Health inspection·August 11, 2023

F 0550 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some Record review of Resident #1's Hospital Records dated 12/05/23 revealed Psychiatric Consult chief complaint: I have this leg .History of present illness: Pt is a [AGE] year old female presented to the hospital due to LLE swelling. Of note, pt. is living in poor conditions with no running water, and it is suspected that there is no electricity. Psych was consulted for capacity to make the decision to return home .Pt is able to state that she wants to go home. However, she does not acknowledge the risks of her current conditions because she does not admit that there are any risks and therefore lacks capacity .follow-up care needs: APS . Record review Resident #1's Accounts Receivable Report dated 08/10/23 by the Regional Accounts Receivable Representative revealed, .07/11/23 Administrator and I went to the bank yesterday and was told they were working on it, got a call that they can't provide bank statements without ID from patients even with POA. Went to their condo today and looked thru apartment and had locksmith come open car and could not find their purse with their ID's .06/11/23 Administrator and I went to the bank with POA paperwork, and we have been approved by bank attorneys to have access to bank account, but their system is requesting ID's . Record review of Resident #1's Statutory Durable POA and Medical document notarized and signed by Resident #1 on June 1, 2023, revealed co-agent POA's Regional Accounts Receiving and the Administrator who had all of the powers listed including (A) through (N) (real property transactions, business operations, benefits from social security, etc.). Interview on 08/10/23 at 5:06 pm, Resident #1 stated she and her sister Resident #2 had been at this facility for a few months and they did not have a POA because she made the decisions for her and her sister Resident #2. She stated she paid the bills for them to stay at this facility, and they were both private pay residents. She stated they had no family or close friends helping with any of their financial matters and felt they did not need a POA or anyone making decisions for them because she was still able to do. She stated the Administrator, and a lady helped her get her ID card today (08/10/23) and she was not able to say why she needed it. She stated she had not signed paperwork for anyone to be her POA. Record review of Resident #1's Drafted Guardianship document emailed by the faclity's Administrator on 08/15/23, undated and un-notarized, revealed, Application of Appointment of Permanent Guardianship for alleged incapacitated person .Proposed Wards: the Regional Accounts Receivable Representative and the facility's Owner .(several areas of this document were blank and highlighted in yellow in certain areas ) . Record review of Resident #2's Face Sheet revealed a family member was her Responsible Party. Record review of Resident #2's MDS assessment dated [DATE] revealed, a [AGE] year-old female who admitted to the facility 12/09/22 with BIMS score 15 which indicated no cognitive impairment; rejection of care 1 to 3 days; extensive one person assist for most ADL care; occasionally incontinent of bladder and always continent of bowel; and diagnoses of Rhabdomyolysis (damaged muscle tissue), fall encounter, legal blindness, lack of coordination, weakness, vitamin d deficiency and combined forms of bilateral age-related cataract. Record review of Resident #2's Doctor/Nurse Practitioner consult dated 07/03/23 revealed, .Anxiety, possible dementia, debility and constipation . Record review of Resident #2's Hospital Records were requested from the DON on 08/10/23 at 5:55 pm, (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 2 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0550 but all of the sheets were not provided to the HHSC Surveyor when requested. Level of Harm - Minimal harm or potential for actual harm Record review of Resident #2's Accounts Receivable Aging Report dated 08/10/23 by the Regional Account Receivables Representative, revealed, .07/11/23 Administrator and I went to the bank yesterday and was told they were working on it, got a call that they cant's provide bank statements without ID from patients even with POA .06/11/23 Administrator and I went to the bank with POA paperwork and we have been approved by bank attorneys to have access to bank account but their system is requesting ID's . Residents Affected - Some Record review of Resident #2's Statutory Durable POA and Medical document notarized and signed by Resident #2 on June 1, 2023, revealed co-agent POA's Regional Accounts Receiving representative and the Administrator who had all of the powers listed including (A) through (N) (real property transactions, business operations, benefits from social security, etc.). Interview on 08/10/23 at 11:16 am, Resident #2 stated her sister Resident #1 took care of their financial matters and they did not have a Power of Attorney or Guardian. She stated she did not remember signing POA paperwork. She stated for the HHSC Surveyor to talk to her sister Resident #1 about any other questions. Record review of Resident #2's Drafted Guardianship document emailed by the facility's Administrator on 08/15/23, undated and un-notarized, revealed, Application of Appointment of Permanent Guardianship for alleged incapacitated person .Proposed Wards: the Regional Accounts Receivable Representative and the facility's Owner .(several areas were blank and highlighted in yellow in certain areas) . Interview on 08/10/23 at 4:52 pm, Residents #1 and #2 family member stated she lived out of town and was not able to be POA or guardian of the two residents because she was already caring for family members at home and could only assist with providing family contact information. Interview on 08/10/23 at 2:55 pm, the LVN Weekend Nurse Supervisor stated Resident #1's cognition was A/O (alert and oriented)x 2 with intermittent confusion and Resident #2's cognition was A/O (alert and oriented) x 2 with intermittent confusion. Interview on 08/10/23 at 5:41 pm, the DON stated Resident #1's cognition was A/O (Alert and oriented) x 2/3 and Resident #2's cognition was A/O x 2/3 and said the Administrator was working on getting their ID cards, because they lost all of their banking info, to get into her account. She stated SW B was working on getting guardianship for them. Interview on 08/10/23 5:22 pm, the BOM stated Residents #1 and #2 were siblings and were private pay residents. She stated they were sent from the hospital without their identification cards or social security cards which was why the facility staff was helping them get replacement cards. She stated although they were being charged the private pay rate, they had not paid rent since they admitted . Interview on 08/10/23 at 6:00 pm, the Administrator stated Residents #1 and #2 were related and admitted to the facility in January 2023 and their cognition was good but they were living alone and needed help and both residents were currently in the middle of getting a guardian. He stated they admitted without their identification cards, social security cards and birth certificates and the residents were unable to do anything like pay their room and board. He stated Residents #1 and #2 had 1.5 million dollars and owned a shopping center and said he was working with an attorney to assist with (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 3 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0550 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some the guardianship process. He stated he was currently Resident #1 and #2's POA and their goal was for both residents to return home. He stated the Doctor assessed them and said they had cognitive deficits and appropriate for needing guardianship and said the facility paid $10,000 dollars for an attorney to start the guardianship process a month and half ago. He stated Residents #1 and #2 had three bank accounts with Bank #1, Bank #2 and he was unsure of the name of Bank #3. He stated Resident #1 and #2's family member said she would not be able to assist with being their guardian. Interview on 08/11/23 at 9:24 am, the Administrator stated Residents #1 and #2's HOA representative told him Residents #1 and #2 had 1.5 million dollars but was not really sure if that was accurate. He stated they could possibly have no money but said he was able to validate they owned a shopping center in another town. He stated Residents #1 and #2 admitted to this facility as Medicare residents getting skilled services and when they became private pay residents and had no money to pay their rent the former SW A contacted APS, A Guardianship Program and the ombudsman and former SW A said neither of those sources were able to assist. He stated they took Resident #1 to the bank with her face sheet, but the bank needed a valid form of ID and Resident #1 said it was at her house, but he could not find them. He stated they then took Resident #1 to the DPS to get an ID card. He stated they received her birth