Seton Health At Schuyler Ridge Residential H C
Inspection history, citations, penalties and survey trends for this long-term care facility in Clifton Park, New York.
- Location
- 1 Abele Drive, Clifton Park, New York 12065
- CMS Provider Number
- 335774
- Inspections on file
- 13
- Latest survey
- March 4, 2025
- Citations (last 12 mo.)
- 0
Citation history
Health deficiencies cited at Seton Health At Schuyler Ridge Residential H C during CMS and state inspections, most recent first.
Two residents experienced neglect resulting in injuries and delayed care. A resident with severe cognitive impairment fell out of bed due to staff not following the care plan, while another resident with osteoporosis had a fracture misdocumented by an ADON, delaying pain management.
The facility failed to develop and implement comprehensive care plans for several residents, including those with specific medical needs such as oxygen administration, splint application, hospice care, and potential abuse risk. The lack of adherence to the facility's policy on care planning compromised resident safety and well-being.
Two residents with communication impairments were not provided with appropriate aids to maintain or improve their communication abilities. A resident with hearing loss did not have consistent access to a communication board, and staff were often unaware of its location. Another nonverbal resident's picture communication board was not used, and staff were unaware of its necessity, relying instead on yes/no questions and facial expressions. Facility policies on effective communication were not followed, impacting residents' ability to communicate.
The facility failed to provide appropriate respiratory care by not labeling oxygen tubing and not administering oxygen as per physician orders for three residents. Observations showed incorrect oxygen flow rates and unlabeled tubing, contrary to facility policy. Staff interviews confirmed these deficiencies, highlighting a lack of adherence to professional standards.
The facility failed to properly label and store medications, with several instances of missing open and expiration dates on medication carts and in a medication room. Staff interviews revealed a lack of awareness about labeling requirements for medications with shortened expiration dates. The DON indicated that the responsibility for maintaining medication carts and verifying expiration dates was assigned to the nurse passing medications, but this was not consistently executed.
The facility did not ensure residents received beverages according to their preferences and needs during a lunch meal observation. Two residents on the Saratoga Hills unit did not receive the beverages listed on their meal tickets, and staff interviews revealed inconsistencies in the process of offering drinks. Staff were expected to ask residents about their preferences, but this was not consistently done.
The facility did not maintain food service safety standards, as observed during a survey. Broken wall coving tiles were found in the dishwashing and main kitchen areas, and food particles soiled microwave ovens, refrigerators, and dining tables in three resident unit kitchenettes. The Executive Chef acknowledged these issues.
The facility failed to implement an effective infection prevention and control program, as evidenced by deficiencies involving two residents. Staff did not adhere to proper procedures for donning and doffing PPE for a resident on enhanced precautions, and another resident's wound care was conducted without proper gowning and hand hygiene. Interviews revealed a lack of awareness of Enhanced Barrier Precautions, indicating gaps in training and compliance.
The facility failed to treat residents with dignity, as staff did not knock before entering rooms, delayed meal assistance while using personal phones, and inadequately addressed wandering residents disturbing others' personal items. These actions compromised the residents' rights to privacy and timely care.
A facility failed to coordinate PASARR assessments for a resident with a new diagnosis of a serious mental disorder. The resident, admitted with chronic obstructive pulmonary disease, dementia, and Bipolar I disorder, was not referred for a PASARR Level II Evaluation despite having an active diagnosis of Bipolar I. The facility's policy required a Level II evaluation if a serious mental illness was indicated, but this was not completed. Psychiatry consults confirmed the resident's diagnosis, yet no Level II evaluation was initiated.
A resident with chronic obstructive pulmonary disease was receiving oxygen at 4.5 liters per minute, contrary to the medical order of 2 liters per minute. The care plan was not updated to reflect this change, and staff were unaware of the correct order. Interviews revealed that nursing staff should have been following the physician's orders and updating care plans accordingly.
A resident with dementia and other conditions was not provided necessary morning care on two occasions, remaining in bed while others attended activities. The resident's care plan required assistance and a preference to be up by 10:00 AM. Staff were unaware of assignments, and there was a lack of communication about staffing shortages, leading to the deficiency.
A resident with Alzheimer's and a history of falls was left alone in the bathroom, contrary to their care plan and posted signs. Staff interviews revealed inconsistencies in supervision, with the resident sometimes using the bathroom independently and turning off the chair alarm. The DON and RN Unit Manager confirmed the need for assistance, but staff did not consistently adhere to safety protocols.
A resident with a history of cerebral infarction and other conditions reported gum pain affecting their ability to chew, but the facility failed to provide emergency dental care. Despite the resident's complaints, they had not been seen by a dentist since refusing an evaluation nearly two years prior. Staff interviews revealed a lack of communication and documentation regarding the resident's dental issues, and the facility's policy for immediate referral in case of dental emergencies was not followed.
Neglect Leads to Resident Injuries and Delayed Care
Penalty
Summary
The facility failed to protect two residents from neglect, resulting in injuries and delayed care. Resident #53, who had severe cognitive impairment and a history of falls, fell out of bed and sustained injuries because the staff did not follow the care plan, which required placing fall mats next to the bed. The Certified Nurse Aide responsible for the resident's care admitted to not following the care plan, leading to the resident's fall and subsequent injuries. Resident #112, who had significant cognitive impairment and a history of osteoporosis, experienced a fall and complained of back pain. An Assistant Director of Nursing incorrectly documented that the resident's x-ray showed no fractures, despite the presence of a thoracic vertebrae fracture. This error led to a delay in appropriate pain management and care for the resident. The Assistant Director of Nursing later admitted uncertainty about reviewing the diagnostic report, and the resident's family was not informed of the change in condition.
Failure to Implement Comprehensive Care Plans
Penalty
Summary
The facility failed to develop and implement comprehensive person-centered care plans for several residents, as identified during a recertification and abbreviated survey. For Resident #20, the care plan for oxygen administration was not followed. Resident #22's care plan required the application of a right blue posey splint, which was not consistently applied, and there was no assessment or documentation regarding the resident's refusal to wear the splint. Resident #46 did not have a care plan addressing incontinence concerns, and Resident #57 lacked a hospice care plan after transitioning to hospice care following a significant change in condition. Resident #101, who was dependent on care due to quadriplegia, did not have a care plan for potential abuse, despite reporting verbal abuse and rough treatment by a Certified Nurse Aide. The facility's investigation into the abuse allegation did not result in the development of a care plan to address the resident's vulnerability. Resident #109 and Resident #113, both with histories of aggressive behavior, did not have appropriate care plans in place or implemented. Additionally, Resident #114 did not have a care plan developed for a new wound. The facility's policy required the development of a baseline interdisciplinary care plan within 48 hours of admission and a comprehensive care plan within 14 days. However, the facility failed to adhere to this policy, resulting in inadequate care planning for the residents mentioned. This lack of comprehensive care planning compromised the residents' safety and well-being, as evidenced by the observations, interviews, and record reviews conducted during the survey.
