F 0656
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
Develop and implement a complete care plan that meets all the resident's needs, with timetables and
actions that can be measured.
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on
interview and record review, the facility failed to develop a comprehensive care plan for the use of heparin
sodium (a blood thinner medication used to treat and prevent blood clots) for one of one sampled resident
(Resident 9).
This deficient practice had the potential to result in unidentified nursing interventions (actions) including
monitoring for side effects of heparin such as bleeding, and negatively affect the quality of care for Resident
9.
Findings:
During a review of Resident 9's admission Record (Face Sheet), the face sheet indicated Resident 9 was
admitted to the facility on [DATE] and readmitted on [DATE] with diagnoses including cerebral infarction
(damage to the brain caused by lack of oxygen), diabetes (an impairment in the way the body regulates and
uses sugar [glucose] as a fuel) and anemia (lack of red blood cells in the body).
During a review of Resident 9's Minimum Data Set ([MDS], a standardized resident assessment and care
screening tool) dated 1/25/2023, the MDS indicated Resident 9 was in persistent vegetative state (coma)
and no discernible consciousness (absence of awareness). The MDS also indicated Resident 9 had an
indwelling urinary catheter and was totally dependent on staff for activities of daily living (ADL's) including
bed mobility, dressing, eating, toilet use, bathing and personal hygiene.
During a review of Resident 9's physician (MD) orders dated 10/7/2022, the MD orders indicated to
administer heparin sodium 5000 units per one milliliter (ml) solution subcutaneously ([SC], applied under
the skin) to the resident daily for deep vein thrombosis ([DVT], blood clot) prophylaxis (action taken to
prevent disease).
During a review of Resident 9's Patient Medication Administration (PMA) dated 12/25/2022 through
1/25/2023, the PMA indicated Resident 9 received Heparin 5000 units SC every 12 hours.
During an interview on 1/27/2023 at 12:57 PM with Registered Nurse (RN 1), RN 1 stated heparin was a
high alert medication (drugs that have heightened risk of causing significant harm when used in error) and
should have had a care plan developed as soon as the medication was started, however was not done. RN
1 also stated possible side effects of heparin included bleeding and the importance of having a care plan
was to identify interventions such as monitoring the resident for bleeding or bruising.
(continued on next page)
Any deficiency statement ending with an asterisk (*) denotes a deficiency which the institution may be excused from correcting providing it is determined that other
safeguards provide sufficient protection to the patients. (See instructions.) Except for nursing homes, the findings stated above are disclosable 90 days following the
date of survey whether or not a plan of correction is provided. For nursing homes, the above findings and plans of correction are disclosable 14 days following the date
these documents are made available to the facility. If deficiencies are cited, an approved plan of correction is requisite to continued program participation.
LABORATORY DIRECTOR'S OR PROVIDER/SUPPLIER
REPRESENTATIVE'S SIGNATURE
TITLE
(X6) DATE
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Facility ID:
If continuation sheet
Page 1 of 16
Event ID:
555874
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0656
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
FORM CMS-2567 (02/99)
Previous Versions Obsolete
During a review of the facility's policies and procedures (P&P) titled Assessment and Care Planning revised
in 9/2022, the P&P indicated the resident assessment information would be used to develop a
comprehensive care plan to allow the resident's highest practicable level of physical, mental and
psychosocial function. The P&P also indicated the comprehensive care plan would be prepared by an
interdisciplinary team that included input from the MD, RN and appropriate health professionals involved in
meeting the needs of the resident.
Event ID:
Facility ID:
555874
If continuation sheet
Page 2 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0690
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
Provide appropriate care for residents who are continent or incontinent of bowel/bladder, appropriate
catheter care, and appropriate care to prevent urinary tract infections.
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on
observation, interview, and record review, the facility failed to ensure two out of two sampled residents
(Residents 1 and Resident 9) received appropriate service and treatment to prevent a urinary tract infection
([UTI], an infection that can occur in any area of the urinary tract) and an injury by:
1. Resident 1 who had sediments (visible particles in the urine) in the urine was not assessed,
documented, and the physician was not notified. The deficient practice resulted in the delay of treatment
and care for Resident 1.
2. For Resident 9 who had an indwelling catheter (a flexible plastic tube inserted into the bladder that
remains there to provide continuous urinary drainage) the indwelling catheter tube was not anchored
(secured) to Resident 9's inner thigh. The deficient practice had the potential to result in an UTI and pain for
Resident 9.
