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Department of
SOCIAL SERVICES

Community Care Licensing


FACILITY EVALUATION REPORT

Facility Number: 374600808
Report Date: 07/10/2024
Date Signed: 07/10/2024 05:14:55 PM


Document Has Been Signed on 07/10/2024 05:14 PM - It Cannot Be Edited

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

FACILITY EVALUATION REPORT
CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 7575 METROPOLITAN DR. #109
SAN DIEGO, CA 92108



FACILITY NAME:MELROSE CARE HOME IIFACILITY NUMBER:
374600808
ADMINISTRATOR:LILIA P. RENAFACILITY TYPE:
740
ADDRESS:1627 MARL AVENUETELEPHONE:
(619) 498-0911
CITY:CHULA VISTASTATE: CAZIP CODE:
91911
CAPACITY:6CENSUS: 3DATE:
07/10/2024
TYPE OF VISIT:Required - 1 YearUNANNOUNCEDTIME BEGAN:
09:20 AM
MET WITH:Licensee Lilila RenaTIME COMPLETED:
05:30 PM
NARRATIVE
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Licensing Program Analyst (LPA) Dang Nguyen conducted an unannounced Required Annual Inspection. The facility file was reviewed prior to the visit. LPA was welcomed by, identified himself to, and discussed the purpose of the visit with Licensee Lilia Rena.

According to the facility’s license, the facility has a maximum capacity for six (6) residents, of whom all may be ambulatory or non-ambulatory, but none may be bedridden. Per LPA observation and review of each resident’s latest LIC602 Physician’s Report: During today’s visit, there were a total of three (3) clients in care, and none were bedridden. This facility’s license does not include endorsements for secured perimeter or delayed egress doors, and none of these were present during the visit.

During today’s visit, LPA interviewed multiple staff and residents. LPA reviewed all staff and resident records/files. LPA, accompanied by Licensee’s staff, toured the interior and exterior of the facility, and inspected each room. The facility was clean, sanitary, and in general good repair. Pathways were free of obstruction and slip hazards. Resident bedrooms contained the required furnishings. Doors, windows and screens, toilets, and showers were in working order. Extra linens, hygiene supplies, and Personal Protective Equipment were present. The facility had sufficient space and equipment to facilitate dining, laundry, visitation, meetings, and resident activities. The facility’s ambient internal temperature was complaint at 73 F. Hot water temperature at taps accessible to residents were all compliant: Kitchen Sink was 111.1 F, Bathroom #1 Sink was 111.6 F, and Bathroom #2 Sink was 112.1 F. Appliances to preserve perishable food were also compliant in temperature: Kitchen Refrigerator was 31 F and Kitchen Freezer was 0 F. Garage Refrigerator was 39 F and Garage Freezers were 0 F and 0 F, respectively. There was at least two (2) days of perishable food, and at least seven (7) days non-perishable food present, all safely stored. Cooking/dining equipment and utensils were present.

[CONTINUED ON LIC 809-C, 1 of 2]
SUPERVISOR'S NAME: Lizzette TellezTELEPHONE: (619) 767-2351
LICENSING EVALUATOR NAME: Dang NguyenTELEPHONE: (619) 210-9024
LICENSING EVALUATOR SIGNATURE:
DATE: 07/10/2024
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:
DATE: 07/10/2024
This report must be available at Child Care and Group Home facilities for public review for 3 years.

LIC809 (FAS) - (06/04)
Page: 1 of 8


Document Has Been Signed on 07/10/2024 05:14 PM - It Cannot Be Edited

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

FACILITY EVALUATION REPORT (Cont)
CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 7575 METROPOLITAN DR. #109
SAN DIEGO, CA 92108


FACILITY NAME: MELROSE CARE HOME II

FACILITY NUMBER: 374600808

DEFICIENCY INFORMATION FOR THIS PAGE:

VISIT DATE: 07/10/2024

DEFICIENCIES & PLANS OF CORRECTION (POCs)
Type B
Section Cited
CCR
87466
Observation of the Resident
The licensee shall ensure that residents are regularly observed for changes in physical, mental, emotional and social functioning and that appropriate assistance is provided when such observation reveals unmet needs. When changes such as unusual weight gains or losses or deterioration of mental ability or a physical health condition are observed, the licensee shall ensure that such changes are documented and brought to the attention of the resident's physician and the resident's responsible person, if any.

