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On August 19th and 20th, 2013; observation revealed that the facility had the following deficiencies:

K-12 (building construction type and height),
K-17 (smoke-tight corridor walls),
K-18 (smoke-tight openings into corridors),
K-29 (hazardous areas),
K-38 (minimum force to open a door),
K-43 (locking of corridor doors),
K-56 (sprinkler system),
K-67 (heating and ventilation),
K-103 (interior walls non-combustible in a Type II building),
K-130 (miscellaneous items),
K-147 (electrical system).

Please refer to the full description of the deficient practice at the individual K-tags: These observations are not compliant with 42 CFR 485.623. These deficiencies were confirmed at the time of discovery by a concurrent observation and interview with staff 'C' and 'E'.

Based on tour and interview (G, I, U) in 3 of 3 nursing units tours, the facility failed to maintain an enviroment for the safety of patients and visitors. This deficiency potentially affects all Pts and visitors at this facility.

Findings include:

During at tour of the medical/surgical/ICU nursing unit on 8/20/2013 from 1:15 PM through 2:00 PM accompanied by Director of Medical/Surgical/ICU U, noted a room labeled "soiled utility room" unlocked. This room has access from both sides of the nursing station and both doors do not have locks. This room contains cleaning chemicals and biohazard materials. Director of Medical/Surgical/ICU U confirmed at time of discovery that this room contains biohazard materials and chemicals and is unlocked from both sides.

During a tour of the Maternal/Child Health Unit on 8/21/2013 from 10:30 AM through 12:00 PM accompanied by Director of Maternal/Child Health Unit G, noted a room labeled "soiled utility room" unlocked. This room contains cleaning chemicals and biohazard materials. Director of Maternal/Child Health Unit G confirmed at time of discovery that this room contains biohazard materials and chemicals and does not have a locking door.


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Per tour of the PACU on 8/20/13 at 8:30 AM with Dir I, rooms 9, 11, and 13 had dings and gouges in the walls making them unwashable. This finding was acknowledged by Dir I during the tour.

On August 19th and 20th, 2013; observation revealed that the facility had the following deficiencies:

K-12 (building construction type and height),
K-17 (smoke-tight corridor walls),
K-18 (smoke-tight openings into corridors),
K-29 (hazardous areas),
K-38 (minimum force to open a door),
K-43 (locking of corridor doors),
K-56 (sprinkler system),
K-67 (heating and ventilation),
K-103 (interior walls non-combustible in a Type II building),
K-130 (miscellaneous items),
K-147 (electrical system).

Please refer to the full description of the deficient practice at the individual K-tags: These observations are not compliant with 42 CFR 485.623. These deficiencies were confirmed at the time of discovery by a concurrent observation and interview with staff 'C' and 'E'.

Based on tour, observation, review of P & P and interviews with staff (S, H, I, U) in 1 of 4 observations of staff (P) the facility failed to use aseptic technique when preparing medications; in 4 of 4 patient care units the facility failed to ensure all medications and biologicals are secure and not available to unauthorized staff, patients and visitors; and dated or discarded after opening. This deficiency potentially affects all patients, staff and visitors at the facility.

Findings include:

Per review on 8/21/13 in the PM of facility policy titled Surveillance, Prevention & Control of Infection: Single Dose and Multidose Vials, dated 5/11 it states under II. Procedure B "All multiple-dose containers will be labeled with date open sticker..."

Per review on 8/21/13 in the PM of facility policy titled Medication Management-Storage: General, dated 5/11, it states under Medication Storage Areas it states "...All drugs and biologicals must be secure; controlled substances must be locked within a secure area. Generally, all drugs should be kept in a locked room or Pyxis cabinet. All drugs and biologicals must be stored in a manner to prevent access by non-authorized individuals. Persons without legal access to drugs and biologicals cannot have unmonitored access to drugs or biologicals." It also states under Nursing Medication Carts, Anesthesia Carts, and Other Medication Carts "When not in use, nursing medication carts, anesthesia carts, and other medication carts containing drugs or biologicals must be locked or stored in a locked storage room."