Findings:
1. During a review of Resident 1's admission Record, the admission Record indicated Resident 1 was
originally admitted to the facility on [DATE] and readmitted on [DATE], with diagnoses that included anemia
(a condition in which you lack enough healthy red blood cells to carry adequate oxygen to your body's
tissues), disorder of thyroid (a medical condition that keeps your thyroid gland from making the right
amount of hormones to keep ones body functioning normally), diabetes mellitus (Abnormal blood sugar).
During a review of Resident 1's Minimum Data Set ([MDS] a comprehensive assessment and
care-screening tool) dated 12/6/2022, the MDS indicated Resident 1's decision making skills was severely
impaired. The MDS indicated Resident 1 had an indwelling urinary catheter.
During a review of Resident 1's Care Plan for Suprapubic Catheter (a flexible plastic tube inserted into the
bladder that remains there to provide continuous urinary drainage) initiated on 4/15/2020, the care plan
goal indicated Resident 1 would not have signs and symptoms of a UTI. The care plan interventions were to
monitor the urine for color, sediments, and amount.
During a review of Resident 1's Narrative Notes (nursing note) dated 1/25/2023, at 19:36 AM, the nursing
notes indicated, at 7:00 AM, sedimentation was noticed in Resident 1's urine, the nurse practitioner was
notified and ordered a urine culture ([UA] a laboratory test to check for UTI).
During a review of Resident 1's UA results collected on 1/25/2023, the test results indicated Resident 1 had
an abnormal UA test result and may have a UTI.
During a review of Resident 1's Physician Daily Progress Notes (Progress Notes) dated 1/26/2023, at 12:10
AM, the progress notes indicated Resident 1 had sediments in his urine. The progress notes also indicated
Resident 1 UA had pyuria (a condition in which you have high levels of white blood cells (leukocytes) or pus
in the urine) and Cefepime (and antibiotic used to treat a wide variety of bacterial infections) was ordered to
treat Resident 1's UTI.
During an observation on 1/24/2023, at 11:11 AM, in Resident 1's room, Resident 1's Suprapubic
(continued on next page)
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 3 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0690
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
Catheter (a flexible plastic tube inserted into the bladder that remains there to provide continuous urinary
drainage) tubing and bag had urine that appeared cloudy and had particles in the urine.
During a concurrent observation and interview on 1/24/2023, at 12:15 PM, with the Registered Nurse (RN)
2, in Resident 1's room, RN 2 stated Resident 1 urine had a large amount of sediments. RN 2 stated the
sediments appeared to be older than a day's worth. The RN 2 stated sediments could be a sign Resident 1
had an UTI. The RN 2 stated she was not sure if the doctor was notified of the large amount of sediments in
Resident 1's urine. RN 2 stated an UTI infection could lead to hospitalization.
2. During a review of Resident 9's admission Record, the admission record indicated Resident 9 was
originally admitted to the facility on [DATE], and readmitted on [DATE] with diagnoses not limited to chronic
respiratory failure (a condition that occurs when the lungs cannot get enough oxygen into the blood or
eliminate enough carbon dioxide [a type of gas produced by respiration] from the body), cerebral infarction
(occurs as a result of disrupted blood flow to the brain), type 2 diabetes (abnormal blood sugar).
During a review of Resident 9's MDS dated [DATE], indicated Resident 9 was in a persistent vegetative
state (coma) and no discernible consciousness (the absence of awareness). The MDS indicated Resident 9
had an indwelling urinary catheter.
During a review of Resident 9's Care Plan for Indwelling Urethral Catheter, dated 1/15/2023, e care plan
interventions indicated to have the indwelling urethral catheter tubing unkinked and securement to Resident
9's inner thigh.
During a concurrent observation and interview on 1/26/2023, at 12:28 PM, with Licensed Vocational Nurse
(LVN) 1, in Resident 9's room, Resident 9's indwelling urinary catheter tubing was not securely anchored to
Resident 9's leg. LVN 1 confirmed Resident 1's indwelling urinary catheter tubing was not securely
anchored. LVN 1 stated the indwelling urinary catheter tubing should be secured. LVN 1 stated the
importance of securing the catheter tubing was to prevent the tubing from pulling and hurting the resident.
