INITIAL COMMENTS
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This report is a result of an on-site licensure renewal inspection and methadone and buprenorphine monitoring inspection conducted on November 16 & 17, 2023 by staff from the Department of Drug and Alcohol Programs, Bureau of Program Licensure. Based on the findings of the on-site inspection, Tadiso, Inc. was found not to be in compliance with the applicable chapters of 28 PA Code which pertain to the facility. The following deficiencies were identified during this inspection:
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Plan of Correction
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704.9(c) LICENSURE Supervised Period
704.9. Supervision of counselor assistant.
(c) Supervised period.
(1) A counselor assistant with a Master's Degree as set forth in 704.8 (a)(1) (relating to qualifications for the position of counselor assistant) may counsel clients only under the close supervision of a trained counselor or clinical supervisor for at least the first 3 months of employment.
(2) A counselor assistant with a Bachelor's Degree as set forth in 704.8 (a)(2) may counsel clients only under the close supervision of a trained counselor or clinical supervisor for at least the first 6 months of employment.
(3) A registered nurse as set forth in 704.8 (a)(3) may counsel clients only under the close supervision of a trained counselor or clinical supervisor for at least the first 6 months of employment.
(4) A counselor assistant with an Associate Degree as set forth in 704.8 (a)(4) may counsel clients only under the close supervision of a trained counselor or clinical supervisor for at least the first 9 months of employment.
(5) A counselor assistant with a high school diploma or GED equivalent as set forth in 704.8 (a)(5) may counsel clients only under the direct observation of a trained counselor or clinical supervisor for the first 3 months of employment. For the next 9 months, the counselor assistant may counsel clients only under the close supervision of a lead counselor or a clinical supervisor.
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Observations
Based on a review of fourteen personnel records, the facility failed to ensure that two counselor assistants were counseling clients under the supervision of a trained counselor or clinical supervisor based on their education.
Employee #13 was hired on April 10, 2023 as a counselor assistant. Employee # 13 has a bachelor ' s degree with no experience and may counsel clients only under close supervision of a trained counselor or clinical supervisor for the first 6 months of employment. Employee #13 did not receive formal case review during supervisions occurring on May 3, 12, 17, June 7, 13, 26, July 21, 28, August 4, 18, September 8, 15, 29 October 6, 27 and November 3, 2023. Employee #13 did not have documented one hour a week of direct observation from May 1, 2023 through November 3, 2023. Close supervision is defined by regulation as follows: " Formal documented case review and an additional hour of direct observation by a supervising counselor or a clinical supervisor once a week " . Based on a review of the supervision notes there is no documented formal case review or direct observation for the first six months of employment.
Employee #14 was hired on March 30, 2023 as a counselor assistant. Employee # 14 has a bachelor ' s degree with no experience and may counsel clients only under close supervision of a trained counselor or clinical supervisor for the first 6 months of employment. Employee #14 did not receive formal case review during supervisions occurring on May 1, 8, 18, 23, 30, June 7, 13, 22, 27, July 11, August 2, 8, 15, 23, September 21, and October 4, 2023. Employee #14 did not have documented one hour a week of direct observation from May 1, 2023 through November 1, 2023. Close supervision is defined by regulation as follows: " Formal documented case review and an additional hour of direct observation by a supervising counselor or a clinical supervisor once a week " . Based on a review of the supervision notes there is no documented formal case review or direct observation for the first six months of employment.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
Employee Thirteen will receive 6 months of close supervision by a clinical supervisor or trained counselor beginning 12/18/2023 which will include one hour of clinical supervision with formal case review and one hour of direct observation by either the clinical supervisor or a trained counselor each week for the 6-month period. This will be documented in the employee's weekly clinical supervision notes and will be completed by their assigned clinical supervisor.
Employee Fourteen will receive 6 months of close supervision by a clinical supervisor or trained counselor beginning 12/18/2023 which will include one hour of clinical supervision with formal case review and one hour of direct observation by either the clinical supervisor or a trained counselor each week for the 6-month period. This will be documented in the employee's weekly clinical supervision notes and will be completed by their assigned clinical supervisor.
