Inspection on 28/02/07 for Royal Avenue Residential Home

This inspection was carried out on 28th February 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

Royal Avenue Residential Home 12/11/08

Royal Avenue Residential Home 07/09/05

Royal Avenue Residential Home 29/06/05

Royal Avenue Residential Home 13/01/05

Royal Avenue Residential Home 09/09/04

Similar services:

Coopers Mill Ltd

Bramley Avenue (73)

Paradise Lodge

Grangewood

Upaya Ananda

Newton Court (1-2)

Kings Lane (32)

Pemdale

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

CARE HOME ADULTS 18-65 Royal Avenue Residential Home 77, 81-83 Royal Avenue Lowestoft Suffolk NR32 4HJ Lead Inspector John Goodship Key Unannounced Inspection 28th February 2007 10:40 DS0000024482.V332184.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 DS0000024482.V332184.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. DS0000024482.V332184.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Royal Avenue Residential Home Address 77, 81-83 Royal Avenue Lowestoft Suffolk NR32 4HJ 01502 572057 01502 531405 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) Mrs Patricia Barnard Mrs Patricia Barnard Care Home 16 Category(ies) of Learning disability (16), Learning disability over registration, with number 65 years of age (1) of places DS0000024482.V332184.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: 1. 1 81 and 83 Royal Avenue may accommodate persons of either sex, under the age of 65, who require care by reason of a learning disability (not to exceed 9 persons). 2 77 Royal Avenue may accommodate persons of either sex, under the age of 65, who require care by reason of a learning disability ( not to exceed 7 persons). 3 The total number accommodated must not exceed 16. 4 One person aged 65 years old and over who requires care by reason of a learning disability (not to exceed one person). 7th September 2005 2. 3. 4. Date of last inspection Brief Description of the Service: The service at Royal Avenue offers accommodation and personal care to 16 younger adults with a learning disability, including one person over 65 years old. The residents live together in three large terraced houses in a pleasant residential area of North Lowestoft. Two of the houses, Numbers 81 and 83 adjoin and the other, Number 77, is next but one on the same side of the street. There is rear access to all the houses via a small service road. Each has a small, secure garden where service users can enjoy the open air. The fees currently range from £320 to £670 per annum. DS0000024482.V332184.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This inspection visit was unannounced and covered the key standards which are listed under each Outcome Group overleaf. This report includes evidence gathered during the visit together with information already held by the Commission. The inspection took place on a weekday and lasted five hours. The manager and deputy manager joined the inspection after returning from a review meeting at the hospital about a resident. The inspector toured the home, and spoke to some of the residents, and the staff, both individually and in a group. The inspector also examined care plans, staff records, maintenance records and training records. A questionnaire survey was sent out by the Commission to residents and to relatives. Five residents responded, with staff support, and eight relatives. Their answers to the questions and any additional comments have been included in this summary and in appropriate sections of this report. What the service does well: There is friendly and caring support from staff, which is shown by the excellent rapport between them, and by the comments of residents and relatives. “My relative is very well looked after. Could not have a better home.” “My relative is very happy and the staff are really caring. X is always dressed nicely and looks really well.” The home has prepared a substantial guide to the home with photos and text which help prospective residents. Residents’ needs are kept under regular review, with clear recording of changes in needs and instructions to staff on how to best support residents. Residents are supported to express their views about the home and to determine what they do each day. The home has a good programme of staff induction and training. Health and safety monitoring is well recorded and up-to-date. DS0000024482.V332184.R01.S.doc Version 5.2 Page 6 What has improved since the last inspection? What they could do better: Please contact the provider for advice of actions taken in response to this inspection. The report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. The summary of this inspection report can be made available in other formats on request. DS0000024482.V332184.R01.S.doc Version 5.2 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–5) Individual Needs and Choices (Standards 6-10) Lifestyle (Standards 11-17) Personal and Healthcare Support (Standards 18-21) Concerns, Complaints and Protection (Standards 22-23) Environment (Standards 24-30) Staffing (Standards 31-36) Conduct and Management of the Home (Standards 37 – 43) Scoring of Outcomes Statutory Requirements Identified During the Inspection DS0000024482.V332184.R01.S.doc Version 5.2 Page 8 Choice of Home The intended outcomes for Standards 1 – 5 are: 1. 2. 3. 4. 