Deficiency in Communication Support for Residents with Impairments
Penalty
Summary
The facility failed to ensure that two residents with communication impairments were provided with appropriate treatment and services to maintain or improve their communication abilities. Resident #13, who had severe cognitive impairment and hearing loss, was not consistently provided with access to a communication dry/erase board, which was necessary for effective communication. Despite the care plan and Kardex indicating the need for a communication board, staff were often unaware of its location or did not use it, relying instead on hand signals or speaking close to the resident's ear. The board was not kept with the resident, making it difficult for staff to use it when needed. Resident #74, who was nonverbal due to conditions including aphasia and dementia, was supposed to use a picture communication board to express their needs. However, the communication sheet provided was small, cumbersome, and not utilized by staff, as it was often found across the room and under other objects. Staff were not aware of the need to use the communication board and instead relied on yes/no questions and interpreting facial expressions. The Speech Language Pathologist was unaware that the picture board was not in use and had not explored other communication modalities. The facility's policies on effective communication with residents with impairments were not followed, leading to deficiencies in providing necessary communication aids to the residents. The Director of Nursing acknowledged that the communication boards should have been available and used as per the care plans, but they were not consistently accessible to the residents, impacting their ability to communicate effectively.
Deficiency in Oxygen Administration and Tubing Labeling
Penalty
Summary
The facility failed to ensure that residents received the necessary respiratory care and services according to professional standards of practice. Specifically, the facility did not date and label supplemental oxygen tubing to reflect when it was changed, and supplemental oxygen was not provided as ordered by the physician for three residents. The facility's policy on oxygen administration required that oxygen tubing be labeled and dated, and that oxygen be administered according to physician orders. However, observations revealed that the oxygen tubing for the residents was not labeled with the date of change, and the oxygen flow rates were not set according to the physician's orders. Resident #20, who had chronic obstructive pulmonary disease and was dependent on supplemental oxygen, was observed receiving oxygen at 4.5 liters per minute, contrary to the physician's order of 2 liters per minute. The oxygen tubing was not labeled with the date it was changed, and the Treatment Administration Record indicated that the tubing was to be changed weekly. Licensed Practical Nurse #3 was unaware of the correct oxygen order and acknowledged that the tubing should have been labeled. Resident #60, also with chronic obstructive pulmonary disease, was observed receiving oxygen at 3 liters per minute instead of the ordered 2 liters per minute. Similarly, the oxygen tubing was not labeled with the date of change. Resident #75, with hypertensive heart failure, was observed with an oxygen regulator set to zero and later at 4 liters per minute, but the oxygen bottle needed changing. The tubing was also unlabeled. Interviews with staff, including the Assistant Director of Nursing and the Director of Nursing, confirmed that the facility's policy was not followed, and the oxygen administration was inappropriate and potentially harmful.
Medication Labeling and Storage Deficiencies
Penalty
Summary
The facility failed to ensure that drugs and biologicals were labeled and stored according to professional standards of practice. During the recertification survey, it was observed that medication carts and a medication room contained several medications without proper labeling of open and expiration dates. Specifically, two open bottles of ear drops and four inhalers lacked open and expiration dates, while one bottle of ear drops and three bottles of eye drops were expired. Additionally, two vials of insulin and a bottle of purified protein derivative (PPD) were found without open or expiration dates. Interviews with facility staff revealed a lack of awareness regarding the shortened expiration dates of medications once opened. Licensed Practical Nurses (LPNs) were unaware of the need to label medications with open dates and expiration dates, and there was a reliance on preprinted expiration dates on bottles. The Director of Nursing (DON) indicated that the responsibility for ensuring medication carts were clean and orderly, and that medications were checked for expiration dates, fell on the nurse assigned to pass medications. However, this task was sometimes delegated to the overnight medication nurse. The facility's policy required that medications with shortened expiration dates be labeled upon opening, but this was not consistently followed by the staff, leading to the observed deficiencies.
Failure to Provide Beverages Consistent with Resident Preferences
Penalty
Summary
The facility failed to ensure that residents on the Saratoga Hills unit received beverages consistent with their needs and preferences, as evidenced during a lunch meal observation. Specifically, two residents did not receive the beverages documented on their meal tickets. One resident did not receive the 8 ounces of water listed, and another did not receive the 6 ounces of coffee. Both residents reported that they were not asked if they wanted these beverages when their meals were delivered to their rooms. Interviews with staff revealed inconsistencies in the process of providing beverages to residents. A Certified Nursing Aide mentioned that they sometimes provided drinks based on residents' preferences rather than what was listed on the meal ticket. The Registered Nurse Unit Manager and Licensed Practical Nurse confirmed that staff were expected to ask residents about their beverage preferences and provide accordingly. However, the Clinical Nutrition Manager stated that while meal tickets should guide beverage choices, residents should still be offered the drinks listed on their tickets.
Food Service Safety Deficiency
Penalty
Summary
The facility failed to ensure that food was stored, prepared, distributed, or served in accordance with professional standards for food service safety. During the recertification survey, it was observed that 10 wall coving tiles were broken in the dishwashing machine area, and seven wall coving tiles were broken in the main kitchen. Additionally, the microwave ovens, refrigerators, including door gaskets, and the undersides of dining tables were soiled with food particles in three resident unit kitchenettes. These observations were made in the [NAME] kitchenette, [NAME] A kitchenette, and [NAME] B kitchenette. The Executive Chef acknowledged the issues and indicated that they would address them with housekeeping and maintenance.