Clinical supervisors will receive training by the Director of Social Services on the requirements and expectations of counselor assistant supervision at the supervisor meeting to be held on 12/19/2023 and this policy will be implemented from the date of hire with future counselor assistant staff members. The Clinical supervisors will be responsible for ensuring the corrective action plan is implemented and the Director of Social Service will be responsible for ensuring that the corrective action plan is followed.
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705.24 (3) LICENSURE Bathrooms.
705.24. Bathrooms.
The nonresidential facility shall:
(3) Have hot and cold water under pressure. Hot water temperature may not exceed 120F.
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Observations
Based on a physical plant inspection on November 16, 2023, it was observed that the facility failed to maintain hot water to not exceed 120 degrees. The water temperature in the second-floor staff bathroom was 164 degrees.
This finding was reviewed with facility staff during the licensing process.
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Plan of Correction
On November 16, 2023, an exception to this request was sent to RA-licensure stating our reason for the request. The exception is still being processed as of November 27, 2023.
In 2019 our water supply was evaluated positive for Legionella, after discovering two of our employees had become ill from the water supply.
Tadiso contracted with Special Pathogens Laboratories and developed a water management plan and quarterly testing to mitigate problems as they arise. All staff have been educated on the Water Management plan and the need for elevated water temperatures. Patient bathrooms have valve mixers to regulate the temperature of the water supply, and the drop in child services has only a cold-water supply. All bathrooms with increased temperature have signs posted advising of the increased water temperature.
Water filling stations are found throughout the building. To effectively kill the bacteria after a positive result, we were recommended to scald the lines, the water temperature must be set to at least 145 degrees Fahrenheit.
On 12/21/2023 an inquiry to our exception was sent to RA-licensure but have not received a response or decision in return. |
715.13(b) LICENSURE Patient identification
(b) A narcotic treatment program shall maintain onsite a photograph of each patient which includes the patient 's name and birth date. The narcotic treatment program shall update the photograph every 3 years.
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Observations
Based on a review of patient records, the facility failed to maintain onsite a photograph of each patient which includes the patient 's name and birth date and update the photograph every 3 years in seven out of eighteen applicable records reviewed.
Patient #1 was admitted on January 21, 2014 and was discharged on May 22, 2023. The photograph located in the patient record was over three years old. Facility staff confirmed there was no updated photograph.
Patient #2 was admitted on February 13, 2017 and was discharged on September 21, 2023. The photograph located in the patient record was over three years old. Facility staff confirmed there was no updated photograph.
Patient #4 was admitted on May 8, 2020 and still active at the time of the inspection. The photograph located in the patient record was over three years old. Facility staff confirmed there was no updated photograph.
Patient #7 was admitted on September 24, 2013 and was still active at the time of the inspection. The photograph located in the patient record was over three years old. Facility staff confirmed there was no updated photograph.
Patient #10 was admitted on July 9, 2010 and was discharged on June 22, 2023. The photograph located in the patient record was over three years old. Facility staff confirmed there was no updated photograph.
Patient #14 was admitted on January 29, 2015 and was discharged on November 16, 2023. The photograph located in the patient record was over three years old. Facility staff confirmed there was no updated photograph.
Patient #19 was admitted on May 31, 2022 and discharged on April 25, 2023. The photograph located in the patient record was over three years old. Facility staff confirmed there was no updated photograph.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
Effective December 1, 2023
At the end of every month a form called the blank liability will be completed by fiscal personnel noting the patients that have yearly paperwork due as per Tadiso procedures. The Chief Financial Officer will review the form with the fiscal personnel noting that these patients are due for yearly paperwork and sign off on the document noting that the yearly paperwork was completed and that it included the patients' photograph being updated with patient's name and birthdate. The hardcopy of the liability form will be kept on file by fiscal personnel if it would need reviewed for auditing purposes. The Chief Financial Officer will be responsible for ensuring the plan of correction is followed. |
715.19(1) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(1) A narcotic treatment program shall provide each patient an average of 2.5 hours of psychotherapy per month during the patient 's first 2 years, 1 hour of which shall be individual psychotherapy. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
Based on a review of patient records, the facility failed to provide patients with 2.5 hours of psychotherapy per month during the patient's first two years of treatment, one hour of which shall be individual psychotherapy, in five out of nine applicable records reviewed.