5. Prospective service users have the information they need to make an informed choice about where to live. Prospective users’ individual aspirations and needs are assessed. Prospective service users know that the home that they will choose will meet their needs and aspirations. Prospective service users have an opportunity to visit and to “test drive” the home. Each service user has an individual written contract or statement of terms and conditions with the home. The Commission consider Standard 2 the key standard to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 1,2,3,4. Quality in this outcome area is good. Prospective residents are given comprehensive information about the home, in a suitable format for their needs. They have opportunities to assess the home before moving in. This judgement has been made using available evidence including a visit to this service. EVIDENCE: No long-term resident had been admitted since the last inspection. One resident had been admitted in August 2006 for short-term care. Pre-admission assessments were available in the file. This person was being assessed for suitability for moving into supported living. The resident spoke to the inspector about what they were able to do to look after themselves. They were anxious about the possible move to supported living as they had settled into Royal Avenue and liked it there. One resident said that before they moved in, they had come up to the home for tea several times. One resident was over eighty years old for which the home had a variation to their registration. All other residents were under 62. DS0000024482.V332184.R01.S.doc Version 5.2 Page 9 The Statement of Purpose and the Service Users’ Guide were examined. They contained all the information required by the Regulations. The Service Users’ Guide had been arranged to include many photos illustrating the buildings, the fire procedures, the rooms, the activities both inside and outside the home, and the staff. These illustrated the pages of text in each section. The Guide contained information about residents’ meetings and satisfaction surveys. This Guide was in the form of a large album. The manager said that because of its size, prospective residents were not given a copy but were shown it when they visited before taking up residence. However the Statement of Purpose included the information fro the Guide in text form which was given out to prospective resdidents. DS0000024482.V332184.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): 6,7,8,9,10. Quality in this outcome area is good. Residents can be assured that their care needs will be identified, monitored and reviewed to ensure that these needs are met. They are able to make decisions about what they do, and how they contribute to the life of the home. This judgement has been made using available evidence including a visit to this service. EVIDENCE: Care plans were reviewed at least every six months by keyworkers with all relevant parties invited. The review schedules were listed in the plans. Two care plans were examined in detail. One was for a resident whose health had deteriorated suddenly the previous week and they had been admitted to hospital. The other was a resident who was in the house during the visit. DS0000024482.V332184.R01.S.doc Version 5.2 Page 11 Both care plans followed a similar format. There were assessments of all aspects of daily living, personal care, mobility, and safety. Both highlighted instructions for staff on how to support each person, such as maintaining continence, good nutrition, remembering appointments. Care plans identified needs and set objectives for meeting those needs or eliminating them. Each need was detailed with specific outcomes and strategies for achieving those outcomes. One outcome for a resident had been set to halt their weight loss. With advice from the dietitian about nutrition and build-up foods, the weight had stabilised since September 2006. Likes and dislikes for food, activities and personal care were listed in the care plans. These were discussed by the inspector with one of the residents who confirmed their preferences. They enjoyed shopping, going to the pub and helping round the house. Talking to residents demonstrated that most of them had the ability to express what they wanted to do, whether it was what they wanted for lunch or where they wanted to go for their day care. “If I don’t want to go to the day service, I don’t have to.” Although there had not been any issue over personal relationships between residents, the home had a clear policy in the file detailing the rights of residents to form relationships, and that staff should be supportive and nonjudgemental. The home had a policy on confidentiality and access to personal information by residents. DS0000024482.V332184.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): 11,12,13,14,15,16,17. Quality in this outcome area is good. Residents have many opportunities to take part in daytime, evening and weekend activities. They are supported by staff if they wish. They are supported in developing personal relationships. They are able to make decisions about what they do, and how they contribute to the life of the home. This judgement has been made using available evidence including a visit to this service. EVIDENCE: Many residents went out to a daytime activity on some days of the week. Locations for these included Lowestoft College, Aspire, Gateway Lodge, Aid and Assist. One resident explained how they enjoyed going to college and that they were hoping they might be able to get some work with children. The oldest resident had a set routine of going out early to the nearby café for the first part of the morning. DS0000024482.V332184.R01.S.doc Version 5.2 Page 13 One resident had taken the decision to give up all external activities. However the community nurse took them out occasionally and was encouraging them to start going out to activities again. Some residents had named social workers where there were issues to be sorted out for residents. However most residents had no named social worker. The home had its own 14-seater minibus for group outings and for holidays. Residents were not charged for the use of the minibus, although they did pay if they needed a taxi for other visits and appointments. Residents were able to talk to the inspector about trips, including going to the owner’s caravan at Skegness. Photos of these activities were displayed around the home. Records were seen which demonstrated how the home supported residents in discussions about their future accommodation. Although some residents did not have any or only limited verbal communication, the records of the meetings and correspondence showed that the person’s rights and choices were respected. Both lunch and dinner menus took into account that those residents who went out for the day needed a full meal in the evening, and those who stayed in the home needed a full meal at lunchtime. Lunch on the day of inspection was chicken stew with potatoes and fresh vegetables, followed by semolina (which the manager instructed a carer how to prepare properly). The lunchtime was a friendly and talkative occasion with residents chatting to staff about their morning and their plans for the rest of the day. DS0000024482.V332184.