Inspection on 22/11/05 for The Old Rectory

This inspection was carried out on 22nd November 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 no outstanding requirements from the previous inspection report, but made 1 statutory requirements (actions the home must comply with) as a result of this inspection.

Other inspections for this house

The Old Rectory 04/03/09

The Old Rectory 05/03/08

The Old Rectory 29/11/06

Similar services:

2 Perhaver Park

The Vicarage

St George`s

5 Seafield Road

Credence House

Radfords

Honeybourne House

32 Beaumont Way

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

CARE HOME ADULTS 18-65 The Old Rectory Chewton Hill Chewton Mendip Near Bath Somerset BA3 4NQ Lead Inspector Justine Button Unannounced Inspection 22nd November 2005 09:30 The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 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 The Old Rectory DS0000064624.V268408.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 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. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 3 SERVICE INFORMATION Name of service The Old Rectory Address Chewton Hill Chewton Mendip Near Bath Somerset BA3 4NQ 01761 241207 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) Mr Neil Bradbury Mr Philip John Kilburn Care Home 10 Category(ies) of Learning disability (10) registration, with number of places The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 4 SERVICE INFORMATION Conditions of registration: 1. Service users who have concurrent mental health needs may be admitted. Date of last inspection Brief Description of the Service: The Old Rectory is registered for ten younger adults who have a learning disability. The service aims to support people who have relatively high needs including those who have Autistic Spectrum Disorders. The service is located in a large substantial house in the rural village of Chewton Mendip. The cathedral city of Wells is approximately 6 miles away and the city centres of Bath and Bristol are within travelling distance. There is a village shop across the main road. The home provides accommodation on three floors. The ground floor provides a lounge, dining room and activities/games room. There are two kitchens. The first is the “house” kitchen, which provides meals for the home. The second kitchen is accessible, with staff supervision, to the people living at the service. This kitchen is used to develop life skills. There is also a downstairs bathroom. In addition to the living accommodation there are a range of staff areas including meeting room, administration office and staff office on the lower floor. The bedrooms are located on the upper floors. All the bedrooms are large and have en-suite facilities. The bedrooms are large enough for them to contain a small sitting area. There are a further three bathrooms, one of which has a spa bath. There are plans to develop a multi sensory room in the future. There is a staff area predominantly used by staff for night supervision. Additionally there is separate self-contained staff accommodation. The service would not be suitable for people with a physical disability who could not access the stairs, as there is no lift to the upper floors. There is an accessible secure garden to the front of the house and a courtyard area to the rear. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 5 The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 6 SUMMARY This is an overview of what the inspector found during the inspection. The service has recently been registered with the CSCI. This was therefore the first inspection to be conducted. The inspection was unannounced and was conducted between the hours of 09:30 and 15:00 Hrs. The service is currently accommodating six people with at least two further admissions due in the next few weeks. The remaining rooms will be occupied in the near future depending on the needs of the individual moving in. The aim of this inspection was to ascertain how the service was progressing and to gain a baseline assessment against the National Minimum Standards. What the service does well: What has improved since the last inspection? As this is the first inspection this section is not relevant. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 7 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 Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 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 The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 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 at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 1, 2, 3, 4, 5. The service provides written information about the home. In addition people who are considering moving into the home are able to visit. A full assessment is conducted prior to the person moving in. These aspects ensure that the service can meet the individual’s needs. EVIDENCE: As all the people who live at the home have recently moved in, all have undergone the admission process. Prospective individuals are introduced to the service dependant on their needs and requirements. For some people this could mean a number of visits over several weeks. Families and advocates are used to ensure that information the person requires is communicated using an appropriate method. The proposed statements of purpose and service user guide were seen during the registration process. These were not seen during the inspection process and it could not be confirmed if these are used. During the visit staff at the service ensure that the service can meet the individual needs. In addition to this written communications are gained from other professionals. The management team conduct an in-depth assessment prior to admission to ensure that they can meet the individuals needs. The management team recently visited Norfolk in order to conduct such an assessment. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 10 Admission to the service is not rushed and can take several weeks to ensure that all parties are happy to proceed. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 11 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 at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 6, 7, 8, 9, 10. All people who live at the home have an individual plan. People who live at the home are able to make decisions and choices. People are supported to take risks. One issue with regard to confidentiality was raised during the inspection. EVIDENCE: All people who live at the service have an individual plan; four of the plans were viewed in detail on the day of inspection. The plans gave clear details of the needs of the person. There were in depth and gave guidance to staff on issues such as behavioural triggers and diffusion techniques. Protocols are in place for staff to follow with regard to identified needs. Both of these measures ensure that there is a consistent approach by staff. At the end of each shift staff complete a diary sheet documenting the shift’s events. These sheets contain information on all the people live at the service. It is recommended that each individual who resides at the home have a separate sheet. This will ensure that if the individual or interested party wishes to view events this can be done without compromising the The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 12 confidentiality of the others. This may also allow patterns of behaviour to be seen more easily. Some of the people who live at the service have had the opportunity to be involved in the review of the care and support that is available to them. For others this opportunity had not yet been made available. This is due in part to the timescales that the individuals had lived at the home. Communication systems are in the process of being developed including pics, symbols and photographs. These developments will need to continue to ensure that all people who live at the service have the opportunity to be involved to the fullest extent in the day to day running of the service. People are supported to make decisions, choices and risks in their daily life. Documented evidence was seen to support this in the “daily diary” and Regulation 37 form (forms which are sent to the CSCI following an adverse incident). Part of the support plans includes a section on self-advocacy. Staff allow the individual to make choices and try to explain to the individual the consequence of the choices made in line with a documented risk assessment. An example of this was an individual who wished to access the pub with reduced staff support. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 13 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 at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 11, 12, 13, 14, 15, 16, 17. There is a good range of opportunities available for personal development, recreation and community involvement. People who live at the service are supported to maintain links with family and friends. The food provided is of a satisfactory standard. EVIDENCE: The home is part of the Bradbury Group. The group own a farm, which is used as a day service. People living at the service have access to the farm. Access to the farm is dependant on the individual’s needs and requirements. Individuals access the sessions, which they would enjoy and gain most from. Some access these opportunities in small groups while others require individual support. The farm is affiliated to a local further education college. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 14 In addition to attending “the farm” a number of people access a local college again to attend a course of interest or for personal development. The activity plans were viewed and these also included swimming. There was documented evidence of family and friends visiting the service although there were no visitors on the day of inspection. There are a number of areas for people to entertain family and friends including in the large bedrooms. The service is hoping to develop a multi sensory room in the near future. This would be welcomed. There is a large games room within the home. This area contains such items as a karaoke machine, snooker/table tennis table and is available for arts and crafts. There was documented evidence of people visiting the local pub and going shopping using the homes own transport. One person goes swimming with staff support. There are two kitchens within the home. The first is used to cook and prepare food for the home. This kitchen is not accessible to the people who live at the home. This area has all necessary equipment and was clean and tidy on the day of inspection. The second kitchen is used to develop life skills for the people who live at the service. One person was observed using this kitchen with staff support during the inspection. The service provides an adequate standard of food. Staff need to keep under review the amount of processed foods such as burgers, sausage rolls and chips that are served. The inspector appreciates however, that this can be difficult when individuals choose this type of diet. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 15 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 at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 18, 19, 20. The health of service users is maintained and promoted. Medication is on the whole well managed. EVIDENCE: The service user plans demonstrated that the people who live at the service have access to health care professionals including GP’s, dentist etc. Psychology and psychiatric input is gained as and when required. The Bradbury Group employs their own professionals in this area. As the home is registered for personal care clinical tasks have to be undertaken by the community nurse or alternatively “delegated authority” needs to be gained. This was discussed with the manager on the day of the inspection for one individual that is at the service. The care needs of one individual were discussed during the inspection and it is advised that specialist advice is sought with regard to this issue. Staff need to ensure that people’s health needs do not impact on their dignity and self esteem. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 16 The Old Rectory has in place a policy with regard to the handling of medication. All medication is stored and administrated in line with this policy. Provision is made for those service users who are able to self medicate although this is not applicable at this time. Some of the staff have undertaken medication training while others have not received formal training. These staff have been shown by other staff how to dispense medication. This is not best practise and it is recommended that only staff who have received formal training handle medication. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 17 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 at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 22, 23. People who live at the service are protected by a clear complaints procedure and robust prevention of abuse policies. EVIDENCE: There was evidence in the care and support plan that some of people who live at the service are asked on a regular basis if they are happy with life at the home. This needs to be developed using differing communication methods, if necessary, to ensure that all people are able to express their views. Two written compliments were seen from relatives of people living at the service. There is a formal complaints procedure. One complaint has been received. This complaint occurred during the registration process and was handled in line with the policy. The complaint has been resolved. Staff are aware of the vulnerable adults and whistle blowing policies. Staff stated that they had discussed this area during the induction process. In addition there is in place a policy for the two areas. The policies complied with the Public Disclosure Act and the DOH Guidance ‘No Secrets’. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 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 at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 24, 25, 26, 27, 28, 29, 30. The home is suitable for it’s stated purpose with a good standard of facilities. EVIDENCE: The service was previously a care home for older people. In order to meet the needs of this group of people the building underwent redevelopment and refurbishment prior to being reregistered. This work has been completed to a high standard. All the bedrooms are single with en-suite facilities. Nine of the bedrooms are large and all are able to accommodate a small sitting area. This enables the individual to spend private time in their room if they wish. The additional room contains a separate living space, kitchen, and bathroom. This suite of rooms will be used for an individual who requires less support or for an individual who requires care and support separate from others. The occupied rooms have been personalised In addition to the en-suite facilities there are an additional three bathrooms. One of these bathrooms has been developed since the service opened to meet The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 19 the needs of one individual. All the bathrooms are decorated to a high standard. There is a range of communal spaces as previously described. All are furnished and decorated to a good standard. Due to the needs of one individual the furniture in the lounge area may not be suitable. This may impact on the dignity of this individual. Strong consideration should be given to replacing this furniture with some that is more suitable. This was discussed with the manager on the day of the inspection. The service was clean and tidy on the day of inspection. Adequate provision is in place with regard to infection control and hand washing facilities. There is a sluice but this is rarely used. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 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 at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 31, 32, 33, 34, 35, 36. People who live at the service are supported by adequate numbers of staff. Some staff however are working long shift patterns. Staff have received adequate training to fulfil their role. Recruitment practises are robust. Systems are in place to provide staff with supervision and appraisals. EVIDENCE: The duty rotas were examined. These demonstrated that staffing numbers are provided in numbers according to the needs of the people who live at the home on any given day. Staffing numbers are relatively high due to the complex and occasional challenging needs of the people who live at the service. The rotas examined demonstrated that at least five staff are working a shift of twenty-four hours. This shift includes a waking night. The manager has stated that these staff have opted out of the working time directive. Despite this the management team need to consider the health and safety implications for staff and how this may impact on the standard of care and support that is given when shifts of this lengths are worked. The management team need to ensure that annual health checks are conducted on staff that work night shifts. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 21 All staff receive a two-week induction this is in excess of minimum requirements. All Staff have received training NAPPI and are working through the learning disability framework. This is in line with good practise guidelines. Training in Autistic Spectrum Disorders is currently being sourced. Other training, which has been completed, includes food hygiene, fire prevention, prevention of abuse and administration of medication. Some first aid training has been completed although it could not be confirmed that there are adequate staff with this qualification to enable a first aider to be on each shift. Staff spoken to during the inspection stated that they felt that they had received sufficient training in order to fulfil their role. This is a new staff team with some having no previous experience in this role. Continued staff development is planned and would be welcomed. Consideration should be given to providing training in communication e.g. Somerset Total Communication or similar according to the needs of the people living at the service. There is a planned programme of formal staff supervision and appraisals, in addition to regular staff meetings. This will have a positive contribution to the continued development of the team. Staff recruitment files were viewed during the inspection. These were in good order with all necessary checks being completed prior to employment. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 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 at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 37, 38, 39, 40, 41, 42, 43. The service is well run and managed. The service is yet to develop a quality assurance or self-monitoring systems. A recommendation has been made with regard to the handling of service users’ finances. The health and safety of the people who live at the service is promoted. There are a range of policies and procedures. EVIDENCE: The manager, Mr Kilburn, has worked in the field for a number of years. Mr Kilburn has completed NVQ 4 and is working towards the Registered Manager’s Award. Staff spoken to during the inspection stated that they found Mr Kilburn approachable. There is a clear management structure at both company and service level. The area manager visits the service regularly. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 23 Discussion took place with the manager with regard to the development of a quality assurance/self monitoring system. This aspect will be considered in the near future. As previously stated the area manager visits the service regularly. This includes a tour of the building and gives the opportunity to talk to staff and the people who live at the service. The registered provider, Mr Nick Bradbury, is the appointee for some of the people who live at the service. This means that he has access to the finances of these individuals. In order to safe guard all parties it would be good practise if an alternative person were nominated. This person should not be employed by the service or involved in the management or administration of the company. A family member, advocate or case manager should be considered. The service has a range of policies and procedures. Some of these were viewed on the day of the inspection and were satisfactory. Staff stated that they were aware of the policies and where they would find the information they required. A range of health and safety documentation was seen including fire safety and hot water checks. These were in good order. Consideration should be given to providing training in moving and handling. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 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 CONCERNS AND COMPLAINTS Standard No 1 2 3 4 5 Score 3 3 3 3 3 Standard No 22 23 Score 3 3 ENVIRONMENT INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score 3 3 3 3 3 Standard No 24 25 26 27 28 29 30 STAFFING Score 3 4 3 3 3 3 3 LIFESTYLES Standard No Score 11 4 12 3 13 3 14 3 15 3 16 3 17 Standard No 31 32 33 34 35 36 Score 3 3 1 3 3 3 CONDUCT AND MANAGEMENT OF THE HOME 3 PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 The Old Rectory Score 3 2 2 x Standard No 37 38 39 40 41 42 43 Score 3 3 3 2 3 3 3 DS0000064624.V268408.R01.S.doc Version 5.0 Page 25 Are there any outstanding requirements from the last inspection? No. 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 YA33 Regulation 18 (1) (a) Requirement It is required that the staff shift times are reviewed to ensure that the health and safety of staff and service users are not compromised. All staff who work nights should receive a medical assessment to assess their suitability to work nights on an annual basis. Documentation with regard to night working needs to be kept in line with the Working Time Directive. Timescale for action 31/01/06 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 YA40 YA20 YA19 Good Practice Recommendations It is recommended that appointees for service users’ finances should not be employed by the service or involved in the management or administration of the company. It is recommended that only staff who have received formal medication training handle and dispense medication. It is recommended that the health needs of the identified DS0000064624.V268408.R01.S.doc Version 5.0 Page 26 The Old Rectory 4 5 YA28 YA6 individual are reassessed and that this aspect of her care does not impact on her dignity and self-esteem. It is recommended that the furniture in the lounge be reviewed to ensure it is adequate to meet the needs of the service user group It is recommended that the daily diary be completed on an individual basis. The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 27 Commission for Social Care Inspection Somerset Records Management Unit Ground Floor Riverside Chambers Castle Street Taunton TA1 4AL 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 The Old Rectory DS0000064624.V268408.R01.S.doc Version 5.0 Page 28 - 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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