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December 31, 2025 Sheila Sartwell, Authorized Agent Connections 550 13th Avenue East West Fargo, North Dakota 58078 License Number: 1073193 (245D – HCBS) CORRECTION ORDER Dear Sheila Sartwell: On December 2, 2025, through December 4, 2025, a licensing review of Connections, located at 550 13th Avenue East, West Fargo, North Dakota, was conducted to determine compliance with state and federal laws and rules governing the provision of home and community-based services to persons with disabilities and age 65 and older under Minnesota Statutes, Chapter 245D. As a result of this licensing review a Correction Order is being issued. A. Reason for Correction Order Pursuant to Minnesota Statutes, section 245A.06, if the Commissioner of the Department of Human Services (DHS) finds that the license holder has failed to comply with an applicable law or rule and this failure does not imminently endanger the health, safety, or rights of the persons served by the program, the Commissioner may issue a Correction Order to the license holder. The following violation(s) of state or federal laws and rules were determined as a result of the licensing review. Corrective action for each violation is required by Minnesota Statutes, section 245A.06 and is hereby ordered by the Commissioner of Human Services. 1. Citation: Minnesota Statutes, section 245A.65, subdivision 1. Violation: For two of six persons whose records were reviewed (P3 and P5), the license holder did not provide an orientation to the internal and external reporting procedures related to suspected or alleged maltreatment as required. The license holder did not provide P3 and P5 with an orientation to the internal and external reporting procedures related to suspected or alleged maltreatment within 24 hours of admission. The license holder initiated services for P3 on November 14, 2021. At the time of the review, P3 had not received this orientation. The license holder initiated services for P5 on September 15, 2025. P5 received this orientation on October 17, 2025. Corrective Action Ordered: Within 30 days of receiving this order, you must provide P3 with an orientation to the internal and external reporting procedures related to suspected or alleged maltreatment. Documentation of this orientation must be maintained in the service recipient record. On an ongoing basis, you must maintain compliance as required in this subdivision. 2. Citation: Minnesota Statutes, section 245A.65, subdivision 2, paragraph (b). Violation: For three persons whose records were reviewed (P1, P3 and P4), the license holder did not develop and document an individual abuse prevention plan (IAPP) as required. 245A.02, subdivision 2b defines “annual” or “annually” to mean prior to or within the same month of the subsequent calendar year. a. The license holder did not include in the IAPP for P1 the specific actions the program would take to minimize the risk of abuse within the scope of licensed services. Additionally, the license holder did not review the IAPP for P1 with P1’s interdisciplinary team annually in 2024. The license holder reviewed the IAPP for P1 in March 2023 and December 2024. b. The license holder did not develop an accurate IAPP for P3. The license holder maintained an IAPP for P3 that stated they were not vulnerable in any areas which was inconsistent with information found elsewhere in P3’s record. c. The license holder did not include in the IAPP for P4 statements of the specific measures that would be taken to minimize the risk of abuse to P4 within the scope of licensed services. Corrective Action Ordered: Within 30 days of receiving this order, you must: · update P1’s IAPP with the specific action the program will take to minimize the risk of abuse to P1 within the scope of licensed services; · review the updated IAPP with P1 and P1’s case manager and maintain documentation of the review in the service recipient record; · develop and document an IAPP for P3 that contains the requirements outlined above; · review the IAPP with P3 and P3’s case manager and document the review in the service recipient record; · update the IAPP for P4 to include statements of the specific measures to be taken to minimize the risk of abuse to P4 and other vulnerable adults; · review the updated IAPP with P4 and P4’s case manager; and · provide training to all staff that work with P1, P3, and P4 on the updated IAPP and maintain documentation of this training in the personnel record including the date the training is completed, the number of hours per subject area, and the name of the trainer or instructor. On an ongoing basis, you must maintain compliance as required in this subdivision. 3. Citation: Minnesota Statutes, section 245D.04, subdivision 1. Violation: For two persons whose records were reviewed (P2 and P3), the license holder did not provide a written notice of service recipient rights as required. The license holder did not provide P2 and P3 with a written notice of service recipient rights and an explanation of those rights that included the right to access personal possessions at any time, including financial resources. Corrective Action Ordered: Within 30 days of receiving this order, you must provide P2 and P3 with a written notice of service recipient rights and an explanation of those rights that includes the right to access personal possessions at any time, including financial resources. Documentation of P2 and P3 receiving the written notice and explanation of the rights must be maintained in the service recipient record. On an ongoing basis, you must maintain compliance as required in this subdivision. 