Health inspection·July 12, 2022

F 0565 Honor the resident's right to organize and participate in resident/family groups in the facility. Level of Harm - Minimal harm or potential for actual harm Based on record review, review of Resident Council meeting minutes, review of the facility's policy, and resident and staff interviews, the facility failed to respond to grievances identified at the Resident Council meetings. This affected two (Residents #8 and #12) of three residents interviewed regarding Resident Council meetings. The facility census was 41. Residents Affected - Few Findings include: Record review for Resident #8 revealed an admission date of 10/14/21. Diagnoses included chronic kidney disease stage three, anxiety disorder, and polyarthritis. Review of the Minimum Data Set (MDS) assessment, dated 04/22/22, revealed Resident #8 had mild cognitive impairment. Record review for Resident #12 revealed an admission date of 01/24/21. Diagnoses included Parkinson's disease, bipolar disorder, and adult failure to thrive. Review of the quarterly MDS assessment, dated 05/01/22 revealed Resident #12 was cognitively intact. Interviews during Resident Council meeting on 07/07/22 at 10:40 A.M. revealed Resident #8 stated the facility staff does not follow up on concerns brought to the attention of the Resident Council. Resident #12 stated she has the same concern. Resident #12 stated she has brought issues and concerns to the Resident Council meetings, and the facility never followed up on her issues and concerns. Resident #8 stated she feels the concerns were not addressed and not followed up on. Both residents provided examples of bringing their concerns of agency staff and their lack of customer service and approach. Resident #8 and #12 stated they have not received follow up regarding agency staff. Review of the Resident Council meeting minutes, dated January 2022 through March 2022, revealed the facility failed to have a Resident Council meeting for the months of March 2022 and April 2022 and no issues were identified for February 2022. However, during the months of January 2022, May 2022, and June 2022, the Resident Council met and brought forward concerns or grievances for the facility to address. There was no indication the concerns or grievances were followed up by the facility. Interview with the Activity Director (AD) #359 on 07/07/22 at 11:03 A.M. revealed she provides the resident council notes with the grievances and concerns to the Administrator. AD #359 could not confirm if the grievances were followed up on because they were given to the Administrator. Interview on 07/07/22 at 2:32 P.M. with the Administrator confirmed the facility failed to have Resident Council Meetings for the month of March 2022 and April 2022. The Administrator confirmed the facility did not address or provide follow up regarding any of the concerns or grievances brought forth from Resident Council for the months reviewed January 2022 through June 2022. Page 1 of 12 365798 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0565 Level of Harm - Minimal harm or potential for actual harm Review of the facility's policy titled Resident Council/Association, dated 09/09/21, revealed the facility representative will be responsible for researching state regulatory guidelines to meet their specific regulations for their community setting and population. Residents Affected - Few 365798 Page 2 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0610 Respond appropriately to all alleged violations. Level of Harm - Minimal harm or potential for actual harm **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** 2. Review of Resident#16's medical record revealed Resident #16 was admitted to the facility on [DATE]. Diagnoses included cerebral infarction, dementia, major depressive disorder, vascular dementia, and anxiety disorder. Residents Affected - Few Review of the quarterly Minimum Data Set (MDS) assessment, dated 05/07/22, revealed Resident #16 had severely impaired cognition. Resident #16 required extensive assistance with bed mobility and transfers. Resident #16 was totally dependent on staff for dressing, eating, toilet use, and personal hygiene. Review of Resident #16's progress notes dated 02/23/22 revealed a hospice nurse reported to the nurse bruising and swelling identified on Resident #16's left foot third digit. The note stated Resident #16 did not voice any complaints of pain. Review of the facility's Self-Reported Incidents (SRI) control number 218341 revealed there was an allegation of injury of unknown origin reported to the State Survey Agency. Resident #16 had a bruise of unknown origin identified on 02/23/22. The bruise was located on the third digit toe on Resident #16's left foot. The facility could not provide