During an interview on 1/27/2023 at 11:20 AM with the NM, the NM stated the indwelling urinary tubing
should be anchored to the resident's thigh to prevent pulling and infection.
During a review of the facility's Policy and Procedure (P&P) titled, Catheter Care, Routine Daily dated
1/2014, the P&P indicated nursing care included observing urinary drainage for cloudiness, odor, mucus,
blood or sediment.
During a review of the facility's Policy and Procedure (P&P) titled, Indwelling Urethral Catheter
Management dated 9/2019, the P&P indicated the facility should take measures to prevent UTI and utilize a
catheter-securing device.
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 4 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0726
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
Ensure that nurses and nurse aides have the appropriate competencies to care for every resident in a way
that maximizes each resident's well being.
Based on observation, interview, and record review, the facility failed to ensure two (2) out of two license
nurses (Registered Nurse 1 [RN1] and Nurse Manager 1 [NM 1]) had the appropriate knowledge and skills
to manage and care for an intravenous ([IV]-existing, taking place or administering into a vein) midline
catheter (a catheter placed into the peripheral vein).
This deficient practice had the potential to result in infection and blood clot for Resident 2 and other
residents.
Findings:
During an observation on 1/24/2023, at 11:21 a.m., Resident 2 was observed with an IV midline catheter.
Resident 2's midline dressing was observed with a date of 1/21/2023.
During a concurrent interview and record review on 1/26/2023, at 11:28 a.m., with Registered Nurse 1
(RN1), Resident 2's physician's orders were reviewed. RN 1 stated Resident 2 had an order for a midline
catheter to be placed on Resident 2 on 11/27/2022 for antibiotic (medication used to treat an infection)
administration. RN 1 stated she was not sure how long the midline catheter should remain in the vein, but
she believed it was good for at least six (6) weeks. RN 1 stated she was responsible for flushing, assessing,
and changing the dressing of the IV midline catheter when needed. RN 1 stated the IV midline dressing
was changed every seven (7) days. RN 1 stated she did not know the facility's policy on IV therapy and
management instructed the IV midline dressing to be changed every 72 hours
During an interview on 1/24/2023, at 11:35 a.m., with the nurse manager (NM1), the NM 1 stated she was
not aware the facility's policy on IV therapy and management instructed the staff to change the IV midline
dressing every 72 hours. NM 1 stated it was important for the nurses to know and understand the
importance of changing the midline catheter dressing every 72 hours because of infection control issues
that could affect the resident's health.
During an interview on 1/26/2023, at 11:45 a.m., with the facility's peripherally inserted central catheter
nurse ([PICC Nurse]-RNs that insert catheter lines into a patient's vein to administer medication), the PICC
Nurse stated the midline catheter was used for 29 days. The PICC Nurse stated after 29 days the midline
catheter must be removed because there was an increased risk for the resident to develop an infection, the
catheter could become blocked, or a blood clot could form.
During an interview on 1/26/2023, at 11:55 a.m. with RN 1 and NM 1, RN 1 stated she taught the midline
catheter was good for six weeks. NM 1 stated she also taught the midline catheter was used for at least six
weeks.
During a review of the manufacturers undated guidelines for a powerglide midline catheter, the guidelines
indicated the device was intended for short term use (less than 30 days) to sample blood and administer
fluids.
During a review of the facility's policy (P&P) titled Intravenous Therapy-Initiation and Management of
Peripheral Intravenous Lines with a revision date of 3/2022, the P&P indicated the dressing should be
changed aseptically (free from contamination) after 72 hours.
(continued on next page)
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 5 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0726
During a review of the facility's P&P titled Nurse Manager with a revision date of 12/2022, the P&P
indicated, The nurse manager shall be responsible for standards of good nursing practice.
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 6 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0732
Post nurse staffing information every day.
Level of Harm - Minimal harm
or potential for actual harm
Based on observation, interview and record review, the facility failed to ensure staffing information was
posted in a visible and prominent place daily.
Residents Affected - Few
This deficient practice resulted in residents and visitors not being able to access the accurate number of
clinical staff taking care of residents daily.
Findings:
During an observation on 1/24/2023 at 10:22 AM., daily staffing information was not found to be posted at
the facility.
During a concurrent observation and interview on 1/25/2023 at 1:29 PM with Director of Staff Development
(DSD), the DSD stated staffing information was not posted and should be posted daily.