4. Citation: Minnesota Statutes, section 245D.05, subdivision 1. Violation: For one person whose record was reviewed (P5), the license holder did not document how health needs would be met as required. The license holder was assigned responsibility for meeting P5’s health needs in the support plan and support plan addendum. The license holder did not maintain documentation on how P5’s health needs would be met, including a description of the procedures the license holder would follow in order to use medical equipment, devices, or adaptive aides or technology safely and correctly according to written instructions from a licensed health professional. Corrective Action Ordered: Within 30 days of receiving this order, you must: · update P5’s support plan addendum to include a description of the procedures you will follow in order to meet P5’s health needs; and · provide training to all staff that works with P5 on the updated support plan addendum and maintain documentation of this training in the personnel record including the date the training is provided, the number of hours per subject area, and the name of the trainer or instructor. On an ongoing basis, you must maintain compliance as required in this subdivision. 5. Citation: Minnesota Statutes, section 245D.05, subdivision 1a. Violation: For one person whose record was reviewed (P3), the license holder did not ensure medication set up was completed as required. The license holder was responsible for medication set up for P3. The license holder did not document the following in the medication administration record (MAR) for P3: · the dates of set up; · the name of medication; · quantity of dose; · times to be administered; · route of administration at time of setup; and · when the person will be away from home, to whom the medications were given. Corrective Action Ordered: On an ongoing basis, you must maintain compliance as required in this subdivision. 6. Citation: Minnesota Statutes, section 245D.051, subdivision 1. Violation: For one person whose record was reviewed (P1), the license holder did not maintain documentation related to psychotropic medication administration as required. “Target symptom” refers to any perceptible diagnostic criteria for a person’s diagnosed mental disorder, as defined by the Diagnostic and Statistical Manual of Mental Disorders Fourth Edition Text Revision (DSM-IV-TR) or successive editions that have been identified for alleviation. The license holder was assigned the responsibility of medication administration for P1 including psychotropic medications. The license holder did not maintain a description of the target symptoms each psychotropic medication was to alleviate for P1. Corrective Action Ordered: Within 30 days of receiving this order, you must review and revise P1’s support plan addendum to document a description of the target symptoms P1’s psychotropic medications are to alleviate. You must provide all staff that work with P1 training on the updated information and maintain documentation of this training in the personnel record, including the date the training is completed, the number of hours per subject area, and the name of the trainer or instructor. On an ongoing basis, you must maintain compliance as required in this subdivision. 7. Citation: Minnesota Statutes, section 245D.07, subdivision 3. Violation: For two persons whose records were reviewed (P1 and P4), the license holder did not provide written reports as required. a. The license holder documented in P1’s support plan addendum that they would provide quarterly progress reports to P1’s support team. The license holder did not provide P1’s support team with quarterly progress reports as assigned. Progress reports were provided January 2024, December 2024, and July 2025. b. The license holder documented in P4’s support plan addendum that they would provide semi-annual progress review reports to P4’s support team. The license holder did not provide semi-annual progress reports as assigned. Corrective Action Ordered: Within 30 days of receiving this order, you must provide written reports for P4 as assigned in P4’s support plan addendum. On an ongoing basis, you must maintain compliance as required in this subdivision. 8. Citation: Minnesota Statutes, section 245D.071, subdivision 3, paragraph (b). Violation: For two persons whose records were reviewed (P1 and P5), the license holder did not conduct assessments as required. a. The license holder did not conduct assessments of P1 that produced information and described P1’s overall strengths, functional skills and abilities, and behaviors or symptoms. b. The license holder did not conduct an assessment of P5 before providing 45 days of service in the following areas: · P5’s ability to self-manage health and medical needs to maintain or improve physical, mental, and emotional well-being, including, when applicable, allergies, seizures, choking, special dietary needs, chronic medical conditions, self-administration of medication or treatment orders, preventative screening, and medical and dental appointments; · P5’s ability to self-manage personal safety to avoid injury or accident in the service setting, including, when applicable, risk of falling, mobility, regulating water temperature, community survival skills, water safety skills, and sensory disabilities; and · P5’s ability to self-manage symptoms or behavior that may otherwise result in an incident as defined in section 245D.02, subdivision 11, clauses (4) to (7), suspension or termination of services by the license holder, or other symptoms or behaviors that may jeopardize the health and welfare of P5 or others. Corrective Action Ordered: Within 30 days of receiving this order, you must: · update P1’s assessment to include information about P1 that describes P1’s overall strengths, functional skills and abilities, and behaviors or symptoms; · review the updated assessment with P1 and P1’s case manager; · conduct an assessment of P5 that describe P5’s overall strengths, functional skills and abilities, and behaviors or symptoms; · review the results of the assessments with P5, P5’s legal representative, and P5’s case manager; and · provide training to all staff that work with P1 and P5 on the updated assessments and maintain documentation of this training in the personnel record including the date the training is completed, the number of hours per subject area, and the name of the trainer or instructor. On an ongoing basis, you must maintain compliance as required in this subdivision. 