an investigation related to this SRI. Interview on 07/07/22 at 3:11 P.M. with the Director of Nursing (DON) confirmed the facility did not have an investigation on SRI 218341. The DON confirmed the facility reported the bruise of unknown origin to the State Survey Agency as a reportable abuse; however, did not complete an investigation of the cause. The DON stated Resident #16 was known to be combative with care, so the nursing staff assumed this was the cause of the injured toe. Review of the facility's policy titled Abuse Investigation, dated 02/21/12, revealed the facility will identify and investigate all suspicions of abuse. The facility will complete a thorough investigation following an allegation of abuse. The investigation will consists of notifying the physician, family, interviewing staff, and interviewing residents among other steps. Based on staff interview, medical record review, review of the facility's Self-Reported Incidents and investigations, and policy review, the facility failed to complete thorough investigations of allegations of resident abuse. This affected two (Resident #16 and #97) of three residents reviewed for abuse. The facility census was 41. Findings include: 1. Review of the medical record for Resident #97 revealed an admission date of 02/21/22 with a discharge date of 03/23/22. Diagnoses included multiple fractures of pelvis and chronic obstructive pulmonary disease. Review of the admission Minimum Data Set (MDS) assessment dated [DATE] revealed Resident #97 had intact cognition. Resident #97 required one-person extensive assistance with transfers, dressing, toileting, and bathing. Review of Resident #97's medical record revealed no documentation of an incident occurring on 02/25/22. 365798 Page 3 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0610 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Review of the self-reported incident (SRI) control number 218359 revealed Resident #97 reported an allegation of neglect on 02/25/22. Resident #97 reported Licensed Practical Nurse (LPN) #343 came into her room to provide care. At that time, LPN #343 asked Resident #97 to turn down her television and was unable to transfer Resident #97. The Director of Nursing (DON) interviewed Resident #97. Resident #97 reported LPN #343 told her loudly to turn down the television, and night shift was unable to transfer her at that time. The DON spoke to LPN #343. LPN #343 stated Resident #97's family requested staff to encourage her to turn off her television at night for rest. LPN #343 explained to Resident #97 the importance of sleep. LPN #343 reported Resident #97 was hard of hearing and raised her voice to speak over oxygen concentrator and the television. LPN #343 revealed Resident #97 requested to get in her recliner at 4:00 A.M., and LPN #343 explained she was doing medication pass and would not be able to assist her at that time. Resident #97 requested to get up to use the restroom. LPN #343 explained Resident #97 was incontinent and felt she was being manipulative to get out of bed. LPN #343 educated Resident #97, and Resident #97 agreed to wait until day shift to get out of bed. Social services will meet with Resident #97 to determine when she would like to get out of bed in the mornings and update her care plan. Staff will be educated on how to accommodate resident's needs. Review of the facility's investigation revealed it did not include staff and resident statements. The investigation did not include any skin assessments of Resident #97 to assess if Resident #97 had any skin impairments related to lack of assistance with toileting when Resident #97 requested to utilize the restroom. The investigation did not include any assessments or interviews of nearby residents. Interview on 07/07/22 at 2:56 P.M. with the DON verified the facility's information regarding SRI 218359 was very limited and reported previous Administrator completed this abuse investigation. The DON reported the facility interviewed residents on the same hall where the incident occurred but unable to obtain the documentation. The DON verified there was no skin assessment completed for Resident #97 after the allegation of neglect. 