David Gletty: Undercover Investigative report for Assisted Living Facilities (ALF's)


Assisted Living Facilities (ALF’s)

Unlicensed Adult Family Care Homes (AFCH’s)

Source of Information and Facts: Undercover Investigator David Gletty and Associates.

Introduction:

This Investigative Report concerns the Adult Family/Care Homes (AFCH’s) division of Assisted Living Facilities (ALF’s). Specifically the unlicensed AFCH’s conducting business without suffering consequences of breaking the law.

This is a problem that has been forming for years and there are multiple major issues coming up from lack of addressing the issue in the past. Because of lack of enforcement over the years on unlicensed Adult Family/Care Homes (AFCH’s) there are many more operating now than just 6 years ago. I will be very honest about the issue and state that most of the unlicensed AFCH’s that my associates and I have investigated, in an undercover capacity, were very caring, clean and the residents that received care were happy and comfortable. The only problem was that they were unlicensed, staff did not meet training/safety standards requirements, staff/members of household have not had a background check and the homes are not up to local building codes/safety requirements.

With the rising numbers of elderly persons needing private care and more unlicensed AFCH’s operating in local neighborhoods it is only a matter of time when a string of foreseen critical issues will hit the state of Florida like a storm not seen before.

This is a very sensitive issue because it would be cruel and harsh punishment for the care residents of an unlicensed AFCH to go through an immediate closure of the facility they are living in and be relocated to an Emergency Care Home. In Part 5 of this report you will read about a common sense solution to this problem.

This report from an Undercover Investigator’s perspective is comprised of 6 parts:

1.      Part 1: Page 2:  Terms and Abbreviations.

2.      Part 2: Page 2: Exposing the truth about how these unlicensed AFCH’s conduct business in plain sight.

3.      Part 3:  Page 6: Explanation of how this issue has been able to get out of control.

4.      Part 4: Page 9: The major problems that will arise because of enforcement.

5.      Part 5: Page 9: Solutions that will not overwhelm licensed facilities and homes.

6.      Part 6: Page 13: Media interviews and what senators have stated.

Part 1: Terms and Abbreviations:

1.      Adult Family Care Home: AFCH

2.      Agency for Health Care Administration: AHCA

3.      AHCA Compliance Program: ACP

4.      Assisted Daily Living: ADL

5.      Assisted Living Facility: ALF

6.      Assisted Living Unit: ALU

7.      Care Residents: Residents receiving care in a home or facility

8.      Department of Children and Families: DCF

9.      Emergency Medical Services: EMS

10.  Emergency Care Home: ECH

11.  Health Quality Assurance: HQA (the enforcement division of AHCA)

12.  Housing and Urban Development: HUD

13.  Independent Special Investigator: ISI

Part 2: Exposing the truth about how these unlicensed AFCH’s conduct business in plain sight.

What the law is as stated on the AHCA and Dept. of Elder Affairs Websites:

Adult Family Care Home (AFCH) LICENSE REQUIREMENTS Top 5 Points:

1.      In the State of Florida, all adult family care homes (AFCHs) must obtain and maintain an AFCH license from the Agency for Health Care Administration (AHCA) Assisted Living Unit (ALU).

2.      For the purposes of licensing, an "adult family care home" means a full-time, family-type living arrangement, in a private home, under which a person who owns or rents the home provides room, board, and personal care, on a 24-hour basis, for no more than five (5) disabled adults or frail elders who are not relatives.

3.      It is unlawful to own, operate, or maintain an AFCH without obtaining/maintaining a current AFCH license. Any person who owns, operates, or maintains an unlicensed AFCH commits a felony of the third degree. AFCH licenses are required to be posted in a common area.

4.      Unless the adult family care home is a community residential home subject to chapter 419, the applicant must provide documentation, signed by the appropriate governmental official, that the home has met local zoning requirements for the location for which the license is sought.

5.      Although the maximum number of residents is limited to five (5) disabled adults or frail elders who are not relatives of the provider, the actual licensed capacity of each adult family care home shall be based on the service needs of the residents and the capability of the provider to meet the needs of the residents. Adult relatives of the provider who require personal care and supervision and reside in the home for more than 30 days shall be considered residents only for the purposes of determining capacity.