Patient #6 was admitted on January 27, 2021 and was still active at the time of the inspection. The patient record only had 2 hours of psychotherapy documented for the months of August and October of 2023.
Patient #12 was admitted on March 20, 2023 and was still active at the time of the inspection. The patient record documented no psychotherapy hours in the month of September 2023.
Patient #15 was admitted on February 23, 2023 and was still active at time of the inspection. The patient record only had half an hour of psychotherapy documented for the months of June and August 2023.
Patient #16 was admitted on May 17, 2021 and discharged on April 21, 2023. The patient record only had one hour of psychotherapy documented for November and December 2022.
Patient #19 was admitted on May 31, 2022 and discharged on April 25, 2023. The patient record only had one and half hours documented for December 2022 and January 2023, forty-five minutes documented for February 2023 and one and a half hours documented for March 2023.
This is a repeat citation from the November 30, 2022 licensing inspection.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
Patients who are in their first 2 years of treatment will be scheduled for the 2.5 hours of required psychotherapy per month by their assigned counselor.
The counselor will clearly document the date and length of the scheduled counseling session in their progress notes.
If a patient does not attend their scheduled counseling session the primary counselor will document that the patient did not show or had been rescheduled for another session.
Clinical supervisors will review and document the counselor's monthly action plan that outlines why each patient did not receive their required counseling hours with the primary counselor in clinical supervision beginning January 4th, 2024.
This process will be reviewed with the counseling staff at the social service department meeting on January 4th, 2024, by the Director of Social Services.
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715.19(2) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(2) A narcotic treatment program shall provide each patient at least 1 hour per month of group or individual psychotherapy during the third and fourth year of treatment. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
Based on a review of the patient records, the facility failed to provide each patient at least 1 hour per month of group or individual psychotherapy during the third and fourth year of treatment in one out of four applicable records reviewed.
Patient #17 was admitted on June 15, 2021 and was current at the time of the inspection. The patient record did not have psychotherapy documented for the months of April and October 2023.
This finding was reviewed with the facility staff during the licensing process.
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Plan of Correction
Patients who are between their 3rd and 4th year of treatment will be scheduled for the required 1 hour of individual counseling per month by their primary counselor.
The counselor will clearly document the date and length of the scheduled counseling session in their progress notes.
If a patient does not attend their scheduled counseling the primary counselor will document that the patient did not show or had been rescheduled.
Clinical supervisors will review and document the counselor's monthly action plan that outlines why each patient did not receive their required counseling hours with the primary counselor in clinical supervision beginning January 4, 2024.
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715.19(3) LICENSURE Psychotherapy services
A narcotic treatment program shall provide individualized psychotherapy services and shall meet the following requirements:
(3) After 4 years of treatment, a narcotic treatment program shall provide each patient with at least 1 hour of group or individual psychotherapy every 2 months. Additional psychotherapy shall be provided as dictated by ongoing assessment of the patient.
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Observations
Based on a review of patient records, the facility failed to provide patients with one hour of psychotherapy every other month after four years in treatment in one out of five applicable records reviewed.
Patient # 14 was admitted on January 29, 2015 and was discharged on November 16, 2023. Patient #14 only had half an hour of psychotherapy documented for January/February 2023 and July/August 2023 were missing documentation of any individual or group psychotherapy hours.
This finding was reviewed with facility staff during the licensing process.
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Plan of Correction
Patients who have been in treatment for 4 years will be scheduled for the required 1 hour of group or individual psychotherapy every 2 months by their assigned counselor.
The counselor will clearly document the date and length of the scheduled counseling session in their progress notes.
If a patient does not attend their scheduled counseling session the primary counselor will document that the patient did not show or had been rescheduled for another session.
Clinical supervisors will review and document the counselor's monthly action plan that outlines why each patient did not receive their required counseling hours with the primary counselor in clinical supervision beginning January 4, 2024.
This process will be reviewed with the counseling staff at the social service department meeting on January 4th, 2024, by the Director of Social Services.
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715.20(1) LICENSURE Patient transfers
A narcotic treatment program shall develop written transfer policies and procedures which shall require that the narcotic treatment program transfer a patient to another narcotic treatment program for continued maintenance, detoxification or another treatment activity within 7 days of the request of the patient.