Infection Control Deficiencies in PPE Use and Wound Care
Penalty
Summary
The facility failed to implement an effective infection prevention and control program, as evidenced by deficiencies observed during a recertification survey involving two residents. For Resident #57, staff did not adhere to proper procedures for donning and doffing personal protective equipment (PPE). Specifically, a Certified Nurse Aide entered the resident's room without a gown, wearing gloves that had been used to handle outside bins, and did not sanitize hands before putting on a gown. After providing care, the aide improperly removed the gown without first removing gloves and carried the soiled gown across the hallway, failing to dispose of it in the designated receptacle immediately. In the case of Resident #77, the staff did not follow proper infection control procedures during wound care. A Licensed Practical Nurse conducted a dressing change without wearing a gown and failed to sanitize hands after removing gloves. The nurse was unaware of the requirement to wear a gown under Enhanced Barrier Precautions, which were newly implemented at the facility. Additionally, there was no hand sanitizer available in the resident's room, further complicating adherence to infection control protocols. Interviews with staff revealed a lack of awareness and understanding of the Enhanced Barrier Precautions, indicating a gap in training and compliance with infection control measures. The facility's Infection Prevention and Control Plan aimed to prevent the transmission of infectious diseases, but the observed practices demonstrated a failure to meet these objectives, compromising the safety and sanitary conditions for residents.
Failure to Ensure Resident Dignity and Timely Assistance
Penalty
Summary
The facility failed to ensure that residents were treated with dignity and respect, as evidenced by several incidents involving staff behavior and interactions with residents. For instance, multiple residents reported that staff did not knock on their doors before entering, which is a basic courtesy and respect for privacy. This was observed with several residents, including one who had reported the issue to the resident council, indicating a pattern of behavior rather than isolated incidents. Additionally, there were issues with meal service and staff engagement during mealtimes. One resident, who required assistance with feeding due to severe cognitive impairment, was left without food for an extended period while other residents were served. A Certified Nurse Aide was observed using their personal phone instead of assisting the resident, delaying the resident's meal for over 20 minutes. This lack of attention and prioritization of personal activities over resident care further highlights the deficiency in providing dignified care. Another incident involved a resident's personal items being disturbed by another resident who frequently wandered into their room. Despite the placement of a red stop sign to deter entry, the wandering continued, and staff appeared dismissive of the concerns raised by the resident's representative. These incidents collectively demonstrate a failure to uphold the residents' rights to a dignified existence and self-determination, as required by regulations.
Failure to Coordinate PASARR Assessments for Resident with Mental Disorder
Penalty
Summary
The facility failed to ensure that assessments were coordinated with the Pre-Admission Screening and Resident Review (PASARR) program for a resident with a new diagnosis of a serious mental disorder. Specifically, the resident, who was admitted with chronic obstructive pulmonary disease, dementia, and Bipolar I disorder, was not referred for a PASARR Level II Evaluation despite having an active diagnosis of Bipolar I. The facility's policy required that all individuals seeking admission undergo a PASARR Level I screening, and if indicated, a Level II evaluation should be completed by a qualified mental health professional. The deficiency was identified during a recertification survey, where it was noted that the resident's Minimum Data Set documented severe cognitive impairment and an active diagnosis of Bipolar I. Despite this, a SCREEN dated earlier in the year did not document a diagnosis of a serious mental illness. Psychiatry consults throughout the year confirmed the resident's diagnosis of major depressive disorder and bipolar disorder, yet no Level II evaluation was initiated. During an interview, a social worker indicated that the hospital was responsible for completing the PASARR, but acknowledged that a Level II screen should have been initiated if a serious mental illness was diagnosed after admission.
Failure to Update Care Plan for Oxygen Therapy
Penalty
Summary
The facility failed to ensure that the Comprehensive Care Plan for a resident was reviewed and revised by the interdisciplinary team to reflect changes in the resident's oxygen therapy. Specifically, the care plan did not include the updated medical order for the resident's oxygen liter flow. The resident, who was admitted with chronic obstructive pulmonary disease and dependence on supplemental oxygen, was observed receiving oxygen at 4.5 liters per minute, contrary to the medical order of 2 liters per minute. This discrepancy was not reflected in the resident's care plan, which documented an incorrect oxygen flow rate of 3 liters per minute. Interviews with facility staff revealed a lack of awareness and adherence to the correct oxygen order. A Licensed Practical Nurse initially believed the order was for 3 liters per minute but later acknowledged the correct order of 2 liters per minute after reviewing the medical records. The Assistant Director of Nursing and the Director of Nursing both stated that nursing staff should be aware of and follow the physician's orders, and that care plans should be updated to reflect any changes in the resident's status. The failure to update the care plan and ensure the correct oxygen administration was identified as inappropriate and potentially harmful to the resident.
Failure to Provide Necessary Care for Resident's Daily Living Activities
Penalty
Summary
The facility failed to ensure that a resident, who was unable to perform activities of daily living, received the necessary services to maintain good grooming, personal, and oral hygiene. Specifically, Resident #74 was observed in bed without morning care provided on two separate occasions, while other residents were attending meals and activities. The resident was admitted with diagnoses of achalasia, aphasia, and dementia, and required assistance with activities of daily living due to balance problems, limited range of motion, weakness, dementia, and anxiety. The comprehensive care plan indicated that the resident preferred to be out of bed by 09:30-10:00 AM and required a complete one-person assist. On two separate dates, the resident was found still in bed wearing nightclothes, with a tube feed bottle half completed at the bedside. Interviews revealed that the resident's representative had previously discussed the resident's preference to be up early with staff, who were receptive to the plan. However, the resident was still found in bed after 11:00 AM on multiple occasions. The Assistant Director of Nursing and Certified Nurse Aide were unaware of the resident's assignment, and there was a lack of communication regarding staffing assignments. Additionally, the Director of Nursing was not informed of a staffing shortage, which contributed to the failure to provide the necessary care for the resident.
Failure to Provide Adequate Supervision in Bathroom
Penalty
Summary
The facility failed to ensure a safe environment for Resident #11, who was left alone in the bathroom despite clear instructions in their care plan, Kardex, and posted signs indicating that they should not be left unattended. Resident #11, who has Alzheimer's Disease, chronic systolic heart failure, and a history of falls, was observed alone in the bathroom on multiple occasions. The resident's care plan specifically required assistance with personal hygiene and supervision in the bathroom to prevent accidents. Interviews with staff revealed inconsistencies in following the care plan. Certified Nursing Aide #1 and Licensed Practical Nurse #1 acknowledged that Resident #11 sometimes used the bathroom independently, and the chair alarm intended to alert staff was not always effective, as the resident could turn it off. Licensed Practical Nurse #2 admitted to leaving the resident alone in the bathroom, despite knowing the resident's need for supervision. The staff's failure to consistently monitor and assist the resident in the bathroom contributed to the deficiency. The Director of Nursing and Registered Nurse Unit Manager confirmed that Resident #11 required assistance in the bathroom for safety reasons. Despite the care plan and posted signs, staff did not consistently adhere to the required supervision, leading to a lapse in safety protocols. This deficiency highlights a failure in ensuring adequate supervision and accident prevention measures for Resident #11.
