felt progress has already been made for the person in rediscovering their independence skills. What has improved since the last inspection? What they could do better: In general the home provides a good service to the people living there, however shortfalls in key outcome areas impact on the overall quality rating awarded to the home. The manager and staff need to ensure that safe systems are in place for the administration and recording of medication and that procedures implemented to minimise errors are adhered to. The organisation must ensure that recruitment of staff whether undertaken locally or by the head office is carried out in keeping with the regulations and that relevant required documentation is in place at all times prior to commencement of employment within he home. The home has made progress in the management of behaviours both inside and external to the home, consistency of approach would benefit from the development of clearly agreed behaviour management guidelines. The home should review with some urgency current arrangements for the management of cash belonging to people living in the home. The organisation should provide opportunities for the manager to receive professional supervision to support practice and development. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 7 Please contact the provider for advice of actions taken in response to this inspection. The report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. The summary of this inspection report can be made available in other formats on request. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 8 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–5) Individual Needs and Choices (Standards 6-10) Lifestyle (Standards 11-17) Personal and Healthcare Support (Standards 18-21) Concerns, Complaints and Protection (Standards 22-23) Environment (Standards 24-30) Staffing (Standards 31-36) Conduct and Management of the Home (Standards 37 – 43) Scoring of Outcomes Statutory Requirements Identified During the Inspection Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 9 Choice of Home The intended outcomes for Standards 1 – 5 are: 1. 2. 3. 4. 5. Prospective service users have the information they need to make an informed choice about where to live. Prospective users’ individual aspirations and needs are assessed. Prospective service users know that the home that they will choose will meet their needs and aspirations. Prospective service users have an opportunity to visit and to “test drive” the home. Each service user has an individual written contract or statement of terms and conditions with the home. The Commission consider Standard 2 the key standard to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 2, 4, 5 Quality in this outcome area is good, This judgement has been made using available evidence including a visit to this service. People who come to live at the home can be confident that their needs will be assessed prior to admission to ensure these can be met. Information about the service and the terms and conditions of residence is provided, but the format of this needs to be more accessible to existing and prospective residents. EVIDENCE: No new admissions have been made to the home since the last inspection. Discussion with a relative during the site visit confirmed that a lengthy introduction and assessment process had been undertaken by the home prior to full admission of their relative. One person at the home confirmed they had been given the option of choosing between this and another home prior to admission. A review of a case tracked file indicated that pre-assessment information and a written terms and conditions document is in place. A previous requirement to ensure terms and conditions information is made available to prospective residents has been addressed, however, a simplified version that makes this information accessible to those living in the home should also be available. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 10 Individual Needs and Choices The intended outcomes for Standards 6 – 10 are: 6. 7. 8. 9. 10. Service users know their assessed and changing needs and personal goals are reflected in their individual Plan. Service users make decisions about their lives with assistance as needed. Service users are consulted on, and participate in, all aspects of life in the home. Service users are supported to take risks as part of an independent lifestyle. Service users know that information about them is handled appropriately, and that their confidences are kept. The Commission considers Standards 6, 7 and 9 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 6,7,9 Quality in this outcome area is good. This judgement has been made using available evidence including a visit to this service. Staff have a good understanding of individual needs, support routines and risks and have access to detailed supporting documentation to guide them, more clarity is needed on how to progress aspirations and wishes. There are increased opportunities for people in the home to be more involved and make decisions. Risks are generally well managed EVIDENCE: Documentation viewed as part of case tracking indicated that staff have access to detailed information in respect of individuals care support plan, aspirations, goals, health monitoring etc. Staff work well with individuals in the home offering discreet support but not taking over, staff attitudes are respectful and encouraging; in discussion staff demonstrate a good level of understanding of individual needs and risks. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 11 Individual communication needs and methods of communication are well understood but would benefit from being accurately recorded for staff to aid consistency of support offered. There is a need for people who live in the home, to be provided with more opportunities to be involved in the development of their plan, the manager is aware of a need for more person centred plans and reported that one is being developed by the company. Goals and aspirations are documented currently but activities plans do not generally provide opportunities for some of these to be worked towards through daily or weekly routines. The manager is aware that improved planning needs to take place to progress aspirations and goals if they are to be meaningful and had an understanding of how she might take this forward. Where possible people are given choices and encouraged to become more involved in their day-to-day routines but the manager accepts this could be developed further. Risks are understood and generally well managed both inside and external to the home without the need for restrictive practices, risk assessments are developed or adapted to respond to changing needs and situations, examples of this were noted within case tracked documentation. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 12 Lifestyle The intended outcomes for Standards 11 - 17 are: 11. 12. 13. 14. 15. 16. 17. Service users have opportunities for personal development. Service users are able to take part in age, peer and culturally appropriate activities. Service users are part of the local community. Service users engage in appropriate leisure activities. Service users have appropriate personal, family and sexual relationships. Service users’ rights are respected and responsibilities recognised in their daily lives. Service users are offered a healthy diet and enjoy their meals and mealtimes. The Commission considers Standards 12, 13, 15, 16 and 17 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 12,13,15,16,17 Quality in this outcome area is good, This judgement has been made using available evidence including a visit to this service. People living in the home are provided with opportunities to be more involved in their daily routines and to be active and use the local community on an individual and group basis; they are supported to maintain links with their friends and family. Staff’ are aware of individual food preferences and provide a nutritious and healthy diet that people enjoy eating. EVIDENCE: People have individual activity plans and these provide opportunity for individuals to participate in activities both in the home and in the community the manager is aware that there is a need to link some of these activities with the progression of goals and aspirations for some people. The lack of available staff to drive the company vehicle whilst not impacting on planned excursions inhibits the ability of the home to respond flexibly to providing activities and outings in the community, and this should be reviewed. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 13 Contact with families is promoted and facilitated; a relative reported they are made welcome. Another relative commented positively that the home was responsive to changes in visiting arrangements and were good at keeping to agreed times. The home has initiated involvement of some outside workers to undertake aromatherapy and English numeracy and literacy, opportunities for people to develop their independence skills are also being promoted, with staff reporting that people in the home are now undertaking many activities for themselves previously supported with by staff. One relative reports that they have noted measurable improvements in their relative’s skills since admission and is supportive of skills promotion. People living in the home sit down together and enjoy their meals, staff are conscious of some residents who may over indulge in some foods and take precautions to restrict this. One person indicated in discussion that he prepared his own breakfast and does so routinely. There is an established menu that takes account of individual likes and dislikes, at the site visit staff were observed providing discreet support to individuals around the lunch time meal where needed. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 14 Personal and Healthcare Support The intended outcomes for Standards 18 - 21 are: 18. 19. 20. 21. Service users receive personal support in the way they prefer and require. Service users’ physical and emotional health needs are met. Service users retain, administer and control their own medication where appropriate, and are protected by the home’s policies and procedures for dealing with medicines. The ageing, illness and death of a service user are handled with respect and as the individual would wish. The Commission considers Standards 18, 19, and 20 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 18,19,20 Quality in this outcome area is adequate This judgement has been made using available evidence including a visit to this service. People in the home are supported and encouraged to be more independent and involved in their daily routines; health care needs are generally well supported. Improvements to staff practice in the administration and recording of medication are needed. EVIDENCE: Personal care routines are detailed within support plans, staff offer support in consultation with individuals to establish preferred routines, but, for the purpose of continuity and to ensure consistency people in the home need to be involved in development of a more person centred format that accurately reflects their preferences, the manager reports this to be in the early stage of development by the company. Discussion with the manager and staff indicated that some people in the home are taking a more active role in their personal care and daily routines. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 15 A review of case tracked documentation highlighted that routine and specialist healthcare needs are well supported. The home ensures that all staff administering medications are trained, and this was confirmed in discussion with staff. A previous requirement in respect of specialist medication guidance has been addressed. Observation of a medication round found this to be carried out satisfactorily, however a review of MAR sheets highlighted omissions in recording, whilst an audit of the liquid medications concerned indicated that administration had taken place, and that this was a recording error, staff are not adhering to additional procedures implemented by the manager to minimise errors and a requirement has been issued for these matters to be addressed. Discussion with a support worker acting in senior capacity whilst the manager was absent highlighted some lack of clarity about actions to take in the event of a medication error, this was discussed with the manager who will remind staff of the correct procedure to follow. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 16 Concerns, Complaints and Protection The intended outcomes for Standards 22 – 23 are: 22. 23. Service users feel their views are listened to and acted on. Service users are protected from abuse, neglect and self-harm. The Commission considers Standards 22, and 23 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 22,23 Quality in this outcome area is adequate This judgement has been made using available evidence including a visit to this service. People living in the home and their representatives have been provided with information about the complaints procedure. Staff attitudes and awareness of adult protection issues generally protect people from harm but would benefit from all staff being trained; there are risks in not having clear and agreed behaviour management plans, and restrictions on the level of cash retained within the home for individuals living there. EVIDENCE: There have been a minimal number of complaints since the last inspection, these have been appropriately recorded and dealt with. An accessible version of the complaints procedure has been provided to people living in the home but this now needs updating. The manager has provided accessible versions of the complaints procedure to the residents but this now needs updating. A relative spoken with during the site visit, said they felt confident about making any concerns they might have known and understood about how to complain. Owing to staff turnover only 50 of staff have received adult protection training, although a programme of training including Adult protection is in place. Feedback from social care professionals suggests the home manager and staff are viewed as having a good understanding of the needs of people with challenging or complex behaviour and manage this effectively. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 17 Risks are managed well and staff knowledgeable of behaviours and implement de-escalation strategies, they demonstrated an awareness of behaviour triggers and indicators. It is recommended that to ensure consistency of support and management of behaviours, management plans are developed and agreed with all relevant persons including the individual concerned and these are supported by relevant risk assessments. The home ensures that individuals can access their personal monies as needed, although it is strongly recommended that the home discourage the build up of cash sums for any individual, and should review current arrangements as a matter of some urgency. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 18 Environment The intended outcomes for Standards 24 – 30 are: 24. 25. 26. 27. 28. 29. 30. Service users live in a homely, comfortable and safe environment. Service users’ bedrooms suit their needs and lifestyles. Service users’ bedrooms promote their independence. Service users’ toilets and bathrooms provide sufficient privacy and meet their individual needs. Shared spaces complement and supplement service users’ individual rooms. Service users have the specialist equipment they require to maximise their independence. The home is clean and hygienic. The Commission considers Standards 24, and 30 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 24,26,30 Quality in this outcome area is good This judgement has been made using available evidence including a visit to this service. The home is maintained to a good standard of cleanliness and décor and people enjoy living and working in a homely and welcoming environment EVIDENCE: The home is bright and welcoming with a nice atmosphere. It is maintained to a good standard of cleanliness and décor; although furnishings are showing signs of wear and tear they remain serviceable at present. Communal rooms are comfortable and homely. A bedroom viewed with permission was personalised reflecting the individuals interests and tastes, they confirmed they had been involved in selection of the colour scheme and carpet, and reported that they loved their room and liked living at the home. The home ensures that appropriate aids are in place to support people in the home. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 19 Staffing The intended outcomes for Standards 31 – 36 are: 31. 32. 33. 34. 35. 36. Service users benefit from clarity of staff roles and responsibilities. Service users are supported by competent and qualified staff. Service users are supported by an effective staff team. Service users are supported and protected by the home’s recruitment policy and practices. Service users’ individual and joint needs are met by appropriately trained staff. Service users benefit from well supported and supervised staff. The Commission considers Standards 32, 34 and 35 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 32,34,35,36 Quality in this outcome area is adequate This judgement has been made using available evidence including a visit to this service. Staff’ have opportunities to train and attain care qualifications. Recruitment practices are generally robust but the provision of two written references for all staff must be adhered to. Staff’ are well supported by the manager, whose own development and practice will benefit from receiving regular opportunities for formal supervision. EVIDENCE: Information provided by the home prior to inspection indicates that more than 50 of staff have attained NVQ2 qualifications and above. Whilst recruitment of staff is generally robust a review of two new staff files highlighted that only one written reference was provided for each, it is a requirement that all staff, including overseas staff recruited centrally by the organisation have two written references in place prior to commencement of employment. Staff confirmed they had received appropriate induction into their role and this was evident in their awareness and understanding of individuals’ care and support needs and their assured and confident responses. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 20 Staff reported that they felt well supported by the manager and enjoyed their job, they receive regular supervision with the manager who acknowledged that frequencies for this have slipped slightly, and supervision sessions are recorded. There is no evidence of the manager receiving regular supervision, and it is recommended that opportunities be provided for her professional supervision to discuss practice and development issues There is a training programme in place and staff booked on courses as they come up, not all staff have achieved all core skills or adult protection training as yet. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 21 Conduct and Management of the Home The intended outcomes for Standards 37 – 43 are: 37. 38. 39. 40. 41. 42. 43. Service users benefit from a well run home. Service users benefit from the ethos, leadership and management approach of the home. Service users are confident their views underpin all self-monitoring, review and development by the home. Service users’ rights and best interests are safeguarded by the home’s policies and procedures. Service users’ rights and best interests are safeguarded by the home’s record keeping policies and procedures. The health, safety and welfare of service users are promoted and protected. Service users benefit from competent and accountable management of the service. The Commission considers Standards 37, 39, and 42 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 37,39,42 Quality in this outcome area is good, This judgement has been made using available evidence including a visit to this service. The home is well managed and generally promotes the health, welfare and safety of people living there. The home consults with people living in the home but needs to evidence clearly how their views influence service development. EVIDENCE: The manager is suitably qualified and experienced to manage the home, she demonstrates a commitment to improving the lives of the young men in her care and ensures that staff’ are adequately prepared to provide effective support. As a result of the managers input there have been measurable improvements for all people living in the home, and this was confirmed in discussion with a relative. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 22 Some quality assurance is undertaken and relatives views sought, the ethos of the home ensures that people living there are routinely consulted about things in the home and are encouraged to make choices and decisions but there is currently no evidence of how this information is analysed, published and feeds into service development, this is an area that needs strengthening. Health and safety checks are undertaken on a monthly basis, a sample of servicing certificates for equipment and services in the home indicated that generally these are addressed within appropriate timescales, there has been an oversight with the electrical installation which is now due and the manager has agreed to have this checked as soon as possible. Maintenance of the home is generally good with no current outstanding problems. Security of the office was discussed with the manager and it is suggested this is reviewed. Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 23 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Adults 18-65 have been met and uses the following scale. The scale ranges from: 4 Standard Exceeded 2 Standard Almost Met (Commendable) (Minor Shortfalls) 3 Standard Met 1 Standard Not Met (No Shortfalls) (Major Shortfalls) “X” in the standard met box denotes standard not assessed on this occasion “N/A” in the standard met box denotes standard not applicable CHOICE OF HOME Standard No Score 1 X 2 3 3 X 4 3 5 2 INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score CONCERNS AND COMPLAINTS Standard No Score 22 3 23 2 ENVIRONMENT Standard No Score 24 3 25 X 26 3 27 X 28 X 29 3 30 3 STAFFING Standard No Score 31 X 32 3 33 X 34 2 35 2 36 2 CONDUCT AND MANAGEMENT OF THE HOME Standard No 37 38 39 40 41 42 43 Score 3 3 X 3 X LIFESTYLES Standard No Score 11 X 12 3 13 3 14 X 15 3 16 3 17 3 PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Score 3 3 2 X 3 X 2 X X 3 X Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 24 NO Are there any outstanding requirements from the last inspection? STATUTORY REQUIREMENTS This section sets out the actions, which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard YA20 Regulation 13(2) 17 Sched.3 3(m) 19 Requirement The manager must make arrangements to ensure the safe administration and recording of medicines in the home. The company must ensure that all staff recruited has required documentation in place including two written references prior to commencement of employment in the home. Timescale for action 31/07/07 2. YA34 31/08/07 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 Refer to Standard YA23 YA23 YA36 Good Practice Recommendations The home to develop behaviour management plans to aid consistency of support. Home to review current arrangements for personal allowance monies and discourage the build up of large amounts of cash Manager to be offered regular professional supervision Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 Page 25 Commission for Social Care Inspection Maidstone Local Office The Oast Hermitage Court Hermitage Lane Maidstone ME16 9NT National Enquiry Line: Telephone: 0845 015 0120 or 0191 233 3323 Textphone: 0845 015 2255 or 0191 233 3588 Email: enquiries@csci.gsi.gov.uk Web: www.csci.org.uk © This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI Palm Care Limited DS0000023506.V340343.R01.S.doc Version 5.2 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. 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