(1) The transferring narcotic treatment program shall transfer patient files which include admission date, medical and psychosocial summaries, dosage level, urinalysis reports or summary, exception requests, and current status of the patient, and shall contain the written consent of the patient.
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Observations
Based on a review of patient records, the facility failed to transfer patient files which included admission date, medical and psychosocial summaries, dosage level, urinalysis reports or summary, exception requests, and current status of the patient, and shall contain the written consent of the patient in one of two applicable records reviewed.
Patient #19 was admitted on May 31, 2022 and discharged on April 25, 2023. There was no documentation in the record that the patient ' s file including admission date, medical and psychosocial summaries, dosage level, urinalysis reports or summary, exception requests, and current status of the patient was transferred to the receiving facility.
This finding was reviewed with facility staff during the licensing process.
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Plan of Correction
Upon receipt of a notification of transfer from another providing facility, a clinical supervisor will transfer patient files including admission date, medical and psychosocial summaries, dosage level, urinalysis reports or summary, exception requests, and current status of the patient, and shall contain the written consent of the patient.
The documents will be scanned into the patient file by the administrative assistant after successful transmission from the transferring/receiving facility of all required documents for electronic health record.
The Director of Social services will review this process with all clinical supervisors at the supervisor meeting held on December 19, 2023. The Director of Social Service will be responsible for ensuring the plan of correction is implemented and followed.
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715.20(4) LICENSURE Patient transfers
A narcotic treatment program shall develop written transfer policies and procedures which shall require that the narcotic treatment program transfer a patient to another narcotic treatment program for continued maintenance, detoxification or another treatment activity within 7 days of the request of the patient.
(4) The receiving narcotic treatment program shall document in writing that it notified the transferring narcotic treatment program of the admission of the patient and the date of the initial dose given to the patient by the receiving narcotic treatment program.
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Observations
Based on a review of patient records, the facility failed to document the notification of the previous narcotic treatment program of the admission and initial dose of the patient in one out of one applicable record.
Patient #8 was admitted on August 18, 2023 and was still active at the time of the inspection.
This is a repeat citation from the November 30, 2022 licensing inspection.
This finding was reviewed with facility staff during the licensing process.
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Plan of Correction
Intake coordinators will send a notification of transfer to any incoming transfer patient's prior clinic on the date the patient completes the intake process and is dosed.
A copy of the notification of transfer will be scanned into the patient's electronic health record and documented in the patient's case history by the intake coordinator. All paper copies of the notification of transfer will be kept in the intake office area in a designated binder.
The Director of Social Services will review this process with all intake coordinators at the scheduled intake meeting on December 18th, 2023. The Director of Social Service will be responsible to ensure the plan of correction is being implemented and followed.
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715.23(b)(5) LICENSURE Patient records
(b) Each patient file shall include the following information:
(5) The results of all annual physical examinations given by the narcotic treatment program which includes an annual reevaluation by the narcotic treatment physician.
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Observations
Based on the review of patient records, the facility failed to document an annual physical examination by the narcotic treatment physician within the regulatory timeframe in one out of eleven applicable records reviewed.
Patient #7 was admitted on September 24, 2023 and was still active at the time of the inspection. An annual physical was completed on September 14, 2022. The next annual physical was due no later than September 14, 2023; however, it was not completed until September 27, 2023.
This finding was reviewed with facility staff during the licensing process.
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Plan of Correction
Patient #7 had a doctor hold placed on September 14, 2023, for their Annual Physical. The patient dosed on September 13, 2023, and received take home bottles and was not to be present back in the building for dosing until September 27, 2023. This is the reason the annual physical was completed late.
The Medical Department will pull a report the last week of the month and place a doctor hold in the patient's electronic health record for the upcoming month for all annual physicals. This will alleviate the hold being placed after the fact for patients that receive take home bottles.
Assistant Director of Medical will be responsible for ensuring the corrective action plan is implemented and followed.
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715.23(c)(1-7) LICENSURE Patient records
(c) An annual evaluation of each patient 's status shall be completed by the patient 's counselor and shall be reviewed, dated and signed by the medical director. The annual evaluation period shall start on the date of the patient 's admission to a narcotic treatment program and shall address the following areas:
(1) Employment, education and training.
