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February 29, 2024 Gerald Powers, Authorized Agent Pathway House 613 2nd Street SW Rochester, MN 55902 License Number: 802845 (245G)
Dear Gerald Powers: This matter arises from an Order of Conditional License, dated October 26, 2023, issued after a licensing review conducted on July 24, 25 and 26, 2023 (See attached Exhibit A). On November 14, 2023, the Minnesota Department of Human Services (DHS), Licensing Division, received your request for reconsideration on behalf of Pathway House of the Order of Conditional License. You requested reconsideration of the following citations: 1, 2, 4, 6, 8, 13, 14, 16, 19, 21 and 22. You did not request reconsideration of the remaining citations, and those citations are therefore final and not included in the scope of this review. A. CONDITIONAL LICENSE DISPUTED, YOUR RECONSIDERATION REQUEST REGARDING STATUTORY CITATIONS AND LICENSING VIOLATIONS, AND DHS’ RESPONSE 1. Citation 1: Minnesota Statutes, sections 245C.03, subdivision 1, 245C.04, subdivision 1, paragraphs (a), (b), and (g), and 245C.07, paragraph (a) Violation: The license holder failed to comply with the following background study requirements: a. The license holder failed to request background studies on five staff persons (SP) (personnel files numbered 8 through 11) before they began working in positions allowing direct contact with persons served. 1) SP (personnel numbered 8) was hired and began working in a position allowing direct contact with persons served by the program on December 7, 2018. At the time of the licensing review and investigation on July 27, 2023, the license holder had not submitted a background study request for the SP. 2) SP (personnel numbered 9) is a controlling individual, in a position allowing direct contact with persons served by the program since March 14, 1991. At the time of the licensing review and investigation on July 27, 2023, the license holder had not submitted a background study request for the SP. 3) SP (personnel numbered 10) was hired and began working in a position allowing direct contact with persons served by the program on April 19, 2022. At the time of the licensing review and investigation on July 27, 2023, the license holder had not submitted a background study request for the SP. 4) SP (personnel numbered 11) was hired and began working in a position allowing direct contact with persons served by the program on July 5, 2023. At the time of the licensing review and investigation on July 27, 2023, the license holder had not submitted a background study request for the SP. b. The license holder has multiple programs but failed to affiliate two SP (personnel files numbered 4 and 13) on both active rosters. 1) SP (personnel numbered 4) was hired and began working in a position allowing direct contact with persons served by the program on December 20, 2022. At the time of the licensing review and investigation on July 27, 2023, the license holder had not affiliated the SP with license number 802845. 2) SP (personnel numbered 13) was hired and began working in a position allowing direct contact with persons served by the program on June 5, 2023. At the time of the licensing review and investigation on July 27, 2023, the license holder had not affiliated the SP with license number 802845. c. The license holder did not submit a background study request to DHS for an individual who previously had a cleared study that expired (personnel files numbered 5 ,7, and 12). 1) SP (personnel numbered 5) was hired and began working in a position allowing direct contact with persons served by the program on December 17, 2020. At the time of the licensing review and investigation on July 27, 2023, the license holder had not submitted a background study request to the commissioner using the electronic system known as NetStudy 2.0 before the individual continued in a position allowing direct contact. 2) SP (personnel numbered 7) was hired and began working in a position allowing direct contact with persons served by the program on December 15, 2022 At the time of the licensing review and investigation on July 27, 2023, the license holder had not submitted a background study request to the commissioner using the electronic system known as NetStudy 2.0 before the individual continued in a position allowing direct contact. 3) SP (personnel numbered 12) was hired and began working in a position allowing direct contact with persons served by the program on February 24, 2018. At the time of the licensing review and investigation on July 27, 2023, the license holder had not submitted a background study request to the commissioner using the electronic system known as NetStudy 2.0 before the individual continued in a position allowing direct contact. Repeat Violation: In a Correction Order issued on September 29, 2021, you were found in violation of the same statute. Request for reconsideration: You indicate in the reconsideration request that the program conducted background studies under a “COVID study” in Netstudy 2.0, and that the program was notified the studies were expired and needed to be completed again. You indicate you assumed the background studies were valid and that individuals could begin working if they had positive reports. You also indicate an initial study has been completed for each individual that was working under direct contact, and you indicate the program’s sensitive information person (SIP) was a past program director who passed away in 2020. DHS’ response: Due to an exception authorized as a result of the COVID-19 peacetime emergency, subjects who submitted background studies during a specific timeframe were not required to submit fingerprints as a part of their study. As of December 31, 2022, all license holders were required to come into compliance with enhanced background studies by ensuring all background study subjects had completed fingerprint-based studies, including those who had previously completed a “COVID study.” A review of the personnel checklist indicates multiple staff persons had expired background studies as of December 31, 2022, and submission of a background study request was required using the electronic system known as NetStudy 2.0 before individuals continued in a position allowing direct contact. Also, the license holder is responsible for updating the program’s designated SIP and ensuring that expired studies are corrected. As a result, there is sufficient evidence to support the violation, and it is affirmed. 