certificate at the end of July 2023 and her social security card came last week. He stated they called the social security office to see if they had social security benefits, but they were not able to determine what income they had from the shopping center or who was managing it. He stated they had no family members or children and spoke to the hospital, HOA lady and no one knew who assisted them with their finances or business. Interview on 08/11/23 at 10:52 am, the Guardianship Services Supervisor stated Residents #1 and #2 was not in their database and they did not have guardians. She stated the facility would have to file an application with the County Probate court for Residents #1 and #2 to be assigned a court investigator to visit both residents to determine next steps. Interview on 08/11/23 at 11:14 am, the HOA Representative stated Residents #1 and #2 were sisters with a condo and it had always been the two of them without any other family members for the 20 years she knew them. She stated Residents #1 and #2 were removed from their home sometime after thanksgiving of 2022 because one of the sisters was screaming like she was in pain and a neighbor called 911. She stated due to the hoarding condition of their house, it took a while for law enforcement to find the 2nd sister. She stated they lived in the condo without any electricity and water, and they were not able to use the toilet so they urinated in bottles and plastic jars and pooped in the trash can and sat the trash with feces outside their front door, which caused a bad odor. She stated Residents #1 and #2 had a POA at the healthcare facility who was taking care of both residents' situations. She stated Resident #1 and #2's POA's were the healthcare facility's Regional Account Receivable Representative and the Administer. She stated Residents #1 and #2 had a strip mall building and heard the rental checks had not been cashed and the sisters were late on their taxes for the strip mall. She stated the facility was not able to find their purses and they were trying to figure out if they had any money. She stated they owed HOA dues that used to automatically be paid from their bank. Interview on 08/11/23 at 12:08 pm, the Financial Institution Representative stated she worked in the Fraud at Risk Department, and it was reported Residents #1 and #2 had suspicious activity of their bank account based on the interaction on 06/22/23 from the Administrator and Regional Accounts Receivable Representative who tried to become the representative payer over Resident #1 and #2's financials. She stated there was an aggressive attempt to transfer Resident #1 and #2's money from (Bank #1) with $600,000 dollars to their account with this financial institution (Bank #2) that raised the red flags. She stated Residents #1 and #2 had no withdrawal activity and the POA documents (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 4 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0550 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some the Administrator and Regional Account Receivable Representative provided were declined and the residents' account were frozen because of how the facility Administrator and Regional Accounts Receivable Representative acted at the bank Interview on 08/11/23 at 1:07 pm, a Shopping Center Tenant stated she paid rent monthly to Residents #1 and #2 for the suite she had at the shopping center they owned. She stated she interacted with Residents #1 and #2 only and there was no management company and there were 6 other shops at the strip plaza. Interview on 08/11/23 at 1:33 pm, the facility's Ombudsman stated in February 2023, the facility was trying to get in contact with APS, because Residents #1 and #2 had an open APS case, due to their hoarding situation at home. She stated there was some concerns with them being discharged back home because it was an unsafe environment. She stated since Residents #1 and #2 were hoarders this facility was looking for them to move to an assisted living and was not sure what became of that. She stated either January 2023 or February 2023, she suggested Former SW A contact the local guardianship service for assistance with getting them a guardian. Interview on 08/11/23 at 2:24 pm, SW B stated the facility's Administrator and Regional Account Receivables Representative went to Resident #1 and #2's condo with the HOA Representative. Then about a month ago, the Administrator, Corporate BOM, Maintenance Director and herself went to Residents #1 and #2's condo and the HOA Representative nor LE were present with them because it never occurred for her to call the LE. She stated there was no electricity or running water, but they were there to look for the residents' social security and identification cards. She stated there were bank statements for Bank #1's business account, Bank account #2 and Bank account #3 had a statement with 200,000 on it. She stated she heard Residents #1 and #2 owned a shopping center they picked up the payments from. She stated Resident #1 and #2's condo was in horrible condition with tons of mail everywhere and they were not able to find the residents identification and social security cards. She stated they looked inside the residents 1960's car for Resident #1's purse and identification, and they found a long term insurance policy and were able to find out Resident #1 and #2's mother's DOB to get Resident #1's birth certificate. She stated last week they applied for Resident #1's social security card and yesterday, 08/10/23, the Administrator and Resident #1 went to the DMV to get her identification card. She stated she called Guardianship Specialist to get the guardianship forms and she received today and was currently filling out the forms to submit to the court. She stated Resident #1 and #2's cousin did not want to get involved. She stated the facility had not received any payments from them yet and added an attorney was helping with the guardianship process as well. She stated she was getting ready to call the guardianship specialist to see if the guardianship requests could be expedited because of the circumstances and added it was not a good idea to be POA of a facility resident because it would come across as taking the residents money and could be considered a conflict of interest. She stated Resident #1 had a neuro psychiatric evaluation which showed she had mild memory loss. Interview on 08/11/23 at 3:25 pm, the Admissions Coordinator stated when Residents #1 and #2 admitted to the facility they had no social security or identification cards or any documentation but had traditional Medicare. She stated they had no family of friends helping them get their ID and social security cards, but Former SW A was trying to assist them with obtaining them. She stated the Administrator and the Regional Accounts Receivables Representative had been their POA's for about one or two months now. Interview on 08/11/23 at 3:52 pm, the Regional Accounts Receivable Representative stated Residents (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 5 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0550 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some #1 and #2 admitted to the facility December 2022 for a short term stay and only had Medicare information from the hospital and were getting skilled nursing services. She stated sometime in February 2023 they went past their Medicare stay and Resident #1 said her, and Resident #2's identification and social security cards were in her purse at their condo. She stated Former SW A reported their living condition then the facility contacted APS and they said both residents were safe and also contacted APS to assist with long term care Medicaid, and APS said no need for APS involvement. She stated she was not sure of the first time the Administrator went to both residents condo, but the Administrator took the POA documents to the HOA Representative and she gave the Administrator a key to their condo. She stated she was not sure if the guardianship process had been started or not, but the Administrator was able to get their social security and identification cards. She stated a month ago the Administrator, Maintenance Director, SW B and herself went to Resident #1 and #2's home with the use of a key the Administrator had. She stated she was not able to determine how much money Residents #1 and #2 possibly had because she could not find recent bank statements and found a [AGE] year old social security check. She stated the facility had their attorney involved in an attempt to get their guardianships done. She stated they were able to find a couple of bank statements from 6 years ago and was not sure of the current balances; there was Bank #2 and said Bank #1's statement had a $300,000 dollars balance dated 2019 and was not sure about a Bank #1 account. She stated about a month ago, the Administrator and herself went to Bank #2 and were not able to get statements to see if Residents #1 and #2 were possibly eligible for Medicaid. She stated the facility's goal was to get them back home with home health. She