Per observation of CRNA P preparing medications for Pt #13's surgery on 8/20/13 at 8:45 AM, CRNA P used one alcohol wipe to clean three vials of medications, rather than one wipe for each, to prevent cross contamination.

Per tour of the off site clinic on 8/20/13 at 1:45 PM with VP S, in examination room 120, there was an open undated bottle of Gentian Violet and an open undated bottle Lumicain Topical Hemostatic Solution (to stop minor hemorrhage). There were packets of povidone iodine and chloraprep in an unsecured drawer, allowing unauthorized access by Pts and visitors. This was acknowledged by VP S during the tour, adding the items should be dated and secure.

Per tour of the Rehab department on 8/21/13 at 8:45 AM with Dir H, there was an open undated bottle of Gentian Violet (anti-infective), and open Plain Packing labeled "sterile" in the hydrotherapy room. The Occupational Therapist room(327) had an open undated bottle of massage oil. This was acknowledge by Dir H during the tour, adding the items should be dated and the packing should be discarded after opening.

Per tour on 8/20/12 at 7:30 AM with Dir I, the crash cart in PACU has a breakaway lock, is not in view at all times, and is accessible to unauthorized staff.


32670

During a tour of the nursing unit on 8/20/2013 from 1:15 PM through 2:00 PM accompanied by Director of Medical/Surgical/ICU U, noted a crash cart containing medications with breakaway locks in the hallway near the nurses station. When asked if the crash cart is in view at all times by staff at the nursing desk, Director of Medical/Surgical ICU U stated there are times when no one would be at the desk and in view of the cart.

Based on tour, observations (M, N, O, P, Q, W, K, L) P&P reviews, AORN standards of practice, and interviews with staff (G, D, J, K, I, S), 4 of 4 tours the facility failed to ensure there is a comprehensive infections control program to monitor, prevent and control potential infections. This deficiency potentially affects all Inpatients 23 treated at the facility during survey.

Findings include:

Per review on 8/21/13 in the PM of facility policy titled Intra Operative Skin Prep, dated 4/13, it states under Procedure 7. "If using Scrub & Paint prep tray: a. Open prep tray on prep table using sterile technique. b. Put on sterile gloves..."

Per review on 8/21/13 in the PM of facility policy titled Surgical Attire, dated 4/12, it stated under #2 "Cap or hood covering all possible head and facial hair..."

Per review on 8/21/13 in the PM of facility policy titled Cleaning Operating Room Before and After Cases, dated 2/13, it states under Environmental Services f) "Using cleaning cloths and metal basin with disinfectant solution wash in the fallowing order: 1. Extra equipment and return to storage areas. 2. All horizontal surfaces: a. 1st overhead lights and wipe with dry cloth. b. Tables. c. Equipment surfaces on boom. c.(sic) Surface and outside anesthesia cart and machine d. Back table, mayo stand, basin stand, linen hamper. e. Suction stand, kick bucket, garbage and step stools.."

Per AORN Perioperative Standards of Practice and Recommended Practices for Inpatient and Ambulatory Settings, 2013 Edition, it states under Recommended Practices for Cleaning and Care of Surgical Instruments and Powered Equipment Recommendation V.b. "All instruments opened in the operating or procedure room should be decontaminated whether or not they were used. All instruments opened during a surgical procedure are considered contaminated. Scrubbed persons may touch instruments without being aware of it. Used instruments also may come in contact with other instruments." Under Recommendation X.b.1. it states "Manual cleaning should be accomplished by submerging the instrument in warm water with an appropriate detergent followed by complete submersion of the instrument in rinse solution to minimize aerosolization of contaminants." Under Recommendation X.c.10 it states "Cleaning solution should be checked between cycles and changed is visibly soiled. The presence of gross soil in the water impedes the effectiveness of cavitation on the instruments. X.c.11. Ultrasonic cleaners should be emptied, cleaned, rinsed with sterile water, and the chamber wiped with alcohol or other disinfectant, as recommended by the equipment manufacturer, when visibly soiled and at least daily."