2. Citation 2: Minnesota Statutes, section 245A.04, subdivision 12, paragraph (d), and 245G.15, subdivision 1. Violation: The license holder failed to monitor the implementation of their policies and procedures to ensure client rights were protected under MN Statute 144.651. The license holder’s implementation of their policy Client Statuses at Pathway House, violated client’s rights in the following ways: a. Violation of the right to refuse care under MN Statute 144.651, subdivision 12. During an interview with a client and staff person at the time of the licensing review and investigation, it was identified that clients are given a (1) on the accountability sheet if the client misses medication time. Two (1s) received within 24 hours results in the client’s movement being restricted to the house; and b. Violation of services to the facility under MN Statute 144.651, subdivision 23. Household chores are a part of the client statuses as Pathway House protocol, and this includes cleaning staff and client bathrooms, grounds keeping, cleaning the kitchen, etc. This is a standard of practice within the facility and ties to the accountability sheet to determine the level client of status of independence. Services within the facility must be for therapeutic purposes and appropriately goal-related in their individual medical record. Repeat Violation: In a Correction Order issued on September 29, 2021, you were found in violation of the same statute. Request for reconsideration: You indicate in the request for reconsideration that the program stresses the importance of remaining medication compliant and holds clients responsible for taking their prescribed medications. You also indicate the restrictions are not implemented to punish the client but rather to allow time for the client and their counselor or physician to discuss future medication plans. You indicate that chores are assigned to clients as daily responsibilities to promote a healthy and safe environment. DHS’ response: The program’s Client’s House Expectation policy indicates that all medications must be taken as prescribed and specifies that “refusal to remain medication compliant directly affects the client’s status.” However, a client’s right to refuse care is protected under the Health Care Bill of Rights in Minnesota Statutes, section 144.651, subdivision 12. With regard to chores, the policy refers to assigned chores and indicates clients “are not allowed to leave the house until all chores are completed and checked by staff.” Also, the policy lists multiple “client statuses” which restrict a client’s ability to leave the house. Minnesota Statutes, section 144.651, subdivision 23 indicates that patients and residents shall not perform labor or services for the facility unless the activities are included for therapeutic purposes and appropriately goal-related in their individual medical record. As a result, because the record supports the citation, it is affirmed. 3. Citation 4: Minnesota Statutes, sections 245A.04, subdivision 1, paragraph (i), and 245A.191. Violation: The license holder failed to meet requirements for receiving public funding reimbursement from the commissioner for services provided. The license holder failed to provide the 15 hours of weekly clinical services required under Minnesota Statutes, section 254B.05, subdivision 5, paragraph (b) to clients receiving public funding reimbursement for medium intensity residential treatment (client file numbered 3). The file documented the client received: a. No hours of services the week ending February 19, 2023; b. 3.25 hours of services the week ending February 26, 2023; c. 3.25 hours of services the week ending March 5, 2023; and d. 4 hours of services the week ending March 12, 2023. Repeat Violation: In a Correction Order issued on September 29, 2021, you were found in violation of the same statute. Request for reconsideration: You indicate in the reconsideration request that the program had documentation of client group attendance in binders and that information was then entered into a database to be stored. You indicate that during the licensing review, the licensors were unable to locate the information in the database but that there were group sign in sheets and group notes for clients identified in the violation. DHS’ response: The information provided with the reconsideration request was reviewed and considered during the licensing review along with information forwarded for further consideration within 24 hours after the licensing review. The information did not indicate treatment services were documented according to requirements. Licensors also met with the program’s treatment director to explain further findings related to the program’s group notes and how the method of entering appointments did not meet the requirement for clinical service documentation. As a result, because the record supports the citation, it is affirmed. 