(2) Legal standing.
(3) Substance abuse.
(4) Financial management abilities.
(5) Physical and emotional health.
(6) Fulfillment of treatment objectives.
(7) Family and community supports.
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Observations
Based on the review of patient records, the facility failed to document an annual evaluation of each patient 's status completed by the patient 's counselor and reviewed, dated and signed by the medical director. with all areas of regulation addressed within the regulatory timeframe in eight out of ten applicable records reviewed.
Patient #1 was admitted on January 21, 2014 and was discharged on May 22, 2023. An annual evaluation was completed on January 4, 2023; however, there was no documentation that it was reviewed, dated and signed by the medical director.
Patient #2 was admitted on February 13, 2017 and was discharged on September 21, 2023. An annual evaluation was due no later than February 13, 2023; however, there was no documentation that one was completed.
Patient #4 was admitted on May 8, 2020 and was still active at the time of the inspection. An annual evaluation was due no later than May 8, 2023; however, there was no documentation that one was completed.
Patient #6 was admitted on January 27, 2021and was still active at the time of the inspection. An annual evaluation was due no later than January 27, 2023; however, there was no documentation that one was completed.
Patient #7 was admitted on September 24, 2013 and was still active at the time of the inspection. An annual evaluation was completed on October 4, 2023; however, there was no documentation that it was reviewed, dated and signed by the medical director.
Patient #9 was admitted on March 21, 2022 and discharged on April 13, 2023. An annual evaluation was due no later than March 21, 2023; however, there is no documentation that one was completed.
Patient # 14 was admitted on January 29, 2015 and was discharged on November 16, 2023. An annual evaluation was due to be completed January 29, 2023; however, it was not completed until March 30, 2023, and there was no documentation that it was reviewed, dated and signed by the medical director.
Patient #17 was admitted on June 15, 2021 and was current at the time of the inspection. An annual evaluation was due to be completed June 15, 2023; however, there was no documentation that one was completed.
This is a repeat citation from the November 30, 2022 licensing inspection.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
Annual Clinical Evaluations will be completed by the primary counselor annually based on their intake date. The annual clinical evaluation will address employment, education, training, legal standing, substance use, financial management, physical and emotional health, fulfillment of treatment objectives and family and community involvement.
Counselors will pull services due weekly to identify patients that will need an annual clinical evaluation completed. Clinical supervisors will review the counselor's services due monthly in clinical supervision to ensure that annual clinical evaluations are being completed by the due date.
This process will be reviewed by the Director of Social Services with counseling staff at the department meeting held on January 4th, 2024.
Medical Director or CRNP designee will sign annual clinical evaluation. IT will add signature box for medical director or designee on the annual clinical evaluation on January 2, 2024.
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709.92(b) LICENSURE Treatment and rehabilitation services
709.92. Treatment and rehabilitation services.
(b) Treatment and rehabilitation plans shall be reviewed and updated at least every 60 days.
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Observations
Based on a review of client records, the facility failed to document treatment plan updates within the regulatory timeframe in eleven out of nineteen records reviewed.
Client #2 was admitted on February 12, 2017 and discharged on September 21, 2023. A treatment plan update was completed on January 24, 2023, and the next update was due no later than March 24, 2023; however, it was not completed until April 5, 2023. A treatment plan update was completed on May 16, 2023. The next update was due no later than July 16, 2023; however, it was not completed until on August 8, 2023.
Client #4 was admitted on May 8, 2020 and was still active at the time of the inspection. A treatment plan update was completed on August 15, 2023, and the next update was due no later than October 15, 2023; however, it was not completed until October 19, 2023.
Client #5 was admitted on December 23, 2021 and was still active at the time of the inspection. A treatment plan update was completed on February 12, 2023, and the next update was due no later than April 12, 2023; however, it was not completed until April 19, 2023. The next treatment plan update was due no later than June 19, 2023; however, it was not completed until June 20, 2023. A treatment plan update was completed on August 14, 2023. The next treatment plan update was due no later than October 14, 2023; however, it was not completed until October 19, 2023.