Failure to Provide Emergency Dental Care
Penalty
Summary
The facility failed to ensure that Resident #76 received routine and 24-hour emergency dental care, as required. Resident #76, who had diagnoses including cerebral infarction, paroxysmal atrial fibrillation, and epilepsy, reported experiencing pain in their lower gum, which made it difficult to chew food. Despite the resident's complaints on February 25, 2025, and the presence of gum pain for several weeks, the facility did not assist the resident in obtaining emergency dental care. The resident had not been seen by a dentist since March 15, 2023, when they refused an evaluation. The facility's policy required immediate referral to a dentist if pain or a dental emergency was present, but this was not followed. Interviews with staff revealed a lack of communication and documentation regarding the resident's dental issues. Licensed Practical Nurse #2 was aware of the resident's gum pain but did not report it to a Registered Nurse for further assessment. Registered Nurse #1 was unaware of the resident's complaints and stated that the resident should have been put on the list to see the dentist if they had reported gum pain. The Director of Nursing indicated that residents were expected to be seen by the dentist annually, with additional appointments as needed, but this protocol was not adhered to in the case of Resident #76.
Latest citations in New York
A resident with spastic quadriplegic cerebral palsy, severe hypoxic ischemic encephalopathy, chronic respiratory failure, and a tracheostomy was on continuous pulse oximetry with ordered SpO2 parameters and linked Vocera alerts. When the resident’s oxygen saturation dropped significantly, the Vocera system sent sequential alarms to the primary RN, buddy RN, charge RN, and RT. The primary RN repeatedly pressed “Accept” on the alert device without assessing the resident, while the buddy RN, charge RN, and RT did not respond to the alarms, each assuming others would intervene or not recalling the alert. For approximately 25 minutes, no assigned clinician assessed the resident despite ongoing alarms, until another RN, not assigned to the resident, heard an alarm while passing the room and found the resident unresponsive and gray. A Code Blue was initiated, CPR was performed, and the resident was transferred to the hospital, where they were found to have no brain activity and later died. The facility’s investigation determined that staff failed to respond to and appropriately manage the pulse oximetry/Vocera alerts and failed to maintain and use required communication devices as expected.
A resident with Parkinson’s disease, dementia with behavioral disturbances, and known exit-seeking behaviors, care planned with a wander alarm, eloped through a 3rd floor stairwell door whose alarm had been disabled days earlier by maintenance and security while addressing a wandering system issue. A plastic barrier was placed in front of the door, but the door remained accessible and unrepaired. Video showed the resident repeatedly attempting to exit, bypassing the barrier, trying to remove the wander device, and ultimately opening the door, falling into the stairwell, and leaving the unit. Staff observed the resident at the door but did not consistently redirect them, and the resident was later found outside the building by a visitor after staff realized the resident was missing and discovered the wheelchair in the stairwell.
Two residents with psychiatric and behavioral histories were waiting by an elevator in a lobby when one, known to have prior aggressive behavior and a care plan noting risk for physical aggression, removed a wheelchair armrest and struck the other in the forehead, causing a bump and laceration that required ED evaluation. Video, staff, and security accounts confirmed that the aggressor resident was able to access and weaponize the removable armrest in a common area despite prior documented altercations and behavioral concerns, and was only on 30‑minute checks at the time, resulting in a failure to protect another resident from physical abuse.
Staff failed to respond promptly to an oxygen alert alarm for a resident with spastic quadriplegic CP, severe hypoxic ischemic encephalopathy, chronic respiratory failure, severe cognitive impairment, and total dependence for ADLs, resulting in the resident being found unresponsive with gray skin and requiring a Code Blue, CPR, and hospital transfer where no brain activity was found and life support was later withdrawn. Despite facility policy requiring alleged or suspected neglect and serious bodily injury to be reported to the State Agency within 2 hours (or within 24 hours if no serious bodily injury), the Administrator was not notified until days after the event and the NYS DOH was notified four days after the incident; the DON reported they were initially unaware of the failure to respond to alarms or of the need to report the incident, and the Administrator stated they had not been informed of the Code Blue on the day it occurred.
Surveyors found that the facility failed to implement an effective infection surveillance and reporting process during a norovirus gastroenteritis outbreak and in its routine infection tracking. During the outbreak, only a single-day tracking sheet was completed for several residents with gastrointestinal illness on two units, and daily surveillance with updated symptoms and management was not maintained as required by facility policy. Despite receiving a directive from the state health department to submit a Nosocomial Outbreak Reporting Application for the identified cluster, the DON acknowledged that the report was never submitted. Additionally, monthly infection control line lists for residents on antibiotics for various infections lacked documentation of signs and symptoms, diagnostic and lab results, precautions used, and outbreak potential, even though the IP relied on these lists for surveillance.
A resident with multiple chronic conditions and numerous scheduled medications had repeated discrepancies between scheduled morning medication times and documented administration times. On multiple days, all medications ordered for a 9:00 a.m. pass were documented as given around midday by an RN, contrary to policy requiring timely administration and immediate electronic documentation. The RN cited computer timeouts, possible late documentation, and workload pressures, while leadership acknowledged that a single nurse was responsible for passing medications to roughly 40 residents within a limited time window and that MAR review was primarily done by the passing nurse and through monthly reports, with no routine MAR review by the pharmacy consultant.
The facility did not ensure residents understood how to file grievances and failed to document and track grievances and their resolutions. Residents reported that they only voiced concerns during resident council and were unclear about the grievance process otherwise, and the designated Grievance Officer could not produce a grievance log or forms. The DON acknowledged the grievance process was informal and lacked clear documentation. In addition, a resident with significant cardiac and neurologic conditions and moderately impaired cognition had a representative who raised multiple concerns about care coordination, communication, discharge planning, call bell response, personal property, preferences, and nutrition, but these grievances were largely handled verbally, with no consistent documentation of how each concern was addressed or resolved.