stated they tried to contact different resources and were not successful. She stated they spoke to the residents cousin, and she said she was not able to assist the residents and could only let them know about other family contacts. She stated at this time they were not able to determine what assets Residents #1 and #2 had and said she was not aware Former SW A had tried to become Resident #1 and #2's POA. She stated she was not sure why the guardianship process had not been pursued until just recently. She stated the only payments they received were from Resident #1 and #2's Medicare benefit. She stated the Administrator and herself were Resident #1 and #2's POA for about a month or two. She stated they were not POA of any other residents and were only Resident #1 and #2's POA to help them with getting back home or getting them Medicaid. She stated she preferred not to be Resident #1 and #2's POA and that was why they were seeking guardianship. She stated she was not aware Residents #1 and #2 had 1.5 million dollars, but was aware they owned a shopping center according to the HOA Representative. Interview on 08/11/23 at 4:32 pm, the DON stated she did not know a lot but last year one of the resident's had fallen at home and was not able to get off the floor and LE was initially not able to find the other resident because of the condition of the condo being so cluttered. She stated Residents #1 and #2 were getting therapy services when they first admitted to the facility and were getting psych services. She stated they were not able to determine what assets they had but knew they inherited a shopping center. She stated they had no access to get into Residents #1 and #2's accounts and was not sure of anything else. She stated the Administrator, and the Regional Accounts Receivable Representative were working on being Residents #1 and #2's POA's. She stated no one had taken money out of Residents #1 and #2's bank accounts and added she did not feel the Administrator and the Regional Accounts Receivable Representative were exploiting Residents #1 and #2 in any way and were just trying to help them. Interview on 08/11/23 at 4:56 pm, the Administrator stated Residents #1 and #2 admitted to the facility January 2023, he believed, and he did not seek guardianship for them initially because they were short term stay residents. He stated they did not admit to the facility with their purses, with their identification and (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 6 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0550 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some social security cards, but they had their Medicare number from the hospital. He stated the hospital staff said Residents #1 and #2 admitted to the hospital with the clothes off of their backs. He stated mid-February 2023, they spoke to the facility's Ombudsman and APS, and they were not able to assist. He stated the police did the wellness check and they said Residents #1 and #2 could not return home until the house was cleaned. He stated he spoke to the facility's attorney and was told he could become Residents #1 and #2's POA in order to get their identification and social security cards. He stated the Regional Accounts Receivable Representative was also assisting with the matter. He stated from February 2023 to May 2023 they did not have a social worker. He stated around May 2023 or June 2023 was the first time he took Resident #1 to Bank #2 with her face sheet and the bank said the face sheet was not a legal document and they would need a valid identification card. He stated Resident #1 received her birth certificate 3 to 4 weeks ago and received her social security card two weeks ago and just recently got Resident #1's identification card. He stated they would continue working on the process to get access to Residents #1 and #2's bank accounts to determine if they could return home or not. He stated all they knew was that the HOA Representative said Residents #1 and #2 had millions of dollars but they may not have anything. He stated Residents #1 and #2's Bank #1 statements from 2018 showed a balance of $300,000 dollars, but he could not remember the balance of Bank# 2 and was not aware of a Bank #3 account. He stated Residents #1 and #2 had a life insurance policy and was not sure of the amount. He stated they started the guardianship process mid-July 2023, and was not sure why they had not completed the guardianship application sooner. He stated the Regional Accounts Receivable Representative and himself were Residents #1 and #2's POA for about a month or two months. Interview on 08/11/23 at 6:10 pm, the Administrator stated he was able to get Residents #1 and #2's condo key by giving the HOA Representative a copy showing he was POA in June 2023 or July 2023. He stated Residents #1 and #2's condo key was stored in his office. He stated the Administrative Assistant and Regional Human Resources spoke to Former SW A and handled the matter because he was out of town. He stated he and the Regional Accounts Receivable Representative went through corporate and the attorney to get the POA, but Former SW A tried to do it by herself without the Administrator's instructions. He stated the first time going to Residents #1 and #2's condo he was with the HOA Representative, the HOA [NAME] President and the second time they went to Residents #1 and #2's condo he went with the Regional Accounts Receivable Representative, Maintenance Director. He stated he was not sure of Residents #1 and #2's capacity, but their doctor said they were appropriate to apply for guardianship and to get off of being their POA's. Interview on 08/11/23 at 1:48 pm and 3:20 pm was attempted and messages were left with Residents #1 and #2's Doctor and did not get a return call. Interview on 08/11/23 at 6:45 pm was attempted and a message was left for Residents #1 and #2's Attorney to call the HHSC Surveyor. Record review of the facility's Advance Directives Policy Revised December 2016 revealed, Policy Statement: Advance directives will be respected in accordance with state law and facility policy .8. If the resident indicates that he or she has not established advance directives, the facility staff will offer assistance in establishing advance directives. FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 7 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0607 Develop and implement policies and procedures to prevent abuse, neglect, and theft. 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 written policies and procedures to prohibit and prevent misappropriation of property for two (Residents #1 and #2) of seven residents reviewed for abuse. Residents Affected - Some The facility failed to follow their own Abuse, Neglect and Misappropriation of Property Policy once they found out Former SW A alleged attempt to become Residents #1 and #2's POA and clean their condo on 02/15/23. The Administrator failed to report and start investigating Former SW A for alleged misappropriation of property of Residents #1 and #2's personal belongings and funds, which was reported to the DON, Administrator and Administrative Assistant on 02/15/23, by the local Fire and Rescue and HOA Representatives. This failure could place all residents at risk of misappropriation of property which could result in diminished funds, emotional anguish, discomfort, and decreased psycho-social well-being. Findings included: Record review of Resident #1's MDS assessment dated [DATE] revealed, a [AGE] year-old female who admitted to the facility on [DATE] with a BIMS Score of 9 which indicated moderate cognitive impairment ); rejection of care 1 to 3 days and functional status was supervision with setup and one person assist for most ADL's; occasionally incontinent of bladder and always continent of bowel; and diagnoses of lymphedema, lack of coordination, weakness, primary insomnia, folate deficiency anemia and vitamin d deficiency. Record review of Resident #1's Doctor/Nurse Practitioner note dated 07/08/23 revealed left lower extremity lymphedema .anxiety .possible dementia .constipation. Record review of Resident #1's Hospital Records dated 12/05/23 revealed Psychiatric Consult chief complaint: I have this leg .History of present illness: Pt is a [AGE] year old female presented to the hospital due to LLE swelling. Of note, pt. is living in poor conditions with no running water, and it is suspected that there is no electricity. Psych was consulted for capacity to make the decision to return home .Pt is able to state that she wants to go home. However, she does not acknowledge the risks of her current conditions because she does not admit that there are any risks and therefore lacks capacity .follow-up care needs: APS . Interview on 08/10/23 at 5:06 pm, Resident #1 stated she and her sister Resident #2 had been at this facility for a few months and they did not have a POA because she made the decisions for her and her sister Resident #2. She stated she paid the bills for them to stay here, and they were both private pay residents. She stated they had no