365798 Page 4 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0623 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Provide timely notification to the resident, and if applicable to the resident representative and ombudsman, before transfer or discharge, including appeal rights. **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on staff interview, review of the facility's policy, and record review, the facility failed to provide written notification of the resident's transfer to the hospital to the residents and/or their representatives. This affected two (Residents #27 and #32) of four residents reviewed for transfers. The facility census was 41. Findings include: 1. Review of the medical record for Resident #32 revealed an admission date of 06/01/22 with surgical aftercare following surgery, pain in right hip and pain in right leg. Review of the Minimum Data Set (MDS) assessment dated [DATE] revealed Resident #32 was cognitively intact. Review of the physician's order dated 05/25/22 revealed Resident #32 was to go to the hospital. Review of the progress note dated 05/25/22 at 7:26 P.M. revealed Resident #32 had uncontrollable pain in her right hip and right leg. Pharmacological and non-pharmacological interventions were attempted without relief. The physician ordered Resident #32 be sent to the emergency room for further evaluation. There was no evidence Resident #32 received a written notice of transfer. Interview on 07/07/22 at 9:02 A.M. with the Director of Nursing (DON) verified the facility was not providing a written reason for transfer to the resident and/or resident's representative. The DON stated they had a change in personnel and the written reason for transfer was not being completed. 2. Review of Resident #27's medical record revealed the resident was admitted to the facility on [DATE]. Diagnoses included anxiety disorder, heart failure, paraplegia, and obstructive sleep apnea. Review of the quarterly Minimum Data Set (MDS) assessment, dated 06/21/22, revealed Resident #27 was cognitively intact. Review of the progress notes revealed Resident #27 was discharged to the hospital on [DATE]. Resident #27 returned from the hospital on [DATE]. There was no evidence the facility provided written notification of transfer to the hospital to Resident #27. Interview on 07/07/22 at 12:55 P.M. with the Director of Nursing (DON) verified the facility did provide written notification of the resident's transfer to the hospital to Resident #27. Review of the facility's policy titled Transfer, Discharge Notice, dated 03/07/18, revealed all transfer/discharge notices must be sent to the resident, resident representative(s), the Long-Term Care Ombudsman program, and any state specific agency, as required. 365798 Page 5 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0625 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Notify the resident or the resident’s representative in writing how long the nursing home will hold the resident’s bed in cases of transfer to a hospital or therapeutic leave. **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on staff interview, review of facility's policy, and record review, the facility failed to provide bed hold notices to the residents and their representatives when the residents transferred to the hospital. This affected two (Residents #27 and #32) of four residents reviewed for bed hold notices. The facility census was 41. Findings included: 1. Review of the medical record for Resident #32 revealed an admission date of 06/01/22 with surgical aftercare following surgery, pain in right hip and pain in right leg. Review of the Minimum Data Set (MDS) assessment dated [DATE] revealed Resident #32 was cognitively intact. Review of the physician's order dated 05/25/22 revealed Resident #32 was to go to the hospital. Review of the progress note dated 05/25/22 at 7:26 P.M. revealed Resident #32 had uncontrollable pain in her right hip and right leg. Pharmacological and non-pharmacological interventions were attempted without relief. The physician ordered Resident #32 be sent to the emergency room for further evaluation. There was no evidence Resident #32 received a bed hold notice when sent to the hospital Interview on 07/07/22 at 9:02 A.M. with the Director of Nursing (DON) verified the facility did not provide Resident #32 and/or resident's representative of a bed hold notice when Resident #32 went to the hospital on [DATE]. The DON stated they had a change in personnel and the bed hold notices were not being completed. 2. Review of Resident #27's medical record revealed the resident was admitted to the facility on [DATE]. Diagnoses included anxiety disorder, heart failure, paraplegia, and obstructive sleep apnea. Review of the quarterly Minimum Data Set (MDS) assessment, dated 06/21/22, revealed Resident #27 was cognitively intact. Review of the progress notes revealed Resident #27 was discharged to the hospital on [DATE]. Resident #27 returned from the hospital on [DATE]. There was no evidence the facility provided a bed hold notice to Resident #27. Interview on 07/07/22 at 12:55 P.M. with the Director of Nursing (DON) verified the facility did not provide Resident #27 and/or resident's representative a bed hold notice when Resident #27 went to the hospital on [DATE]. The DON stated they had a change in personnel and the bed hold notices were not being completed. Review of the facility's policy titled Transfer, Discharge Notice, dated 03/07/18, revealed the facility will provide notice of their Bed-Hold policy to the resident and representative at the time of admission and again with emergency transfer from the facility. 