Inspection IDReason for InspectionInspection DateInspection Status 
SIN-00198456 Renewal 01/03/2022 Non Compliant - Finalized
RegulationLIS Non-Compliance AreaCorrection RequiredPlans of CorrectionCorrection DatePOC Status
6400.15(a)(Repeat from inspection dated 1/11/21) No Self-Assessment was completed for this home.The agency shall complete a self-assessment of each home the agency operates serving eight or fewer individuals, within 3 to 6 months prior to the expiration date of the agency¿s certificate of compliance, to measure and record compliance with this chapter. This occurred due to Self-Assessments not being collected and reviewed for completion. Staff will be trained on how to complete the Self-Assessment form thoroughly. Quality department will monitor for completion.Staff will be trained on how to complete the Self-Assessment form thoroughly on 2/22/22. 02/22/2022 Implemented
6400.22(d)(1)The Snap Benefit log that staff documents for Individual #1 was missing the following transactions: 8/1/21-$95.45 and 9/14/21-$92.01.The home shall keep an up-to-date financial and property record for each individual that includes the following: Personal possessions and funds received by or deposited with the home. This occurred due to the staff not turning in necessary receipts, potentially due to lack of training or knowledge. TLC has designated the Assistant Program Managers to complete the money book and the Program Managers to review before submitting to fiscal as opposed to having DSPs submitting them. TLC will retrain all staff on 6400.22 requirements including Money Books and requirements for receipt keeping by 2/22/22. 02/22/2022 Not Implemented
6400.22(e)(3)Individual #1's Snap Benefit log was missing the following receipts: 8/1/21-$95.45 and 9/14/21-92.01. If the home assumes the responsibility of maintaining an individual's financial resources, the following shall be maintained for each individual: Documentation, by actual receipt or expense record, of each single purchase exceeding $15 made on behalf of the individual carried out by or in conjunction with a staff person. This occurred due to the staff not turning in necessary receipts, potentially due to lack of training or knowledge. TLC has designated the Assistant Program Managers to complete the money book and the Program Managers to review before submitting to fiscal as opposed to having DSPs submitting them. TLC will retrain all staff on 6400.22 requirements including Money Books and requirements for receipt keeping. 02/22/2022 Implemented
6400.67(b)There was a golf-ball sized amount of lint in the dryer. Floors, walls, ceilings and other surfaces shall be free of hazards.The lint was immediately removed. This occurred due to TLC currently having a form on SharePoint that staff complete following a physical site check. Quality department will utilize the physical site check list form which was updated on 1/20/2022 to determine which homes have not completed the physical site check list. The quality department will send an email to Program Manager, and DORS to inform them of which homes need to be completed. Staff will be retrained Program Specialists will be trained on Physical Site Requirements beginning on 02/16/2022, all other staff will be trained during the staff meeting on 02/22/2022. 02/22/2022 Implemented
6400.103(Repeat from Inspection dated 1/11/21)-There was no written emergency evacuation plan for Individual #1. The written evacuation plan was a medical emergency plan.There shall be written emergency evacuation procedures that include individual and staff responsibilities, means of transportation and an emergency shelter location. This occurred due to there being a standard form in AWARDS for staff to complete that did not meet regulations. Residential staff will be rewriting all emergency medical plans after creating a new template which will be based off the 6400 regulations. 02/28/2022 Implemented
6400.112(e)(Repeat from Inspection dated 1/11/21)-A sleep drill was held on 1/8/21 and not again until 10/10/21; outside of the bi-annual time frame.A fire drill shall be held during sleeping hours at least every 6 months. This occurred due to TLC currently has a form on SharePoint that staff complete following a fire drill. Quality department will utilize the Fire Drill Log form which was updated on 1/20/2022 to determine which homes have not completed fire drills. Quality department will send email to Program Manager, and DORS to inform them of which homes need to be completed. Staff will be retrained no later then 2/22/22. 03/01/2022 Not Implemented
6400.141(b)(Repeat Violation from 1/11/21, 5/10/21, and 10/12/21) The physical completed 7/23/21 is not signed or dated by the PCP.The physical examination shall be completed, signed and dated by a licensed physician, certified nurse practitioner or licensed physician's assistant. This occurred due to staff not being trained on medical appointments, required documentation, retraining/ educating individuals when refusing and documenting, nor were medical appointments, forms or orders being monitored following appointments. Staff will be retrained on medical appointments and requirements including printing medical appointment form prior to appointment, taking the form along, ensuring the form is completed and signed my licensed medical professional (not CRNP or nurse). This will be completed by 2/16/22. QD is currently going through records to determine dates of all individual's annual physicals and will contact appropriate management to schedule the appointment (PS, PM). This will be completed by 2/16/22. Physicals will be scheduled in advance to ensure completion. 02/28/2022 Implemented