4. Citation 6: Minnesota Statutes, section 245G.11, subdivision 11 and 245G.13, subdivision 3. Violation: Two of two personnel files reviewed for requirements governing staff qualifications failed to meet requirements in the following ways: a. The personnel file did not contain the staff person’s temporary permit (personnel files numbered 1 and 3); and b. The license holder failed to document weekly supervision of individuals with temporary permits. 1) May, 2022 to May 2023 (personnel file numbered 1); and 2) September, 2022 (personnel file numbered 3). The license holder, during the licensing review and investigation, did verify staff member’s temporary permit (personnel files numbered 1 and 3) and placed copies in the personnel files. Request for reconsideration: You indicate in the reconsideration request that you feel the citation was unfair because the supervision was completed and the licensors validated the information on site. You indicate the supervisor with the temporary permit was no longer employed by the program and took their notes with them when they left. DHS’ response: Although the violation specified in paragraph a was corrected during the licensing review, the violation still occurred. With regard to the violation specified in paragraph b, the license holder was given 24 hours after the licensing review to provide documentation missing from the personnel file. No documents were submitted. Asa result, because the record supports the citation, it is affirmed. 5. Citation 8: Minnesota Statutes, sections 245A.65, subdivision 1, paragraph (c), 245G.09, subdivision 3, and 245G.15, subdivision 1. Violation: Two of five client files reviewed for requirements governing service initiation and orientation failed to meet requirements in the following ways: a. The statement of client rights and responsibilities were not given to the client on the day of service initiation (client files numbered 2 and 6); b. The client was not oriented to internal and external reporting policies, including the telephone number for the Minnesota Adult Abuse Reporting Center and the program abuse prevention plan within 24 hours of admission to the program, or 72 hours for persons who would benefit more from a later orientation (client file numbered 2 and 6); and c. The license holder did not seek consent for the disclosure of suspected maltreatment upon admission (client file numbered 2). Repeat Violation: In a Correction Order issued on September 29, 2021, you were found in violation of the same statute. Request for reconsideration: You indicate in the reconsideration request that when clients are admitted to the program, they receive an intake packet. You indicate program staff then go over the packet with the client and the clients sign a form acknowledging they received the documents and that the documents are explained to them. You indicate the violation was false and that clients had signed a statement indicating they received the packet and that it was explained to them.
DHS’ response: With regard to paragraph a, records showed clients numbered 2 and 6 received the statement of client rights and responsibilities on dates other than the required day of service initiation. Client numbered 2 was admitted on June 5, 2023, and received the statement on June 12, 2023. Client numbered 6 was admitted on June 3, 2023, and received the statement on June 8, 2023. With regard to paragraph b, records showed clients numbered 2 and 6 were not oriented during the required time period. Client file numbered 2 was admitted on June 5, 2023, and was oriented on June 12, 2023. Client numbered 6 was admitted on June 3, 2023, and oriented on June 8, 2023. Because the record supports the citation, it is affirmed. 6. Citation 13: Minnesota Statutes, sections 245A.65, subdivision 3, and 245G.13, subdivision 1. Violation: One of two personnel files reviewed for requirements governing orientation training failed to meet requirements. There was no documentation to demonstrate the staff person (personnel file numbered 4) received orientation within 24 hours of starting. Repeat Violation: In a Correction Order issued on September 29, 2021, you were found in violation of this same statute. Request for reconsideration: You indicate that the staff person was oriented within 24 hours of their employment and that the orientation was documented.
DHS’ response: Documentation submitted with the reconsideration request contains a signed orientation dated December 11, 2022, and December 12, 2022, for the staff person in personnel file numbered 4. However, the license holder was given 24 hours after the licensing review to provide documentation, and no documents were provided during that time. Under Minnesota Statutes, section 245A.04, subdivision 5, licensing must be given access to documents and records without prior notice and as often as the commissioner considers necessary as a part of a licensing inspection. Because you failed to provide these documents at the review or within 24 hours as requested by licensing, the record supports the citation and it is affirmed. 7. Citation 14: Minnesota Statutes, sections 245A.19, paragraph (b), 245A.65, subdivision 3, 245G.13, subdivision 2, paragraphs (c), (d), and (e), and 260E. Violation: One of two personnel files reviewed for requirements governing annual training and every two-year training (personnel file numbered 3) failed to contain documentation of any annual or every two-year training records. Repeat Violation: In a Correction Order issued on September 29, 2021, you were found in violation of this same statute. Request for reconsideration: You indicate that all staff members had yearly training signed and completed in their files. You also indicate the two-year required training is combined with the one-year training to ensure completion.