During an interview on 1/27/2023 at 12:12 PM with Nurse Manager (NM), NM stated staffing information
should be posted daily to ensure transparency in the number of nursing staff taking care of each resident in
the facility.
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 7 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0812
Level of Harm - Minimal harm
or potential for actual harm
Procure food from sources approved or considered satisfactory and store, prepare, distribute and serve
food in accordance with professional standards.
Based on observation, interview and record review, the facility failed to ensure safe and sanitary food
storage and preparation practices were followed in the kitchen by failing to:
Residents Affected - Some
1. Ensure the handwashing sink had proper water temperature for effective hand washing by staff.
2. Ensure food items and dairy beverages kept in the refrigerator were dated or labeled after being opened
and previously cooked rice stored in the hot-holding cabinet (equipment used to hold hot foods before
service) was dated.
3. Ensure sanitizer used to wash fruits and vegetables was at acceptable levels.
These deficient practices had the potential to result in harmful bacteria growth and cross-contamination
(transfer of harmful bacteria from one place to another) that could lead to foodborne illness in 1 of 17
medically compromised residents in addition to staff and visitor who received food from the kitchen.
Findings:
1.During an observation on 1/24/2023 at 10:00 a.m. in the kitchen, two separate foot pedals were observed
at the handwashing sink for hot and cold water. Hot water from the sink felt very hot when the foot pedal for
the hot water was pressed. Surveyor was not able to wash hands effectively and kitchen staff were
observed using cold water for hand washing.
During a concurrent observation and interview on 1/24/2023 at 10:00 a.m. with Food Service Director
(FSD), hot water at the kitchen handwashing sink was 128 degrees Fahrenheit (°F). FSD stated the
water was very hot and she would speak with the Maintenance Supervisor (MS) to adjust the temperature.
During an interview on 1/24/2023 at 1:00 p.m. with MS, MS stated the facility recently added two new water
heaters which may have affected the water temperatures of the handwashing sink. MS stated the water
temperature should be 100-110 °F and 128 °F was too hot which could burn your hands. MS also
stated he had called the department engineers to adjust the water temperature.
During a review of the facility's policy and procedure (P&P) titled, Hand Hygiene dated 2/2022, the P&P
indicated, staff should wet hands first with warm water and apply an amount of product recommended by
the manufacturer to the hands, use warm, but not hot water, as hot water may increase the risk of
dermatitis.
During a review of 2022 U.S. Food and Drug Administration (FDA) Food Code section 2-301 titled, Where
to Wash, the Food Code indicated it was important that handwashing be done only at a properly equipped
handwashing facility to help ensure that food employees effectively cleaned their hands. Handwashing sinks
were to be conveniently located, always accessible for hand washing, and maintained to provide proper
water temperatures and pressure.
During a review of the 2022 U.S. FDA Food Code section 5-202.12 titled, Handwashing Sink, Installation,
the Food Code indicated an inadequate flow or temperature of water may lead to poor handwashing
(continued on next page)
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 8 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0812
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Some
practices by food employees. A mixing valve or combination faucet was needed to provide properly
tempered water for handwashing. The International Plumbing Code (IPC) indicated that tempered water is
having a temperature range between 29.4°C (85°F) and 43°C (110°F).
2. During concurrent observations and interviews on 1/24/2023 at 10:30 a.m.-10:35 a.m. with FSD in the
kitchen, the following were observed to be stored in the refrigerator:
An opened bag of garden burgers with no date when it was received, opened, or needed to be used by.
An undated opened bag of bread sticks
Six unlabeled and undated paper cups filled with beverage
FSD stated she did not see any dates written on the products and any opened items should be labeled and
dated. FSD also stated the cups were filled with milk for patients on renal diets (a food plan for people with
kidney disease) and should have been labeled and dated.
During a concurrent observation and interview on 1/24/2023 at 10:40 a.m. with FSD in the kitchen, two
large pans of cooked rice were stored in the hot holding cabinet which were unlabeled and undated. FSD
stated the rice would be used as an alternative to the lunch menu being served and would also be used for
the hospital cafeteria to serve to staff and visitors. FSD stated she was not sure what time the rice was
prepared and should have had the date and time of preparation to know when it would expire and when it
needed to be discarded.
During a concurrent observation and interview on 1/24/23 at 12:10 p.m. with Kitchen Supervisor (KS), KS
stated beverages in the paper cups in the reach in refrigerator were soy milk and should have been labeled
and dated to identify the content and to indicated when to discard it.
