STATE OF FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION AGENCY FOR HEALTH CARE ADMINISTRATION, Petitioner. ; Division of Administrative Hearings VS. ALTERRA HEALTH CARE CORPORATION d/b/a ALTERRA WYNWOOD OF SARASOTA, Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Agency for Health Care Administration (“AHCA”), by and through its undersigned counsel, and files this Administrative Complaint against Respondent, Alterra Health Care Corporation d/b/a Alterra Wynwood of Sarasota, (hereinafter sometimes referred to as “Respondent”) pursuant to Sections 120.569 and 120.57, Florida Statutes (2002), and alleges: NATURE OF THE ACTION 1. This is an action to impose an administrative fine in the amount of $1,500.00 against the Respondent pursuant to Section 400.419, Florida Statutes (2002), based on three repeat Class III deficiencies cited at a survey on or about May 20-21, 2003. JURISDICTION AND VENUE 2. This Tribunal has jurisdiction over the Respondent pursuant to Sections 120.569 and 120.57, Florida Statutes (2002). 3. Venue shall be determined pursuant to Chapter 28-106.207, Florida Administrative Code (2002). PARTIES 4. Pursuant to Chapter 400, Part III, Florida Statutes, and Chapter 58A-5, Florida Administrative Code, AHCA is the licensing and enforcing authority with regard to assisted living facility laws and rules. 5. Alterra Health Care Corporation is a foreign for profit corporation with a principal address of 10,000 Innovation Drive, Tax Department, Milwaukee, Wisconsin 53226. 6. Respondent is an assisted living facility located at 5501 Swift Road, ~ Sarasota, Florida 34231. 7. Respondent is and was at all times material hereto a licensed facility under Chapter 400, Part III, Florida Statutes (2002), and Chapter 58A-5, Florida Administrative Code (2002), having been issued license number 7102 by AHCA. COUNTI RESPONDENT FAILED TO MAINTAIN AN ACCURATE, DAILY, UP-TO- DATE, MEDICATION OBSERVATION RECORD (“MOR”) FOR EACH RESIDENT. Fla. Admin. Code R. 58A-5.0185(5)(b) (2002) REPEAT CLASS III 8. AHCA repeats, re-alleges, and incorporates by reference paragraphs one (1) through seven (7) above as if fully set forth herein. Survey on or about May 21-22, 2001 9. On or about May 21-22, 2001, AHCA conducted a survey at Respondent. AHCA cited Respondent for a class ITI deficiency based on the findings below involving Resident #1 or Resident #5. Resident #1 10. _ Resident #1 had a physician’s order for Hydrodiuril 25 mg. (milligrams) one tablet M-W-F. The MOR failed to correlate with the physician’s order. Additionally, the pharmacy label read, "Hydrodiuril 25 mg., take 1/2 tab M-W-F." During an interview with Respondent’s Health Care Service Coordinator (“HCSC”), the HCSC admitted to the AHCA surveyor that Respondent had failed to request a pharmacy label change from the pharmacy. Resident #5 11. Resident #5 had a physician’s order for Micro K 10 meq. (millequivelents) i BID (twice a day). The pharmacy label for this medication read, "Micro K 20 mg. i qd (daily)." During an interview with Respondent’s HCSC, the HCSC admitted that Respondent had failed to request a pharmacy label change from the pharmacy. Resident #5 also had a physician’s order for “Mellaril 50 mg i HS [at hour of sleep] daily.” The MOR read “Mellaril tab 25 mg i HS” and did not correlate with the physician’s order. 12. Based on the foregoing, Respondent violated Rule 58A-5.0185(5)(b) Florida Administrative Code, by failing to maintain an accurate, daily, up-to-date, MOR for Resident #1 or Resident #5. 13. The daily update of resident MORs is required, in pertinent part, as follows: (5) MEDICATION RECORDS...(b) For residents who receive assistance with self-administration or medication administration, the facility shall maintain a daily up-to-date, medication observation record (MOR) for each resident. A MOR must include the name of the resident and any known allergies the resident may have; the name of the resident’s health care provider, the health care provider’s telephone number; the name of each medication prescribed, its strength, and directions for use; and a chart for recording each time the medication is taken, any missed dosages, refusals to take medication as prescribed, or medication errors. The MOR must be immediately updated each time the medication is offered or administered...” Fla. Admin. Code R. 58A- 5.0185(5)(b) (2002). 14. _ For this deficiency, AHCA provided Respondent with a mandated correction date of June 22, 2001. 