Under AORN's Asptic Practice, Recommended Practice for Sterile Technique states under Recommendation III.c. "The front of a sterile gown should be considered sterile from the chest to the level of the sterile field....III.c.2. The surgical gown back should be considered unsterile. The back of the gown cannot be constantly monitored...VII Sterile fields should be constantly monitored..." and under VIII.d. "When changing position with each other, scrubbed tam members should turn back to back or face to face while maintaining distance from each other, the sterile field, and unsterile areas."

Example in Maternal/Child Health Unit:

During a tour of the Maternal/Child Health Unit on 8/21/2013 from 10:30 AM through 12:00 PM accompanied by Director of Maternal/Child Health Unit G, noted brown sticky substance under the sink in the anti-room to the nursery. Director of Maternal/Child Health Unit G stated the substance was sticky after touching it. Also noted the ice machine in the nursing hallway had a large build up of white residue. Director of Maternal/Child Health Unit G stated the the machine is old and the maintenance department is responsible for the cleaning of the machine.


18816

Examples in ED:

Per tour of the ED on 8/19/13 at 1:45 PM with Dir D, soiled room that contains biohazards is not secure allowing access by unauthorized staff, Pts and visitors. There is no signage related to biohazards being stored in the soiled room Dir D acknowledged the soiled room door was unsecured, and was unaware it should be secure.

Examples in Radiology:

Per tour of the Radiology department on 8/19/13 at 2:10 PM with Dir J, there is "breakfast syrup" and butter in a drawer and salt and pepper in the lower cabinet in the mamogram room. Dir J acknowledged the food items in the room, adding they should not be in the mamogram room.

Examples in Surgery:

On 8/20/12 between 7:30 AM and 10:30 AM the following was observed in the OR:

*There is a sheet under the sink in Untility Room "2".
*The endoscopy room contains several supply items that are not enclosed and would require being individual cleaning between cases. The cabinet containing scopes is not vented.
*Staff M, N, O, and P did not have all their hair encased in a bonnet.
*During set up of the instrument table, CST M repeatedly had back turned to the instrument table. During the skin prep, CST M and N had their backs to the instrument table.
*RN Q did not wear sterile gloves while applying skin prep to Pt #13's abdomen per policy.
*After prepping Pt #13, MD W picked up sterile towels and walked behind CST N crossing front to back rather than back to back or front to front, to begin draping Pt #13 for surgery;
*CST K stated at 10:10 AM, a container with a towel over the instruments meant the instruments were not used and did not need scrubbing. When the towel was removed, CST K noted a scissors had blood on it. When questioned about the other instruments and "invisible" bioburden, CST K said "it could be there", but did not scrub any of the other instruments. While scrubbing other instruments, CST K held the item above the water containing detergent, causing splatter on the clean paper towel above the sink. CST K stated he always brushed downward to prevent splatter on his face. When CST K finished scrubbing instruments, CST K proceeding to wipe down the ring stand that holds sterile bowls in the OR during surgery, with out the benefit of changing gloves and washing hands.
*A flying insect was noted floating in the Cavitator UltraSonic cleaning liquid. CST K confirmed the insect's presence and said "the water should have been dumped yesterday and will be dumped out today:"
*During Housekeeper L's cleaning of OR after Pt #13's surgery, Housekeeper L began at one side of the OR room and used one rag for three tables; wiped down a foot stool, did not change out rags and began wiping down the "tower" containing electronic equipment. Housekeeper L proceeded to wipe down the Pt OR table, another foot stool and then the transfer roller. Housekeeper L used a new wipe, cleaned a monitor, failing to wipe down the handle to adjust the monitor position, wiped down a trash can then began wiping down the anesthesia cart without changing to a clean cloth. This process allows for cross contamination throughout the OR.
These findings were discussed with the Dir of Surgery Services I, in the PM of 8/20/13, acknowledging staff should follow facility policy, and that the facility follows AORN recommendations.