Surveyors found that the facility failed to provide timely toileting assistance and call bell response for multiple residents who were dependent on staff for ADLs. A resident with Parkinson’s disease and dementia, care planned for two-hour toileting checks, was found by family with urine-saturated clothing and wheelchair cushion after a CNA admitted not changing or checking on the resident for most of a shift, and documentation showed numerous missing toileting and check entries over several months. Another resident with a history of stroke and MI, requiring maximal assist for toileting, reported long waits for morning care while the call bell rang, with staff not responding for extended periods, and the resident’s representative described multiple episodes of call bell waits exceeding an hour. Resident Council minutes, call bell audits, and observations showed repeated long call bell wait times, including bells ringing for 15–45 minutes while various staff passed the rooms without responding, and a spouse reported frequent overnight calls from a resident seeking help because call bells were unanswered.
A resident with bowel incontinence and new-onset loose, watery stools and nausea had a physician and NP order for a stool bacterial detection panel with C. difficile and a GI PCR, along with PRN Zofran. Over subsequent shifts, documentation showed the resident remained incontinent of bowel and that the ordered stool collection was repeatedly marked on the TAR as "not administered, unable to obtain" by LPNs, despite multiple incontinence episodes. There was no documentation that the NP or physician were notified that the ordered stool specimen had not been collected, even though facility policy required practitioner notification when orders were not carried out and the physician and NP later stated they expected to be informed if a lab test they ordered was not completed.
A resident with vascular dementia, behavioral disturbances, and dependence for transfers and toileting was sent to the hospital for suspected GI bleeding, with documentation indicating an unplanned hospital transfer and anticipated return. An IDT meeting held earlier did not document any discharge planning, and the resident’s care plan lacked a planned discharge. While the resident remained hospitalized, the facility issued a same-day discharge notice citing inability to meet needs and endangerment to others, based on interference from the resident’s guardians rather than documented resident behavior, and later did not accept the resident back after medical clearance. The medical record contained no IDT discharge plan and no subsequent nursing or social work notes, demonstrating a lack of documented discharge planning and coordination.
Failure to Respond to Pulse Oximetry Alarms for Tracheostomy-Dependent Resident
Penalty
Summary
The deficiency involves the facility’s failure to ensure that a resident requiring respiratory care and continuous pulse oximetry monitoring received services consistent with professional standards of practice and the resident’s care plan. The resident had spastic quadriplegic cerebral palsy, severe hypoxic ischemic encephalopathy, and chronic respiratory failure, was severely cognitively impaired, and was totally dependent on staff for all ADLs. The care plan and physician’s orders required mechanical ventilation with CPAP to tracheostomy collar overnight, humidified trach collar oxygen during the day, and maintenance of oxygen saturation above 92%, with pulse oximeter alarm parameters set to alert below 92%. The resident was equipped with a pulse oximeter linked to the Vocera alert system, which generated alarms at the bedside and on staff mobile devices when oxygen saturation fell outside ordered parameters. On the day of the incident, the resident’s oxygen saturation dropped to 84% at 8:58 AM, triggering an alert to the primary RN via the Patient Safe Solutions/Vocera system, followed by sequential escalation to the buddy RN, the charge RN, and the RT when not acknowledged. The Call Point Detailed Activity Report showed that an alert was sent to the primary RN at 8:58 AM, to the buddy RN at 8:59 AM, and to the charge RN and RT at 9:01 AM. The primary RN pressed “Accepted” on the device at 9:04 AM, and again when the system alerted at 9:17 AM and 9:18 AM, but did not go to the resident’s room to assess the resident and did not document any assessment or intervention. The buddy RN reported not recalling hearing the alert and stated they were administering medications and unaware of the resident’s distress until the rapid response was called. The charge RN acknowledged receiving the alert but did not respond timely, stating they expected the primary or buddy nurse to respond. The RT stated they received the alert but were busy with other residents and expected other staff to respond. From 8:58 AM to 9:23 AM, no assigned nurse or RT responded to the alarms or performed a clinical assessment of the resident, and the alarm cycle continued without intervention. At 9:23 AM, a second alert was triggered when the resident’s oxygen saturation dropped to 52%. An RN who was not assigned to the resident heard an alarm while passing the room, entered, and found the resident in a wheelchair, unresponsive with gray skin. This RN activated a rapid response/Code Blue, assisted in returning the resident to bed, and another RN began chest compressions. EMS was called and arrived at 9:44 AM; a pulse was briefly restored, and the resident was placed on a ventilator and transferred to the hospital, where they were determined to have no brain activity. Life support was later terminated and the resident expired. The facility’s own investigation concluded that nursing and respiratory staff failed to respond to alarms, failed to appropriately acknowledge and review alerts, failed to maintain accessibility to required communication devices, and failed to escalate when they were occupied or unable to respond, resulting in actual harm and Immediate Jeopardy to the resident and placing other monitored residents at risk.
Removal Plan
- Review camera footage, Patient Safe Solution phone verification notifications, and the pulse oximetry policy.
- Re-educate involved staff on pulse oximetry alarm response, notification handling, and escalation expectations.
- Send voice alarm presentation via email to all assistant nurse managers and assistant directors of nursing for review during evening and morning huddles.
- Ensure Vocera device functionality is reviewed and staff are instructed to keep devices accessible and operational.
- Have IT/MIS check and confirm monitoring equipment is functioning properly.
- Implement disciplinary action for staff involved.
- Discuss and initiate a root cause analysis.
- Review and revise the pulse oximetry policy.
- Provide leadership oversight.
- Implement an audit of alert response times.