family or close friends helping with any of their financial matters and felt they did not need a POA or anyone making decisions for them because she was still able to do. She stated the Administrator, and a lady helped her get her ID card today and was not able to say why she needed it. She stated she had not signed any paperwork for anyone to be her POA. Record review of Resident #2's MDS assessment dated [DATE] revealed, a [AGE] year-old female who admitted to the facility 12/09/22 with BIMS score 15 which indicated no cognitive impairment; rejection of care 1 to 3 days; extensive one person assist for most ADL care; occasionally incontinent of bladder and always continent of bowel; and diagnoses of Rhabdomyolysis (damaged muscle tissue), fall encounter, legal blindness, lack of coordination, weakness, vitamin d deficiency and combined forms (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 8 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0607 of bilateral age-related cataract. Level of Harm - Minimal harm or potential for actual harm Record review of Resident #2's Doctor/Nurse Practitioner consult dated 07/03/23 revealed, .Anxiety, possible dementia, debility and constipation . Residents Affected - Some Record review of Resident #2's Hospital Records were requested from the DON on 08/10/23 at 5:55 pm, but all of the sheets were not provided to the HHSC Surveyor when requested. Interview on 08/10/23 at 11:16 am, Resident #2 stated her sister Resident #1 took care of their financial matters and they did not have a Power of Attorney or Guardian. She stated she did not remember signing for anyone to be her POA. She stated for the HHSC Surveyor to talk to her sister Resident #1 about any other questions. Record Review of Former SW A's Disciplinary Action form dated 02/15/23 by the Director of Human Services revealed, Dear [Former SW A], this letter confirms our discussion today informing you that your employment with this facility is terminated effective immediately due to violation of the company ethics policy as listed in the employee handbook issued to you at the time of hire. You willfully mislead the company and outside agencies of your intentions regarding resident financial and guardianship status . Interview on 08/10/23 at 6:00 pm, the Administrator stated Residents #1 and #2 were related and admitted in January 2023 and their cognition was good but they were living alone and needed help and both residents were currently in the middle of getting a guardian. He stated they admitted without their identification cards, social security cards and birth certificates and the residents were unable to do anything like pay their room and board. He stated Residents #1 and #2 had 1.5 million dollars and owned a shopping center and said he was working with an attorney to assist with the guardianship process. He stated the Doctor assessed them and said they had cognitive deficits and appropriate for needing guardianship and said the facility paid $10,000 dollars for an Attorney to start the guardianship process a month and half ago. He stated Residents #1 and #2 had three bank accounts with Bank #1, Bank #2 and was unsure of the name of Bank #3. He stated Resident #1 and #2's family member said she would not be able to assist with being their guardian. Interview on 08/11/23 at 9:24 am, the Administrator stated Residents #1 and #2's HOA representative told him Residents #1 and #2 had $ 1.5 million dollars, but was not really sure if that was accurate. He stated they could possibly have no money but said he was able to validate they owned a shopping center in another town. Interview on 08/11/23 at 11:14 am, the HOA Representative stated earlier this year, Former SW A tried to get guardianship of the sisters and she wanted to come over with her friends to clean Residents #1 and #2's condo and said she was able to get the local Fire Department Representative to talk to Former SW A about her plans of going out to clean the sister's condo. She stated the local Fire Department representative told her about the conversation with Former SW A just gave him a bad vibe and he said he went to the facility earlier this year and asked the DON if former SW A should be cleaning Residents #1 and #2's condo and the DON said no Former SW A should not be going to their condo or doing anything else. She stated the local Fire Department Representative said the Administrator suspended former SW A. Interview on 08/11/23 at 12:43 pm, the Fire and Rescue Department Representative stated he was working with trying to get Residents #1 and #2 situated at the facility and the facility's Former SW A (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 9 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0607 was talking about getting the residents to sign something and to help them out with cleaning their property. Level of Harm - Minimal harm or potential for actual harm Interview on 08/11/23 at 2:24 pm, SW B stated she heard Former SW A was terminated because she tried to be Resident #1 and #2's POA but the local Fire and Rescue Representative made a complaint to the DON and Administrator and Former SW A was terminated. She added it was not a good idea to be the POA of a facility resident because it would not come across taking the residents money and could be considered a conflict of interest. Residents Affected - Some Interview on 08/11/23 at 3:52 pm, the Regional Accounts Receivable Representative stated she was not exactly sure what happened to Former SW A, but they had SW B working at this facility for about 3 months. She stated she was not aware Residents #1 and #2 had 1.5 million dollars, but was aware they owned a shopping center according to the HOA Representative. Interview on 08/11/23 at 4:32 pm, the DON stated she did not know a lot, but last February 2023 the HOA Representative questioned Former SW A's intent with why she was at Resident #1 was and #2's condo trying to help clean their condo to find their wallet. She stated mid-February 2023, the Fire and Rescue Representative said he spoke to former SW A on the phone with the HOA Representative and he was afraid something not okay going on at the Residents #1 an #2's condo; he questioned was Former SW A wanting to go the resident's condo for her own gain. She stated two people from the HOA and two people from Fire and Rescue wrote statements about former SW A 's actions of wanting to clean the resident's condo and have the resident's sign something and gave them to the Administrator and Former SW A was sent home immediately. She stated SW A was upset someone would think she tried to manipulate Residents #1 and #2. She stated former SW A said she was trying to be their POA because their apartment was a mess and Residents #1 and #2 were not able to return home to clean it on their own because they had no running water or electricity. She stated she was not sure if the allegations against SW A were reported to HHSC, and she would have to ask the Administrator. Interview on 08/11/23 at 4:56 pm, the Administrator stated the Former SW A was terminated due to code of conduct back in February 2023, because the Fire and Rescue Representative said he had concerns about Former SW A because she was asking questions about Residents #1 and #2's condo and wanting to clean it. He stated Former SW A was not able to say why was she trying to do that and was not sure of the specifics and was not able to recall much about it. He stated they questioned Former SW A about Residents #1 and #2 and she was terminated due to poor work quality and that she tried to go to their house without the facility staff knowing about it and without Residents #1 and #2's consent. He stated they determined Former SW A had no access to anything because no documents had been signed by Residents #1 and #2. He stated all they knew was that the HOA Representative said Residents #1 and #2 had millions of dollars but they may not have nothing. He stated Residents #1 and #2's Bank 1 statements from 2018 showed a balance of $300,000 dollars, but could not remember the balance of Bank 2 and was not aware of a Bank 3 account. He stated Residents #1 and #2 had a life insurance policy and was not sure of the amount. He stated he was responsible for protecting the resident's funds and responsible for reporting allegations of abuse, neglect and misappropriation on property. Interview on 08/11/23 at 6:10 pm, the Administrator stated earlier this year, the Administrative Assistant and Regional Human Resources spoke to Former SW A and handled the matter by writing her up and terminating her, because he was out of town. He stated he and the Regional Accounts Receivable Representative went through corporate and the attorney to get the POA, but Former SW A tried to be Resident's #1 and #2's POA by herself and without the Administrator's instructions. He stated the reason why the incident involving Former SW A was not reported to HHSC was because she did not steal or (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 10 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0607 