9. Citation: Minnesota Statutes, section 245D.071, subdivision 3, paragraph (c) and (d). Violation: For three persons whose records were reviewed (P1, P3, and P5), the license holder did not complete initial intensive service planning as required. a. The license holder did not determine the following information at the initial planning meeting with P1, P1’s case manager, and other members of the support team: · P1’s desired outcomes and the supports necessary to accomplish P1’s desired outcomes; · P1’s preferences for how services and supports are provided, including how the provider would support P1 to have control of P1’s schedule; · opportunities to develop and maintain essential and life-enriching skills, abilities, strengths, interests, and preferences; · opportunities for community access, participation, and inclusion in preferred community activities; · opportunities to develop and strengthen personal relationships with other persons of P1’s choice in the community; and · how technology might be used to meet P1’s desired outcomes. The license holder initiated services for P1 on February 2, 2023, and held an initial planning meeting with P1 on March 16, 2023. The above information was not determined until a service plan review meeting held in January 2024. b. The license holder did not hold an initial planning meeting with P3, P3’s case manager, and other members of the support team or expanded support team within 60 days of service initiation. The license holder initiated services for P3 on November 14, 2021. An initial planning meeting was held with P3 and P3’s case manager on January 25, 2022. c. The license did not hold an initial planning meeting with P5, P5’s legal representative, and P5’s case manager within 45 days of service initiation to determine the following: · the scope of the services to be provided to support P5’s daily needs and activities; · P5’s desired outcomes and the supports necessary to accomplish the desired outcomes; · P5’s preferences for how services and supports are provided, including how the provider will support P5 to have control of their own schedule; · whether the current service setting is the most integrated setting available and appropriate for P5; · opportunities to develop and maintain essential and life enriching skills, abilities, strengths, interests, and preferences; · opportunities for community access, participation, and inclusion in preferred community activities; · opportunities to develop and strengthen personal relationships with other persons of P5’s choice in the community; · opportunities to seek competitive employment and work at competitively paying jobs in the community; · how services must be coordinated across other providers licensed under this chapter serving P5; and · how technology might be used to meet P5’s desired outcomes The license holder initiated services for P5 on October 17, 2025. At the time of the review, the license holder had not held this meeting. Corrective Action Ordered: Within 30 days of receiving this order, you must: · hold a meeting with P5, P5’s legal representative and P5’s case manager to determine the items outlined above in (c); · document the discussions held with P5, P5’s legal representative and P5’s case manager in the support plan addendum; · send the support plan addendum to P5, P5’s legal representative and P5’s case manager for review and obtain dated signatures documenting approval; and · provide training to all staff on the updated support plan addendum and maintain documentation of this training in the personnel file including the date the training is completed, the number of hours per subject area, and the name of the trainer or instructor. On an ongoing basis, you must maintain compliance as required in this subdivision. 10. Citation: Minnesota Statutes, section 245D.071, subdivision 4. Violation: For two persons whose records were reviewed (P1 and P3), the license holder did not develop service outcomes and supports as required. a. The license holder did not develop a service plan that documented service outcomes and supports within ten working days of the initial planning meeting. The license holder held an initial planning meeting on March 16, 2023. The service outcomes and supports were developed and documented in January 2024. b. The license holder did not develop and document the supports and methods to be implemented to support P3 and accomplish outcomes related to acquiring, retaining, or improving skills and physical, mental, and emotional health and well-being including: · the methods or actions that would be used to support P3 and to accomplish service outcomes, including information about: o any changes or modifications to the physical and social environments necessary when the service supports are provided; o any equipment and materials required; and o techniques that were consistent with P3’s communication mode and learning style; and · the names of the staff persons or position responsible for implementing the supports and methods. Corrective Action Ordered: Within 30 days of receiving this order, you must: · develop and document the supports and methods listed above for P3; · submit the updated supports and methods to P3 and P3’s case manager for review and obtain dated signatures documenting approval of the changes; and · provide training to all staff on the updated supports and methods and maintain documentation of this training in the personnel file including the date the training is completed, the number of hours per subject area, and the name of the instructor or trainer. On an ongoing basis, you must maintain compliance as required in this subdivision. 