Elopement of High-Risk Resident Through Disabled Stairwell Door Alarm
Penalty
Summary
The deficiency involves the facility’s failure to provide adequate supervision and maintain a safe environment for a resident with known exit-seeking behaviors and elopement risk. The resident had diagnoses of Parkinson’s disease, dementia with behavioral disturbances, and anxiety, and was assessed as having moderately impaired cognition. The resident’s MDS documented exit-seeking behaviors and daily use of a wander/elopement alarm, and the comprehensive care plan identified the resident as an elopement risk/wanderer related to disorientation to place, with an intervention for a wandering device on the ankle. A physician’s order also specified a wandering device to the right ankle with checks every shift. The 3rd floor North stairwell door alarm had been disabled by maintenance following a work order dated 07/02/2024. Maintenance and security staff attempted to address a wandering system alarm issue, and the alarm on the 3rd floor North stairwell door was turned off by removing a screw from the alarm box. A yellow plastic accordion-style barrier was placed in front of the door, and nursing staff were notified that the door was broken. However, the door itself remained accessible, and the alarm remained disabled for days prior to the elopement. Staff on the unit, including CNAs, were not all aware that the stairwell door was broken, and the door was not repaired until 07/17/2024. On the day of the incident, video footage showed the resident repeatedly exit-seeking at the 3rd floor North stairwell door over several hours. The resident moved the yellow barrier, wheeled around it, and closed it behind them. At one point, two unidentified staff observed the resident at the door, opened the barrier, and walked away without redirecting the resident. The footage documented multiple attempts by the resident to exit, including attempts to remove the wander alert bracelet and repeated efforts to push on the delayed egress bar with their leg and hands. Eventually, the resident stood from the wheelchair, pushed the crash bar, opened the door, and fell backwards into the stairwell while pulling the wheelchair through. The resident then maneuvered the wheelchair into the stairwell and exited the unit. Staff later discovered the resident missing, found the wheelchair in the stairwell, and the resident was ultimately located outside the building by a visitor and brought back inside by nursing and security. The DON’s investigation summary identified the root cause of the elopement as the 3rd floor North stairwell door alarm being disabled while the door remained broken and unsecured.
Removal Plan
- Resident #1 was placed on 15-minute safety checks and kept under line-of-sight supervision when outside of their room; continued with use of a wander alert device; and resided in a room adjacent to the nursing station for frequent observations.
- All staff were educated on the Elopement policy and what measures to take if a resident went missing, including a power point presentation and post-tests.
- All exit and stairwell doors in the facility on the 2nd and 3rd floors were repaired by an outside vendor.
Failure to Prevent Resident-to-Resident Physical Abuse in Lobby Elevator Area
Penalty
Summary
The deficiency involves the facility’s failure to protect a resident from physical abuse by another resident, despite a known history of aggressive behavior. One resident with paraplegia, mood disorder, major depressive disorder, and anxiety disorder had an established care plan noting potential for physical aggression and risk of being abused. Prior documentation showed that this resident had been involved in a physical altercation with another resident in June of the previous year, during which they reported being punched and stated they hit the other resident back. The care plan was updated at that time to reflect that the resident was abused by peers, with interventions including relocation as needed and a psychiatry referral, but later updates reflecting another resident-to-resident altercation did not include new interventions. On the day of the incident, video surveillance and witness statements documented that the aggressive resident and another resident were waiting at the elevator in the lobby, along with other residents. The second resident, who had diagnoses including schizophrenia and bipolar disorder, approached and stood next to the first resident’s wheelchair. The first resident was seen making hand gestures, then removed the left wheelchair armrest and used both hands to swing it toward the second resident. When the second resident reached toward the armrest, the first resident struck them on the forehead with the armrest, causing bleeding and resulting in a bump and small laceration. Staff arrived immediately after the assault and separated the residents, and the injured resident was later assessed and transferred to the hospital for evaluation. Interviews conducted after the event revealed differing accounts of the interaction leading up to the assault. The first resident reported that the second resident had previously used a racial epithet toward them and, on the day of the incident, again stood close, touched their shoulder, and repeated the racial epithet, prompting them to remove the armrest and strike the other resident. The second resident stated they were standing at the elevator, heard the first resident saying something, ignored it, and were then struck without warning. A security guard reported hearing the first resident tell the second resident not to stand close and to stop touching them, then observed the first resident swinging the armrest and hitting the second resident. Facility staff, including the RN Supervisor and DON, acknowledged that the incident occurred off the unit, that the aggressive resident had a history of verbal and physical abusive behavior toward staff, and that this was the first documented physical altercation between these two specific residents. Despite prior behavioral incidents and care plan documentation of aggression risk, the resident was on 30‑minute checks and was able to access and weaponize a removable wheelchair armrest in a common area, resulting in physical abuse of another resident.
Failure to Timely Respond to Oxygen Alarm and Report Suspected Neglect
Penalty
Summary
Facility staff failed to immediately report an alleged incident of neglect involving a resident who was dependent on respiratory support and continuous monitoring. The resident had spastic quadriplegic cerebral palsy, severe hypoxic ischemic encephalopathy, chronic respiratory failure, was severely cognitively impaired, and totally dependent on staff for all ADLs. On the date of the incident at 8:58 AM, the resident’s alert alarm indicated decreasing oxygen levels, but nursing and respiratory staff did not respond to the alarm or assess the resident in a timely manner, in deviation from the facility’s pulse oximetry escalation pathway and alarm response procedures. The resident was later found unresponsive with gray skin, and a Code Blue was initiated. CPR was started, and the resident was transferred to the hospital, where they were determined to have no brain activity; life support was later terminated and the resident expired. Although the facility’s policy required that alleged or suspected violations involving mistreatment, neglect, or other reportable events be reported to the State Survey Agency and other appropriate authorities no later than 2 hours after forming the suspicion if serious bodily injury occurred, or within 24 hours otherwise, the incident was not reported in accordance with these time frames. The incident occurred on one date, the Administrator was not notified until a later date, and the New York State Department of Health was not notified until four days after the event. The DON stated they were unaware that staff had failed to respond to the alerts until reviewing the alert system report and interviewing staff, and also stated they were unaware the incident should have been reported to the Department of Health, while the Administrator confirmed they had not been notified of the Code Blue on the day it occurred.