This requirement is not met as evidenced by:
Deficient Practice Statement
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3
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Based on records review and manager interview: The Licensee did not ensure that 3 of 3 residents (R1, R2, and R3) were regularly observed for changes in physical functioning, specifically weight gain/loss. This posed a potential health risk to persons in care.
POC Due Date: 08/09/2024
Plan of Correction
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2
3
4
Licensee agreed to measure and log the body weights of R1, R2, and R3, and to E-mail copies of these logs to LPA, by the POC due date. Going forward, Licensee agreed to weigh each resident in care once per month, and to record/log the weight in writing in the resident's care binder.
Type B
Section Cited
CCR
87470(b)(2)(C)
Infection Control Requirements
(b) In addition to subsection (a), when one or more residents in the facility are diagnosed with a contagious disease, the following shall apply: (2) All staff and volunteers providing direct care to a resident who has a contagious disease shall wear appropriate Personal Protective Equipment (PPE) to prevent exposure to infectious agents or chemicals through the respiratory system, skin, or mucous membranes of the eyes, nose, or mouth. PPE may include gloves, gowns, masks, respirators, shoe coverings and eye protection. (C) The licensee shall ensure all staff and volunteers are trained in the proper use of all required PPE prior to being around residents and annually thereafter.

This requirement is not met as evidenced by:
Deficient Practice Statement
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Based on records review and manager interview: Licensee did not ensure that 4 of 4 staff [S1 through S4] were trained in the proper use of all required PPE prior to being around residents and at least once per year (annually). This posed a potential health risk to 3 of 3 residents (R1, R2, and R3) in care.
POC Due Date: 08/09/2024
Plan of Correction
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3
4
Licensee agreed to arrange for all four (4) of its staff to receive training on how to property don and doff PPE (to include surgical masks, N-95 respirators, faceshields, gowns, and gloves), and to document such retraining on an in-service sign-in sheet. Licensee agreed to E-mail LPA the training sign-in sheet, by the POC due date.
Failure to correct the cited deficiency(ies), on or before the Plan of Correction (POC) due date, may result in a civil penalty assessment.
SUPERVISOR'S NAME: Lizzette TellezTELEPHONE: (619) 767-2351
LICENSING EVALUATOR NAME: Dang NguyenTELEPHONE: (619) 210-9024
LICENSING EVALUATOR SIGNATURE:
DATE: 07/10/2024
I acknowledge receipt of this form and understand my appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:
DATE: 07/10/2024
LIC809 (FAS) - (06/04)
Page: 2 of 8


Document Has Been Signed on 07/10/2024 05:14 PM - It Cannot Be Edited

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

FACILITY EVALUATION REPORT (Cont)
CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 7575 METROPOLITAN DR. #109
SAN DIEGO, CA 92108


FACILITY NAME: MELROSE CARE HOME II

FACILITY NUMBER: 374600808

DEFICIENCY INFORMATION FOR THIS PAGE:

VISIT DATE: 07/10/2024

DEFICIENCIES & PLANS OF CORRECTION (POCs)
Type B
Section Cited
HSC
1569.267(d)
Resident's Bill of Rights
(d) The licensee shall provide initial and ongoing training for all members of its staff to ensure that residents’ rights are fully respected and implemented.

This requirement is not met as evidenced by:
Deficient Practice Statement
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Based on records review and manager interview: Licensee did not ensure that 4 of 4 staff [S1 through S4] were trained on Resident's Personal Rights, initially and ongoing. This posed a potential health risk to clients in care.
POC Due Date: 08/09/2024
Plan of Correction
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Licensee agreed to arrange for all four (4) of its staff to receive training on Resident's Personal Rights (as articulated in form LIC613C-2), and to E-mail LPA the training sign-in sheet, by the POC due date. Going forward, Licensee agreed to repeat this training on an ongoing basis.
Type B
Section Cited
CCR
87465(d)(3)
Incidental Medical and Dental Care Services
(d) If the resident is unable to determine his/her own need for a prescription or nonprescription PRN medication, and is unable to communicate his/her symptoms clearly, facility staff designated by the licensee, shall be permitted to assist the resident with self-administration, provided all of the following requirements are met: (3) The date and time the PRN medication was taken, the dosage taken, and the resident's response shall be documented and maintained in the resident's facility record.