Client #6 was admitted on January 27, 2021 and was still active at the time of the inspection. A treatment plan update was completed on May 17, 2023, and the next update was due no later than July 17, 2023; however, it was not completed until July 27, 2023.
Client #9 was admitted on March 21, 2022 and was discharged on April 13, 2023. A treatment plan update was completed on January 30, 2023, and the next update was due no later than March 30, 2023; however, there is no documentation that one was completed.
Client #10 was admitted on July 9, 2010 and was still active at the time of the inspection. A treatment plan update was completed on January 5, 2023, and the next update was due no later than March 5, 2023; however, it was not completed until March 9, 2023.
Client #11 was admitted on February 8, 2023 and was still active at the time of the inspection. A treatment plan update was completed on June 13, 2023, and the next update was due no later than August 13, 2023; however, it was not completed until August 15, 2023. The next treatment plan update was due no later than October 15, 2023; however, it was not completed until November 2, 2023.
Patient # 14 was admitted on January 29, 2015 and was discharged on November 16, 2023. A treatment plan update was completed on May 17, 2023, and the next was due no later than July 17, 2023; however it was not completed until August 11, 2023.
Patient #15 was admitted on February 23, 2023 and was still active at the time of the inspection. A treatment plan update was completed on March 24, 2023, and the next was due no later than May 24, 2023; however it was not completed until September 27, 2023.
Patient #17 was admitted on June 15, 2021 and was still active at the time of the inspection. A treatment plan update was completed on December 30, 2022, and the next was due no later than March 2, 2023; however, it was not completed until March 7, 2023. A treatment plan update was completed August 14, 2023, and the next update was due no later than October 14, 2023; however, it was not completed October 17, 2023.
Patient #19 was admitted on May 31, 2022 and discharged on April 25, 2023. A treatment plan update was completed on January 12, 2023, and the next was due no later than March 12, 2023; however it was not completed until March 30, 2023.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The patient's primary counselor will review and update the patient's treatment plan at least every 60 days.
If the patient does not attend scheduled counseling session to update the treatment plan and treatment plan is due, the primary counselor will complete a treatment plan update in the patients EHR that will indicate the patient's progress towards treatment goals and identifies the required amount of psychotherapy for that individual patient. The treatment plan will be updated at the next psychotherapy session.
Clinical supervisors will review counselor's services due monthly in clinical supervision to ensure that treatment plans are being updated within the required time.
This process will be reviewed with all counseling staff by the Director of Social Services at the Department meeting to be held on January 4th, 2024.
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709.93(a)(10) LICENSURE Client records
709.93. Client records.
(a) There shall be a complete client record on an individual which includes information relative to the client's involvement with the project. This shall include, but not be limited to, the following:
(10) Discharge summary.
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Observations
Based on a review of client records, the facility failed to ensure a complete client record on an individual which includes information relative to the client ' s involvement with the project including a discharge summary per the facility ' s policy and procedures manual within 30 days of discharge in five out of nine applicable records.
Client #3 was admitted on September 21, 2020 and was discharged on January 27, 2023. There was no documentation that a discharge summary was completed.
Client #9 was admitted on March 21, 2022 and was discharged on April 13, 2023. The discharge summary was due no later than May 13, 2023; however, was not completed until July 13, 2023.
Client #10 was admitted on July 9, 2010 and was discharged on June 22, 2023. There was no documentation that a discharge summary was completed.
Client #18 was admitted on August 7, 2023 and discharged on September 27, 2023. The discharge summary was due no later than October 27, 2023; however, it was not completed until November 2, 2023.
Client #19 was admitted on May 31, 2022 and discharged on April 25, 2023. The discharge summary was due no later than May 25, 2023; however, it was not completed until June 5, 2023.
These findings were reviewed with facility staff during the licensing process.
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Plan of Correction
The primary counselor will complete the patient's discharge summary which will include information relative to the patient's involvement in the project within 30 days of discharge. Counselors should check services due weekly to ensure discharge summaries are completed in the electronic health record within the required time.
Clinical Supervisors will review counselor's services due monthly in clinical supervision to ensure that discharge summaries are being completed within the required time.
This process will be reviewed with all counseling staff by the Director of Social Services at the Department Meeting to be held on January 4th, 2024.
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