15. On or about July 11, 2001, AHCA conducted a follow-up visit to the survey on or about May 21-22, 2001. Respondent had corrected the foregoing class III deficiency. Survey on or about May 20-21 , 2003 16. | Onor about May 20-21, 2003, AHCA conducted a survey at Respondent. AHCA cited Respondent again for violating Rule 58A-5.0185(5)(b), Florida Administrative Code, based on the findings below involving Resident #12. Resident #12 17. Onor about May 21, 2003, at approximately 10:00 a.m., an AHCA surveyor reviewed Resident #12’s medical record including the MOR. The record contained a physician's order for Lopressor (Metoprolol) 25 mg BID (twice a day). According to the MOR, Resident #12 had a physician’s order for Metoprolol 50 milligrams (mg), take % tablet (25mg) by mouth twice daily at 8:00 a.m. and 5:00 p.m. The 5:00 p.m. dose was crossed out on the MOR and the following note was documented: "if pulse greater than 90 then increase to BID (twice a day).” 18. The HCSC reviewed Resident #12’s medical record and was unable to find a physician’s order that changed the dose from twice a day to once a day and twice a day only if pulse is greater than ninety (90). According to Resident #12’s MOR dated April 2003, the physician’s order was changed on or about April 7, 2003. The medical record, however, contained no physician's order showing this change. The MOR did not correlate with the physician’s order in Resident #12’s medical record. Respondent’s staff called the physician's office to clarify the order. 19. According to the daily pulses recorded in the record, Resident #12's pulse was higher than ninety (90) on three (3) days in the month of May. A second dose of the medication was not documented in the MOR as given to Resident #12 per the new physician’s order. An AHCA surveyor asked Respondent’s HCSC if the medication had been given. The HCSC reviewed the MOR and said the MOR contained no documentation showing that Resident #12 received the medication twice on those three days in May as per the change in the physician’s order. 20. Based on the foregoing, Respondent violated Rule 58A-5.0185(5)(b) Florida Administrative Code, by failing to maintain an accurate, daily, up-to-date, MOR for Resident #12. 21. The foregoing deficiency constitutes a repeat Class III deficiency and warrants fine of $500.00, to wit: ...(c) Class III violations are those conditions or occurrences related to the operation and maintenance of a facility or the personal care of residents which the agency determines indirectly or potentially threaten the physical or emotional health, safety, or security of facility residents, other than class I or II violations. A Class III violation is subject to an administrative fine of not less than $500 and not exceeding $1,000 for each violation... (§ 400.419 (1) (c), Fla. Stat. (2002)) COUNT Il RESPONDENT FAILED TO COMPLY WITH THE RESIDENT BILL OR RIGHTS BY FAILING TO ENSURE THAT EACH RESIDENT HAS THE RIGHT TO LIVE IN A SAFE AND DECENT LIVING ENVIRONMENT FREE FROM NEGLECT OR BY FALING TO ENSURE THAT EACH RESIDENT IS TREATED WITH CONSIDERATION AND RESPECT AND WITH DUE RECOGNITION OF PERSONAL DIGNITY, INDIVIDUALITY AND THE NEED FOR PRIVACY. § 400.428(1), Fla. Stat. (2002) REPEAT CLASS III 22. | AHCA repeats, re-alleges, and incorporates by reference paragraphs one (1) through seven (7) above as if fully set forth herein. Survey on or about May 21-22, 2001 23. | Onor about May 21-22, 2001, AHCA conducted a survey at Respondent. AHCA cited Respondent for a class III deficiency based on the findings below involving Resident #2. Resident #2 24. On or about May 21-22, 2001, an AHCA surveyor reviewed Resident #2’s medical record, interviewed Respondent’s nurse, and observed Resident #2. 25. According to Resident #2’s medical record, Resident #2 was admitted to Respondent on or about January 26, 2001, with a diagnosis of cardio vascular accident. During the survey, an AHCA surveyor knocked on Resident #2's door and entered when a voice said, "Help me." The AHCA surveyor observed Resident #2 wearing a blouse and a brief and sitting with her back to the door. She had wet hair and was shivering. Both legs were bare with two 3-inch flapped open skin tears. The AHCA surveyor observed blood dripping onto the floor from both skin tears. Resident #2 had blue toes and feet and large ecchymotic areas all over her legs and arms. There was no lap blanket or article of clothing to cover the lower extremities visible in the room. The AHCA surveyor observed no staff in attendance. 