AFCH LICENSE EXEMPTIONS

Pursuant to Chapter 429.65, F.S., certain entities may be exempt from AFCH licensure:
  • An arrangement whereby the person who owns or rents the home provides room, board, and personal services for not more than two adults who do not receive optional state supplementation under s. 409.212. The person who provides the housing, meals, and personal care must own or rent the home and reside therein.
  • An arrangement whereby the person who owns or rents the home provides room, board, and personal services only to his or her relatives.
  • An establishment that is licensed as an assisted living facility under Chapter 429, Part I, F.S.

Example and Violations of one unlicensed Adult Family Care Home (AFCH) that was infiltrated by Investigator David Gletty and Associates:

The unlicensed AFCH that we are using as an example is located in central Florida and currently active as of 1/10/14. It is operated by a man that has 8 family members living in the home and 4 residents receiving care. Each care resident pays $3000 a month which means the unlicensed AFCH has a monthly income of $12,000 for services offered as an AFCH. The operator of the unlicensed AFCH stated that he had room for 2 more care residents and was currently making room available for additional beds.

In the last 2 years Emergency Services has responded to the home for a slip and fall broken arm, slip and fall broken hip, run-a-way care resident, death in home and another death in home. All incidents have been recorded in county records and records show that there were follow up visits from Sheriff, DCF and AHCA officials.

By conducting follow up inspections at an unlicensed AFCH’s and knowing that it is unlicensed is for all intents and purposes regulation of unlicensed AFCH’s. There were complaints made against the home and AHCA responded to the home and conducted an unannounced inspection, they issued a response/findings letter, please see below.

A doctor that lives next door to the home in question owns the home in question and is aware that it is operating as an unlicensed AFCH and aware of the monthly income paid to the AFCH in question. The doctor/owner of home in question also operates/owns 2 pain management clinics in central Florida.

The home in question is categorized by the state of Florida as an Adult Family/Care Home. Chapter 429 of the FL. state statutes sections 429.60 thru 429.87. The home is not exempt in any form because there are 4 adults in 24 hour care living in the home, the home is exempt if there are only 2 persons in care living in the home. Because the home is unlicensed they are committing many 3rd degree felony violations.

Below are some of the violations witnessed by Investigator David Gletty and Associates concerning the example unlicensed AFCH:

1.      The requirements of part II of chapter 408 apply to the provision of services that require licensure pursuant to this part and part II of chapter 408 and to entities licensed by or applying for such licensure from the Agency for Health Care Administration pursuant to this part. A license issued by the agency is required in order to operate an adult family-care home in this state.

2.      In accordance with s. 408.805, an applicant or licensee shall pay a fee for each license application submitted under this part, part II of chapter 408, and applicable rules. The amount of the fee shall be $200 per biennium.

3.      The agency shall require level 2 background screening for personnel as required in s. 408.809(1)(e), including the adult family-care home provider, the designated relief person, and all adult household members, pursuant to chapter 435 and s. 408.809. This is a major violation…

4.      Unless the adult family-care home is a community residential home subject to chapter 419, the applicant must provide documentation, signed by the appropriate governmental official, that the home has met local zoning requirements for the location for which the license is sought.

5.      The licensed maximum capacity of each adult family-care home is based on the service needs of the residents and the capability of the provider to meet the needs of the residents. Any relative who lives in the adult family-care home and who is a disabled adult or frail elder must be included in that limitation.

Also:

1.      They do not meet the standards, training and rules requirements.

2.      This applies to the owner of the home in question, concerns the doctor that owns the home and lives next door with full knowledge that the home in question is an unlicensed AFCH.

A.      Sec. 429.08 pt. 2 subsection a. Any health care practitioner, as defined in s. 456.001, who is aware of the operation of an unlicensed facility shall report that facility to the agency. Failure to report a facility that the practitioner knows or has reasonable cause to suspect is unlicensed shall be reported to the practitioner’s licensing board.

3.      While at the home we also witnessed the caretaker give Assisted Daily Living (ADL) services which included bathing, handling of medications, changing of diapers, food preparation, picking up/moving care residents, dressing and undressing and other ADL’s.

4.      Possible patient/resident brokering. An illegal activity as specified in Florida law.

5.      Status of example home investigation is active and we are ready to put an Undercover Elderly Investigator (UEI) into the home.

6.      This same example could be used for every unlicensed AFCH that has been infiltrated by Undercover Investigator David Gletty and associates.