11. Citation: Minnesota Statutes, section 245D.071, subdivision 5. Violation: For four persons whose records were reviewed (P1, P2, P3, and P4), the license holder did not complete service plan review and evaluation as required. a. The license holder did not discuss with P1 during a service planning meeting in 2024 how technology might be used to meet P1’s desired outcomes. b. The license holder did not discuss with P2, P3, and P4 during a service plan review meeting in 2023 and 2024 how technology might be used to meet P2’s, P3’s, and P4’s desired outcomes. Corrective Action Ordered: Within 30 days of receiving this order, you must: · meet with P1, P2, P3, P4, P2’s legal representative, P4’s legal representative, P1’s case manager, P2’s case manager, P3’s case manager, and P4’s case manager to discuss how technology might be used to meet P1’s, P2’s, P3’s and P4’s desired outcomes; · document in the support plan addendum a summary of the discussion including a statement of any decision made related to the use of technology and any further research that must be completed before a decision regarding the use of technology can be made; and · send the updated support plan addendum to P1, P2, P3, P4, P2’s legal representative, P4’s legal representative, P1’s case manager, P2’s case manager, P3’s case manager, and P4’s case manager for review and to obtain dated signatures to document approval of the changes made. On an ongoing basis, you must maintain compliance as required in this subdivision. 12. Citation: Minnesota Statutes, section 245D.10, subdivision 4. Violation: For three persons whose records were reviewed (P1, P3, and P5), the license holder did not make policies and procedures available as required. a. The license holder did not inform and provide copies of the service suspension and termination policy and procedure to P1, P3, and P5 within five working days of service initiation. b. The license holder did not inform and provide a copy of the data privacy requirements to P1 within five working days of service initiation. The license holder initiated services for P1 on February 2, 2023. P1 received a copy of the data privacy requirements on March 16, 2023. c. The license holder did not inform and provide copies of the policies and procedures affecting P1’s and P5’s rights to P1’s and P5’s case managers within five working days of service initiation, including: · grievance policy and procedure; · service suspension and termination policy and procedure; · emergency use of manual restraints policy and procedure; and · data privacy requirements. d. The license holder did not inform and provide copies of the policies and procedures affecting P3’s rights to P3’s case manager within five working days of service initiation including: · grievance policy and procedure; · service suspension and termination policy and procedure; and · data privacy requirements. Corrective Action Ordered: Within 30 days of receiving this order, you must: · provide P1, P3, and P5 with your service suspension and termination policy and procedure; · provide P1’s, P3’s, and P5’s case managers with the policies outlined above in (b) and (c); · conduct an audit of all persons served records to identify service recipients that have not been informed of and received copies of the service suspension and termination policy and procedure; · conduct an audit of all persons served records to identify case managers of service recipients that have not been informed of and received copies of the policies and procedures affecting a person’s rights; · inform and provide copies of policies and procedures affecting a person’s rights to all service recipients and case managers identified in the audit and maintain documentation of these policies being provided to the case managers and person served in the service recipient record; and · maintain documentation of the audit, the results and the corrective action in your records. On an ongoing basis, you must maintain compliance as required in this subdivision. 13. Citation: Minnesota Rules, part 9544.0030, subpart 1. Violation: For three persons whose records were reviewed (P3, P4, and P5), the license holder did not incorporate in writing and evaluate positive support strategies as required. a. The license holder did not evaluate with P3 and P4 at least every six months, the positive support strategies to be used when providing services to P3 and P4. b. The license holder did not incorporate in writing to an existing treatment, service, or other individual plan, the positive support strategies to be used when providing services to P5. Corrective Action Ordered: Within 30 days of receiving this order, you must: · review with P3 and P4 the positive support strategies be used when providing services to P4 and if needed, make necessary changes to the positive support strategies; · develop with P5 and incorporate in writing to the individual plan for P5 the positive support strategies to be used when providing services to P5; and · provide training to all staff that work with P5 on the positive support strategies and maintain documentation of this training in the personnel record including the date the training is completed, the number of hours per subject area, and the name of the trainer or instructor. On an ongoing basis, you must maintain compliance as required in this subdivision. 