6400.143(a)(Repeat from 1/11/21 and 10/12/21) Individual #1 is to exercise 30 minutes a day. From 10/7/21 to the present the individual refused to participate 64 times. The refusals are documented. There is no documentation that the Individual was trained on the importance of following doctor's recommendations. From January 2021 to 10/7/21, this was not tracked. From 10/7/21 to the present, there were 9 times the physical activity was not logged.If an individual refuses routine medical or dental examination or treatment, the refusal and continued attempts to train the individual about the need for health care shall be documented in the individual's record. All direct care staff will be retrained on regulation 6400.143(a) which states, "If an individual refuses routine medical or dental examination or treatment, the refusal and continued attempts to train the individual about the need for health care shall be documented in the individual's record." Training record will be signed by all direct care workers by 2/22/22. 02/28/2022 Not Implemented
6400.144Individual #1 has a BM protocol that the individual is to receive Miralax if the individual has no BM for three days. The individual did not have a BM from 9/27/21 to 9/29/21, from 11/3/21 to 11/5/21, from 11/20/21 to 11/22/21, and from 12/17/21 to 12/19/21. No Miralax was administered.Health services, such as medical, nursing, pharmaceutical, dental, dietary and psychological services that are planned or prescribed for the individual shall be arranged for or provided. Staff will be trained on the importance of documenting and tracking bowel movements whether seen, unseen or reported by individual by 2/22/22. 02/28/2022 Not Implemented
6400.145(3)(Repeat from inspection dated 1/11/21) The emergency medical plan developed for Individual #1 does not address emergency staffing.The home shall have a written emergency medical plan listing the following: An emergency staffing plan.This occurred due to there being a standard form in AWARDS for staff to complete that did not meet regulations. Residential staff will be rewriting all emergency medical plans after creating a new template which will be based off the 6400 regulations. 02/28/2022 Implemented
6400.181(a)(Repeat from 1/11/21, 5/10/21, and 10/12/21)-Individual #1 had an annual assessment completed on 9/16/20 and not again since; outside of the annual time frame. Each individual shall have an initial assessment within 1 year prior to or 60 calendar days after admission to the residential home and an updated assessment annually thereafter. The initial assessment must include an assessment of adaptive behavior and level of skills completed within 6 months prior to admission to the residential home. This occurred because there has been a significant turnaround in Program Specialists as well as a lack of training/ supervision and monitoring. Program Specialists will be retrained on annual assessment requirements per the 6400 regulations including the requirements for which documents need to be uploaded to Individual's File Cabinet along with the ISP (including the attendance record, and if individual was unable to attend, a substantiation). Intermittently, quality department contacted the Program Specialist of each individual who needs an updated assessment as well as the Director of Residential Services and provided due date of required assessments to be completed by 02/28/2022. 02/28/2022 Not Implemented
6400.211(b)(3)Individual #1's record does not indicate who to contact for medical consent.Emergency information for each individual shall include the following: The name, address and telephone number of the person able to give consent for emergency medical treatment, if applicable. Program Specialists will update the current face sheet with necessary information immediately. 02/28/2022 Implemented
6400.18(c)Individual #1 had medication errors on the following dates: 6/17/21, 7/21/21, 8/6/21, 10/2/21, and 10/22/21. Family was not notified of any of the medication errors.The individual and persons designated by the individual shall be notified within 24 hours of discovery of an incident relating to the individual.This has occurred due to the lack of understanding of the medication error regulation. TLC has updated the AWARDS incident form immediately (01/04/2022) to eliminate the drop-down option, "Per regulations family notification is not made for medication errors." It has been added in the incident management training that family notification must occur for medication errors. We developed a schedule for staff meetings that will be held monthly beginning on February 22, 2022, as well as Program Specialist Trainings that will be held weekly beginning February 16, 2022. The purpose of the Staff Meetings are to communicate important changes to all staff, develop consistency, and train all staff on regulations, practices, and guidelines. All staff