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some do anything to have caused it to be reportable. He stated he nor his Administrative Assistant did an investigation after Former SW A was terminated for breaking the company code of conduct and was not sure why. He stated the LE had not been called to report the allegation against Former SW A. He stated the HOA Representative reported former SW A was asking all those questions about Resident #1 and #2's Condo so he got statements from the HOA Representative and Fire and Rescue Representatives and would have to get his Administrative Assistant to get a copy of them. Interview on 08/15/23 at 1:45 pm, the Local Fire and Rescue Representative stated the HOA Representative had been talking back and forth with him because his job was trying to provide solutions for Residents #1 and #2 to return home. He stated he spoke to Former SW A on 02/15/23 by phone with his co-worker and the HOA Representative. He stated Former SW A seemed really adamant more than normal about cleaning Residents #1 and #2's condo. He stated the Former SW A said twice that she was going to get Resident's #1 and #2 to sign POA forms so she could have access to pay their bills. He stated it was a conflict of interest for Former SW A to have access to all of Residents #1 and #2's assets and added Former SW A mentioned her and some of her friends were going to clean up Residents #1 and #2's house. He stated it seemed really weird that the Former SW A said she was going to clean their house instead of professionals. He stated he asked Former SW A where the facility was located, and on 02/15/23 he went straight to the facility and spoke to the DON about what the Former SW A said. He stated the DON told the Administrative Assistant and they called the Administrator on speaker phone about what the Former SW A said to them. He stated the DON, and the Administrative Assistant were both very unsettled about this information. He stated he was in a meeting with the DON, the Administrative Assistant and Administrator (by phone) and Former SW A got super defensive and said that she never said any of that stuff and she started yelling and was upset. He stated he and his co-worker wrote statements about what the Former SW A said about the whole interaction from start to finish and the DON and the other lady and Administrator were shocked about what Former SW A said to them. He stated he went to the facility to prevent Former SW A from having Residents #1 and #2 sign anything. He stated he did not have a copy of the statements about Former SW A because they were given to the DON and Administrative Assistant. Interviews between 08/10/23 - 08/14/23 with Former SW A were attempted several times, but she did not return the HHSC Surveyor's calls. Interview on 08/11/23 at 6:35 pm was attempted with the Administrator Assistant and she did not return the HHSC Surveyor's call. Interview on 08/11/23 at 1:48 pm and 3:20 pm was attempted with Residents #1 and #2's Doctor and did not get a return call. Interview on 08/11/23 at 6:45 pm was attempted and message was left for Residents #1 and #2's Attorney to call the HHSC Surveyor. Record review of the local Fire and Rescue Representative and HOA Representative's statements against Former SW A were requested from the DON on 08/11/23 at 4:32 pm and not provided to the HHSC Surveyor. Record review of the local Fire and Rescue Representative and HOA Representative's statements against Former SW A were requested from the Administrator on 08/11/23 at 4:56 pm and 6:10 pm but were not provided to the HHSC Surveyor. (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 11 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0607 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some FORM CMS-2567 (02/99) Previous Versions Obsolete Record review of the facility's investigation about the allegations made against Former SW A were requested from the Administrator on 08/11/23 at 6:10 pm but were not provided to the HHSC Surveyor. Record review of the Facility's Abuse and Neglect Policy dated 02/01/2020 revealed, Policy: It is the policy of this facility to provide protections for the health, welfare and rights of each resident by developing and implementing written policies and procedures that prohibit and prevent abuse, neglect, exploitation and misappropriation of resident property .the facility will have written procedures that include: 1. Reporting of all alleged violations to the Administrator, state Agency, adult protective services and to all other required agencies (law enforcement when applicable) within specified timeframes: Immediately, but no later than 2 hours after the allegation is made .no later than 24 hours if the events that cause the allegation do not involve abuse and do not result in bodily injury .establish policies and procedures to investigate any such allegations .The facility will provide ongoing oversight and supervision of staff in order to assure that it's policies are implemented as written . Event ID: Facility ID: 675447 If continuation sheet Page 12 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0609 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some Timely report suspected abuse, neglect, or theft and report the results of the investigation to proper authorities. **NOTE- TERMS IN BRACKETS HAVE BEEN EDITED TO PROTECT CONFIDENTIALITY** Based on interviews and record reviews the facility failed to report immediately all alleged violations of misappropriation of property, but not later than 2 hours after the allegation was made for two (Residents #1 and #2) seven residents reviewed for reporting an allegation of abuse. The facility failed to report to HHSC about the complaints against Former SW A for alleged misappropriation of property of Residents #1 and #2's personal belongings and funds, which was reported to the DON, Administrator and Administrative Assistant on 02/15/23, by the local Fire and Rescue and HOA Representatives. This failure could make all residents at risk of misappropriation of property and decline in their financial assets which could cause a decline in the resident's psycho-social well-being. Findings included: Record review of Resident #1's MDS assessment dated [DATE] revealed, a [AGE] year-old female who admitted to the facility on [DATE] with a BIMS Score of 9 which indicated moderate cognitive impairment ); rejection of care 1 to 3 days and functional status was supervision with setup and one person assist for most ADL's; occasionally incontinent of bladder and always continent of bowel; and diagnoses of lymphedema, lack of coordination, weakness, primary insomnia, folate deficiency anemia and vitamin d deficiency. Record review of Resident #1's Doctor/Nurse Practitioner note dated 07/08/23 revealed left lower extremity lymphedema .anxiety .possible dementia .constipation. Record review of Resident #1's Hospital Records dated 12/05/23 revealed Psychiatric Consult chief complaint: I have this leg .History of present illness: Pt is a [AGE] year old female presented to the hospital due to LLE swelling. Of note, pt. is living in poor conditions with no running water, and it is suspected that there is no electricity. Psych was consulted for capacity to make the decision to return home .Pt is able to state that she wants to go home. However, she does not acknowledge the risks of her current conditions because she does not admit that there are any risks and therefore lacks capacity .follow-up care needs: APS . Interview on 08/10/23 at 5:06 pm, Resident #1 stated she and her sister Resident #2 had been at this facility for a few months and they did not have a POA because she made the decisions for her and her sister Resident #2. She stated she paid the bills for them to stay here, and they were both private pay residents. She stated they had no family or close friends helping with any of their financial matters and felt they did not need a POA or anyone making decisions for them because she was still able to do. She stated the Administrator, and a lady helped her get an ID card today and was not able to say why she needed it. She stated she had not signed any paperwork for anyone to be her POA. Record review of Resident #2's MDS assessment dated [DATE] revealed, a [AGE] year-old female who admitted to the facility 12/09/22 with BIMS score 15 which indicated no cognitive impairment; rejection of care 1 to 3 days; extensive one person assist for most ADL care; occasionally incontinent of bladder and always continent of bowel; and diagnoses of Rhabdomyolysis (damaged muscle tissue), fall encounter, legal blindness, lack of coordination, weakness, vitamin d deficiency and combined forms (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 13 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0609 of bilateral age-related cataract. Level of Harm - Minimal harm or potential for actual harm Record review of Resident #2's Doctor/Nurse Practitioner consult dated 07/03/23 revealed, .Anxiety, possible dementia, debility and constipation . Residents Affected - Some Record review of Resident #2's Hospital Records