26. Resident #2 asked the AHCA surveyor for help getting into bed. The AHCA surveyor left Resident #2’s room to find help after reassuring the resident that she would return. The AHCA surveyor located a nurse coming out of another room and requested help for Resident #2. The nurse said, "They showered her and left her for me to dress her legs, she must have kicked the pad away from under her feet." 27. Resident #2 was transported to the hospital for an evaluation of the extensive skin tears on both legs. Resident #2 returned from the hospital that afternoon with steri-strips, wound dressings, and physician’s orders for the wounds to be treated at the Wound Care Center. 28. Based on the foregoing, Respondent violated Section 400.428(1), Florida Statutes, by failing to ensure that Resident #2 lived in a safe and decent living environment, free from neglect or by failing to ensure that Resident #2 was treated with consideration and respect and with due recognition of personal dignity, individuality, and the need for privacy. 29. For this deficiency, AHCA provided Respondent with a mandated correction date of June 22, 2001. 30. | Onor about September 25, 2002, AHCA conducted a follow-up visit to the survey on or about May 21-22, 2001. Respondent had corrected the foregoing class III deficiency. Survey on or about May 20-21, 2003 31. | Onor about May 20-21, 2003, AHCA conducted another survey at Respondent. AHCA cited Respondent again for violating Section 400.428 (1), Florida Statutes, based on the findings below involving Resident #1, Resident #4, Resident #5, Resident #7, Resident #9, Resident #10, or Resident #11. Resident #4 32. On or about May 21, 2003, at approximately 11:25 a.m., an AHCA surveyor observed Respondent’s registered nurse (“RN”) administer gastrostomy tube feeding to Resident #4. 33. The RN failed to wash her hands or put on gloves prior to carrying out the procedure. The RN poured one can of Nutren 2.0 into the tube feed bag. She flushed the gastrostomy tube with 30cc of water and connected the feeding tube to the gastrostomy tube. The RN said she would be back to check the feeding every twenty (20) minutes and would flush again at the end of the procedure. 34. On or about May 20-21, 2003, an AHCA surveyor reviewed Resident #4’s medical record. The record contained a physician's order dated April 18, 2003, to increase the water flush to 125cc pre-feeding and post-feeding. Resident #5 35. | Onor about May 20, 2003, at approximately 2:30 p.m., an AHCA surveyor interviewed Resident #5 in Resident #5’s room. During the interview, the surveyor observed oxygen tanks lying on the floor under a chair. The oxygen tanks were not secured to prevent rolling or falling over. 36. During the survey on or about May 20-21, 2003, an AHCA surveyor requested a copy of Respondent’s policy on oxygen therapy. The policy was as follows: 1) Make sure that the oxygen tank is in an approved stand to prevent rolling or accidental fall. The oxygen in these tanks is under high pressure. If the tank falls over and the valve stem breaks, the pressure is released, causing the tank to be propelled like a projectile. 2) Store tanks away from direct sunlight or heat. 37. On or about May 20, 2003, at approximately 4:15 p.m., an AHCA surveyor interviewed Respondent’s Executive Director and HCSC. The Executive Director said he would take care of the oxygen tanks immediately. The following morning at about 9:40 a.m., the AHCA surveyor observed Resident #5’s room. The oxygen tanks were still on the floor unsecured. At approximately 11:30 a.m., Respondent secured the oxygen tank in a blue plastic container with separators. 38. Onor about May 20, 2003, at approximately 2:30 p.m., an AHCA surveyor interviewed Resident #5. During the interview, Resident #5 said she was told by administration upon admission that she had to use Respondent’s pharmacy to order medications because Respondent uses the punch card system. Resident #5 said she has “Tri Care for Life", a federal prescription plan for retired armed service personnel that has a $3.00 charge for generic medications for ninety (90) days and a $9.00 charge for non-generics. Resident #5 said the cost of medication from Respondent’s pharmacy was much higher than the cost under the Tri Care for Life plan. The AHCA surveyor observed punch cards and cassettes for medication distribution on Respondent’s medicine cart. 39. On or about May 20, 2003, at about 4:14 p.m., an AHCA surveyor interviewed Respondent’s Administrator. The Administrator said he