DHS’ response: Documentation submitted with the reconsideration requests contains signed 2021 and 2022 annual training for personnel file numbered 3. However, the license holder was given 24 hours after the licensing review to provide documentation, and no documents were provided during that time. As a result, because the record supports the citation, it is affirmed. 8. Citation 16: Minnesota Statutes, section 245G.06, subdivision 2a Violation: Three of four client files reviewed for documentation of treatment services received in weeks sampled (client files numbered 1, 2 and 4) failed to meet requirements in the following ways: a. The client file did not contain documentation of the following treatment services: 1) Group counseling on June 28, 2023 (client files numbered 1 and 2); 2) Group counseling on July 19, 2023 (client file numbered 2); and 3) Group counseling on March 20 and March 27, 2023 (client file numbered 4); and b. Groups were led by one staff and documented by a different staff in the client record: 1) April 3, 2023 (client file numbered 4); 2) April 20, 2023 (client file numbered 1); 3) April 24, 2023 (client files numbered 1 and 4); and 4) July 19, 2023 (client file numbered 2). Request for reconsideration: You indicate the staff providing the treatment services was a supervisor, and that both staff were present when the treatment service was documented. You also dispute that the violation was a repeat violation. DHS’ response: Your request for reconsideration relates to paragraph b. The documentation provided with the reconsideration request identifies the treatment director as supervisor for a staff person, but the supervision required for licensure of a staff person is a separate matter unrelated to the violation. The violation was issued because groups were led by one staff and documented by a different staff in the client record. A review of group sign-in sheets obtained at the time of the licensing review indicated the treatment director was entering notes in the client record when other staff were facilitating groups. As a result, because the record supports the citation, it is affirmed. The violation was identified as a repeat violation in error, and the record is corrected to indicate it was not a repeat violation. 9. Citation 19: Minnesota Statutes, section 245G.06, subdivision 2b. Violation: Three of five client files reviewed for requirements governing client record documentation (client files numbered 1, 2, and 6) failed to meet requirements in the following ways: a. A note was not entered following a significant event impacting the client’s treatment plan (client files numbered 1, 2 and 6); b. The client record did not contain documentation of a therapy appointment the client attended (client numbered 6); and c. Each entry was not signed, dated and inclusive of the job title or position of the staff person making the entry (client files numbered 1, 2, and 6). Repeat Violation: In a Correction Order issued on September 29, 2021, you were found in violation of this same statute. Request for reconsideration: You indicate in the reconsideration request that medical appointments are documented in the program’s database in the “medical records” file.
DHS’ response: You request reconsideration of paragraph b. You submitted documentation regarding a client’s file, but the documentation did not relate to the client file that was cited in the violation. Because the record supports the citation, it is affirmed. 10. Citation 21: Minnesota Statutes, section 245G.09, subdivision 1. Violation: The license holder failed to maintain accurate client records. Group notes included template information relating to relapse prevention groups that discharged clients were required to attend for 8-12 weeks. The treatment director confirmed this was no longer the program’s practice at the time of the licensing review and investigation (client files numbered 1 and 2). Repeat Violation: In a Correction Order issued on September 29, 2021, you were found in violation of the same statute. Request for reconsideration: You indicate in the reconsideration request that templates are a working tool for staff use and are not used as a treatment service and permanent record information for medium intensity programming. DHS’ response: At the time of the licensing review and investigation, the program’s treatment director indicated that the template language in various group notes is inaccurate. Although the program no longer has alumni attending groups for 8-12 weeks, the group notes indicate those clients were required to attend groups. Because the record supports the citation, it is affirmed. 11. Citation 22: Minnesota Statutes, section 245A.04, subdivision 14, paragraph (b) and 245A.65, subdivision 1, paragraph (d). Violation: The license holder failed to monitor the implementation of their policies. The license holder had two internal and external maltreatment reporting policies posted that indicated different primary and secondary persons/positions to whom internal reports may be made. This violation was self-corrected at the time of the licensing review and investigation. Request for reconsideration: You indicate in the reconsideration request that program policy indicates clients can make reports to either the executive director or the program director and that clients have the option to report to either of those persons based on their preference. You indicate the policy was corrected for consistency during the licensing visit. DHS’ response: Although the violation was corrected during the licensing review, the violation still occurred. Because the record supports the citation, it is affirmed. B. DISPOSITION Based on the foregoing, the Commissioner finds that the citations in the October 26, 2023, Order of Conditional License are supported by the record, and they are affirmed. Citation 16 was identified in error as a repeat violation, and