will be retrained on Fire Safety, Rights of the Individual, Individual Funds and Property and Medication Error Reporting during the meeting. The purpose of the Program Specialist Trainings is to ensure that all Program Specialists are aware of, following, and in compliance with the regulations. During the first Program Specialist training, job responsibilities, medication administration & errors, physical site checklists/ home monitoring schedules, medical appointments, assessments, fire safety, individual rights, releases of information, and individual records will be addressed. Moving forward, Program Specialist training will focus on things that the Quality Department identifies as areas of concern (QD will be utilizing the Home Monitoring Tool, Physical Site Checklist and Fire Monitoring Tool to determine where the areas of need are). 02/22/2022 Not Implemented
6400.165(c)(Repeat from 1/11/21, 4/26/21, 5/10/21, and 10/12/21) Individual #1 is to receive Divalproex 500 mg twice a day, at 8am and 8pm. On 3/16/21, Individual #1 received two doses of Divalproex 500mg at 8pm.A prescription medication shall be administered as prescribed.This occurred due to a lack of training and monitoring regarding documentation. TLC has recognized the need for continued training and has added the nurses to complete quality monitors for medication and medication management. TLC has now hired a full-time LPN, RN and an additional Training Specialist. The nurses will be reviewing physician orders and updating CARASOLVA/ AWARDS as necessary to ensure that all medications are updated, correct, and all components are completed. The new Training Specialist will focus on the Med Training and Med Observations and complete retraining as necessary as well as updated the AWARDS forms to ensure that all medication errors are addressed appropriately. Staff will be retrained to on proper documentation, medication management, the 5 rights of medication, quarterly medication reviews, discontinuation and disposal. Education regarding the medication error and reporting will occur during the ALL Staff Meeting on February 22, 2022. Training specialist will begin February 28th. 02/28/2022 Not Implemented
6400.165(g)(Repeat from 1/11/21 and 5/10/21) Individual #1 had a Psychiatric Medication Review completed on 1/25/21, 6/28/21, and 12/6/21. Med Reviews were not completed quarterly as regulations require.If a medication is prescribed to treat symptoms of a psychiatric illness, there shall be a review by a licensed physician at least every 3 months that includes to document the reason for prescribing the medication, the need to continue the medication and the necessary dosage.Program Specialists will be retrained on quarterly medication reviews and the requirements by 2/16/22. 02/28/2022 Implemented
6400.166(b)(Repeat from 6/30/21 and 10/12/21) Individual #1 received Sodium Chloride at 4pm on 11/11/21. It was not logged immediately. It was logged the following evening.The information in subsection (a)(12) and (13) shall be recorded in the medication record at the time the medication is administered.This occurred due to a lack of training and monitoring regarding documentation. TLC has recognized the need for continued training and has added the nurses to complete quality monitors for medication and medication management. TLC has now hired a full-time LPN, RN and an additional Training Specialist. The nurses will be reviewing physician orders and updating CARASOLVA/ AWARDS as necessary to ensure that all medications are updated, correct, and all components are completed. The new Training Specialist will focus on the Med Training and Med Observations and complete retraining as necessary as well as updated the AWARDS forms to ensure that all medication errors are addressed appropriately. Staff will be retrained to on proper documentation, medication management, the 5 rights of medication, quarterly medication reviews, discontinuation and disposal. Education regarding the medication error and reporting will occur during the ALL Staff Meeting on February 22, 2022. Training specialist will begin February 28th. 02/28/2022 Implemented
6400.167(c)(Repeat from inspection dated 10/12/21) Individual #1 is to receive Divalproex 500 mg twice a day, at 8am and 8pm. On 3/16/21, Individual #1 received two doses of Divalproex 500mg at 8pm. This medication error was not reported in EIM.A medication error shall be reported as an incident as specified in § 6400.18(b) (relating to incident report and investigation).This occurred due to a lack of training and monitoring regarding documentation. TLC has recognized the need for continued training and has added the nurses to complete quality monitors for medication and medication management. TLC has now hired a full-time LPN, RN and an additional Training Specialist. The nurses will be reviewing physician orders and updating CARASOLVA/ AWARDS as necessary to ensure that all medications are updated, correct, and all components are completed. The new Training Specialist will focus on the Med Training and Med Observations and complete retraining as necessary as well as updated the AWARDS forms to ensure that all medication errors are addressed appropriately. Staff will be retrained to on proper documentation, medication management, the 5 rights of medication, quarterly medication reviews, discontinuation and disposal. Education regarding the medication error and reporting will occur during the ALL Staff Meeting on February 22, 2022. Training specialist will begin February 28th. 02/28/2022 Not Implemented