14. Citation: Minnesota Statutes, section 245D.09, subdivision 5. Minnesota Statutes, section 245A.02, subdivision 2b defines “annual” or “annually” to mean prior to or within the same month of the subsequent calendar year. Violation: For three of fifteen staff persons whose records were reviewed (SP1, SP2, and SP3), the license holder did not provide annual training as required. a. The license holder did not provide SP1 with annual training in the following areas: · data privacy requirements according to sections 13.01 to 13.10 and 13.46, the federal Health Insurance Portability and Accountability Act of 1996 (HIPAA), and staff responsibilities related to complying with data privacy practices. SP1 completed this training in November 2022 and February 2024; · the service recipient rights, and staff responsibilities related to ensuring the exercise and protection of those rights according to the requirements in section 245D.04. SP1 completed this training in November 2022 and June 2024; · sections 245A.65, 245A.66, and 626.557 and chapter 260 E governing maltreatment reporting and service planning for children and vulnerable adults, and staff responsibilities related to protecting persons from maltreatment and reporting maltreatment. SP1 completed this training in February 2022, November 2023, and December 2024; · the principles of person centered-centered service planning and delivery as identified in section 245D.07, subdivision 1a, and how they apply to direct support service provided by the staff person. SP1 completed this training in February 2021 and November 2023; · the safe and correct use of manual restraint on an emergency basis according to the requirements in section 245D.061 or successor provisions, and what constitutes the use of restraints, time out, and seclusion, including chemical restraint. SP1 completed this training in November 2022 and June 2024; and · staff responsibilities related to prohibited procedures under section 245D.06, subdivision 5, or successor provisions, why such procedures are not effective for reducing or eliminating symptoms or undesired behavior, and why such procedures are not safe. SP1 completed this training in November 2022 and June 2024. b. The license holder did not provide SP2 with annual training in the following areas: · data privacy requirements according to sections 13.01 to 13.10 and 13.46, the federal Health Insurance Portability and Accountability Act of 1996 (HIPAA), and staff responsibilities related to complying with data privacy practices. SP2 completed this training in August 2023 and September 2024; · the service recipient rights, and staff responsibilities related to ensuring the exercise and protection of those right according to the requirements in section 245D.04. SP2 completed this training in August 2023 and September 2024; · sections 245A.65, 245A.66, and 626.557, and chapter 260E governing maltreatment reporting and service planning for children and vulnerable adults, and staff responsibilities related to protecting persons from maltreatment and reporting maltreatment. SP2 completed this training in August 2023 and September 2024; · the principles of person-centered service planning and delivery as identified in section 245D.07, subdivision 1a, and how they apply to direct support service provided by the staff person. SP2 did not receive this training in 2022. SP2 completed this training in August 2023 and September 2024; · the safe and correct use of manual restraint on an emergency basis according to the requirements in section 245D.061 or successor provisions, and what constitutes the use of restraints, time out, and seclusion, including chemical restraint. SP2 completed this training in August 2023 and September 2024; · staff responsibilities related to prohibited procedures under section 245D.06, subdivision 5, or successor provisions, why such procedures are not effective for reducing or eliminating symptoms or undesired behavior, and why such procedures are not safe. SP2 completed this training in August 2023 and September 2024; and · strategies to minimize the risk of sexual violence, including concepts of healthy relationships, consent, and bodily autonomy of people with disabilities. SP2 completed this training in August 2023 and September 2024. Corrective Action Ordered: On an ongoing basis, you must maintain compliance as required in this subdivision. 15. Citation: Minnesota Statutes, section 245D.095, subdivision 5. Violation: For three staff persons whose records were reviewed (SP1, SP4, and SP5), the license holder did not maintain a personnel record as required. The license holder did not maintain a personnel record for SP1, SP4 and SP5 that included documentation or training including the date the training was completed, the number of hours per subject area, and the name of the trainer or instructor. Corrective Action Ordered: On an ongoing basis, you must maintain compliance as required in this subdivision. If you fail to correct the violations specified in the Correction Order within the prescribed time lines the Commissioner may issue an Order of Conditional License or may impose a fine and order other licensing sanctions pursuant to Minnesota Statutes, sections 245A.06 and 245A.07. B. Right to Request Reconsideration If you believe any of the citations are in error, you have the right to request that the Commissioner of Human Services reconsider the parts of the Correction Order that you believe to be in error. The request for reconsideration must be in writing and received by the Commissioner within 20 calendar days after receipt of this report. Your request for reconsideration must be sent to: Commissioner, Department of Human Services ATTN: Legal Unit Licensing Division PO Box 64242 St. Paul, MN 55164-0242 Please note that a request for reconsideration does not stay any provisions or requirements of the Correction Order. The Commissioner’s disposition of a request for reconsideration is final and not subject to appeal under Minnesota Statutes, chapter 14. If you have any questions regarding this Correction Order, please contact me as soon as possible. Erin White, Home and Community Based Services Licensor Licensing Division Office of Inspector General 651-431-4821
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