This requirement is not met as evidenced by:
Deficient Practice Statement
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Based on records and manager interview, for 1 of 3 residents (R1), Licensee did not record in the resident’s record the date, time, dosage, and client’s response to PRN dose(s) which were given to them. This posed a potential health and personal rights risk to persons in care.
POC Due Date: 08/09/2024
Plan of Correction
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Licensee agreed to immediately implement a form/log to document PRN medicines which staff give to residents. Licensee agreed to instruct/train all staff on the documenation requirements related to PRN medications, and to submit the training sign-in sheet and PRN log for R1 to LPA, by the POC due date.
Failure to correct the cited deficiency(ies), on or before the Plan of Correction (POC) due date, may result in a civil penalty assessment.
SUPERVISOR'S NAME: Lizzette TellezTELEPHONE: (619) 767-2351
LICENSING EVALUATOR NAME: Dang NguyenTELEPHONE: (619) 210-9024
LICENSING EVALUATOR SIGNATURE:
DATE: 07/10/2024
I acknowledge receipt of this form and understand my appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:
DATE: 07/10/2024
LIC809 (FAS) - (06/04)
Page: 3 of 8


Document Has Been Signed on 07/10/2024 05:14 PM - It Cannot Be Edited

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

FACILITY EVALUATION REPORT (Cont)
CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 7575 METROPOLITAN DR. #109
SAN DIEGO, CA 92108


FACILITY NAME: MELROSE CARE HOME II

FACILITY NUMBER: 374600808

DEFICIENCY INFORMATION FOR THIS PAGE:

VISIT DATE: 07/10/2024

DEFICIENCIES & PLANS OF CORRECTION (POCs)
Type B
Section Cited
CCR
87463(c)
Reappraisals
(c) The licensee shall arrange a meeting with the resident, the resident's representative, if any, appropriate facility staff, and a representative of the resident's home health agency, if any, when there is significant change in the resident's condition, or once every 12 months, whichever occurs first, as specified in Section 87467, Resident Participation in Decision Making.

This requirement is not met as evidenced by:
Deficient Practice Statement
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Based on records review and manager interview, for 3 of 3 residents (R1, R2, and R3), Licensee did not complete a care reappraisal of the resident and meet with their responsible person to review it, at least once every twelve (12) months. This posed a potential health and personal rights risk to persons in care.
POC Due Date: 08/09/2024
Plan of Correction
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Licensee agreed to complete an updated LIC625 Appraisal/Needs and Services Plan and LIC9172 Funcitonal Capability Assessment forms on R1, R2, and R3, to include meeting with each clients' respective responsible person (RP) to review the document and obtain the RP's signature on it. Licensee agreed to E-mail these signed updated LIC625 and LIC9172 forms to LPA, by the POC due date. Going forward, Licnesee agreed to update these two forms and meet with RPs to review them at least once per year.
Section Cited
Deficient Practice Statement
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POC Due Date:
Plan of Correction
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Failure to correct the cited deficiency(ies), on or before the Plan of Correction (POC) due date, may result in a civil penalty assessment.
SUPERVISOR'S NAME: Lizzette TellezTELEPHONE: (619) 767-2351
LICENSING EVALUATOR NAME: Dang NguyenTELEPHONE: (619) 210-9024
LICENSING EVALUATOR SIGNATURE:
DATE: 07/10/2024
I acknowledge receipt of this form and understand my appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:
DATE: 07/10/2024
LIC809 (FAS) - (06/04)
Page: 4 of 8


Document Has Been Signed on 07/10/2024 05:14 PM - It Cannot Be Edited

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

FACILITY EVALUATION REPORT (Cont)
CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 7575 METROPOLITAN DR. #109
SAN DIEGO, CA 92108


FACILITY NAME: MELROSE CARE HOME II

FACILITY NUMBER: 374600808

DEFICIENCY INFORMATION FOR THIS PAGE:

VISIT DATE: 07/10/2024

DEFICIENCIES & PLANS OF CORRECTION (POCs)
Type B
Section Cited
CCR
87467(a)(3)
Resident Participation in Decisionmaking
(a) Prior to, or within two weeks of the resident's admission, the licensee shall arrange a meeting with the resident, the resident's representative, if any, appropriate facility staff, and a representative of the resident's home health agency, if any, and any other appropriate parties, to prepare a written record of the care the resident will receive in the facility, and the resident's preferences regarding the services provided at the facility. (3) The licensee shall arrange a meeting with the resident and appropriate individuals identified in Section 87467(a)(1) to review and revise the written record as specified, when there is a significant change in the resident's condition, or once every 12 months, whichever occurs first. Significant changes shall include, but not be limited to occurrences specified in Section 87463, Reappraisals.

This requirement is not met as evidenced by:
Deficient Practice Statement
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Based on records review and manager interview, for 3 of 3 residents (R1, R2, and R3), Licensee did not prepare a written record of care the resident will receive in the facility, to include the resident's preferences regarding the services provided at the facility, and meet with the resident and/or their responsible person to review it, at least once every twelve (12) months. This posed a potential health and personal rights risk to persons in care.
POC Due Date: 08/09/2024
Plan of Correction
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Licensee agreed to complete an LIC625 Appraisal/Needs and Services Plan on R1, R2, and R3, to include meeting with each clients' respective responsible person (RP) to review the document and obtain the RP's signature. Licenseee agreed to E-mail the signed LIC625s to LPA, by the POC due date. Going forward, Licnesee agreed to this forms and meet with RPs to review them at least once per year.