would look into Resident #5’s ability to have her medications filled through the federal program. Resident #7 40. On or about May 20, 2003, at approximately 9:50 a.m., an AHCA surveyor performed an initial tour of Respondent. The surveyor observed three large, 30- inch, and six, small, 15-inch, oxygen tanks lying on the floor under a chair near the air conditioning/heating unit in Resident #7’s room. The oxygen tanks were not secured to prevent rolling or falling over. During an interview, Resident #7 told the surveyor that the oxygen tanks had always been there. The next day at approximately 11:30 a.m., Respondent secured the oxygen tank in a blue plastic container with separators. Resident #9 41. Onor about May 20-21, 2003, an AHCA surveyor reviewed Resident #9’s medical record. Resident #9 was admitted to Respondent on or about February 26, 2003, and re-admitted to Respondent on or about March 18, 2003, after a hospitalization. 42. A note in the record revealed that Resident #1 agitated Resident #9 during lunch on or about May 18, 2003, by calling out. According to the note, Resident #9 said, "My wife and I will not eat in the dining room if he [Resident #1] is in here." 43. | Onor about May 20, 2003, at approximately 2:00 p.m., an AHCA surveyor interviewed Resident #9. Resident #9 said Resident #1's calling out during meals is unpleasant and Respondent has done nothing to address the problem. 44, On or about May 20, 2003, at about 11:45 a.m., an AHCA surveyor observed lunch in the dining room. Resident #9 complained that he was tired of Resident #1’s calling out and said he did not want to sit there. Respondent’s staff ignored Resident #9 and his wife. Resident #9 got up and left the dining room. At about 12:00 p.m., Resident #1 finished his sandwich and called out "Help!" several times. Resident #9 returned to the dining room and said, "you can be crazy as a loon and they feed you, but if you want a quiet place to eat, they refuse you." Resident #9 went back down the hall and sat down. Respondent’s staff failed to intervene. 45. | Onor about May 20-21, 2003, an AHCA surveyor discussed the situation with Respondent’s staff and Administrator. At approximately 12:20 p.m., Respondent served Resident #9 and his wife lunch on the outside patio. Resident #9 and his wife told 10 the AHCA surveyor that they desire to eat in a quiet environment and do not expect to be served every meal outdoors. Resident #10 46. Onor about May 21, 2003, at approximately 12:05 p.m., an AHCA surveyor observed Resident #10 eating her lunch with three (3) other residents at the table. Respondent’s nurse approached Resident #10 and said she was here to administer eye drops. Respondent’s nurse failed to ask Resident #10 if she wanted privacy before administering the eye drops. The nurse administered the eye drops while Resident #10 sat at the dining room table with the other three (3) residents. Respondent’s nurse failed to administer Resident #10’s eye drops in a private setting. Resident #11 47. Onor about May 21, 2003, at approximately 10:00 a.m., an AHCA surveyor observed a medication pass. A nurse administered eye drops to Resident #11 in the hallway outside the main dining room. Resident #11 was sitting on a bench with two other residents. Respondent’s nurse failed to administer Resident #11’s eye drops ina private setting. 48. Based on all of the foregoing, Respondent violated Section 400.428(1) Florida Statutes, by failing to ensure that each resident in the facility shall have the night to live in a safe and decent living environment, free from neglect or by failing to ensure that each resident is treated with consideration and respect and with due recognition of personal dignity, individuality, and the need for privacy. 49. The foregoing deficiency constitutes a repeat Class II deficiency and warrants a fine of $500.00, to wit: (c) Class III violations are those conditions or occurrences related to the operation and maintenance of a facility or the personal care of residents which the agency determines indirectly or potentially threaten the physical or emotional health, safety, or security of facility residents, other than class I or II violations. A Class III violation is subject to an administrative fine of not less than $500 and not exceeding $1,000 for each violation... (§ 400.419(1)(c), Fla. Stat. (2002)). COUNT II RESPONDENT FAILED TO ENSURE THAT THE USE OF PHYSICAL RESTRAINTS SHALL BE LIMITED TO HALF-BED RAILS, AND ONLY UPON THE WRITTEN ORDER OF THE RESIDENT’S