6400.181(f)(Repeat from 1/11/21, 5/10/21, and 10/12/21)-Individual #1 had an annual assessment completed on 9/16/20 and not again since; outside of the annual time frame.The program specialist shall provide the assessment to the individual plan team members at least 30 calendar days prior to an individual plan meeting.This occurred because there has been a significant turnaround in Program Specialists as well as a lack of training/ supervision and monitoring. Program Specialists will be retrained on annual assessment requirements per the 6400 regulations including the requirements for which documents need to be uploaded to Individual's File Cabinet along with the ISP (including the attendance record, and if individual was unable to attend, a substantiation). Intermittently, quality department contacted the Program Specialist of each individual who needs an updated assessment as well as the Director of Residential Services and provided due date of required assessments to be completed by 02/28/2022. 02/28/2022 Implemented
SIN-00181480 Renewal 01/11/2021 Non Compliant - Finalized
RegulationLIS Non-Compliance AreaCorrection RequiredPlans of CorrectionCorrection DatePOC Status
6400.15(a)REPEAT VIOLATION FROM 12/10/19: The self-assessment for this home is undated, so it is unclear when it was completed.The agency shall complete a self-assessment of each home the agency operates serving eight or fewer individuals, within 3 to 6 months prior to the expiration date of the agency¿s certificate of compliance, to measure and record compliance with this chapter. A self-assessment is necessary to understand any deficiencies within a residence, be able to correct them in a timely manner, identify safety hazards for the supported people and provide guidance to the staff in areas necessary for regulatory compliance. Violations occurred because the self assessments were not completed nor submitted within the allowed 3-6 month window before license expiration A lack of complete understanding by new staff, including ADOS, Directors and Quality about when the 3-6 month window opens and closes for submittal of the document Within the months of February and March each ADOS, Directors of Residential Services, Quality Staff, including the Director of Compliance, the Quality Coordinator and Quality Assistant will receive trainiing in the completion of the self assessments. In addition, the Program Managers will participate in the trainings. A training log of participants will be kept and maintained by the Quality Department. 1. TLC commits to one timely self assessment in each calendar year. The self assessment will be done in May beginning in 2021 and will continue in 2022 and each succeeding year 2. The May self assessment will be submitted for each location in accordance with the regulation. 3. The Quality Department, specifically the Quality Assistant will maintain a paper copy as well as a folder in Sharepoint where each assessment will be electronically filed in a folder titled Self Assessments-Residential. 4. Each Service Area's ADOS staff will review within 4 weeks with the Director of Compliance, Quality Coordinator, Quality Assistant and appropriate Director of Services. 5. The assessment identification of deficiencies will be used to develop an in-house correction plan. 6. The Quality Coordinator and Quality Assistant will monitor the correction plan, report to the monthly quality meeting the status of the POCs and the Compliance Director will report at a quarterly meeting in of the Directors in writing the data/finidings regarding compliance with this POC and the status of each location's assessment. 7. All assessments will be reviewed and completed with Plans of Correction by June 20th. 8. All new leadership staff will complete a training during their orientation on self assessments and their importance to each location within the company. 02/26/2021 Implemented
6400.103There are no written emergency evacuation procedures for the home.There shall be written emergency evacuation procedures that include individual and staff responsibilities, means of transportation and an emergency shelter location. Ensure a calm transition and the safety of people in care in an emergency situation Plans used in the past were found to be inadequate There has been an increased rate of staff and leadership turnover Directors will review the regulation and develop an evacation template plan that is sufficient for all residents. The Program Managers and Associate Director of Services will tailor to their specific locations. The Director of Compliance and the Residential Directors will meet semi-annually in June and November to review the evacaution plans for the residences. 03/12/2021 Implemented