Failure to correct the cited deficiency(ies), on or before the Plan of Correction (POC) due date, may result in a civil penalty assessment.
SUPERVISOR'S NAME: Lizzette TellezTELEPHONE: (619) 767-2351
LICENSING EVALUATOR NAME: Dang NguyenTELEPHONE: (619) 210-9024
LICENSING EVALUATOR SIGNATURE:
DATE: 07/10/2024
I acknowledge receipt of this form and understand my appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:
DATE: 07/10/2024
LIC809 (FAS) - (06/04)
Page: 5 of 8


Document Has Been Signed on 07/10/2024 05:14 PM - It Cannot Be Edited

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

FACILITY EVALUATION REPORT (Cont)
CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 7575 METROPOLITAN DR. #109
SAN DIEGO, CA 92108


FACILITY NAME: MELROSE CARE HOME II

FACILITY NUMBER: 374600808

DEFICIENCY INFORMATION FOR THIS PAGE:

VISIT DATE: 07/10/2024

DEFICIENCIES & PLANS OF CORRECTION (POCs)
Type B
Section Cited
HSC
1569.695(b)
Other Provisions
(b) A facility shall provide training on the plan to each staff member upon hire and annually thereafter. The training shall include staff responsibilities during an emergency or disaster.

This requirement is not met as evidenced by:
Deficient Practice Statement
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Based on records review and manager interview, Licensee did not ensure that 4 of 4 staff (S1 through S4) received training on the facility's emergency/disaster plan, to include their individual responsiblities during an emergency/disaster, upon hire and annually thereafter. This posed a potential safety risk to 3 of 3 residents (R1, R2, and R3) in care.
POC Due Date: 08/09/2024
Plan of Correction
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3
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Licensee agreed to provide a copy of its LIC610D Emergency and Disaster Plan to each staff, and to train its four (4) current staff on the plan. Licensee agreed to E-mail a copy of the training sign-in sheet to LPA, by the POC due date.
Type B
Section Cited
HSC
1569.695(c)
Other Provisions
(c) A facility shall conduct a drill at least quarterly for each shift. The type of emergency covered in a drill shall vary from quarter to quarter, taking into account different emergency scenarios. An actual evacuation of residents is not required during a drill. While a facility may provide an opportunity for residents to participate in a drill, it shall not require any resident participation. Documentation of the drills shall include the date, the type of emergency covered by the drill, and the names of staff participating in the drill.

This requirement is not met as evidenced by:
Deficient Practice Statement
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3
4
Based on records review and manager interview: Licensee did not conduct an emergency/disaster drill at least quarterly for each shift and document them. This posed a potential safety risk to 4 of 4 staff (S1 through S4) and 3 of 3 residents (R1, R2, and R3) in care.
POC Due Date: 08/09/2024
Plan of Correction
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Licnesee agreed to perform three (3) diaster drills [one will occur during the AM/morning shift (6:00 AM to 2:00 PM), one will occur during the PM/afternoon shift (2:00 PM to 10:00 PM), and one will occur during the NOC/overnight shift (10:00 PM to 6:00 AM)] with its current staff and residents. Licensee agreed to E-mail LPA the documentation of such drills, by the POC due date. Going forward, Licensee agreed to drill (and doucment in writing) each shift, at least once per quarter.
Failure to correct the cited deficiency(ies), on or before the Plan of Correction (POC) due date, may result in a civil penalty assessment.
SUPERVISOR'S NAME: Lizzette TellezTELEPHONE: (619) 767-2351
LICENSING EVALUATOR NAME: Dang NguyenTELEPHONE: (619) 210-9024
LICENSING EVALUATOR SIGNATURE:
DATE: 07/10/2024
I acknowledge receipt of this form and understand my appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:
DATE: 07/10/2024
LIC809 (FAS) - (06/04)
Page: 6 of 8


STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

FACILITY EVALUATION REPORT (Cont)
CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 7575 METROPOLITAN DR. #109
SAN DIEGO, CA 92108
FACILITY NAME: MELROSE CARE HOME II
FACILITY NUMBER: 374600808
VISIT DATE: 07/10/2024
NARRATIVE
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[CONTINUED FROM LIC 809]

There were no sharp objects, toxic chemicals/poisons, active fireplaces, or open-faced heaters accessible to residents. Medications were labeled, as required, and stored in locked areas. Confidential records were stored in locked areas. No pools or bodies of water were observed on the premises. Per the Licensee, no firearms or ammunition are kept at the facility. Carbon monoxide detector, smoke detectors, emergency lighting, and facility telephone were all working. The facility’s fire extinguisher was serviced within the last twelve (12) months. A complete first aid kit was present and readily accessible. Required licensing postings were observed in visible areas of the facility. Confidential records were stored in locked areas. Licensee's staff also presented proof of current/active business liability insurance.


