Care Home: Saltram Crescent, 91 & 99

What the care home does well The home provides a supportive atmosphere that meets the needs of people who use the service. They said they feel safe, well supported, make their own decisions and are more than satisfied with the care received and way it is delivered. There is an assessment procedure that works well. The care plans were up to date focused on the individual and enabled them to lead the life they want. Activities are chosen by people who use the service and suit them and they have a say in how the service is run. What has improved since the last inspection? The care plan system has been streamlined and is now more focused on the individual and encourages them to become more involved in their care planning. What the care home could do better: The physical environment needs to be improved with some areas redecorated, new kitchen equipment and cupboards provided, carpets replaced and equipment repairs carried out. This will ensure that the residents live in a comfortable environment CARE HOME ADULTS 18-65 Saltram Crescent, 91 & 99 91 & 99 Saltram Crescent London W9 3JS Lead Inspector Wynne Price-Rees Unannounced Inspection 26th September & 2 October 2008 10:00 nd Saltram Crescent, 91 & 99 DS0000010872.V367943.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 Saltram Crescent, 91 & 99 DS0000010872.V367943.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. Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Saltram Crescent, 91 & 99 Address 91 & 99 Saltram Crescent London W9 3JS 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) 020 8964 8154 020 8968 1983 Lookahead Housing & Care Manager post vacant Care Home 12 Category(ies) of Mental disorder, excluding learning disability or registration, with number dementia (12) of places Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: 1. The registered person may provide the following category of service only: Care Home only Code PC to service users of the following gender: Either whose primary care needs on admission to the home are within the following categories: 2. Mental Disorder, excluding learning disability or dementia - Code MD The maximum number of service users who can be accommodated is: 12 8th June 2007 Date of last inspection Brief Description of the Service: Saltram Crescent is a Registered Care Home that operates in two, three storey houses (No 91 and No 99). The service is registered to provide accommodation for 12 people with a mental disorder. Each home accommodates six residents and both houses are managed from number 91. Look Ahead Housing and Care Ltd provides the care. The homes are situated in the Queens Park area with good access to public transport and local services. Each person who uses the service has a single bedroom and both houses have a kitchen/diner, lounge, adequate bathroom space and attractive patio garden area to the back of the two houses. Currently No 99, has only male service users. There are male and female service users at No 91. In each house the bedrooms are on the first and second floors making the service unsuitable for anyone with a physical disability. The current scale of charges can be obtained from the service. Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The quality rating for this service is 2 stars. This means the people who use this service experience good quality outcomes. The inspection was unannounced and took seven hours to complete over two days. During the course of the inspection we spoke with people who use the service to get their views of the service they receive. We also spoke with staff, care practices were observed and policies and procedures checked. The Care Manager was not present during the inspection as she was on leave. We inspected all key standards and the information seen was triangulated with that gathered since the previous key inspection including Regulation 37 notifications forwarded. Regulation 37 notifications inform us of any accidents or incidents that affect people who use the service. This was compared with AQAA information returned by the home before the inspection. An AQAA is an annual quality assurance self-assessment carried out by the home. The files of three people who use the service were case tracked. What the service does well: What has improved since the last inspection? The care plan system has been streamlined and is now more focused on the individual and encourages them to become more involved in their care planning. Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 6 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. Saltram Crescent, 91 & 99 DS0000010872.V367943.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 Saltram Crescent, 91 & 99 DS0000010872.V367943.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): 2. People who use the service experience good outcomes in this area. This judgement has been made using available evidence including a visit to this service. The needs of people who use the service are fully assessed prior to moving in and they are able choose if they want to move into the home. EVIDENCE: Whilst meeting with people who use the service during the inspection, they commented on the assessment procedure and opportunity to visit the service before deciding if they wished to move in. These comments are included in the evidence. “I completed an assessment form before moving in”. People who use the service are fully assessed before a decision is made if their needs can be met and the home is suitable for them. The Care Manager and staff team take this decision. People who use the service participate in completing a joint assessment form that means they have more information to decide if they want to move in. “I visited before moving in”. “I stayed overnight”. They are invited to visit the home as many times as they feel necessary before deciding if they want to move in. Care plans and referral forms are completed and forwarded by organisations making referrals to provide further information and inform the decision if a Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 9 placement is suitable. These include departure notes, discharge summary and adult mental health assessments. The files of six people case tracked show the procedure is followed and information needed to make a decision is provided. Saltram Crescent, 91 & 99 DS0000010872.V367943.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 and 9. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. There are comprehensive care plans with information that shows how staff support people to develop their independent living needs. People who use the service are encouraged to make decisions for themselves in a risk-assessed environment. EVIDENCE: Whilst meeting with people who use the service during the inspection, they commented about their involvement in the planning of the care and support they receive. They also commented on their opportunities to make their own decisions in a supportive environment. These comments are included in the evidence text. “I am involved in my care planning”. A sample of three files of people who use the service contained support plans that identified priority needs areas, action plans, goals, how they to be achieved, by whom and when. Staff and people Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 11 who use the service make written comments if they wish. The plans are reviewed a minimum of six monthly or as and when they need updating by staff and people who use the service. They are enabled and underpinned by up to date risk assessments. The plans are discussed at weekly key-working sessions. “I decide what I want to do”. People who use the service are encouraged and enabled wherever possible to participate in the home’s decision-making process. This includes sitting on staff recruitment panels after taking part in a training workshop. House meetings also take place and are used to discuss activity suggestions, complaints, maintenance, disagreements and food menus. Saltram Crescent, 91 & 99 DS0000010872.V367943.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 and 17. People who use the service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. People who use the service have their preferences observed and their social, cultural, religious and recreational needs and interests met, meaning they have fulfilling lifestyles. They also receive a variety of well-balanced meals geared to their individual tastes. EVIDENCE: Whilst meeting with people who use the service during the inspection, they commented about their opportunities for personal development, work, involvement in the local community, daily lives, meals, family contact and activities available to them. These comments are included in the evidence text. The two houses are split with one house providing a service for people with greater needs and the other for people who require less support and this is reflected in the activities provided that are also focused on individual needs and wishes. Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 13 “I choose my activities”. “Its about having freedom to choose” commented residents. People who use the service have individual activity planners that they work on with designated members of staff. Activities are diarised to make sure they are not missed and don’t clash with anything else. Group and individual activities are provided and it is up to the individual how much or how little they join in. There is weekly bingo, arts and crafts, movie nights and a two weekly gardening group run by a visiting gardener. People also go out for meals and make good use of local amenities such as shops, canal walks and the Terrace Day Centre. Generally the outside activities are individualised although group trips to Brighton have taken place. Currently no one is working or attending educational courses through choice. There is support provided should people who use the service decide they wish to seek employment or enrol on courses. “The food is good”. People who use the service plan menus weekly, tend to eat together and use this time to chat, catch up with what people have been doing and socialise. Although a basic menu is agreed it is not rigid and people can change their mind if they wish. They are encouraged to cook if they wish to develop and rediscover life skills needed for independent living. Any religious or cultural food requirements such as halal meat are catered for. Religious and cultural needs are included within care plans and arrangements made to meet them. One person who uses the service regularly attends a temple. People who use the service and staff are currently setting up a calendar of celebratory festivals. Where possible family contact is supported and maintained. Saltram Crescent, 91 & 99 DS0000010872.V367943.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 and 20. People who use the service experience good outcomes in this area. This judgement has been made using available evidence including a visit to this service. People who use the service have their physical and emotional health needs met. Residents are protected by the homes medication policy. EVIDENCE: Whilst meeting with people who use the service during the inspection, they commented about the emotional and health needs support they receive. These comments are included in the evidence text. “I have my own GP”. Health care is included within the support plans. Personal care is not generally required and consists more of prompting and encouragement. People who use the service have access to community-based healthcare including district nurses, dentists, and opticians and encouraged to access them when needed as part of life-skills development. Everyone is registered with a GP and offered annual health checks. There is a healthy living co-ordinator who is involved in the menu planning to encourage healthy eating. Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 15 The medication records were checked for everyone that uses the service and were up to date and correctly recorded. Medication is double checked at the end of each shift. Saltram Crescent, 91 & 99 DS0000010872.V367943.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 and 23. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. People who use the service can feel confident they are listened to and their complaints and concerns investigated with outcomes. They are safe and well protected by the home’s adult protection procedures. EVIDENCE: Whilst meeting with people who use the service during the inspection, they commented on how they feel about the way the home deals with their concerns, complaints and if they feel safe living there. The comments are included in the evidence text. “If I had a problem I would tell staff or the manager”. “I’m very happy living here and don’t have any complaints”. There is a written complaints policy and procedure that people who use the service said they understood and knew how to use. Complaints records are kept with the last entry in 2007. There is also an incident book with one entry for May 2008 that was resolved. Currently there are no Safeguarding Adults issues. The contact number for Westminster City Council Safeguarding team was located on the office wall. Adult protection is part of staff core induction training, they also have access to the training provided by Westminster City Council and in-house refresher courses take place. All staff are CRB checked prior to starting work. CRB is the Criminal Records Bureau. Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 17 Saltram Crescent, 91 & 99 DS0000010872.V367943.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, 28 and 30. People who use this service experience adequate quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. A safe, homely and comfortable environment is provided for people who use the service to live in. Everyone has their own bed-sitting rooms and there are suitable shared areas. Redecoration, repairs and replacement of equipment in some areas are needed to improve the quality of the residents home environment EVIDENCE: Whilst meeting with people who use the service during the inspection, they commented about where they live and if they felt safe, comfortable and happy there. These comments are included in the evidence text. “I enjoy living here it is my home”. “I feel safe living here”. The home provides a comfortable relaxed atmosphere. However a resident commented “It takes a long time to get things fixed”. Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 19 A tour of the buildings showed that whilst there was a homely atmosphere there were a number of areas that required attention. Staff confirmed these had already been reported with some in the process of being attended to whilst others had not been addressed. At number 91 there was a chunk of plaster missing from the wall behind the front door, kitchen tiles are off the wall and part of the upper oven door is missing. The kitchen cupboards were old and worn. The tiles are off the wall in the staff shower room that means it cannot be used. Ceiling paint is flaking off and the fan is not working. The stair carpets smell musty and present tripping hazards and it is unclear if all fire doors form an affective seal. The lock on the office door does not work properly. There were two fire extinguishers that were no longer attached to the walls as the hooks had come away. The organisation responsible for fire equipment visited the week before and provided interim casings for the extinguishers, but they are now tripping hazards when entering or leaving the office. The washing machine and tumble dryer are not working and people have to use those at number 99. This has been reported to the maintenance team. The kitchen at number 99 also has worn décor and there was a toilet light fitting that was not supported by a ceiling rose. Both lounges require redecoration and have been affected by excessive smoking. These repairs and redecoration matters must be followed up by the organisation to ensure that the quality of the residents home environment improves Saltram Crescent, 91 & 99 DS0000010872.V367943.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, 34 and 35. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. There are suitably trained, competent and diverse staff employed to meet the needs and wishes of people who use the service that have been properly vetted. People can be confident they are protected by the home’s robust recruitment policies and procedures. EVIDENCE: Whilst meeting with people who use the service and staff during the inspection, they commented about the staff and staffing at the home. These comments are included in the evidence text. “Staff are okay and do their utmost for us”. People who use the service said they found staff to be friendly, approachable and supportive. The rota demonstrated there are enough people on duty at all times to meet the needs of people who use the service. All staff are CRB checked before starting work as part of a thorough recruitment procedure that protects people who use the service and meets all the criteria required by the standard. Five out of six staff have attained NVQ level two qualifications and three are working towards NVQ level 3. They also have access to induction training and a Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 21 rolling training programme. Appraisals take place six monthly with regular six weekly supervisions. Care practice observed including when staff were unaware we were present and conversations with people who use the service indicated the staff team are competent, efficient and also friendly. Saltram Crescent, 91 & 99 DS0000010872.V367943.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, 39 and 42. People who use this service experience good quality outcomes in this area. This judgement has been made using available evidence including a visit to this service. The home is well managed in the interests of those who use the service and the quality assurance system is effective. Health and safety is well managed meaning that people who use the service live in a safe environment. EVIDENCE: Whilst meeting with people who use the service and staff during the inspection, they commented about the home’s management. These comments are included in the evidence text. There is a new Care Manager in post who was on leave during the inspection. Despite them not being present the home continued to run well in their absence with a well trained and efficient staff team. The new manager has met all registration requirements. Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 23 A Regulation 26 visit took place during the inspection and some areas such as medication were looked at jointly with the person conducting the Regulation 26 visit and we had the same findings regarding medication. A Regulation 26 visit is carried out monthly. This is by someone from a different project, unannounced and part of the quality assurance system. These reports are made available to the Commission should we require them. The quality assurance system is comprehensive with identifiable performance indicators and checks. The home’s performance is measured against the minimum standards and an annual business plan is put together after consultation with people who use the service for projected planning. There are annual customer satisfaction surveys with feedback to individual projects. The projects then provide an action plan that is reviewed six monthly. Fire drills take place quarterly, there are weekly fire alarm tests and firefighting equipment is serviced annually. Portable appliance testing takes place annually or when electrical equipment is brought into the home. Hot water temperatures are checked and recorded daily and fridge and freezers twice per day. Staff have completed mandatory training in health and safety matters. Saltram Crescent, 91 & 99 DS0000010872.V367943.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 X 2 3 3 X 4 X 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 2 25 X 26 X 27 X 28 2 29 X 30 2 STAFFING Standard No Score 31 X 32 3 33 X 34 3 35 3 36 X 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 3 X 3 X 3 X X 3 X Saltram Crescent, 91 & 99 DS0000010872.V367943.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 YA28 Regulation 16 (2) (g) Requirement Both kitchens must be redecorated with new units provided. The cooker door in 91 must be replaced or a new cooker purchased. The kitchen tiles must be put back on the wall or replaced. The staff shower must be retiled, fan repaired and ceiling redecorated. The wall behind the front door must be re-plastered and decorated, fire extinguishers remounted, fire doors tested and made good, office lock made to work, and light fitting in the toilet of 99 made safe. Both lounges require redecoration, the stair carpets in 91 must be replaced The washing machine and tumble-dryer must be repaired or replaced. Timescale for action 01/02/09 2. 3. YA28 YA24 23 (2) (c) 23 (2) (b) 01/02/09 01/02/09 4. YA24 23 (2) (d) & 16 (c) 23 (2) (c) 01/02/09 4. YA24 01/11/08 Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 26 RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. Refer to Standard Good Practice Recommendations Saltram Crescent, 91 & 99 DS0000010872.V367943.R01.S.doc Version 5.2 Page 27 Commission for Social Care Inspection London Regional Office 4th Floor Caledonia House 223 Pentonville Road London N1 9NG 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. 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