During a review of facility's P&P titled, Food and Supply Storage dated 1/2022, the P&P indicated the
facility should cover, label and date unused portions and open packages. Products were good through the
close of business on the date noted on the label and should refer to the food storage chart to determine
discard dates for food items.
During a review of the 2022 U.S. FDA Food Code section 3-602.11 titled, Food Labels, the Food code
indicated food packaged in food establishment should be labeled the common name of the food.
During a review of the 2022 US FDA Food Code section 3-501.17 titled. Ready-to-Eat, Time/Temperature
Control for Safety Food, Date Marking, the Food Code indicated, ready-to-eat, time/temperature control for
safety food prepared and held in a food establishment for more than 24 hours should be clearly marked to
indicate the date or day by which the food should be consumed on the premises, sold, or discarded.
3.During a concurrent observation and interview on 1/24/23 at 10:55 a.m. with FSD, FSD checked and
tested the vegetable wash and sanitizer and stated the PH (a scale used to specify the acidity or basicity of
a solution) of the sanitizer solution was 5 and acceptable range should be 3.5 or lower.
During a concurrent review of the facility's PH log dated 1/24/23, the log indicated sanitizer PH was within
normal range of 3.5. FSD stated she was not sure what happened but would call the service
(continued on next page)
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 9 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0812
company to check the sanitizer dispenser.
Level of Harm - Minimal harm
or potential for actual harm
During a review of the facility's P&P titled, Food Handling Guidelines (HACCP) dated 1/2022, the P&P
indicated, the facility should follow steps to clean all whole raw fruits, vegetables and herbs which included
verifying PH of the sanitizing solution with a test strip. The P&P also indicated the dispenser should not be
used if PH range was greater than 3.5 and should wash produce under running water using the double
wash method.
Residents Affected - Some
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 10 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0880
Provide and implement an infection prevention and control program.
Level of Harm - Minimal harm
or potential for actual harm
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on
observation, interview, and record review the facility failed to implement and maintain an infection
prevention and control program designated to provide a safe, sanitary, and comfortable environment to help
prevent the development and transmission of diseases and infection for the following:
Residents Affected - Few
1a. Discontinue an intravenous ([IV]-existing, taking place or administering into a vein) midline catheter (a
catheter placed into the peripheral vein) after 29 days as indicated in the manufacturer's guideline for one
out of two sampled residents (Resident 2).
1b. Change the dressing of a Mid- Line IV dressing after 72 hours for one of two sampled residents
(Resident 2) as indicated in the facility's policy and procedures (P&P).
2. Perform hand hygiene in between taking off dirty gloves and putting on clean gloves during wound (an
injury to the body that typically involves a break on the skin) care treatment for one of one sampled resident
(Resident 9).
These deficient practices had the potential to result in the spread of infection for Resident 2 and Resident
9)
Findings:
1a. During a review of Resident 2's admission record (face sheet), the face sheet indicated Resident 2 was
originally admitted on [DATE] and re-admitted on [DATE], with diagnosis that included respiratory failure (a
condition where lungs cannot get enough oxygen into the blood), encephalopathy (altered brain function or
structure), and quadriplegia (paralysis of all limbs [arm and/or legs of a person] of the body)
During a review of Resident 2's minimum data set ([MDS] a standardized care assessment and care
screening tool) dated 12/30/2022, the MDS indicated Resident 2 was in a comatose state (a state of
unconsciousness where a person is unresponsive and cannot be woken). The MDS indicated Resident 2
was total dependent of two-person assist with bed mobility, dressing, eating, personal hygiene, and toilet
use.
During a concurrent interview and record review on 1/26/2023, at 11:28 a.m., with Registered Nurse 1
(RN1), Resident 2's physician's orders were reviewed. RN 1 stated Resident 2 had an order for a midline
catheter to be placed on 11/27/2022 for antibiotic (medication used to treat an infection) administration. RN
1 stated since 11/27/2022, Resident 2 has been on and off antibiotics due to respiratory infections. RN 1
stated she was not sure how long the midline catheter should remain in the vein, but she believed it was
good for at least six (6) weeks.