PHYSICIAN, AND CONSENT OF THE RESIDENT OR THE RESIDENT’S REPRESENTATIVE. § 400.441(1)(k), Fla. Stat. (2002) Fla. Admin. Code R. 58A-5.0182(6)(h) (2002) REPEAT CLASS III 50. | AHCA repeats, re-alleges, and incorporates by reference paragraphs one (1) through seven (7) above as if fully set forth herein. Survey on or about August 5, 2002 51. On or about August 5, 2002, AHCA conducted a survey at the Respondent’s facility. AHCA cited the Respondent for a class III deficiency based on the findings below involving Resident #1 or Resident #2. Resident #1 52. On or about August 5, 2002, an AHCA surveyor observed Resident #1 in bed. Resident#1 had half-bed rails in the up position while in bed. 12 53. On or about August 5, 2002, an AHCA surveyor reviewed Resident #1’s medical record including hospice records. Resident #1 was a Hospice patient as of May 16, 2002. None of the records contained a physician’s order for half-bed rails as required by law. Resident #2 54. On or about August 5, 2002, at approximately 9:00 a.m., an AHCA surveyor observed Resident #2's room. Resident #2’s bed had half-bed-rails and one was in the up position. 55. On or about August 5, 2002, an AHCA surveyor reviewed Resident #2’s medical record. The record contained an old physician’s order for half-bed rails dated September 4, 2001. The record did not contain a new physician’s order for half-bed rails. 56. | Onor about August 5, 2002, an AHCA surveyor interviewed Respondent’s nursing staff. Respondent’s staff stated, "If a resident was Hospice they did not need to have orders for bed-rails." Respondent’s staff was unaware of both the need for a new physician’s order and of the fact that the physician’s order for half-bed rails in the medical record had expired and was no longer valid. 57. Based on the foregoing, Respondent violated Section 400.441(1)(k), Florida Statutes, or Rule 58A-5.0182(6)(h), Florida Administrative Code, by failing ensure that the use of physical restraints is limited to half-bed rails as prescribed and documented by the resident’s physician with the consent of the resident, or if applicable, the resident’s representative or designee or the resident’s surrogate, guardian, or attorney in fact. 58. For this deficiency, AHCA provided Respondent with a mandated correction date of June 21, 2003. 59. On or about September 25, 2002, AHCA conducted a follow-up visit to the survey on or about August 5, 2002. Respondent had corrected the class III deficiency. Survey on or about May 20-21, 2003 60. On or about May 20-21, 2003, AHCA conducted another survey at Respondent. AHCA cited Respondent again for violating Section 400.441(1)(k), Florida Statutes, or Rule 58A-5.0182(6)(h), Florida Administrative Code, based on the findings below involving Resident #2 or Resident #3. Resident #2 61. On or about May 20, 2003, at about 9:15 a.m., an AHCA surveyor entered Respondent’s Clare Bridge Unit. According to Respondent’s staff, Respondent had posted a poem with the access code to the door, but a resident figured it out and staff took it down. 62. | Onor about May 20, 2003, an AHCA surveyor observed Resident #2 standing inside the Clare Bridge Unit at the door. When Respondent’s staff and AHCA surveyor entered, Resident #2 said, "I want to go home to my family. I should be able to get out if [ want to." Respondent’s staff advised Resident #2 that she could not leave. According to Respondent’s staff, Resident #2’s spouse recently passed away and she knew he had an apartment in another part of the building and she looked for him every day. Resident #3 63. | Onor about May 20, 2003, at about 1:30 p.m., an AHCA surveyor observed Resident #3. Resident #3 was asleep in bed with half-bed rails up and a chair positioned next to the bed about one foot down from the half-bed rail. When staff entered the room with the AHCA surveyor, staff moved the chair away from the bed. After observation by the AHCA surveyor of Resident #3 sleeping in the middle of the bed, staff moved the chair back to its position, placing it in a position to assume a full restraint next to the bed. 64. On or about May 20-21, 2003, an AHCA surveyor interviewed Respondent’s staff. According to staff, Resident #3 fell on or about May 15, 2003. 65. | Onor about May 20-21, 2003, an AHCA surveyor reviewed the accident and incident report for the fall on or about May 15, 2003. The review revealed that the resolution was, "make sure the resident is pulled up in bed." 30. The foregoing deficiency constitutes a repeat Class III deficiency and warrants a fine of $500.00, to wit: ...