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December 2, 2024 Daniel Pfarr, Authorized Agent 180 Degrees 236 Clifton Avenue Minneapolis, MN 55403 License Number: 1074484 CORRECTION ORDER Dear Daniel Pfarr:  On September 17 through 19, 2024, Department of Human Services (DHS) licensors conducted a licensing review at 180 Degrees Inc, located at . This review was conducted to determine compliance with state and federal laws and rules governing the provision of children’s residential care under Minnesota Rules, parts 2960.0010 through 2960.0120, group residential services under Minnesota Rules, parts 2960.0130 through 2960.0220, transitional services under Minnesota Rules, part 2960.0500, shelter care services under Minnesota Rules, parts 2960.0510 through 2960.0530, and the Family First Preservation Services Act under Minnesota Statutes, section 245A.25. As a result, DHS is issuing this order which requires you to take the correction action as described under each violation. Details of our findings are provided below. Our next steps and your options are also detailed. LICENSING VIOLATIONS DHS determined that your program failed to follow licensing rules and statutes, as described below. Practices 1. Violation: The first aid kit was locked in a staff area and not accessible to youth without staff assistance. Rule Violated: Minnesota Rules, part 2960.0110, subpart 4. Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that the first aid kit is accessible. This violation was corrected onsite during the license review and no further corrective action is required. 2. Violation: The license holder’s review of the plan for transfer of clients and records did not meet requirements. There was no documentation to demonstrate a controlling individual reviewed and signed the plan for calendar year 2023. Statute Violated: Minnesota Statutes, section 245A.04, subdivision a, paragraph (a). Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure a controlling individual annually reviews and signs the plan of transfer of client and records upon closure. 3. Violation: The license holder’s review of the program abuse prevention plan (PAPP) did not meet requirements. There was no documentation to demonstrate the PAPP was reviewed annually, by February of 2024. Statute Violated: Minnesota Statutes, section 245A.65, subdivision 2, paragraph (a). Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure the review of the PAPP meets all applicable requirements. Personnel Files 4. Violation: Two of two personnel files reviewed for requirements governing ongoing training did not meet requirements (personnel files numbered 1 and 2). There was no documentation to demonstrate the emergency plan was reviewed at least once every six months. Rule Violated: Minnesota Rules, part 2960.0080, subpart 14. Repeat Violation: This is a repeat violation. The license holder was cited for a similar violation in a Correction Order dated May 21, 2021. Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure the ongoing and annual training meets all applicable requirements. Within 30 days receipt of this order, provide training and submit documentation for personnel files numbered 1 and 2 to demonstrate compliance. Resident Files 5. Violation: One of three resident files reviewed for requirements governing resident admission documentation did not meet requirements (resident file numbered 3). The resident file did not include a description of safety concerns, including assaultive behavior and victimization, and the resident’s assets and strengths. Rule Violated: Minnesota Rules, part 2960.0070, subpart 3, item B. Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that resident information meets all applicable requirements. 6. Violation: One resident file reviewed for requirements governing shelter admissions did not meet requirements (resident file numbered 2). The resident file did not include an assessment of the resident’s vulnerability to maltreatment. Rule Violated: Minnesota Rules, part 2960.0520, subpart 2, item A. Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that shelter admissions meet all applicable requirements. 7. Violation: One of three resident files reviewed for requirements governing admission procedures did not meet requirements in the following ways (resident file numbered 1). There was no documentation to demonstrate the resident received verbal and written communication about the facility’s rules and due process system; and there was no documentation to demonstrate that the resident received a written copy of the resident’s basic rights. Rule Violated: Minnesota Rules, parts 2960.0080, subpart 4, 2960.0050, subpart 3, item A. Repeat Violation: This is a repeat violation. The license holder was cited for a similar violation in a Correction Order dated May 21, 2021. Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that admission procedures meet all applicable requirements. 8. Violation: Two of three resident files reviewed for requirements governing admission screenings did not meet requirements in the following ways: a. The resident file did not include health, mental health, education, sexually abusive behavior, vulnerability, and gender-specific needs screenings (resident file numbered 3); and b. There was no documentation of inquiries or the results of inquiries regarding the degree to which the resident’s family desires to be involved during the resident’s stay at the facility. (resident file numbered 1). Rule Violated: Minnesota Rules, part 2960.0070, subpart 5, items A, B, C and D Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that admission screenings meet all applicable requirements. 9. Violation: Two of three resident files reviewed for requirements governing trauma informed care did not meet requirements in the following ways: a. The screening for trauma was completed late (resident file numbered 1); b. The resident file did not include a screening for trauma (resident file numbered 3); and c. There was no documentation to demonstrate that trauma-based interventions were available (resident file numbered 3). Statute Violated: Minnesota Statute, section 245A.25, subdivision 3, paragraph (c). Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that admission screenings meet all applicable requirements. 10. Violation: One resident file reviewed for requirements governing health care did not meet requirements in the following ways (resident file numbered 1): a. There was no record of illness reported by the resident, including action taken by the license holder and dates of care provided to the resident. b. There was no documentation from a prescriber with information about medication administration, targeted symptoms, side effects warranting consultation with physician. c. There was no documentation seeking parent or guardian permission to administer medication. d. There was no documentation of the initial quantity of medication received from the pharmacy. Rule Violated: Minnesota Rules, part 2960.0080, subpart 11, item B, D and E. Repeat Violation: This is a repeat violation. The license holder was cited for a similar violation in a Correction Order dated May 21, 2021. Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that health care services and documentation meet all applicable requirements. 11. Violation: One of two resident files reviewed for requirements governing discharge procedures did not meet requirements (resident file numbered 3). There was no signature upon discharge from the client when client’s personal property was returned. Rule Violated: Minnesota Rules, part 2960.0090, subpart 3. Repeat Violation: This is a repeat violation. The license holder was cited for a similar violation in a Correction Order dated May 21, 2021. Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that discharge procedures meet all applicable requirements. Written Response Required If you fail to correct the violation(s) 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. Submissions required as part of the corrective action ordered must be sent to your licensor by email at laura.huff1@state.mn.us or by mail: Commissioner, Department of Human Services ATTN: Laura Huff Licensing Division PO Box 64242 St. Paul, MN 55164-0242 YOUR RIGHT TO REQUEST RECONSIDERATION You have the right to request reconsideration of this order and the cited violations. Your request must: · Be in writing · List each violation you are challenging and identify what is inaccurate or incomplete about the information in the order · Supply information that is accurate or more complete · Be made before the deadlines provided below If you are mailing your request, it must be received by DHS within 20 calendar days from when you received this order. If you do not meet this deadline, you lose your right to request reconsideration. The timeline to appeal began when you received this order. Please send it to: Office of Inspector General Legal Counsel’s Office Attn: Licensing Legal Unit PO Box 64953 St. Paul, MN 55164-0953 If your request is being personally delivered, it must be received by DHS within 20 calendar days from when you received this order. Please bring it to: Commissioner, Department of Human Services Office of Inspector General, Legal Counsel’s Office - Licensing 444 Lafayette Road North St. Paul, MN 55155 Legal authority This action is taken under Minnesota Statutes, section 245A.06, subdivision 1. The timeline to request reconsideration of the order is provided in Minnesota Statutes, section 245A.06, subdivision 2. Questions If you have any further questions regarding this matter, you may contact me at 651-431-4234 or at laura.huff1@state.mn.us Sincerely, Laura Huff, Licensor Licensing Division Office of Inspector General
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