365798 Page 6 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0657 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Few Develop the complete care plan within 7 days of the comprehensive assessment; and prepared, reviewed, and revised by a team of health professionals. **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on medical record review, review of the facility's policy, and staff interviews, the facility failed to hold quarterly care conferences with residents. This affected one (Residents #10) of 16 residents reviewed for care conferences. The facility census was 41. Findings include: Review of the medical record for Resident #10 revealed an admission date of 09/08/21. Diagnoses included congestive heart failure (CHF), Parkinson's disease, type two diabetes mellitus, atrial fibrillation, liver disease, and chronic kidney disease, stage III. Review of the Minimum Data Set (MDS) assessment dated [DATE] revealed Resident #10 was cognitively intact. Review of the care conferences from 06/21/21 to 07/07/22 revealed Resident #10 had care conferences on 06/21/21, 09/20/21, and 12/08/21. There was no additional care conference documentation available after 12/08/21. Interview on 07/07/22 at 9:41 A.M. with Social Services Director (SSD) #300 verified all care conference documentation was in the electronic medical records. SSD #300 verified Resident #10's last care conference was 12/08/21. Review of the facility's policy titled, Care Plan Process-Skilled, dated 07/07/22, revealed to ensure the timeliness of each resident's person-centered, baseline and comprehensive care plan, and to ensure that these care plans are reviewed and revised by an interdisciplinary team composed of individuals who have knowledge of the resident and his/her needs, and that each resident and resident representative, if applicable, is involved in developing the care plan and making decisions about his or her care. 365798 Page 7 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0692 Provide enough food/fluids to maintain a resident's health. Level of Harm - Minimal harm or potential for actual harm Based on staff interview, review of the facility's policy, and record review, the facility failed to ensure residents were weighed as ordered, residents were re-weighed as needed and timely documentation of addressing the resident's weight changes. This affected one (Resident #10) of five residents reviewed for nutrition. The facility identified four residents with unplanned significant weight gain or loss. The facility census was 41. Residents Affected - Few Findings include: Review of the medical records for Resident #10 revealed an admission date of 09/08/21. Diagnoses included congestive heart failure, Parkinson's disease, type two diabetes mellitus type two, atrial fibrillation, liver disease, and chronic kidney disease, stage III. Review of the Minimum Data Set (MDS) assessment, dated 04/22/22, revealed Resident #10 was cognitively intact and required supervision and setup help only for eating. Review of the physician's orders dated 10/29/21 revealed Resident #10 had an order on for monthly weights. Review of Resident #10's weights revealed the following weights: 166.6 pounds (lbs.) on 01/07/22; 174.0 lbs on 01/08/22, 158.0 lbs. on 04/26/22; and 116.0 lbs on 05/01/22. On 05/01/22, it was a 26.5% significant weight loss. There was no re-weight listed for May 2022 and no June 2022 weight listed in the medical record. Further review of the medical record revealed there was no documentation addressing a re-weight was needed for May 2022 and no documentation related to why there was no weight for June 2022. Interview on 07/06/22 at 3:07 P.M. with Registered Dietitian (RD) #361 stated on 05/01/22 at 116.0 lbs. weight was in error. RD #361 stated she would ask for for re-weights by providing the Director of Nursing (DON) with a report. RD #361 verified that there was no dietary note from her related to the weight on 05/01/22 and verified that there were no monthly weight for June 2022. RD #361 stated the facility's policy was for residents to be weighed monthly by the 10th of the month. Interview on 07/06/22 at 4:48 P.M. with the Director of Nursing (DON) stated the nurses on the floor should be checking and getting residents re-weighed at that time of unusual weights, then notify the physician if there was a significant change. Aides would not be aware of previous weights, only nurses. The DON verified there was no documentation to support nursing contacted the physician. Review of the facility's policy titled Weights Policy, dated 03/03/21, revealed all residents will be weighed monthly by the 10th of the month with weights recorded on the Vital Sign Flow Sheet or the electronic health record (EHR) and in the Weight Log Form. If a discrepancy in weight is noted, the resident will be re-weighed. 