Complaint response letter from AHCA (Orlando, FL Office) concerning AFCH example home:

October 25, 2013 Confidential CCR#2013010184

Mr. Sam XXXXXXX

XXXX Wekiva Springs Rd.

Longwood FL 32779

Dear Mr. XXXXXXX:

Representative(s) from the Agency for Health Care Administration (AHCA) conducted an unannounced visit at 1200 XXXXX Lane Longwood FL. ALF on October 3, 2013. While at the facility, our staff thoroughly reviewed your concerns, the representative(s) observed care, interviewed resident(s), and staff, as well as completed medical chart reviews.

Although at the time of the inspection, the representative(s) did not find the facility was violating any laws or rules, your complaint information is important in helping us ensure facility compliance. This correspondence will remain as a permanent part of our complaint system and we will continue to monitor these concerns or issues during future visits.

Thank you for bringing your concerns to our attention. Inspection results will be available in 45 days at our website.

Sincerely

Lorraine Henry signing for Theresa DeCanio, RN Field Office Manager

Note: The above letter is opposite of the facts. If you search the AHCA website the AFCH in question will not show up as a licensed AFCH and then everything from there on is a violation of the law and AHCA knew the home was unlicensed before they visited the home on the listed date above.

As of 1/10/14 the example unlicensed AFCH is not licensed with AHCA, according to their own records.

Part 3: How this issue has been able to get out of control.

Regulation and Law Enforcement of Adult Family Care Homes (AFCH’s):

The Laws are in place and the websites are full of all the information that is needed to inform the general public about the laws and regulations in the state of Florida concerning ALF’s and AFCH’s. The major problem is that there is not enough enforcement of the law and there is a lack of effort to locate the unlicensed AFCH’s and have them comply with the law and/or prosecute them. Below is information that will explain some of the non-enforcement issues and how the problem of unlicensed AFCH’s has grown to the size that it is now.

Agencies that have documented contact with unlicensed AFCH’s:

A.     Agency for Health Care Administration (AHCA):

1.      AHCA issues all licenses concerning ALF’s and the Health Quality Assurance (HQA) division of AHCA is given the task of regulating and enforcing the law and codes. This division is clearly overwhelmed by the 42,000 entities that they regulate in the state of Florida. The problem has piled up for years and now has come to a breaking point.

2.      When AHCA representatives respond to an AFCH they already know whether the AFCH is licensed or not and the AHCA representative has the ability to enforce the law at that moment concerning unlicensed AFCH’s. Most of the time they do not enforce the law because they are simply only looking for any type of dangerous or unsafe situation that is present that may put the care residents at risk.

3.      AHCA is not looking for what they consider small violations like not being licensed which could also be misunderstood as too many care residents in the home than the law permits under the exemption statutes.

4.      Simply put, AHCA does not enforce the laws that are in place to regulate the industry. This responsibility does not fall on any other agency other than AHCA.

B.      EMS/Fire/Rescue: This agency shows up at the AFCH and they are only there to give assistance in the case of a medical emergency, fire, rescue and etc. They are not concerned about any other issues other than the emergency at hand. Some of the emergencies are common among elderly care facilities and include slip and falls, chest pains, burns, confusion, bodily injury and etc. This agency visits unlicensed AFCH’s in an emergency situation, without knowing they are unlicensed, gives treatment and makes a report of every visit and then notifies Law Enforcement if needed. Some of the unlicensed AFCH’s that we are looking for have their addresses in the records of EMS/Fire/Rescue.

C.      Local Law Enforcement: Law Enforcement shows up at the address of some of these unlicensed AFCH’s when a citizen request them or EMS/Fire/Rescue request them, sometimes care patients leave the AFCH without notice and become missing, a death (common), questionable circumstances, domestic violence and etc.

If there are any laws being broken that law enforcement believes requires an immediate arrest then law enforcement will arrest those that they suspect of committing violations. If law enforcement does not arrest anyone, but believes there is some type of problem with the AFCH then they will have Detectives conduct a follow up visit or notify AHCA and/or DCF of the concerns law enforcement has. Some of the unlicensed AFCH’s that we are looking for have their addresses in the records of Law Enforcement.