During an interview on 1/26/2023, at 11:45 a.m., with the facility's peripherally inserted central catheter
nurse ([PICC Nurse]-RNs that insert catheter lines into a patient's vein to administer medication), the PICC
Nurse stated the midline catheter was used for 29 days. The PICC Nurse stated after 29 days the midline
catheter must be removed because there was an increased risk for the resident to develop an infection, the
catheter could become blocked, or a clot could form.
During an interview on 1/26/2023, at 11:55 a.m. with RN 1, RN 1 stated she taught the midline
(continued on next page)
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 11 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0880
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
catheter was good for six weeks. RN 1 stated she would obtain an order from the physician to discontinue
the midline catheter. RN 1 stated it was important not to keep midline catheter in the resident's vein for
more than 29 days because of infection control issues that could jeopardize the residents' health.
During a review of the manufacturers undated guidelines for a powerglide midline catheter, the guidelines
indicated the device was intended for short term use (less than 30 days) to sample blood and administer
fluids.
1b. During an observation on 1/24/2023, at 11:21 a.m., Resident 2 was observed with an IV midline
catheter. Resident 2's midline catheter dressing had a date of 1/21/2023.
During a concurrent interview and policy review with RN 1 on 1/26/2023, at 11:28 a.m., RN 1 stated she
was responsible for flushing, assessing, and changing the dressing of the IV midline catheter when needed.
RN 1 stated the IV midline dressing was changed every seven (7) days. RN 1 stated she did not know the
facility's policy on IV therapy and management instructed the IV midline dressing to be changed every 72
hours. RN 1 stated it was important to change the midline catheter dressing every 72 hours because of
infection control issues that could jeopardize the resident's health.
During an interview on 1/24/2023, at 11:35 a.m., with the nurse manager (NM1), the NM 1 stated she was
not aware the facility's policy on IV therapy and management instructed the staff to change the IV midline
dressing every 72 hours. NM 1 stated it was important for the nurses to know and understand the
importance of changing the midline catheter dressing every 72 hours because of infection control issues
that could affect the resident's health.
During a review of the facility's policy (P&P) titled Intravenous Therapy-Initiation and Management of
Peripheral Intravenous Lines with a revision date of 3/2022, the P&P indicated the dressing should be
changed aseptically (free from contamination) after 72 hours.
2. During a review of Resident 9's admission Record, the admission record indicated Resident 9 was
originally admitted to the facility on [DATE] and readmitted on [DATE], with diagnoses not limited to chronic
respiratory failure (a condition that occurs when the lungs cannot get enough oxygen into the blood or
eliminate enough carbon dioxide [a type of gas produced by respiration] from the body), cerebral infarction
(occurs as a result of disrupted/blocked blood flow to the brain), type 2 diabetes (abnormal blood sugar).
During a review of Resident 9's MDS dated [DATE], the MDS indicated Resident 9 was in a persistent
vegetative state (coma) and no discernible consciousness (the absence of awareness). The MDS also
indicated Resident 9 was total dependent and required two people to move Resident 9 in bed and side to
side.
During a review of Resident 9's Orders (MD orders), dated 12/29/2022, the MD orders indicated Resident 9
had wound care treatment to the sacrum (tailbone) every 12 hours. The MD orders indicated to clean the
sacrum with dakins (antiseptic cleansing solution), then pat dry, apply dakins soaked gauze, and cover with
Opti foam (a type of dressing).
During a wound care observation on 1/27/2023, at 10:21 AM, in Resident 9's room, licensed vocational
nurse, (LVN) 1 put on clean gloves, removed the dirty dressing, took off the dirty gloves, put on cleaned
gloves, cleansed Resident 9's wound with dakins, took off the dirty gloves, put on clean
(continued on next page)
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 12 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0880
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
gloves, applied a soaked gauze of dakins to Resident 9's wound, applied Opti foam to resident 9's wound,
took off the gloves, put on clean gloves, cleansed the area, took off the gloves, and applied alcohol hand
based sanitizer (AHBS) to hands at the end. LVN 1 did not perform hand hygiene in between tasks while
performing wound care treatment on Resident 9's sacrum.