the record is corrected to reflect that it was not a repeat violation. Under Minnesota Statutes, section 245A.06, subdivision 1, when issuing a conditional license, the Commissioner must consider the nature, chronicity, or severity of the violation of the law or rule and the effect of the violation on the health, safety, or rights of persons served by the program. In the request for reconsideration, you request that the Conditional License be removed. You also ask that actions taken by the program after the site visit be considered. However, the Commissioner has considered the nature, chronicity, and severity of the licensing violations and determined that a conditional license is warranted. The Conditional Order cites twenty-two citations reflecting that Pathway House has failed to comply with multiple requirements. The license holder challenged only eleven of the twenty-two citations on reconsideration, which resulted in all the challenged citations being affirmed. The eleven affirmed citations along with the remaining citations that were unchallenged support the need for a conditional license because they demonstrate a history of serious and chronic licensing violations that indicate a failure to follow procedure and practice requirements which affect the health, safety, and rights of clients. With regard to chronicity, the license holder failed to correct prior violations cited on multiple occasions. Seventeen of the violations cited in the Conditional Order under review were previously cited in a Correction Order dated September 29, 2021. The failure to correct a large number of citations strongly supports the need for a conditional license, the terms of which are focused on ensuring that the license holder is taking meaningful steps toward achieving compliance and thereby protecting clients’ health, safety, and rights. The nature of the cited violations is also a basis for the conditional license. The citations involved a failure to follow requirements which affected the health and safety of the persons served, including a failure to ensure staff were qualified and a failure to comply with background studies requirements. Background study requirements and requirements regarding staff qualifications are in place to ensure the safety of the residents served by the program. Other violations included a failure to ensure client rights were protected, a failure to ensure staff requirements for designating a responsible staff person and first aid certification were met, and a failure to provide training related to administration of medication. The protection of client rights is essential to ensuring their well-being, and requirements regarding certification and training are in place to ensure staff are familiar with policies and procedures related to resident safety and well-being and that staff are able to provide qualified care to residents. Additionally, the license holder failed to meet requirements for receiving public funding reimbursement when it failed to meet requirements for billing for services. Rules and regulations are in place to ensure that public funds received by license holders are allocated properly and used for the benefit of the clients for which the funds are intended. Also, the license holder failed to meet requirements which resulted in violations that were severe in number and duration related to treatment documentation, including a failure to complete individual prevention plans as required, a failure to comply with service initiation and orientation requirements, a failure to complete treatment plan reviews as required, a failure to complete comprehensive assessments and comprehensive assessment summaries as required, and a failure to document treatment services as required. Accurate documentation and determinations in client files are necessary to demonstrate that services are being provided, that the services being provided are relevant, how the client is responding to services, and whether the services are effective. Due to the need to monitor Pathway House for compliance with applicable licensing laws and rules, and to ensure the health and safety of persons served by the program, the Commissioner affirms the Order of Conditional License issued on October 26, 2023. The period of the conditional license is two years, beginning on the date of this reconsideration decision. Because the terms of your conditional license were stayed pending a decision on your request for reconsideration, the terms of the conditional license begin from the date of receipt of this letter. C. TERMS OF THE CONDITIONAL LICENSE In addition to the 245G licensing rules and statutes, you are required to comply with the following terms: 1. Within 14 days of receipt of this decision, you must notify current clients and all parties who refer individuals to your program of the conditional status of your license. The notification must be approved by your DHS Licensor prior to being sent to residents and all other parties. Therefore, the draft notice must be submitted to DHS for approval within 10 days of receipt of this decision. The notification must specify the length of time of the conditional status of your license, the reasons your license was placed on conditional status, and include either a copy of the Order of Conditional License or an offer to provide a copy upon request. While the license is on conditional status, you must notify new clients and referral sources that the license is on conditional status before they begin receiving services. The notification to new clients must specify the length of time of the conditional status of your license, the reasons the license was made conditional, and it must include either a copy of the Order of Conditional License or an offer to provide a copy of the order upon request. A copy of the notice with client and/or legal representative(s) signature must be maintained in the client file. Within 30 days of receipt of this decision, you must submit to your DHS Licensor, a copy of the notice and a list of all referral sources that received the notice. 