6400.110(f)Individual #1 is hearing impaired. There is no fire alert system to alert her of a fire in the bathroom or in the laundry. If one or more individuals or staff persons are not able to hear the smoke detector or fire alarm system, all smoke detectors and fire alarms shall be equipped so that each person with a hearing impairment will be alerted in the event of a fire. This regulation is important to ensure all people we support and staff are alerted of a fire no matter what their needs are or where they are located in the home. Strobe lights were identified as missing in the bathroom and laundry areas. Strobe lights were added to the home when the person we support moved in, but strobe lights in the bathroom and laundry area were not installed. Maintenance added additional strobe lights to the bathroom and laundry area on 1/21/2021. The Director of Properties and Purchasing will work with maintenance and other TLC staff to ensure when a person we support is hearing impaired, all areas of the home will have strobe lights installed. The DSP and management staff will also review strobe light placement especially if there is a bedroom change or room change that puts the strobe light outside of the individuals line of sight. 03/19/2021 Not Implemented
6400.112(a)The fire drill form for 2021 is pre-populated with the dates the upcoming fire drills to be held. The top of the form indicates which months sleep drills will be held. An unannounced fire drill shall be held at least once a month. Consistently completing fire drills ensures that staff and persons in care understand how to respond in the event of a fire emergency. The staff documented when they planned to conduct fire drills on a staff document to ensure they were not missed prior to their being conducted Documentation was not adequately maintained Fire Drills are now input and montiored into the Fire Drill log monthly by Program Specialist/Associate Director of Services/Program Manager. The Listed supervisiors were retrained on the fire drill regulations to ensure understanding of all requirements. 1) All staff will be training in the regulation and its importance. A training log will be maintained of this training. 2) The PM of each house will monitor the completion of the fire drill. 3) In addition the Quality Coordinator and the Quality Assistant will monitor each house and their performance along on at least a monthly basis. A notification will be sent to any home on the nearest business day to the 15th of the month if a fire drill entry has not happened at a home. This will be done with a review of an MS FORMS document that will mirror the old Google form no longer available to staff. 4) A report will be made to the ADOS-Operational Group and the Quality Meeting monthly and to the Director's meeting quarterly. The Quality Meeting Group, consisting of the HR Director, the three Directors of Services, the Training and Development Coordinator, the Director of Compliance and the Quality Coordinator and Assistant will report monthly at those meetings. Minutes of these meetings will be maintained. 03/12/2021 Not Implemented
6400.112(c)The fire drill records do not indicate if all smoke detectors were operative.A written fire drill record shall be kept of the date, time, the amount of time it took for evacuation, the exit route used, problems encountered and whether the fire alarm or smoke detector was operative. Consistently completing fire drills ensures that staff and persons in care understand how to respond in the event of a fire emergency. Thorough notes of the steps taken in the fire drill were not documented Documentation was not adequately maintained Fire Drills are now input and montiored into the Fire Drill log monthly by Program Specialist/Associate Director of Services/Program Manager. The Listed supervisiors were retrained on the fire drill regulations to ensure understanding of all requirements. 1) All staff will be training in the regulation and its importance. A training log will be maintained of this training. 2) The PM of each house will monitor the completion of the fire drill. 3) In addition the Quality Coordinator and the Quality Assistant will monitor each house and their performance along on at least a monthly basis. A notification will be sent to any home on the nearest business day to the 15th of the month if a fire drill entry has not happened at a home. This will be done with a review of an MS FORMS document that will mirror the old Google form no longer available to staff. 4) A report will be made to the ADOS-Operational Group and the Quality Meeting monthly and to the Director's meeting quarterly. The Quality Meeting Group, consisting of the HR Director, the three Directors of Services, the Training and Development Coordinator, the Director of Compliance and the Quality Coordinator and Assistant will report monthly at those meetings. Minutes of these meetings will be maintained. 03/12/2021 Not Implemented