365798 Page 8 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0804 Ensure food and drink is palatable, attractive, and at a safe and appetizing temperature. Level of Harm - Minimal harm or potential for actual harm Based on observation of tray line and a test tray, resident, family, and staff interview, review of the resident council meeting minutes, review of the facility's policy, and record review, the facility failed to ensure food was served at an appetizing temperature and acceptable palatability. This had the potential to affect 40 residents who received food from the kitchen. The facility identified one resident (#37) who did not receive food from the kitchen. The facility census was 41. Residents Affected - Many Findings include; Interview on 07/05/22 at 10:28 A.M. with Resident #141 stated the facility's food was often served cold and this issue was ongoing. Interview on 07/05/22 at 11:15 A.M. with Resident #142 stated the food was served cold. Resident #142 stated this was really the only concern or complaint regarding the facility's food. Interview with Resident #4's spouse on 07/05/22 at 12:29 P.M. stated there were times the hot food was served cold. Observation on 07/06/22 at 11:34 A.M. revealed Dietary [NAME] (DC) #500 placed a food thermometer in a pan of mixed vegetables without sanitizing the thermometer and obtaining a temperature of 199 degree Fahrenheit (F). DC #500 wiped the food thermometer with a dry dish towel and placed it in a large pan of black bean salad and obtain a temperature of 196 degrees F. DC #500 was observed wiping the food thermometer with a dry dishtowel and placing in the meat of a quesadilla and obtaining a holding temperature of 122.5 degrees F. DM #362 was observed to provide DC #500 a alcohol wipe and encouraged him to clean the food thermometer with the alcohol wipes. DM #362 explain to DC #500 the holding temperature for the beef quesadilla was too low and to put in the oven to bring to a temperature of 165 degrees F. Observation of the tray line on 07/06/22 at 12:12 A.M. revealed the tray line was located in the temporary kitchen area due to remodeling. DM #362 stated the facility does not have enough lids to cover the food dishes to ensure the foods stays hot. Observed the tray line run out of lids to cover the food and placed the food in a four-compartment styrofoam container. DM #362 stated the reason they do not have enough lids was because her supplier has them on back order. DM #362 stated she has checked with three suppliers, however, has not asked the current supplier she was using. Observation of meal trays delivered to the floor on 07/06/22 at 12:38 P.M. revealed the last tray was delivered to a resident at 12:38 P.M A test tray was completed at this time and revealed the lunch was served in a styrofoam container and the black beans were served at room temperature. The quesadilla was beef in a flour tortilla wrap with nothing else on it. There was no cheese or garnish like sour cream and/or salsa. The tortilla was cold and chewy. An interview on 07/06/22 at 3:24 P.M. with the Registered Dietitian (RD) #361 revealed the RD was unable to determine why the facility would serve a plain quesadilla that consisted of beef wrapped in a shell without cheese or garnish. The RD stated the quesadillia should have contained cheese. The RD stated she was unaware the facility did not have enough lids to ensure the foods served remained hot on the unit. Review of the resident's diets revealed Resident #37's diet was nothing by mouth. 365798 Page 9 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0804 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Many Review of the facility's Resident Council Meeting Notes dated 05/17/22 revealed Resident #12 had an issue of cold food on her tray. The Resident Council Meeting Notes dated 06/21/22 revealed Resident #12 had the same issue that her food on her tray was often cold and it was an ongoing issue. Review of the facility's policy titled Food Preparation-Food Temperatures Policy, dated 09/05/19, revealed foods should be served at proper temperature to insure food safety and palatability. 