Failure to Implement Effective Infection Surveillance and Outbreak Reporting
Penalty
Summary
The deficiency involves the facility’s failure to maintain and implement an effective infection prevention and control program during a norovirus outbreak and in its ongoing surveillance activities. During a norovirus gastroenteritis outbreak, the facility identified multiple residents with gastrointestinal illness on two units, as documented on an infection control tracking sheet for a single date. The facility’s policy on routine infection control surveillance required ongoing assessment of all residents for changes in symptoms or conditions indicative of infection, but surveillance tracking was only completed for one day and was not continued or updated with symptoms or management throughout the outbreak. The DON and the Infection Preventionist (IP) both acknowledged that surveillance tracking sheets should have been completed daily during the outbreak and that they did not know why this was not done. The facility also did not comply with state reporting requirements related to the outbreak. After the cluster of gastrointestinal illness cases was identified, the NYSDOH sent an email to the DON stating that submission of a Nosocomial Outbreak Reporting Application report was required for a single case of a reportable pathogen in a nursing home resident or a cluster of cases above baseline. The DON stated they were aware of this email but confirmed that the requested outbreak report was never submitted to NYSDOH. The DON further stated that NYSDOH should have been contacted immediately when the outbreak was discovered, and that they were not the DON at the time and did not know why the previous DON failed to submit the report. In addition to the outbreak-related issues, the facility’s ongoing infection surveillance line lists for several months were incomplete. The Infection Control Line List for January, February, and March documented residents on antibiotic therapy for various infections, including wound infections, respiratory infections, urinary tract infections, bacteremia, and Clostridium difficile. However, these line lists lacked documentation of infection signs and symptoms, diagnostic tests and laboratory results, the type of precautions used, and any indication of outbreak potential. During interview, the IP confirmed that they used the line list for surveillance and monitoring of residents with infections and on antibiotics, but acknowledged that the lists did not include the required clinical details and precautions. The DON also stated that the IP was responsible for ensuring surveillance included signs and symptoms, diagnostic tests with results, and precautions to prevent outbreaks.
Incomplete and Inaccurate Medication Administration Documentation for a Resident
Penalty
Summary
The deficiency involves the facility’s failure to maintain complete and accurately documented medical records in accordance with accepted professional standards for one resident. For this cognitively intact resident with essential hypertension, adjustment disorder with mixed anxiety and depressed mood, major depressive disorder, and dementia, standing medication orders included multiple daily and twice-daily medications such as antihypertensives, antidepressants, an anticoagulant, a diuretic, an antianginal patch, an inhaler, and other agents. The facility’s medication administration policy required that medications be administered in accordance with physician orders, that documentation of administration be completed on the computer immediately after administration with the nurse’s initials at the corresponding date and time, and that at the end of each shift the medication nurse review the MAR, 24‑hour report, and nurses’ notes to ensure documentation is accurate and complete. Record review of the medication administration audit report for multiple dates in December 2024 showed discrepancies between the scheduled 9:00 a.m. administration times and the times documented as administered for this resident’s medications. On thirteen separate dates, all medications scheduled for 9:00 a.m. were documented as being administered after 12:00 p.m. but before 1:00 p.m. when a particular RN was passing medications to this resident. These documented times did not align with the scheduled administration time and were inconsistent with the policy requirement that medications be given at the right time and documented immediately after administration. The pattern of late documentation occurred on each of the identified dates when that RN was responsible for the medication pass for this resident. In interviews, the RN who administered the medications stated that the resident received most medications at 9:00 a.m. and some at 5:00 p.m., and described issues such as the computer timing out after about 10 minutes, logging the nurse out, and situations where medications might have been given earlier but not clicked off in the system. The RN reported that the documented times (for example, showing around 12:00 p.m.) might not be accurate, could reflect late documentation, and could be affected by computer glitches, but could not recall specific details from the December dates. The Assistant DON reported that one nurse on the unit was responsible for administering medications to approximately 38–40 residents, that the incoming nurse’s start of shift included a narcotic count and report that delayed the start of the medication pass to about 8:30 a.m., and that this left about two minutes per resident to complete the pass by 10:00 a.m. The Administrator stated that their expectation was that nurses review the MAR at the end of the shift and that unit managers run a monthly report, while the Pharmacy Consultant stated they did not review MARs and assumed nursing conducted internal auditing. These practices and conditions contributed to incomplete and inaccurate medication administration documentation for the resident on the identified dates.
Failure to Inform Residents of Grievance Process and Document Grievances and Resolutions
Penalty
Summary
The facility failed to ensure residents were informed about the grievance process and that grievances were documented and tracked in accordance with its grievance policy. The Social Services/Admissions Coordinator, identified as the Grievance Officer, reported that while they interviewed residents and emailed Administration about complaints they could not resolve, they were unable to provide a grievance log or grievance forms. During resident council, multiple residents stated they voiced concerns in the meeting but did not know how to file grievances outside of that setting, and there was no documented evidence listing grievances or the facility’s responses. The DON stated that grievances should be monitored by Social Services with documentation of the nature of the complaint and the resolution, but acknowledged that the process was informal, dependent on circumstances, and not completely clear, with no forms or documentation used to track grievance progress and resolution. For one resident reviewed for care planning, the facility did not consistently address and document multiple grievances raised by the resident’s representative. This resident had diagnoses including cerebral infarction, occlusion and stenosis of the left carotid artery, and myocardial infarction, with the admission MDS indicating moderately impaired cognition and involvement of the resident and family in assessment and goal setting. The representative reported numerous concerns regarding miscommunication between nursing and rehabilitation, discharge planning, appointment scheduling, call bell response time, personal property, resident preferences, nutrition, and proper diet, all of which were communicated to Administration via email and paper copies. Although a family meeting was held to discuss these concerns, the Social Services/Admissions Coordinator and the DON confirmed there was no documented evidence of how each grievance was addressed or resolved, and that most concerns were handled verbally without formal documentation or investigation of every complaint.