were requested from the DON on 08/10/23 at 5:55 pm, but all of the sheets were not provided to the HHSC Surveyor when requested. Interview on 08/10/23 at 11:16 am, Resident #2 stated her sister Resident #1 took care of their financial matters and they did not have a Power of Attorney or Guardian. She stated she did not remember signing for anyone to be her POA. She stated for the HHSC Surveyor to talk to her sister Resident #1 about any other questions. Record Review of Former SW A's Disciplinary Action form dated 02/15/23 by the Director of Human Services revealed, Dear [Former SW A], this letter confirms our discussion today informing you that your employment with this facility is terminated effective immediately due to violation of the company ethics policy as listed in the employee handbook issued to you at the time of hire. You willfully mislead the company and outside agencies of your intentions regarding resident financial and guardianship status . Interview on 08/10/23 at 6:00 pm, the Administrator stated Residents #1 and #2 were related and admitted in January 2023 and their cognition was good but they were living alone and needed help and both residents were currently in the middle of getting a guardian. He stated they admitted without their identification cards, social security cards and birth certificates and the residents were unable to do anything like pay their room and board. He stated Residents #1 and #2 had 1.5 million dollars and owned a shopping center and said he was working with an attorney to assist with the guardianship process. Interview on 08/11/23 at 9:24 am, the Administrator stated Residents #1 and #2's HOA representative told him Residents #1 and #2 had $ 1.5 million dollars, but was not really sure if that was accurate. He stated they could possibly have no money but said he was able to validate they owned a shopping center in another town. Interview on 08/11/23 at 11:14 am, the HOA Representative stated earlier this year, Former SW A tried to get guardianship of the sisters and she wanted to come over with her friends to clean Residents #1 and #2's condo and said she was able to get the local Fire Department Representative to talk to Former SW A about her plans of going out to clean the sister's condo. She stated the local Fire Department representative told her about the conversation with Former SW A just gave him a bad vibe and he said he went to the facility earlier this year and asked the DON if former SW A should be cleaning Residents #1 and #2's condo and the DON said no Former SW A should not be going to their condo or doing anything else. She stated the local Fire Department Representative said the Administrator suspended former SW A. Interview on 08/11/23 at 12:43 pm, the Fire and Rescue Department Representative stated he was working with trying to get Residents #1 and #2 situated at the facility and the facility's Former SW A was talking about getting the residents to sign something and to help them out with cleaning their property. Interview on 08/11/23 at 2:24 pm, SW B stated she heard Former SW A was terminated because she (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 14 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0609 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some tried to be Resident #1 and #2's POA but the local Fire and Rescue Representative made a complaint to the DON and Administrator and Former SW A was terminated. She added it was not a good idea to be the POA of a facility resident because it would not come across taking the residents money and could be considered a conflict of interest. Interview on 08/11/23 at 3:52 pm, the Regional Accounts Receivable Representative stated she was not exactly sure what happened to Former SW A, but they had SW B working at this facility for about 3 months. She stated she was not aware Residents #1 and #2 had 1.5 million dollars, but was aware they owned a shopping center according to the HOA Representative. Interview on 08/11/23 at 4:32 pm, the DON stated she did not know a lot, but last February 2023 the HOA Representative questioned Former SW A's intent with why she was at Resident #1 was and #2's condo trying to help clean their condo to find their wallet. She stated mid-February 2023, the Fire and Rescue Representative said he spoke to former SW A on the phone with the HOA Representative and he was afraid something not okay going on at the Residents #1 an #2's condo; he questioned was Former SW A wanting to go the resident's condo for her own gain. She stated two people from the HOA and two people from Fire and Rescue wrote statements about former SW A 's actions of wanting to clean the resident's condo and have the resident's sign something and gave them to the Administrator and Former SW A was sent home immediately. She stated SW A was upset someone would think she tried to manipulate Residents #1 and #2. She stated former SW A said she was trying to be their POA because their apartment was a mess and Residents #1 and #2 were not able to return home to clean it on their own because they had no running water or electricity. She stated she was not sure if the allegations against SW A were reported to HHSC, and she would have to ask the Administrator. Interview on 08/11/23 at 4:56 pm, the Administrator stated the Former SW A was terminated due to code of conduct back in February 2023, because the Fire and Rescue Representative said he had concerns about Former SW A because she was asking questions about Residents #1 and #2's condo and wanting to clean it. He stated Former SW A was not able to say why was she trying to do that and was not sure of the specifics and was not able to recall much about it. He stated they questioned Former SW A about Residents #1 and #2 and she was terminated due to poor work quality and that she tried to go to their house without the facility staff knowing about it and without Residents #1 and #2's consent. He stated they determined Former SW A had no access to anything because no documents had been signed by Residents #1 and #2. He stated all they knew was that the HOA Representative said Residents #1 and #2 had millions of dollars but they may not have nothing. He stated Residents #1 and #2's Bank 1 statements from 2018 showed a balance of $300,000 dollars, but could not remember the balance of Bank 2 and was not aware of a Bank 3 account. He stated Residents #1 and #2 had a life insurance policy and was not sure of the amount. He stated he was responsible for protecting the resident's funds and responsible for reporting allegations of abuse, neglect and misappropriation on property. Interview on 08/11/23 at 6:10 pm, the Administrator stated earlier this year, the Administrative Assistant and Regional Human Resources spoke to Former SW A and handled the matter by writing her up and terminating her, because he was out of town. He stated he and the Regional Accounts Receivable Representative went through corporate and the attorney to get the POA, but Former SW A tried to be Resident's #1 and #2's POA by herself and without the Administrator's instructions. He stated the reason why the incident involving Former SW A was not reported to HHSC was because she did not steal or do anything to have caused it to be reportable. He stated he nor his Administrative Assistant did an investigation after Former SW A was terminated for breaking the company code of conduct and was not sure why. He stated the LE had not been called to report the allegation against Former SW A. He stated the HOA Representative reported former SW A was asking all those questions about Resident #1 and (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 15 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0609 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some #2's Condo so he got statements from the HOA Representative and Fire and Rescue Representatives and would have to get his Administrative Assistant to get a copy of them. Interview on 08/15/23 at 1:45 pm, the Local Fire and Rescue Representative stated the HOA Representative had been talking back and forth with him because his job was trying to provide solutions for Residents #1 and #2 to return home. He stated he spoke to Former SW A on 02/15/23 by phone with his co-worker and the HOA Representative. He stated Former SW A seemed really adamant more than normal about cleaning Residents #1 and #2's condo. He stated the Former SW A said twice that she was going to get Resident's #1 and #2 to sign POA forms so she could have access to pay their bills. He stated it was a conflict of interest for Former SW A to have access to all of Residents #1 and #2's assets and added Former SW A mentioned her and some of her friends were going to clean up Residents #1 and #2's house. He stated it seemed really weird that the Former SW A said she was going to clean their house instead of professionals. He stated he asked Former SW A where the facility was located, and on 02/15/23 he went straight to the facility and spoke to the DON about what the Former SW A said. He stated the DON told the Administrative Assistant