Examples at off site clinic:

Per tour of the off site clinic on 8/20/13 at 1:45 PM, with VP S, the rehab department has ultrasound gel that is topped off, rather than tossed or emptied, cleaned and refilled. This was acknowledged during tour by VP S. Dir H on 8/21/13 at 8:30 AM confirmed there is no P&P related to the ultrasound gel, adding they do top off the gel bottles. This practice allows for potential contamination.

Examples in Rehab:

Per tour of the Rehab department on 8/21/13 at 8:30 AM with Dir H, the Occupational Therapy room had cooking and Pt supplies under the sink, and an open box of pancake mix in the cupboard. The Hybresis recharging unit in the supply hallway had dust/debris. Dir H acknowledged the findings during tour, adding the items should not be under the sink and the recharging station should be clean.

Based on observation, tour, review of P&P, and interview with staff (T, B), in 2 of 4 hospital kitchen/kitchenettes, the facility failed to ensure all nutritional items are labeled and not expired beyond use date; and in 1 of 1 staff observation (V) the facility failed to ensure staff follow dress code policy. This deficiency potentially affects all patients, visitors and staff who eat at this facility.

Findings include:

On 8/21/2013 in the PM review of policy titled "Food Storage", dated 10/2008, states "Metal or plastic containers with tight-fitting covers must be used for storing cereal, cereal products, flour, sugar, dried vegetables and other food items not stored in the product container or package it was obtained. All items must be labeled with the name of product and date placed into containers.

On 8/21/2013 in the PM review of policy titled "Supply Outdate Management", dated 2/2012, states "All official inventory with expiration dates will be monitored on a monthly basis to ensure of proper storage protocol as described above. All unofficial inventory with expiration dates will be managed by the department in possession."

Per review on 8/21/13 in the PM of facility policy titled Dress Code for Nutrition Services, dated 5/12 it states under Procedure: Beards & Mustaches...Beard, Mustache, sideburns must be covered by beardnet when in the kitchen or working with clean dishes."

On 8/20/2013 at 7:35 AM during tour of kitchen accompanied by Nutrition Service Manager T, noted 3 bags of food open and undated in freezer #2. At time of discovery Nutrition Services Manager T identified these as 2 bags of french fries and 1 bag of pancakes and agreed they are open and not dated.

On 8/20/2013 at 7:40 AM during tour of the kitchen accompanied by Nutrition Service Manager T, noted an unlabeled bag of a green leafy substance that has become partially brown and starting to decay in the walk in cooler. Nutrition Service Manager T identified the item as parsley and agreed the item was unlabeled and undated.

On 8/21/2013 at 11:15 AM during a tour of the Maternal/Child Health Unit accompanied by Nursing Director of Maternal/Child Health Unit G, noted 24 bottles of glucose water dated August 1, 2013 in cupboard in nursery anti-room. Nursing Director of Maternal/Child Health Unit G stated "if dated for August we will use the items until the end of the month."


18816

Per observation on 8/20/13 at 11:45 AM Cook/dishwasher V, who has a full beard, entered the kitchen pushing a cart with clean dishes, without the benefit of a beardnet, per policy. On 8/21/2013 at approximately 3:30 PM Dir of Pt Services B confirmed that staff V should have worn a beardnet.

Based on MR review, review of P&P and interview with staff, in 2 of 6 OB and NB MRs (#16 and 19) out of a total of 21 MRs reviewed, the facility failed to ensure nursing CPs are individualized to Pts needs. This has the potential to affect all OB and NB patients treated at the facility.

Findings include:

Per review on 8/21/13 in the PM of facility policy titled Plan of Care & Documentation, Interdisciplinary, dated 11/10, it states under Procedure #3.a.2. "New problems will be added when identified...4. If TP (temporary problems) persists over 24 hours it will be added to the Care Plan."

Pt #16's MR review on 8/20/13 at 2:55 PM revealed OB Pt #16 who delivered on 8/16/13, developed blisters and sore nipples while breast feeding on 8/17/13. A lactation consult was conducted on 8/18/13, and Pt #16 was discharged on 8/19. There is no CP in place to address sore nipples with interventions. This is confirmed in interview on 8/20/13 at 2:55 PM with Dir G, stating there should have been a CP specific to the sore nipples.