2. Within 14 days of receipt of this decision, you must contact Paula Halverson, DHS Licensing Mental Health, Substance Use Disorder and Children’s Residential Facilities Unit Manager, to schedule a training on requirements for Substance Use Disorder residential treatment programs under Minnesota Statutes, Chapter 245G. Individuals required to attend are the Treatment Director, ADC Supervisor, Compliance Officer, Registered Nurse, Authorized Agent and Human Resource designee. Training must be completed within 45 days of receipt of this decision. 3. Within 14 days of receipt of this decision, you must submit to DHS Licensing a resume for any proposed Compliance Officer that addresses each qualification listed below. The license holder agrees to ensure that the program’s Compliance Officer will not hold the position of Treatment Director or ADC Supervisor. If providing treatment services, the Compliance Officer may only allocate 50 percent of their working hours to treatment services. The program’s Compliance Officer must have the following minimum qualifications and must be approved by the program’s DHS Licensor: a. 2 years of professional experience in the following: 1) A regulatory or compliance position, and 2) Involved in direct care as a substance use counselor, or 3) The development and implementation of mental health or substance use disorder treatment planning in a DHS licensed 245G Substance Use Disorder program. b. Working knowledge of Minnesota Statutes, Chapter 245A (Human Services Licensing) and Chapter 245G (Substance Use Disorder). c. A Bachelor’s degree or higher in Human Services, Social Work, Sociology, Psychology; or, a related field may substitute for one year of professional experience in Human Services, Social Work, Sociology, Psychology or a related field. 4. Within 30 days of the receipt of this decision, you must develop, and submit to DHS, a self-monitoring plan that ensures an ongoing, systematic approach for monitoring compliance with applicable licensing laws, rules, and statutes. The plan must: a. Identify the Compliance Officer and other persons that may be responsible for assisting the Compliance Officer with monitoring, and these individuals must demonstrate compliance with all applicable laws, rules and statutes; b. Require a sample review of resident records, personnel files, required treatment services, treatment plans and reviews, internal reviews, and grievances on a monthly basis; and c. Require that the Compliance Officer conduct a monthly review of License Holder’s policies and procedures to ensure that they are in compliance with Minnesota Statutes, Chapters 245A and 245G, and that staff are implementing those policies and procedures in compliance with Minnesota Statutes, Chapters 245A and 245G. The self-monitoring plan must be submitted to and approved by the program’s DHS Licensor within 30 days of receipt of this decision. Documentation of the results of the monthly reviews, discrepancies found within the reviews and corrective actions taken must be submitted to the program’s DHS Licensor quarterly, beginning on March 15, 2024, and continuing every three months thereafter, on or before the 15th of that month, for 2 years from the effective date of the conditional license. 5. Within 30 days from receipt of this decision, you must develop and submit a plan for managing personnel files. The personnel plan must be approved by the program’s DHS Licensor and must include: a. Identification of the specific individual designated for Human Resources (HR) duties and responsibilities. The person must not be the treatment director, LADC supervisor, or clinical staff person who is involved with the day to day treatment services; b. A description of how the program will ensure that background study requirements are met on an ongoing basis, including identifying who will be responsible for managing staff background studies, and documentation that the responsible person has received training on these duties; c. A description of how the program will ensure that all applicable qualifications are met for current staff and on an ongoing basis, including identifying who will be responsible for knowing and verifying staff qualifications, and documentation that the responsible person has received training on these duties; and d. A description of how the program will ensure that staff orientation and training requirements are met on an ongoing basis, including identifying who will be responsible for monitoring staff orientation and training on an ongoing basis, and documentation that the responsible person has received training on these duties. Your licensor will monitor your compliance with all applicable laws and rules. Verification of compliance may include unannounced visits. Failure to comply with the requirements in Minnesota Statutes, chapter 245A (Human Services Licensing Act), Minnesota Statutes, chapter 245C (Human Services Background Study Act), Minnesota Statutes, chapter 245G (Chemical Dependency Based Treatment), Minnesota Statutes, section 626.557, and with the terms of your conditional license may result in further negative action, including revocation of your license. This is a final agency decision and is subject to further review only by the Minnesota Court of Appeals. Please note that there are time limits for seeking review by the Minnesota Court of Appeals. See Minnesota Statutes, Chapter 606 and Minnesota Rules of Civil Appellate Procedure, Rule 115. If you have any questions regarding the Order of Conditional License, please contact Maura McGarry, Unit Supervisor, at (651) 431-6671. Sincerely,
Frances Simon Standing, Attorney Legal Counsel’s Office Office of Inspector General
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