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): 18,19,20,21. Quality in this outcome area is good. Residents are supported as they wish in their daily lives and in the monitoring of their health needs. They are protected by the home’s medication procedures and staff training. Residents can feel assured that they will be treated at all times like a family member. This judgement has been made using available evidence including a visit to this service. EVIDENCE: A reflexologist was in the home during the inspection, giving feet and nail care to four residents. The resident who was being treated when the inspector met them said how they enjoyed the session. Records of visits by the reflexologist and the visiting chiropodist were present in the care plans. Records of visits to the dentist were also kept. Staff were advised in the care plan to remind one resident of the need to use the toilet, to improve their continence. The manager said the home received DS0000024482.V332184.R01.S.doc Version 5.2 Page 15 good support from the district nurse, and from the Continence Adviser, who had given staff training in this topic. Evidence was seen to demonstrate how the home supported residents who were taken to hospital. Care plans contained full information on the reasons for admission to hospital and how their future care needs might change. On the day of inspection, the manager and the deputy returned from a meeting at the hospital with the family and the medical staff to review what might happen to one resident. The issues about the home’s competence and registration to care for residents with higher care needs were discussed with the inspector. The medication system was inspected with a member of staff. The medicine administration record (MAR) sheets were filled in fully with all items signed for. The practice in the home, set out in their policy, was that two staff must witness the administration of medication and both sign the record. A stock check showed that the number of tablets in the packs tallied with the MAR sheets. One resident only needed half of one tablet but the pharmacy packed whole tablets. The manager was advised to discuss with the pharmacy how this could be packed differently to prevent contamination. The home’s medication policy gave clear instructions on the procedure for taking verbal changes to prescriptions over the phone from GPs. The home had information on file from residents or relatives on the preferred arrangements at the end of life. DS0000024482.V332184.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 good. Procedures are in place and understood by staff for the protection of residents. This judgement has been made using available evidence including a visit to this service. EVIDENCE: The home had a complaints policy which set out the procedure available to complainants, and included the name and address of the Commission. Information on the procedure was also included in the Statement of Purpose and the Service Users’ Guide, the latter in picture format. Training records showed when staff had received training in the protection of vulnerable adults. One member of staff was asked about their understanding of the term, and what action they would take if they believed any abuse had taken place. The member of staff was well informed on this matter and was able to state clearly the action they would take. The financial affairs of some residents were managed by themselves, but most had their affairs managed by relatives. No member of staff at the home was the appointed officer for any resident. One resident explained to the inspector that they were just going out to the bank to withdraw some money. DS0000024482.V332184.R01.S.doc Version 5.2 Page 17 The home kept cash for those unable to look after it themselves. One wallet was checked against the cash book and receipts and the cash amount was correct. DS0000024482.V332184.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): 24,25,28,30. Quality in this outcome area is good. Residents can expect to live in a homely environment that is safe and provides a range of facilities for them. The home is clean and tidy, which residents contribute to according to their abilities. This judgement has been made using available evidence including a visit to this service. EVIDENCE: Several communal areas of the home had been redecorated in the last year, in both No.77 and No.81. In addition the kitchen in No.77 had been refurbished. Four residents’ rooms had been repainted with their help in choosing colours. Two residents showed the inspector their rooms. Both were personalised, with objects of their choice. One resident explained that they had moved the position of their bed away from the line of the window to reduce the light. DS0000024482.V332184.R01.S.doc Version 5.2 Page 19 All communal toilets and bathrooms had a normal hand towel for use by everyone. This was a potential cause of cross-infection. Alternatives which would be suitable for the residents were discussed with the manager. Door closers had been fitted to ensure doors which were