and they called the Administrator on speaker phone about what the Former SW A said to them. He stated the DON, and the Administrative Assistant were both very unsettled about this information. He stated he was in a meeting with the DON, the Administrative Assistant and Administrator (by phone) and Former SW A got super defensive and said that she never said any of that stuff and she started yelling and was upset. He stated he and his co-worker wrote statements about what the Former SW A said about the whole interaction from start to finish and the DON and the other lady and Administrator were shocked about what Former SW A said to them. He stated he went to the facility to prevent Former SW A from having Residents #1 and #2 sign anything. He stated he did not have a copy of the statements about Former SW A because they were given to the DON and Administrative Assistant. Interviews between 08/10/23 - 08/14/23 with Former SW A were attempted several times, but she did not return the HHSC Surveyor's calls. Interview on 08/11/23 at 6:35 pm was attempted with the Administrator Assistant and she did not return the HHSC Surveyor's call. Record review of the local Fire and Rescue Representative and HOA Representative's statements against Former SW A were requested from the DON on 08/11/23 at 4:32 pm and not provided to the HHSC Surveyor. Record review of the local Fire and Rescue Representative and HOA Representative's statements against Former SW A were requested from the Administrator on 08/11/23 at 4:56 pm and 6:10 pm but were not provided to the HHSC Surveyor. Record review of the Facility's Abuse and Neglect Policy dated 02/01/2020 revealed, Policy: It is the policy of this facility to provide protections for the health, welfare and rights of each resident by developing and implementing written policies and procedures that prohibit and prevent abuse, neglect, exploitation and misappropriation of resident property .the facility will have written procedures that include: 1. Reporting of all alleged violations to the Administrator, state Agency, adult protective services and to all other required agencies (law enforcement when applicable) within specified timeframes: Immediately, but no later than 2 hours after the allegation is made .no later than 24 hours if the events that cause the allegation do not involve abuse and do not result in bodily injury . FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 16 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 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** Based on interviews and record reviews the facility failed to report immediately all alleged violations of misappropriation of property, but not later than 2 hours after the allegation was made for two (Residents #1 and #2) residents reviewed for reporting an allegation of abuse. Residents Affected - Some The facility failed to investigate complaints against Former SW A for alleged misappropriation of property of Residents #1 and #2's personal belongings and funds, which was reported to the DON, Administrator and Administrative Assistant on 02/15/23, by the local Fire and Rescue and HOA Representatives. This failure could make all residents at risk of misappropriation of property and decline in their financial assets which could cause a decline in the resident's psycho-social well-being. Findings included: Record review of Resident #1's MDS assessment dated [DATE] revealed, a [AGE] year-old female who admitted to the facility on [DATE] with a BIMS Score of 9 which indicated moderate cognitive impairment ); rejection of care 1 to 3 days and functional status was supervision with setup and one person assist for most ADL's; occasionally incontinent of bladder and always continent of bowel; and diagnoses of lymphedema, lack of coordination, weakness, primary insomnia, folate deficiency anemia and vitamin d deficiency. Record review of Resident #1's Doctor/Nurse Practitioner note dated 07/08/23 revealed left lower extremity lymphedema .anxiety .possible dementia .constipation. Record review of Resident #1's Hospital Records dated 12/05/23 revealed Psychiatric Consult chief complaint: I have this leg .History of present illness: Pt is a [AGE] year old female presented to the hospital due to LLE swelling. Of note, pt. is living in poor conditions with no running water, and it is suspected that there is no electricity. Psych was consulted for capacity to make the decision to return home .Pt is able to state that she wants to go home. However, she does not acknowledge the risks of her current conditions because she does not admit that there are any risks and therefore lacks capacity .follow-up care needs: APS . Interview on 08/10/23 at 5:06 pm, Resident #1 stated she and her sister Resident #2 had been at this facility for a few months and they did not have a POA because she made the decisions for her and her sister Resident #2. She stated she paid the bills for them to stay here, and they were both private pay residents. She stated they had no family or close friends helping with any of their financial matters and felt they did not need a POA or anyone making decisions for them because she was still able to do. She stated the Administrator, and a lady helped her get an ID card today and was not able to say why she needed it. She stated she had not signed any paperwork for anyone to be her POA. Record review of Resident #2's MDS assessment dated [DATE] revealed, a [AGE] year-old female who admitted to the facility 12/09/22 with BIMS score 15 which indicated no cognitive impairment; rejection of care 1 to 3 days; extensive one person assist for most ADL care; occasionally incontinent of bladder and always continent of bowel; and diagnoses of Rhabdomyolysis (damaged muscle tissue), fall encounter, legal blindness, lack of coordination, weakness, vitamin d deficiency and combined forms of bilateral age-related cataract. (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 17 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0610 Level of Harm - Minimal harm or potential for actual harm Record review of Resident #2's Doctor/Nurse Practitioner consult dated 07/03/23 revealed, .Anxiety, possible dementia, debility and constipation . Record review of Resident #2's Hospital Records were requested from the DON on 08/10/23 at 5:55 pm, but all of the sheets were not provided to the HHSC Surveyor when requested. Residents Affected - Some Interview on 08/10/23 at 11:16 am, Resident #2 stated her sister Resident #1 took care of their financial matters and they did not have a Power of Attorney or Guardian. She stated she did not remember signing for anyone to be her POA. She stated for the HHSC Surveyor to talk to her sister Resident #1 about any other questions. Record Review of Former SW A's Disciplinary Action form dated 02/15/23 by the Director of Human Services revealed, Dear [Former SW A], this letter confirms our discussion today informing you that your employment with this facility is terminated effective immediately due to violation of the company ethics policy as listed in the employee handbook issued to you at the time of hire. You willfully mislead the company and outside agencies of your intentions regarding resident financial and guardianship status . Interview on 08/10/23 at 6:00 pm, the Administrator stated Residents #1 and #2 were related and admitted in January 2023 and their cognition was good but they were living alone and needed help and both residents were currently in the middle of getting a guardian. He stated they admitted without their identification cards, social security cards and birth certificates and the residents were unable to do anything like pay their room and board. He stated Residents #1 and #2 had 1.5 million dollars and owned a shopping center and said he was working with an attorney to assist with the guardianship process. Interview on 08/11/23 at 9:24 am, the Administrator stated Residents #1 and #2's HOA representative told him Residents #1 and #2 had $ 1.5 million dollars, but was not really sure if that was accurate. He stated they could possibly have no money but said he was able to validate they owned a shopping center in another town. Interview on 08/11/23 at 11:14 am, the HOA Representative stated earlier this year, Former SW A tried to get guardianship of the sisters and she wanted to come over with her friends to clean Residents #1 and #2's condo and said she was able to get the local Fire Department Representative to talk to Former SW A about her plans of going out to clean the sister's condo. She stated the local Fire Department representative told her about the conversation with Former SW A just gave him a bad vibe and he said he went to the facility earlier this year and asked the DON if former SW A should be cleaning Residents #1 and #2's condo and the DON said no Former SW A should not be going to their condo or doing anything else. She stated the local Fire Department Representative said the Administrator suspended former SW A. Interview on 08/11/23 at 12:43 pm, the Fire and Rescue Department Representative stated he was working