During an interview on 1/27/2023, at 10:32 AM, with LVN 1, LVN 1 stated she did not cleanse her hands in
between dirty and clean gloves. The LVN 1 stated was importance for her to clean her hands in between
changing dirty gloves either by using a ABHS or washing her hands to prevent cross contamination (the
process by which bacteria or other microorganisms are unintentionally transferred from one substance or
object to another, with harmful effect)
During an interview on 1/27/2023, at 10:35 AM, with Infection Prevention Nurse ([IPN] a nurse in charge of
infection control practices for the facility), IPN stated staff must perform hand hygiene when changing dirty
and clean gloves. The IPN stated the staff could either use AHBS or wash their hands. The IPN stated staff
must wash hands if hands were visibly soiled. IPN also stated the staff must wash hands at the end of
wound care dressing change.
During a review of the facility's P&P titled Hand hygiene with a revision date of 2/2022, the P&P indicated If
hands are not visibly soiled, use an alcohol-based hand rub for decontaminating hands when moving from
a contaminated body site to a clean body site during patient care, every time gloves are removed, and
before donning (putting on) and removing gloves.
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 13 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0881
Implement a program that monitors antibiotic use.
Level of Harm - Minimal harm
or potential for actual harm
**NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on
interview and record review the facility failed to implement its protocol for antibiotic use (medication used to
treat a bacterial infection) for three out of three sampled residents (Resident 2, Resident 14, and Resident
11). Resident 2, Resident 14, and Resident 11 were currently being treated with antibiotics without the
facility verifying the antibiotic was appropriate for the residents' condition.
Residents Affected - Few
This deficient practice had the potential to result in a Multidrug-Resistant Organism ([MDRO]
microorganisms that are resistant to one or more classes of antimicrobial agents) which could jeopardize
the resident's health and make treatment ineffective.
Findings:
During a review of Resident 2's admission Record (Face Sheet), the face sheet indicated Resident 2 was
originally admitted on [DATE] and re-admitted on [DATE] with a diagnosis that included respiratory failure (a
condition where lungs cannot get enough oxygen into the blood), encephalopathy (altered brain function or
structure), and quadriplegia (paralysis of all limbs [legs and/or arms] of the body)
During a review of Resident 2's Minimum Data Set ([MDS] a standardized care assessment and care
screening tool), dated 12/30/2022, the MDS indicated Resident 2 was in a comatose state (a state of
unconsciousness where a person is unresponsive and cannot be woken). The MDS indicated Resident 2
was total dependence of two person-assist with bed mobility, dressing, eating, personal hygiene, and toilet
use.
During a review of Resident 2's Physician Orders dated 1/18/2023, the physician orders indicated Resident
2 had an order for Cefepime (an antibiotic) 1000 milligrams ([mg] unit of measurement), intravenous ([IV]
given within the vein), every twelve (12) hours, for respiratory infection (infection in the lungs).
During a review of Resident 2's Nursing Progress Notes (NPN) dated 1/19/2023, at 4:21 a.m., the NPN
indicated Resident 2 had a new order for IV antibiotic cefepime for respiratory infection.
During a review of Resident 14's Face Sheet, the face sheet indicated Resident 14 was admitted on [DATE]
with a diagnosis of respiratory failure, diabetes (abnormal blood sugar) and dementia (memory loss).
During a review of Resident 14's MDS dated [DATE], the MDS indicated Resident 14 was in a comatose
state. The MDS indicated Resident 2 was total dependent of two-person assist with bed mobility, dressing,
eating, personal hygiene, and toilet use.
During a review of Resident 14's Physician Orders dated 1/24/2023, at 6:19 p.m., the physician orders
indicated Resident 14 had an order for piperacillin-tazobactam (an antibiotic) 3.375 mg, IV, every eight (8)
hours, for pneumonia (infection of the lungs)
During a review of Resident 14's Physician Orders dated 1/24/2023, at 6:33 p.m., the physician orders
indicated Resident 14 had an order for sulfamethoxazole-trimethoprim (an antibiotic) 200-40 mg, IV, every
twelve (12) hours, for pneumonia.
(continued on next page)
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 14 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0881
Level of Harm - Minimal harm
or potential for actual harm
Residents Affected - Few
During a review of Resident 14's NPN dated 1/25/2023, at 7:07 p.m., the NPN indicated Resident 14 was
on IV antibiotics for pneumonia.
During a review of Resident 11's Face Sheet, the face sheet indicated Resident 11 was originally admitted
on [DATE] and re-admitted on [DATE] with a diagnosis of respiratory failure, quadriplegia, and Crohn's
disease (inflammatory disease of the intestine).