D.     Dept. of Children and Families: DCF will show up at the address of the unlicensed AFCH, w/o knowing they are unlicensed, and conduct a quick well being inspection if there was a request by law enforcement, EMT/Fire/Rescue, complaint and etc. DCF will usually pass it on to AHCA if they feel that is necessary and DCF will contact law enforcement if they feel that a crime that has occurred needs an immediate arrest or response and investigation. Some of the unlicensed AFCH’s that we are looking for have their addresses in the records of DCF.

E.      Building Safety/Code Enforcement: This agency will respond to the address of an AFCH, w/o knowing they are unlicensed, if there is a complaint, lawn is not kept up, building has hazardous conditions, large quantity of junk or garbage present, new construction, major repairs and etc. This agency really has no power to regulate the building of an AFCH unless requested by another agency or public complaint and even then they have no part of regulating unlicensed AFCH’s.

Note: Investigator David Gletty and Associates have seen EMS, Law Enforcement and AHCA records that indicate they have visited unlicensed AFCH’s, sometimes w/o knowing of license status.

Why use an unlicensed AFCH:

A.     The low monthly fee fits a family’s budget better than a licensed more expensive AFCH.

B.      Family has no insurance or government assistance, but can afford private care.

C.      The Estate of family member needing care is involved and is taking care of the financial needs of the family member and does not want any type of financial statement to be open to the public via state/county records.

D.     Some clients do not want any record or trace of payment and care concerning their elderly care resident.

Even if you are illegal, once the government regulates you then you are legal:

1.      From what Investigator David Gletty and associates have seen it is an easy conclusion that AHCA is/has been regulating unlicensed AFCH’s.

2.      Who approved AHCA to spend money regulating known unlicensed facilities with no actions being taken against said AFCH’s for not complying with the law?

Part 4: Major problem’s that would start if major enforcement of the law started:

1.      If the state did not have any solutions and plans in place before unlicensed AFCH’s were targeted and shutdown in large numbers it would start a problem in Florida like never seen before.

2.      Homes shutdown would mean that the state would have to take control of the care facility residents and find them a state bed or a home that is associated with the state because the family of the care facility resident cannot or will not take care of the care facility resident.

3.      There would be great stress and emotional problems added to the problems that the care facility residents already endure.

4.      Could you imagine the numbers of care facility residents that would flood the state system if unlicensed ALF’s were suddenly shut down because they have no license or minor/major violations were found, does not meet code enforcement standards and etc. Here is a quick number from the AHCA website, there are only 18 licensed AFCH’s and 88 licensed ALF’s in the Orlando, FL. area. As you know Florida has one of the highest elderly retiree populations in the U.S.

5.      Most of the licensed ALF’s and AFCH’s are at 95% capacity.

6.      Where would the money come from in order for the state to take on the massive numbers of new care facility residents. Would there be a new tax, would other programs have to be cut back and etc.

Part 5: Solutions that will not overwhelm licensed facilities and homes.

1.      In the records of AHCA and Hospice are the addresses of some unlicensed AFCH’s. Hospice visits unlicensed AFCH’s and gives comfort to the ones that are terminally ill and of course Hospice cannot be expected to play the role of “enforcer” and report these unlicensed AFCH’s to authorities, only if there is a very unsafe situation for the care resident.

On the other hand AHCA visits these homes when there is an incident where emergency medical services or law enforcement is needed and then AHCA is notified by those authorities of the incident and AHCA will then send a representative to the home for an unannounced visit and make a report of the visit available to the public. AHCA does visit the unlicensed AFCH’s and within their records are the addresses of some unlicensed AFCH’s that they have visited lately via complaint or local authorities request.

Investigator David Gletty and Associates have also been able to locate unlicensed AFCH’s via craigslist, licensed ALF’s, caregivers and other sources. It is not hard if you know where to look.

Local Law Enforcement, DCF and Emergency Medical Services respond to unlicensed AFCH’s not knowing they are unlicensed and their addresses are in those records also.

2.      An Independent Special Investigator (ISI), with senate support, should work closely with Hospice, AHCA, Law Enforcement, EMS and DCF while going through all the recent records of visits to private homes that give care to residents. We will simply compare addresses of the ones on the Hospice home visit records, AHCA home visit records, Law Enforcement and DCF records with the AHCA database of licensed AFCH’s and we will know which are unlicensed. At that point we would determine which unlicensed homes that we have discovered, via home visit records, meet the criteria for an unlicensed AFCH that is operating as a licensed AFCH. We will then compile a list of each documented unlicensed AFCH in each area of the state.