Pt #19's MR review on 8/20/13 at 3:10 PM revealed NB Pt #19 born on 8/16/13, weighed 7 pounds 5 ounces at birth and 6 pounds and 14 ounces day of discharge. The Newborn Discharge Status completed by the MD on 8/19/13 states a 10% weight loss. There is no CP for Pt #19 to address the weight loss. This is confirmed in interview on 8/20/13 at 3:10 PM with Dir G, stating there should have been a CP specific to the weight loss.

Based on MR review, interview (G) and P&P review in 2 of 21 MR (#14, 20) the facility failed to ensure all consents are obtained and/or timed. This deficiency directly affects 2 patients and has the potential to affect Pts treated at this facility.

Per review on 8/21/13 in the PM of facility policy titled Sexual Assault Policy, dated 12/11, it states under II.D. "Pursuant to Wisconsin Act 102, all staff working in the emergency department will provide the victim with accurate and unbiased written and oral information about emergency contraception and its use and efficacy....III.J. If medications are to be dispenses or the patient refuses medications, the ED nurse will have the patient sign "Consent for Emergency Contraception" form..."

Pt #14's MR review on 8/21/13 at 1:40 PM revealed Pt #14 was a SA victim on 9/2/13. There is no signed consent by Pt #14 for Emergency Contraception and antibiotics. The MR reveals Emergency Contraception and Antibiotics were dispensed to Pt #14 on 9/2/13. This is confirmed in interview on 8/21/13 at 1:40 PM, with Dr G adding the consents should be signed.

Pt #20's MR review on 8/21/13 at 2:30 PM revealed Pt #20 is a newborn that had a circumcision on 7/7/13. There is no time the MD signed the consent on 7/7/13 to indicate the risks and benefits were discussed prior to the procedure. This is confirmed in interview with Dir G on 8/21/13 at 2:30 PM, adding there should be a time with the signature.

Based on MR review, review of R&R, and interviews with staff (B,G,U), in 7 of 21 MR reviewed (#1, 10, 15, 16, 18, 19, 20) the facility failed to ensure all orders and entries are authenticated with a signature, date and time. This practice as the potential to affect all 23 Inpatients treated at this facility during this survey.

Findings Include:

On 8/22/2013 in the PM, reviewed Medical Staff R&R dated November 2012; It states under General Conduct of Care #2, "All orders for treatment shall be in writing and include date, time and signature. The hospitalist or attending practitioner shall, sign, date and time all orders within 24 hours." it also states under Documentation Guidelines for Hospital Charts # 9 "All clinical entries in the medical record should include time and date of documentation."

Review of Pt #1's MR on 8/20/2013 at 10:00 AM revealed a standing order dated 8/16/2013 was not authenticated with a signature, date and time. Per interview with Director of Medical/Surgical/ICU U on 8/20/2013 at 10:20 AM, all orders are to be signed by the physician as soon as possible.

Review of Pt # 10's MR on 8/21/2013 at 2:15 PM revealed un-timed orders on the following dates: 11/4/2012, 11/5/2012, 11/6/2012, 11/7/2012 and 11/8/2012. Per interview with VP of Patient Services B on 8/21/2013 at 2:30 PM, all orders are to be timed.


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Pt #15's MR review on 8/21/13 at 1:50 PM revealed Pt #15 was a SA victim. There are SOs in the MR that are initiated by the RN on 3/2/13, and are not authenticated by the MD. This is confirmed in interview with Dir G on 8/20/13 at 1:50 PM, stating the LC should time the entry.


Pt #16's MR review on 8/20/13 at 2:55 PM revealed the Breastfeeding Assessment Tool, dated by the LC on 8/18/13 is not timed. There are TOs dated 8/17/13 that are authenticated by the MD on 8/19/13 with no time. This is confirmed in interview with Dir G on 8/20/13 at 3:10 PM, stating the LC should time the entry.

