complaint·January 12, 2023

The Department requested and reviewed documentation relevant to the complaint investigation provided by the facility. A written request was sent to Nellie’s Angels Home Care by Clement Law Group PC’s requesting for R1’s documentation to be provided electronically on a CD or thumb drive and mail to their office. The Department reviewed authorization for release of records signed by R1’s Power of Attorney (POA) dated on 11/14/2022. Interview statement received from Administrator indicated facility’s law firm, Knox, Lemmon & Anapolsky LLP, is currently assisting the facility with redactions. Administrator stated all documents and notes that are redacted is necessary to protect the privacy of their residents before submitting documents to Clement Law Group PC for review which was completed on 12/27/2022. Administrator stated Clement Law Group PC did not provide facility with a deadline. On 12/28/2022, Administrator provided proof of R1’s records were produced but were not sent to Clement Law Group PC. On 12/29/2022, LPA Keosavang received an email from administrator to confirm R1’s records were provided. Records were not provided in a timely manner. Based on interviews conducted and records reviewed, the preponderance of evidence standard has been met, therefore the above allegation is found to be SUBSTANTIATED . Health and Safety Code, Title 22, Division 6, Chapter 3.2 are being cited on the attached LIC9099D. Appeal rights provided to the facility. An exit interview was conducted and a copy of this report will be provided to the facility via email.