6400.112(h)The fire drill records do not indicate if all individuals made it to the designated meeting place. Individuals shall evacuate to a designated meeting place outside the building or within the fire safe area during each fire drill.Consistently completing fire drills ensures that staff and persons in care understand how to respond in the event of a fire emergency. The people we support did not make it to the designated location. Various staff and supervisor changes led to inconsistencies within quality of training received and comprehension of regulations Fire Drills are now input and montiored into the Fire Drill log monthly by Program Specialist/Associate Director of Services/Program Manager. The Listed supervisiors were retrained on the fire drill regulations to ensure understanding of all requirements. 1) All staff will be training in the regulation and its importance. A training log will be maintained of this training. 2) The PM of each house will monitor the completion of the fire drill. 3) In addition the Quality Coordinator and the Quality Assistant will monitor each house and their performance along on at least a monthly basis. A notification will be sent to any home on the nearest business day to the 15th of the month if a fire drill entry has not happened at a home. This will be done with a review of an MS FORMS document that will mirror the old Google form no longer available to staff. 4) A report will be made to the ADOS-Operational Group and the Quality Meeting monthly and to the Director's meeting quarterly. The Quality Meeting Group, consisting of the HR Director, the three Directors of Services, the Training and Development Coordinator, the Director of Compliance and the Quality Coordinator and Assistant will report monthly at those meetings. Minutes of these meetings will be maintained. 03/12/2021 Not Implemented
SIN-00167411 Renewal 12/10/2019 Compliant - Finalized
RegulationLIS Non-Compliance AreaCorrection RequiredPlans of CorrectionCorrection DatePOC Status
6400.141(c)(8)Individual #1 mammogram completed 01/29/18 and not again until 07/10/19.The physical examination shall include: A mammogram for women at least every 2 years for women 40 through 49 years of age and at least every year for women 50 years of age or older. The Program Manager will be trained on the methodology of scheduling appointments within their required time frame. Operational ADOS will be responsible to train Program Manager by January 31, 2020. See Attachment #141(c)(8). Outlook Calendar and to-do-list will be used by Program Managers and others that run appointments to create future alerts to ADOS', Program Managers, and Direct Service Professionals 60 days before the due dates for needed appointments as a means to know when to make appointments. All residential staff will be trained in the use of this new tool and the expectations to add information for future appointments immediately upon the current year's appointment taking place. A Practice and Guideline will be created/implemented to ensure all ADOS', Program Managers, and Direct Service Professionals are trained on this procedure. When an appointment is scheduled by the appropriate Program Manager or DSP, the appointment reminder will be cancelled and an automatic cancellation will go to all others, keeping them informed of the status of each appointment. Training will be within each service area and take place within 60 days. See Attachment #141(c)(8) Practice and Guideline and Training Log. 04/01/2020 Implemented
6400.151(c)(3)Staff #1 physical completed 05/01/19 states "PT denies any communicable diseases", not the physician's response to the exam. Staff #2 physical completed 06/26/19 states "PT denies any communicable diseases", not the physician's response to the exam. The physical examination shall include: A signed statement that the staff person is free of communicable diseases or that the staff person has a communicable disease but is able to work in the home if specific precautions are taken that will prevent the spread of the disease to individuals. HR representative will call Industrial Resource Center Manager to request revised physician assistant statement for physical. If unsuccessful in attaining a revised physician note, alternative sources of services will be sought. This will occur before 1/31/2020. HR representative will assure all physicals will be appropriately noted as being the opinion of the medical provider, not a statement of the individual employee. If unable to assure statement will meet regulation, other providers will be sought for this service. HR representative will review every employment physical for statement meeting state regulations. This will happen before employment for every staff member and within 15 days for current employees needing a physical. This will be in effect before March 1, 2020. 03/01/2020 Implemented
SIN-00086416 Renewal 10/20/2015 Compliant - Finalized
RegulationLIS Non-Compliance AreaCorrection RequiredPlans of CorrectionCorrection DatePOC Status
6400.67(a)The counter located by the back door molding on the right side is torn and missing an area. Floors, walls, ceilings and other surfaces shall be in good repair. Maintenance repaired counter molding on 10/23/2015. Attachment #1 is a picture showing the repaired molding. The Chapter 6400 Quality Assurance checklist was revised (addition of checking moldings on all counters) by ADOS for Quality Management on 11/30/15, Attachment #2 . On 12/2/15, all Managers will be trained on the revised Quality Assurance checklist, by the ADOS for Quality Management. The signature sign-in sheet serves as the training sheet (to be submitted no later than 12/30/15). The revised Checklist will be utilized effective 12/3/15 and a completed Checklist will be submitted no later than 12/30/15. Attachments #1 and #2 are submitted via email. 12/30/2015 Implemented
SIN-00241353 Renewal 04/01/2024 Compliant - Finalized