During a review of Resident 11's MDS dated [DATE], the MDS indicated Resident 11 cognitive skills
(thought process) was intact and Resident 11 could be understood by others. The MDS indicated Resident
11 was total dependent of two-person assist with transfers, bed mobility, dressing, eating, personal hygiene
and toilet use. The MDS indicated Resident 11 required an indwelling catheter (flexible tube inserted in the
bladder to help urine).
During a review of Resident 11's care plan titled The Resident Has Indwelling Catheter Due to Neurogenic
Bladder (lack of bladder control) dated of 5/14/202, the care plan interventions indicated to monitor and
report to medical doctor (MD) signs and symptoms of a urinary tract infection ([UTI]- infection in the
bladder).
During a review of Resident 11's care plan titled Resident Has a History of UTI dated 5/14/2020, the care
plan interventions indicated to administer antibiotic therapy as ordered and monitor side effects and
effectiveness of the antibiotic.
During a review of Resident 11's Physician Orders dated 1/18/2023, at 6:13 p.m., the physician orders
indicated Resident 11 had orders for Cefepime (an antibiotic) 1000 mg, IV, every twelve (12) hours, for UTI.
During a review of Resident 11's NPN dated 1/18/2023, at 6:55 p.m., the NPN indicated Resident 11 was
ordered Cefepime for UTI.
During a concurrent interview and record review on 1/26/2023, at 9:40 a.m., with infection prevention (IP)
nurse, the antibiotic forms for Resident 14, and Resident 11 were reviewed. The IP nurse stated Resident
14 was prescribed two antibiotics on 1/24/2023. IP nurse stated the antibiotic form for Resident 14 was not
accurate because the form indicated the antibiotic was for a bloodstream infection and Resident 14
antibiotics were prescribed for a respiratory infection. IP nurse stated for Resident 14, the antibiotic form
was also missing the date and the antibiotics prescribed. IP nurse stated for Resident 11, the antibiotic form
was not accurate because it had a missing date the antibiotic was prescribed. The IP stated Resident 2 was
on antibiotics for a respiratory infection from 1/18/2023 to 1/24/2023. The IP nurse stated Resident 2 was
missing an antibiotic form because the license nurse failed to fill one out. IP nurse stated was important for
the antibiotic forms to be filled correctly because it was part of the facility's antibiotics stewardship program
(refers to a set of commitments and actions designed to optimize the treatment of infections while reducing
the adverse events associated with antibiotic use) to prevent the overuse of antibiotics and antibiotic
resistance bacteria.
During an interview on 1/26/2023, at 2:28 p.m., with License vocational nurse 1 (LVN 1), LVN 1 stated the
nurses were required to fill out the antibiotic form pertinent to the infection the resident was being treated
for each time an antibiotic was prescribed. LVN 1 stated it was important to fill out the antibiotic form correct
to justify the need for the antibiotic use and to prevent the overuse of antibiotics which could lead to
antibiotic resistance organism.
(continued on next page)
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 15 of 16
Printed: 05/15/2026
Form Approved OMB
No. 0938-0391
Department of Health & Human Services
Centers for Medicare & Medicaid Services
STATEMENT OF DEFICIENCIES
AND PLAN OF CORRECTION
(X1) PROVIDER/SUPPLIER/CLIA
IDENTIFICATION NUMBER:
(X2) MULTIPLE CONSTRUCTION
555874
B. Wing
A. Building
(X3) DATE SURVEY
COMPLETED
01/27/2023
NAME OF PROVIDER OR SUPPLIER
STREET ADDRESS, CITY, STATE, ZIP CODE
Southern California Hosp at Culver City D/P Snf
3828 Delmas Terrace
Culver City, CA 90232
For information on the nursing home's plan to correct this deficiency, please contact the nursing home or the state survey agency.
(X4) ID PREFIX TAG
SUMMARY STATEMENT OF DEFICIENCIES
(Each deficiency must be preceded by full regulatory or LSC identifying information)
F 0881
Level of Harm - Minimal harm
or potential for actual harm
During a review of the facility's policies and procedures (P&P) titled Antimicrobial Stewardship Program with
a revision date of 7/2019, the P&P indicated all antimicrobial use would be monitored through the
antimicrobial stewardship program.
Residents Affected - Few
FORM CMS-2567 (02/99)
Previous Versions Obsolete
Event ID:
Facility ID:
555874
If continuation sheet
Page 16 of 16