normally kept open would close at the sound of the fire alarm. Residents were encouraged to contribute to keeping their own rooms, and the communal rooms, clean and tidy according to their abilities. Each house had a small secure garden for residents. DS0000024482.V332184.R01.S.doc Version 5.2 Page 20 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): 32,33,34,35,36. Quality in this outcome area is good. Residents have support from knowledgeable keyworkers, and from a staff team who support each other. Residents are protected by the required recruitment procedures for their safety. Any changes in their needs are assessed for additional staff support. Staff are properly inducted and trained. Residents would benefit from staff receiving regular recorded supervision. This judgement has been made using available evidence including a visit to this service. EVIDENCE: There was only one person on the staff who had joined the home since the last inspection. The recruitment file for this person was examined. The POVA First result had been received two weeks before the person started their employment, and the full CRB was received two days after they started. There were two references and full identification documents in the file. The inspector was able to interview this member of staff as they were on duty. They had prior experience of caring in people’s homes, and had achieved the NVQ Level 2. They were able to describe the induction and training they had DS0000024482.V332184.R01.S.doc Version 5.2 Page 21 received since starting at Royal Avenue. They were able to describe an incident in a previous job which they had reported as possible abuse of a client, and they knew what to report and to whom they should do so. They did not think that they had received supervision in the sense of a regular one-to-one session every two months, but they said that because of the atmosphere in the home, supervision was exercised all the time. Training records for all staff were examined. They covered certificates of attendance and achievement, including safe administration of medication, epilepsy and communicating with people with a learning disability. The medication policy said that no staff could administer medication without the correct training. Those administering had received that training according to the records. All relatives who replied to the questionnaire said there were always sufficient staff on duty. One commented: “The staff are more like friends. They always make you feel welcome.” There was no programme for the regular one-to-one supervision sessions described in Standard 36. It had been in place at the last inspection but had not been kept up. DS0000024482.V332184.R01.S.doc Version 5.2 Page 22 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): 37,38,39,40,41,42. Quality in this outcome area is good. The interaction of residents and staff confirm the ethos of the home, with a family feel to the place. Policies and procedures protect residents and they can be assured that their records are accurate and up-to-date. This judgement has been made using available evidence including a visit to this service. EVIDENCE: The home was run as far as possible to create a family environment, with the residents as part of that family. “The staff are more like friends.” The owner/manager had many years experience of supporting residents with learning disabilities, and the home felt welcoming, with friendly and supportive staff. DS0000024482.V332184.R01.S.doc Version 5.2 Page 23 Residents’ meetings and satisfaction surveys were described in the Statement of Purpose. It was clear that residents were able to express their views to the staff, including those who had communication difficulties. A relative wrote: “I can tell when X is happy by the facial expression. The staff pick this up too.” The inspector was shown the file containing all the home’s policies. These covered all the required topics, and they were reviewed annually. The last review was in August 2006. The fire risk assessment was seen. It had been approved by the Fire Officer on a visit in 2006. The fire log listed the weekly fire drills, which were up-to-date, together with the regular tests of the alarms and emergency lighting. Records were kept of the portable appliance tests. There were records of hazard assessments, which were reviewed every six months, the last time on 9/11/06. DS0000024482.V332184.R01.S.doc Version 5.2 Page 24 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 4 2 3 3 3 4 3 5 X INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score CONCERNS AND COMPLAINTS Standard No Score 22 3 23 3 ENVIRONMENT Standard No Score 24 3 25 3 26 X 27 X 28 3 29 X 30 2 STAFFING Standard No Score 31 X 32 3 33 3 34 3 35 3 36 2 CONDUCT AND MANAGEMENT OF THE HOME Standard No 37 38 39 40 41 42 43 Score 3 3 3 3 3 LIFESTYLES Standard No Score 11 3 12 3 13 3 14 3 15 3 16 3 17 3 PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Score 3 3 3 3 3 3 3 3 X 3 X DS0000024482.V332184.R01.S.doc Version 5.2 Page 25 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 YA30 Regulation 13(3) Requirement The provision of towels in the communal washing facilities must be appropriate for the reduction in the risk of crossinfection. A programme of formal staff supervision must be followed. Timescale for action 01/04/07 2. YA36 18(2) 01/04/07 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 Refer to Standard YA36 Good Practice Recommendations Staff supervision sessions should take place at least every two months. DS0000024482.V332184.R01.S.doc Version 5.2 Page 26 Commission for Social Care Inspection Suffolk Area Office St Vincent House Cutler Street Ipswich Suffolk IP1 1UQ 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 DS0000024482.V332184.R01.S.doc Version 5.2 Page 27 - 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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