(c) Class III violations are those conditions or occurrences related to the operation and maintenance of a facility or the personal care of residents which the agency determines indirectly or potentially threaten the physical or emotional health, safety, or security of facility residents, other than class I or II violations. A Class HI violation is subject to an administrative fine of not less than $500 and not exceeding $1,000 for each violation... (§ 400.419(1)(c), Fla. Stat. (2002)) WHEREFORE, AHCA respectfully requests the following relief: 1. Enter factual and legal findings as set forth in the allegations of Count I, II and OI; and 2. Impose a fine in the amount of $1,500.00 against Respondent. 1S NOTICE Respondent hereby is notified thet fo bes a right to request on ati tnice feo hearing pursuant to Section 129.269, Pleiita Stuttes (2002). Sports opi ns administrative action are set out in the attache ! Tlection of Rights form (0 po) and explained in uisattached Explanation eS 00 Tc Ge yous) Ate, ele shall be made to the Agency for Health Care Administration, and delivered to the Agency for Health Care Administration, 2727 Mahan Drive, Mail Stop #3, Tallahassee, Florida, 32308; Attention: Lealand McCharen, Agency Clerk. RESPONDENT IS FURTHili. 2. OUIFIED THAT THe FUER TO REQUEST A HEARING WITHIN TWENTY-ONE (21) DAYS OF RECEIPT OF THIS ADMINISTRATIVE COMPLAINT WILL RESULT IN AN ADMISSION OF THE FACTS ALLEGED IN T!'E SO MINISTRATIVE COP rep oe THE be TOO PINAL COD: . ene MUST BE RECEIVED BY AITCA WIL0US CESVENTY-CDE (2 os 2h RESPONDENT’S RECEIPT OF THUS SonuilUSeRATIVE CGlhi i Respectfully Submitted, Lori Desnick, Senior Attorney Fla. Bar No. 0129542 Counsel for Petitioner Agency for Health Care Administration 2727 Mahan Drive, Bldg. 3, MSC# 3 Tallahassee, Florida 32308 (850) 922-8854 (office) (850) 921-0158 (fax) 16 NOTICE Respondent hereby is notified that it has a right to request an administrative hearing pursuant to Section 120.569, Florida Statutes (2002). Specific options for administrative action are set out in the attached Election of Rights form (two pages) and explained in the attached Explanation of Rights form (one page). All requests for hearing shall be made to the Agency for Health Care Administration, and delivered to the Agency for Health Care Administration, 2727 Mahan Drive, Mail Stop #3, Tallahassee, Florida, 32308; Attention: Lealand McCharen, Agency Clerk. RESPONDENT IS FURTHER NOTIFIED THAT THE FAILURE TO REQUEST A HEARING WITHIN TWENTY-ONE (21) DAYS OF RECEIPT OF THIS ADMINISTRATIVE COMPLAINT WILL RESULT IN AN ADMISSION OF THE FACTS ALLEGED IN THE ADMINISTRATIVE COMPLAINT AND THE ENTRY OF A FINAL ORDER BY AHCA. THE REQUEST FOR HEARING MUST BE RECEIVED BY AHCA WITHIN TWENTY-ONE (21) DAYS OF RESPONDENT’S RECEIPT OF THIS ADMINISTRATIVE COMPLAINT. Respectfully Submitted, Lori Desnick, Senior Attorney Fla. Bar No. 0129542 Counsel for Petitioner Agency for Health Care Administration 2727 Mahan Drive, Bldg. 3, MSC# 3 Tallahassee, Florida 32308 (850) 922-8854 (office) (850) 921-0158 (fax) 16 CERTIFICATE OF SERVICE IHEREBY CERTIFY that one or inal Rights form, and Election of Ristits forai tas be Reccipt Reyroste! (ctum recei,!?___ 7001 0260 co03 280% 3455 _). to Dress th oO ay A aatiistester, S200 ah! uO, aT one original Administrative Complaint, Explanation of Rights form, and Election of Rights form, has been sent by U.S. Certified Mail, Return Reccipt Requested (return receipt#____—-700! 0360 oc03 FroY B3étio isd), to CT Corporation System, 1200 South Pine Island Road, Plantation, Florida 33324, Registered Agent for Alterra Health Cars Corporation (U/a Altcira Wynwood of Sarasota, on this Xr day of October 2003. . Lori Desnick, Esquire 17 CERTIFICATE OF SERVICE I HEREBY CERTIFY that one original Administrative Complaint, Explanation of Rights form, and Election of Rights form has been sent by U.S. Certified Mail, Return Receipt Requested (return receipt # ), to Bruce L. Collison, Administrator, 5501 Swift Road, Sarasota, Florida 34231, and that one original Administrative Complaint, Explanation of Rights form, and Election of Rights form, has been sent by U.S. Certified Mail, Return Receipt Requested (return receipt # _) to CT Corporation System, 1200 South Pine Island Road, Plantation, Florida 33324, Registered Agent for Alterra Health Care Corporation d/b/a Alterra Wynwood of Sarasota, on this ‘day of October 2003. Lori Desnick, Esquire

Docket for Case No: 03-004506