3.      Once the Independent Special Investigator (ISI) and associates have established a preset number of recorded unlicensed AFCH’s we will then move to start advertising and letting the public know, via public service announcement, that any unlicensed AFCH’s have an opportunity to come forward now and enroll in a AFCH Compliance Program (ACP) within 60 days or suffer the full consequences of the law and immediate closure of the AFCH.

4.      At the same time #3 is taking place the ISI’s office will start making contact with the unlicensed AFCH’s on the list that has been compiled. Contact will be in the form of USPS mail, telephone, email and in person contact. Once the public service announcement has started to hit the public then the 60 day clock will start. It is important that the unlicensed AFCH’s get the message that law enforcement will be coming down on them hard if they do not comply with the offer that has been granted to them by the state.

5.      During the 60 day enrollment period the ISI and associates will be gathering the addresses and contact information for as many of these unlicensed AFCH’s as possible and making contact with the AFCH’s in violation of the law and getting them enrolled in the AHCA Compliance Program (ACP).

6.      Once the enrollment period has expired then the state must be ready to react with a steady and firm response while enforcing the law concerning the unlicensed AFCH’s. This is an action that is regulated by AFCH’s Health Quality Assurance (HQA) division, but HQA is obviously overwhelmed by the 42,000 entities that they regulate. Arrest will have to take place and relocation of care residents will happen, but we have a plan for a smooth transition while moving care residents from an AFCH that has been shutdown.

7.      There must be clear and descriptive laws in place that allow AHCA, DCF and Law Enforcement to act quickly and decisively while dealing with unlicensed AFCH’s.

8.      AHCA Compliance Program (ACP) is not offering unlicensed AFCH’s amnesty. The ACP is a program paid for by the violators and should not cost the tax payers any more money because the overseers of the program are already in place and the violators will be paying all the cost to get their unlicensed AFCH in compliance with the law.

How the ACP program works:

A.     A Provisional License is granted as soon as the unlicensed AFCH comes forward and signs intent to comply agreement along with enrollment into the ACP, payment of annual license fee and payment plan for any fines or additional fees.

B.       A representative of the ACP will visit each AFCH applicant and conduct a home assessment of what needs to be completed for the AFCH to move successfully out of the ACP.

C.      Each step and requirement to complete the ACP is as follows:

1.      Must complete the above requirements in A and B.

2.      Must pay monthly ACP fee, to be determined, and any fines.

3.      Each person living in the AFCH, not including care residents, must complete a level 2 background check. If anyone in the AFCH does not pass the background check then that person must leave home immediately or the home will not be allowed to operate. There can be a special circumstances meeting requested by the AFCH, this can be dealt with in an individual case by case assessment.

4.      All persons in the AFCH that give any type of Assisted Daily Living (ADL) services to the care residents must pass the required safety and training classes. There are many low cost classes/training and charitable organizations that will help those caregivers that cannot afford the full price of the required safety/training classes.

5.      The building that the AFCH operates in must be brought up to local safety/fire/zoning requirements. This is a major issue because many of the AFCH’s are old and do not have the same design layout, doors, lighting, home size, bathroom layout, plumbing, appliances and etc. There are so many variations when a private home is being used as a care facility.

It has to be dealt with in an individual manner and I believe that each home has to have all the major safety features in place including fire extinguishers, hand rails/ramps where needed, proper hygiene/access to, food service, emergency readiness, emergency exits and etc, but when it comes to the smaller building code requirements it has to be dealt with using common sense and individual assessment of each AFCH and what is absolutely necessary to provide a safe living condition for the care residents.

There are many HUD and other government programs available for those that need assistance with building requirements and meet the financial requirements. Some homes have too much income for assistance.

D.     Once an AFCH has completed all the requirements of the ACP then they will be added to the list of licensed AFCH’s and be regulated and regularly reviewed by AHCA.

E.      This is the way that the system was designed to work in the past, but it has gotten out of control and many policies have been neglected. It will take decisive and quick action to get back on track and weed out all the unlicensed AFCH’s that do not want to comply with the law.

 Part 6: Media interviews and what the senators stated:

Below is one of many media interviews that have been conducted concerning unlicensed ALF’s.

TALLAHASSEE (CBS Miami/NSF) — A Florida Senate panel Tuesday instructed the Agency for Health Care Administration to draft legislation — fast — that would allow the state to shut down unlicensed assisted-living facilities as quickly as possible.