Failure to Provide Timely Toileting Assistance and Call Bell Response
Penalty
Summary
Surveyors identified a deficiency in the facility’s failure to provide necessary assistance with toileting and timely response to call bells for residents who were unable to perform activities of daily living independently. Facility policy on Activities of Daily Living required that residents receive appropriate treatment and services to maintain or improve their ability to carry out ADLs, including elimination and toileting, and the facility’s No Pass policy required all staff to respond to call lights and obtain help if they could not provide it themselves. Despite these policies, multiple observations, interviews, and record reviews showed that residents did not consistently receive timely toileting care or call bell responses. One resident with Parkinson’s disease, dementia, heart disease, severely impaired cognition, and total dependence on staff for toileting and hygiene was care planned to be checked for incontinence and changed as needed, and to have toileting needs anticipated every two hours with assistance to the toilet. Kardex instructions for several months reiterated two-hour toileting checks and assistance, and CNA documentation reports for January through March showed numerous missing entries for toileting and two-hour checks across multiple shifts. A nursing home investigative report documented that a family member found this resident with urine-saturated clothing and wheelchair cushion in the afternoon, and the Administrator confirmed the saturation. The CNA identified as responsible for ADLs and accountability tasks for that shift stated they did not change the resident at all during the eight-hour shift, did not perform end-of-day care, and did not inform anyone that they were unable to care for the resident, and also stated they did not check on the resident until late morning. There was conflicting documentation on the assignment sheet, and another CNA reported that the resident was checked every two hours and could indicate when cleaning was needed, while a second family member reported having observed a strong urine smell on three Sunday visits in recent months, which staff addressed when notified. Another resident with a history of stroke and myocardial infarction, and moderately impaired cognition, required maximal assistance with toileting and moderate assistance with bathing and dressing. During one observation, this resident’s call bell was ringing, and the resident reported having waited a long time for care and stated they had been waiting since early morning; staff did not respond until several minutes after the surveyor’s observation began, at which time morning care was provided. On another day, the shared room call bell was ringing while two residents in the room reported they were still in bed, unwashed, undressed, and waiting to get out of bed, stating they had been waiting about half an hour; staff arrived to assist approximately 18 minutes after the surveyor’s initial observation. The resident’s representative reported multiple episodes when call bell response times exceeded one hour and had communicated these concerns to staff. The DON stated that call bells should be responded to when heard and that 30–60 minutes was not acceptable, but also indicated that response time depended on staffing. Additional evidence of delayed call bell response and unmet toileting needs came from Resident Council minutes, call bell audits, and direct observations. Resident Council minutes over several months documented ongoing resident reports that call bell wait times were “on the longer side” and “too long,” and that more nursing staff were needed, particularly on weekends when residents reported only three CNAs were often scheduled. Facility call bell audits conducted in response to complaints documented 23 observations, including one call bell active for 45 minutes and another for 15 minutes in the same room. During one observation, a room call bell rang for at least 14 minutes while multiple staff, including a CNA, a medication nurse, a social work/admissions coordinator, and a unit clerk, passed the room without entering; when the CNA finally entered, the resident requested a bedpan and the CNA left and did not return with the bedpan for another 10 minutes. In another observation, a room call bell rang for at least 27 minutes while a medication nurse, social work/administration staff, and a unit clerk were present in the hallway or nearby but did not respond to the bell. A spouse reported receiving at least 10 overnight phone calls from a resident asking them to call the nurses’ station because no one was responding to the call bell, and also reported that it took a long time for the nurses’ station to answer the phone.
Failure to Collect Ordered Stool Specimen and Notify Practitioner of Uncompleted Lab Test
Penalty
Summary
The deficiency involves the facility’s failure to ensure that a resident received treatment and care in accordance with professional standards and practitioner orders when a stool specimen was not collected as ordered, and the ordering practitioners were not notified. The facility’s policy dated 05/2025 required that when a physician or other authorized practitioner’s order is not carried out as ordered, delayed, modified, or discontinued, the practitioner must be notified. Resident #124 had diagnoses including moderate persistent asthma, essential hypertension, and spinal stenosis, and was documented as always incontinent of bowel and dependent on staff for toileting and hygiene per the care guide, care plan, and admission MDS. On 12/11/2024, the resident developed loose, watery stools and nausea, and the physician and NP were notified, resulting in orders for a stool bacterial detection panel with C. difficile and Zofran as needed. On 12/11/2024, nursing documentation showed that the resident had an episode of loose watery stool in the morning, with the physician notified and an order given to collect stool for testing. Later that day, an RN documented that the resident had nausea and loose stool, that the NP was made aware, and that stool collection and Zofran were ordered. The NP progress note that evening documented watery stool, ordered a GI PCR to rule out gastroenteritis, and planned to monitor the resident, noting stable vitals and a mildly elevated white blood count. The functional abilities record showed the resident was incontinent of bowel on multiple shifts on 12/11/2024, 12/12/2024, and 12/13/2024. The Treatment Administration Record for December 2024 documented the stool test order on 12/11/2024 and 12/12/2024, with entries by LPN #2 and LPN #3 indicating the stool collection was “not administered, unable to obtain.” Despite repeated incontinence episodes that could have provided opportunities to obtain a specimen, there was no documented evidence that the NP or physician were notified that the ordered stool sample had not been collected. A nursing progress note on 12/12/2024 at 2:24 A.M. documented that the resident was alert, able to make needs known, had poor appetite, good fluid intake, an episode of emesis after drinking water too fast, and was feeling better afterward, but did not address the outstanding stool order. During interviews, LPN #3 acknowledged awareness of the stool collection order and documented “not administered” on two shifts but did not write a note indicating that the NP or physician had been informed that the specimen was not obtained. The LPN Unit Manager stated that whether to notify the NP or physician when a stool sample was not collected was handled on a case-by-case basis. In contrast, the Medical Director/Primary Physician and NP #1 both stated they expected to be informed if a lab test they ordered, such as a stool specimen, was not completed, and NP #1 indicated they might have added additional orders and reminded staff to collect the stool if they had known it was not obtained.
Failure to Provide Appropriate Discharge Planning and Readmission for Hospitalized Resident
Penalty
Summary
Surveyors identified that the facility failed to ensure an appropriate discharge plan for one resident who was hospitalized for a suspected gastrointestinal bleed. The resident had vascular dementia with behavioral disturbances, sequelae of cerebral infarction, constipation, and atrial fibrillation, and was dependent for toileting and transfers with documented verbal and physical behaviors toward others. After the resident vomited coffee-ground emesis, the physician ordered a transfer to the hospital emergency department to rule out a GI bleed, and the discharge MDS reflected an unplanned discharge to a short-term general hospital with return anticipated. An interdisciplinary care plan meeting held prior to the hospitalization included multiple disciplines, the resident’s companion, and two guardians, but there was no documentation that discharge planning was discussed, and the resident’s care plan contained no evidence of a planned discharge. While the resident was in the hospital, the facility issued a same-day Transfer/Discharge Notice stating that the IDT had determined the resident would be discharged that day, citing that the resident’s needs could not be met after reasonable accommodation and that the safety and health of individuals in the facility would be endangered. The notice identified interference from the resident’s two guardians as the evidence supporting these reasons, but there was no documentation that the resident personally endangered the health or safety of others. The notice included information about the right to appeal the discharge, and the discharge was appealed. When the resident was medically cleared to return, the facility did not accept the resident back. Review of the electronic medical record showed no documented IDT discharge plan and no nursing progress notes after the date of hospital transfer, and no social work progress notes after that time, indicating a lack of documented planning and coordination related to the discharge decision.
Trusted data from CMS and state health departments
Every citation, penalty and Plan of Correction is sourced from public CMS records (latest release May 27, 2026) and official state health department websites — never guesswork.
Trusted by long-term care providers and associations.