During records review, LPA observed, and staff interviews confirmed: Resident #1 (R1) had an as-needed (PRN) medication made available to them by their doctor. [See LIC811 Confidential Names List for a description of resident identifiers used in this report.] Staff had given R1 this PRN medication often, prior to LPA’s 07-10-2024 visit. However, the staff assisting R1 did not record in writing the date, time, dosage, and the resident’s response to doses of this PRN which were given to them, as was required. For R1, Resident #2 (R2), and Resident #3 (R3), Licensee had not prepared a written record of care (i.e., a “care plan”) describing the services the resident will receive in the facility and the resident’s preferences, which was required to be done within two (2) weeks of admission to the facility. Because these care plans did not exist for R1, R2, and R3, those residents’ respective responsible persons (RPs) also did not have the opportunity to meet with Licensee to review them (which was required to be done at least annually). The latest LIC603 Resident Appraisals which Licensee had conducted on R1, R2, and R3 were all more than one year old. (Regulation required these residents’ condition to be reappraised upon any change in condition, but also at least annually.) For R3, Licensee did not have a record of body weight measurement for them. For R1, it had been over seventeen (17) months since Licensee last obtained a body weight measurement for them. For R3, it had been over sixteen (16) months since Licensee last obtained a body weight measurement for them. (Regulation required Licensee to “regularly observe” residents for changes in physical condition, to include “unusual weight gains or losses.”)


[CONTINUED ON LIC 809-C, 2 of 2]
SUPERVISOR'S NAME: Lizzette TellezTELEPHONE: (619) 767-2351
LICENSING EVALUATOR NAME: Dang NguyenTELEPHONE: (619) 210-9024
LICENSING EVALUATOR SIGNATURE:

DATE: 07/10/2024
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 07/10/2024
LIC809 (FAS) - (06/04)
Page: 7 of 8
STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

FACILITY EVALUATION REPORT (Cont)
CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 7575 METROPOLITAN DR. #109
SAN DIEGO, CA 92108
FACILITY NAME: MELROSE CARE HOME II
FACILITY NUMBER: 374600808
VISIT DATE: 07/10/2024
NARRATIVE
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32
[CONTINUED FROM LIC 809-C, 1 of 2]

LPA also observed, and Licensee interview confirmed: Licensee did not perform emergency/disaster drills with the staff and/or residents. (Regulation required each shift to be drilled at least once per quarter). Licensee did have proof that 4 of 4 staff were trained on its written LIC610 Emergency Disaster Plan and the staff’s individual roles/responsibilities under this plan. (Regulation required staff to be trained on the plan at time of hire and at least once per year thereafter). Licensee did not have proof that 4 of 4 staff received training on the use of Personal Protective Equipment (PPE). (Regulation required staff to be trained on PPE annually.) Licensee also did not have proof that 4 of 4 staff received training on Resident’s Personal Rights described in law. (Regulation required staff to be trained on this topic initially and on an ongoing basis).

Five (5) deficiencies were cited per California Code of Regulations, Title 22, and three (3) deficiencies were cited per California Health and Safety Code (refer to the attached LIC 809-D pages). Plans of Correction were jointly developed with the Licensee. LPA issued two (2) Technical Violations (TVs) regarding physician-authorized medication lists and night lights in bathrooms and hallways (refer to the attached LIC9102-TV pages). LPA also provided Technical Assistance (TA) regarding obtaining updated medical assessments for residents, and regarding staff auditory alert devices on exit doors (refer to the attached LIC 9102-TA page).

An exit interview was conducted with Rena, to whom a copy of this report, the LIC 809-D pages, the LIC9102-TV pages, LIC9102-TA pages, the LIC811 Confidential Names List, and the Licensee/Appeal Rights (LIC9058 03/22) were provided during today’s visit.
SUPERVISOR'S NAME: Lizzette TellezTELEPHONE: (619) 767-2351
LICENSING EVALUATOR NAME: Dang NguyenTELEPHONE: (619) 210-9024
LICENSING EVALUATOR SIGNATURE:

DATE: 07/10/2024
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 07/10/2024
LIC809 (FAS) - (06/04)
Page: 8 of 8