“Tell them to hustle,” said Sen. Alan Hays, a Umatilla Republican and vice-chairman of the Senate Children, Families and Elder Affairs Committee. Hays was addressing AHCA Secretary Liz Dudek, who briefed senators as they consider a third attempt in three years at tightening oversight of Florida’s assisted-living facilities .But he seemed to be speaking for all the members of the committee.“Don’t treat them with kid gloves,” Hays urged Dudek. “Treat them with a hammer.”

Committee members were irate over reports that unlicensed assisted-living facilities, or ALFs, were failing to provide proper health care, background checks of staffers or basic safety and cleanliness — and that state regulators were missing or ignoring the transgressions.

“Last year, state health-care regulators received more than 200 complaints about unlicensed activity and confirmed that 62 were, indeed, unlicensed ALFs, including 15 in Miami-Dade and Broward,” The Miami Herald reported Sept. 9. “These numbers have risen more than 60 percent from 2010. By June this year, the Agency for Health Care Administration had identified another 37 unlicensed homes around the state.”

The panel’s discussion focused on why unlicensed facilities were flying under the state’s radar.

“You don’t know they’re there until somebody brings it to your attention,” Dudek said. She called SB 7000, the committee’s new ALF reform proposal, “really great” and said it provided her agency additional help with enforcement.

Lawmakers have been trying to pass ALF reforms since the Herald reported in 2011 that at least 70 residents of Florida’s 3,015 assisted-living facilities had died from abuse and neglect since 2002. The series prompted Gov. Rick Scott to form an ALF task force that year, but the House and Senate couldn’t agree on a 2012 bill based on the task force’s recommendations. And during the 2013 session, the Senate passed a reform measure 38-0, but it died in the House.

This year, Sen. Eleanor Sobel, the Hollywood Democrat who chairs the Children, Families and Elder Affairs Committee, is pushing the Senate’s latest reform effort. “There’s a message that needs to come out of Florida,” Sobel said. “We’re going to protect our seniors…It’s these unlicensed ones that give the good ones bad reputations. And it hurts our image in terms of being a place baby boomers are coming to, and we have to fix this problem.”

Working with prosecutors and law enforcement would help, she said. Asked whether the House would be the stumbling block again this year, Sobel said she’s almost ready to announce the bill’s House sponsor. She added that she’d met with most of the associations representing nursing homes and assisted living facilities, and that they support the current proposal. “You can’t please all the groups,” Sobel said. “We just need to get the members in the House to agree with us that this is the best bill for Florida.”

On Tuesday, the panel unanimously passed the measure, which would beef up fines and sanctions on ALFs, including doubling the fines for repeated serious violations. It would require the Office of Program Policy Analysis and Government Accountability to conduct a study of AHCA’s consistency in regulating the facilities. And it would specify who is responsible for assuring that mental health residents of ALFs receive necessary services.

Additionally, the bill would require AHCA to create a rating system for ALFs by November 2014. Peggy Rigsby, director of government services at the Florida Health Care Association, which represents nursing home providers, said her organization supports SB 7000 and the regulation it contains — but no more. “There are current regulations as well, that exist now, and there are regulations in this bill, and we support that,” Rigsby said. “We just don’t want to go and add even more above and beyond what’s in the proposal.” Rigsby said the unlicensed facilities were the biggest concern. She agreed with earlier suggestions by the committee that involving law enforcement and greater regulatory authority by AHCA would be effective in closing more unlicensed ALFs.

“The profession is looking for certainty,” said Bob Asztalos, chief lobbyist for the Florida Health Care Association. “Passing legislation so that everyone knows what the rules are going to be helps us provide better care to our residents. That’s why, this year, Florida Health Care is going to try very hard to pass this bill, putting some certainty out there and making sure that the bad actors can be cleaned up.”

“The News Service of Florida contributed to this report.”

End of Investigative Report:

This Investigative Report was written by Investigator David Gletty and is based on the information and intelligence that was gained by Investigator David Gletty and Associates while they conducted/are conducting an undercover investigation targeting unlicensed Adult Family Care Homes (AFCH’s) in Florida as of 1/10/14.

Thank you and please do not hesitate to contact Investigator David Gletty if there is anything else your office may need concerning this matter.

Investigative/Security Specialist

David Gletty

(407)625-7297