with trying to get Residents #1 and #2 situated at the facility and the facility's Former SW A was talking about getting the residents to sign something and to help them out with cleaning their property. Interview on 08/11/23 at 2:24 pm, SW B stated she heard Former SW A was terminated because she tried to be Resident #1 and #2's POA but the local Fire and Rescue Representative made a complaint to the DON and Administrator and Former SW A was terminated. She added it was not a good idea to be the (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 18 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0610 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some POA of a facility resident because it would not come across taking the residents money and could be considered a conflict of interest. Interview on 08/11/23 at 3:52 pm, the Regional Accounts Receivable Representative stated she was not exactly sure what happened to Former SW A, but they had SW B working at this facility for about 3 months. She stated she was not aware Residents #1 and #2 had 1.5 million dollars, but was aware they owned a shopping center according to the HOA Representative. Interview on 08/11/23 at 4:32 pm, the DON stated she did not know a lot, but last February 2023 the HOA Representative questioned Former SW A's intent with why she was at Resident #1 was and #2's condo trying to help clean their condo to find their wallet. She stated mid-February 2023, the Fire and Rescue Representative said he spoke to former SW A on the phone with the HOA Representative and he was afraid something not okay going on at the Residents #1 an #2's condo; he questioned was Former SW A wanting to go the resident's condo for her own gain. She stated two people from the HOA and two people from Fire and Rescue wrote statements about former SW A 's actions of wanting to clean the resident's condo and have the resident's sign something and gave them to the Administrator and Former SW A was sent home immediately. She stated SW A was upset someone would think she tried to manipulate Residents #1 and #2. She stated former SW A said she was trying to be their POA because their apartment was a mess and Residents #1 and #2 were not able to return home to clean it on their own because they had no running water or electricity. She stated she was not sure if the allegations against SW A were investigated, and she would have to ask the Administrator. Interview on 08/11/23 at 4:56 pm, the Administrator stated the Former SW A was terminated due to code of conduct back in February 2023, because the Fire and Rescue Representative said he had concerns about Former SW A because she was asking questions about Residents #1 and #2's condo and wanting to clean it. He stated Former SW A was not able to say why was she trying to do that and was not sure of the specifics and was not able to recall much about it. He stated they questioned Former SW A about Residents #1 and #2 and she was terminated due to poor work quality and that she tried to go to their house without the facility staff knowing about it and without Residents #1 and #2's consent. He stated they determined Former SW A had no access to anything because no documents had been signed by Residents #1 and #2. He stated all they knew was that the HOA Representative said Residents #1 and #2 had millions of dollars but they may not have nothing. He stated Residents #1 and #2's Bank 1 statements from 2018 showed a balance of $300,000 dollars, but could not remember the balance of Bank 2 and was not aware of a Bank 3 account. He stated Residents #1 and #2 had a life insurance policy and was not sure of the amount. He stated he was responsible for protecting the resident's funds and responsible for reporting allegations of abuse, neglect and misappropriation on property. Interview on 08/11/23 at 6:10 pm, the Administrator stated earlier this year, the Administrative Assistant and Regional Human Resources spoke to Former SW A and handled the matter by writing her up and terminating her, because he was out of town. He stated he and the Regional Accounts Receivable Representative went through corporate and the attorney to get the POA, but Former SW A tried to be Resident's #1 and #2's POA by herself and without the Administrator's instructions. He stated the reason why the incident involving Former SW A was not reported to HHSC was because she did not steal or do anything to have caused it to be reportable. He stated he nor his Administrative Assistant did an investigation after Former SW A was terminated for breaking the company code of conduct and was not sure why. He stated the LE had not been called to report the allegation against Former SW A. He stated the HOA Representative reported former SW A was asking all those questions about Resident #1 and #2's Condo so he got statements from the HOA Representative and Fire and Rescue Representatives and would have to get his Administrative Assistant to get a copy of them. (continued on next page) FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 19 of 20 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 675447 B. Wing A. Building (X3) DATE SURVEY COMPLETED 08/11/2023 NAME OF PROVIDER OR SUPPLIER STREET ADDRESS, CITY, STATE, ZIP CODE The Highlands Guest Care Center 9009 Forest LN Dallas, TX 75243 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 0610 Level of Harm - Minimal harm or potential for actual harm Residents Affected - Some Interview on 08/15/23 at 1:45 pm, the Local Fire and Rescue Representative stated the HOA Representative had been talking back and forth with him because his job was trying to provide solutions for Residents #1 and #2 to return home. He stated he spoke to Former SW A on 02/15/23 by phone with his co-worker and the HOA Representative. He stated Former SW A seemed really adamant more than normal about cleaning Residents #1 and #2's condo. He stated the Former SW A said twice that she was going to get Resident's #1 and #2 to sign POA forms so she could have access to pay their bills. He stated it was a conflict of interest for Former SW A to have access to all of Residents #1 and #2's assets and added Former SW A mentioned her and some of her friends were going to clean up Residents #1 and #2's house. He stated it seemed really weird that the Former SW A said she was going to clean their house instead of professionals. He stated he asked Former SW A where the facility was located, and on 02/15/23 he went straight to the facility and spoke to the DON about what the Former SW A said. He stated the DON told the Administrative Assistant and they called the Administrator on speaker phone about what the Former SW A said to them. He stated the DON, and the Administrative Assistant were both very unsettled about this information. He stated he was in a meeting with the DON, the Administrative Assistant and Administrator (by phone) and Former SW A got super defensive and said that she never said any of that stuff and she started yelling and was upset. He stated he and his co-worker wrote statements about what the Former SW A said about the whole interaction from start to finish and the DON and the other lady and Administrator were shocked about what Former SW A said to them. He stated he went to the facility to prevent Former SW A from having Residents #1 and #2 sign anything. He stated he did not have a copy of the statements about Former SW A because they were given to the DON and Administrative Assistant. Interviews between 08/10/23 - 08/14/23 with Former SW A were attempted several times, but she did not return the HHSC Surveyor's calls. Interview on 08/11/23 at 6:35 pm was attempted with the Administrator Assistant and she did not return the HHSC Surveyor's call. Record review of the local Fire and Rescue Representative and HOA Representative's statements against Former SW A were requested from the DON on 08/11/23 at 4:32 pm and not provided to the HHSC Surveyor. Record review of the local Fire and Rescue Representative and HOA Representative's statements against Former SW A were requested from the Administrator on 08/11/23 at 4:56 pm and 6:10 pm but were not provided to the HHSC Surveyor. Record review of the facility's investigation about the allegations made against Former SW A were requested from the Administrator on 08/11/23 at 6:10 pm but were not provided to the HHSC Surveyor. Record review of the Facility's Abuse and Neglect Policy dated 02/01/2020 revealed, Policy: It is the policy of this facility to provide protections for the health, welfare and rights of each resident by developing and implementing written policies and procedures that prohibit and prevent abuse, neglect, exploitation and misappropriation of resident property .the facility will have written procedures that include: 1 .establish policies and procedures to investigate any such allegations .The facility will provide ongoing oversight and supervision of staff in order to assure that it's policies are implemented as written . FORM CMS-2567 (02/99) Previous Versions Obsolete Event ID: Facility ID: 675447 If continuation sheet Page 20 of 20