365798 Page 10 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0812 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Many Procure food from sources approved or considered satisfactory and store, prepare, distribute and serve food in accordance with professional standards. Based on observation, record review, review of the facility's policy, and staff interview, the facility failed to maintain a clean and sanitary kitchen area. This had the potential to affect 40 residents who received food from the kitchen. The facility identified one resident (#37) who did not receive food from the kitchen. The facility census was 41. Findings include: Observation and interview during the initial tour of the facility's kitchen on 07/05/22 at 8:12 A.M. revealed Dietary Manager (DM) #362 was standing in the kitchen area without a hair net covering her hair. The dining room manger (DRM) #322 was standing at the counter with no hair net covering her hair. DM #362 confirmed the findings. DM #362 provided a tour of the kitchen and confirmed an employee lunch was located inside the facility's refrigerator. A pound cake was observed on a shelf in the refrigerator with no label or date. DM #362 confirmed a large bag of open frozen cookies with no label or date. DM #362 opened the free standing ice cream cooler and revealed four three gallon tubs of ice cream with no lids. DM #362 confirmed the ice cream should be covered and labeled with a date. Observation on 07/06/22 at 11:34 A.M. revealed Dietary [NAME] (DC) #500 placed a food thermometer in a pan of mixed vegetables without sanitizing the thermometer. DC #500 then wiped the food thermometer with a dry dish towel and placed the thermometer in a large pan of black bean salad. DC #500 was observed wiping the food thermometer with a dry dishtowel and placing in the meat of a quesadilla. DM #362 then gave DC #500 a alcohol wipe and encouraged him to clean the food thermometer utilizing the alcohol wipe. Interview on 07/06/22 at 11:34 A.M. with DC #500 confirmed he did not sanitize the food thermometer while obtaining the food temperatures. Review of the resident's diets revealed Resident #37's diet was nothing by mouth. Review of the facility's policy titled Food Preparation Policy, dated 08/20/18, revealed food items should be stored following good sanitary practices and local codes and manufactories specifications. Review of the facility's policy titled General Cleaning and Sanitizing, dated 03/18/21, revealed food contact surfaces must be cleaned and sanitized after every use. Review of the facility's policy titled Personal Hygiene Policy-Personal Hygiene, dated 08/20/18, revealed for staff to wear a clean hat or other hair restraint in all kitchen production/food service areas. Hair must be appropriately restrained per state regulations. 365798 Page 11 of 12 365798 07/12/2022 Courtyard at Seasons 7100 Dearwester Drive Cincinnati, OH 45236

F 0880 Provide and implement an infection prevention and control program. Level of Harm - Potential for minimal harm Based on staff interview, review of the facility's policy and risk assessment, and review of the employee files, the facility failed to ensure the facility newly hired staff received the second step of the tuberculin skin test (TST). This had the potential to affect all 41 residents residing in the facility. The facility census was 41. Residents Affected - Many Findings include: Review of the employee file for State Tested Nursing Assistant (STNA) #326, revealed a hire date of 06/07/22. Further review of the employee file revealed a form titled Initial TB testing for Residents and Health Care Workers, dated 01/28/21, revealed the first TB step was completed on 05/27/22 and results were read on 05/30/22. However, the second step was blank and not completed. Review of the employee file for STNA #316 revealed a hire date of 05/12/22. Review of the form titled Initial TB testing for Residents and Health Care Workers, dated 01/28/22, revealed the first TB step testing was completed on 04/27/22 and results read on 04/29/22. However, the second step was blank and not completed. Review of the employee file for STNA #350 revealed a hire date of 05/31/22. Review of the form titled Initial TB testing for Residents and Health Care Workers, dated 01/28/22, revealed the first TB step testing was completed on 05/06/22 and results were read on 05/09/22. However, the second step was blank and not completed. Interview on 07/07/22 at 2:32 P.M. with the Director of Nursing (DON) revealed the facility failed to complete the second TB testing for new hires STNA #326, #316 and #350. Review of the facility's TB risk assessment titled Tuberculosis (TB) risk assessment worksheet, dated 2022, revealed the facility will assess employees for TB upon hire and PRN (as needed). Review of the facility's policy titled Community-Employee Tuberculosis Testing Policy, dated 02/10/22, revealed it is the standard for the company that all employees receive a two-step intra-cutaneous (Mantoux) test. 365798 Page 12 of 12