Pt #18's MR review on 8/20/13 at 2:10 PM revealed the Pre-Partum SO's and Pre-Partum SOs dated by the MD on 7/5/13 are not timed. This is confirmed in interview with Dir G on 8/21/13 at 2:10 PM, stating the MD should time the entry.

Pt #19's MR review on 8/20/13 at 3:10 PM revealed the Newborn Discharge exam dated by the MD on 8/19/13 is not timed. This is confirmed in interview with Dir G on 8/20/13 at 3:10 PM, stating the MD should time the entry.

Pt #20's MR review on 8/21/13 at 2:30 PM revealed the Newborn Admission exam dated by the MD on 7/5/13 is not timed. The Routine Orders-Normal Newborn dated by the MD on 7/5/13 are not timed. This is confirmed in interview with Dir G on 8/21/13 at 2:30 PM, stating the MD should time the entry.

Based on MR review, review of P&P and interview with staff (I,G) in 2 of 3 surgical MRs (#13,15) out of a total of 21 MRs reviewed, the facility failed to ensure verbal confirmation and documentation the alcohol based skin preparation is dry prior to draping.

Based on MR review, review of P&P and interview with staff, in 2 of 4 where anesthesia services is provided (#17 and 18) out of 21 MR's reviewed, the facility failed to ensure the post anesthesia evaluation is documented reflecting recovery from the anesthesia/analgesia provided. See tag 322.

The cumulative effect of these deficiencies potentially affects all surgical Pts and Pts requiring anesthesia services treated at this facility.

Findings include:

Per review on 8/21/13 in the PM of facility policy titled Intra Operative Skin Prep, dated 4/13, it states under Procedure 7. "If using Scrub & Paint prep tray: a. Open prep tray on prep table using sterile technique. b. Put on sterile gloves...8. If using Chloraprep:...c. Allow prepping agent to dry 3 minutes before draping. Chloraprep contains alcohol which gives off flammable vapors while drying...12. document skin prep on Intra Operative Nursing Record including solution used, area prepped, skin condition, and hair clipping/shaving if needed and person (initials) performing skin prep." There is no instruction to verbally or document the skin prep is dry in the policy. Per Dir I on 8/22/13 at 2:55 PM, staff are supposed to document the skin prep is dry.

Pt #13's MR review on 8/21/13 at 1:20 PM revealed Pt #13 had a laproscopic gall bladder removal on 8/20/13. Alcohol based skin preparation was used, the RN set a 3 minute timer, once it went off, the MD immediately draped Pt #13. There was no verbal statement the skin prep was dry. There is no documentation of the alcohol based skin prep being dry prior to draping. This is confirmed in interview on 8/20/13 at 2:55 PM with Dir I, adding the prep should be documented as dry.

Pt #15's MR review on 8/20/13 at 2:55 PM revealed Pt #15 had a cesarean section on 8/16/13. There is no documentation of the alcohol based skin prep being dry prior to draping. This is confirmed in interview on 8/20/13 at 2:55 PM with Dir G, adding the prep should be documented as dry.

Based on MR review, review of P&P and interview with staff, in 2 of 4 where anesthesia services is provided (#17 and 18) out of 21 MR's reviewed, the facility failed to ensure the post anesthesia evaluation is documented reflecting recovery from the anesthesia/analgesia provided. This deficiency has the potential to affect all Pt's receiving anesthesia services at this facility.

Findings include:

Per review on 8/21/13 in the PM of facility policy titled Pre and Post Anesthesia, dated 12/08, it states "The patient's post-anesthesia status will be assessed by the anesthetist, who administered the anesthesia, and will be documented on the Pre-and (sic) Post-Anesthesia Record prior to discharge, not less than 30 minutes after case is completed....Inpatients will be seen prior to discharge not more than 48 hours after surgery...The post anesthesia exam will include at minimum: Cardiopulmonary status, Level of consciousness, Any follow up care and/or observations, Any complications during the post anesthesia recovery."

Pt #17's MR review on 8/20/13 at 3:20 PM revealed Pt #17 had an epidural for relief of pain in labor on 8/18/13. There is no documentation of a post anesthesia evaluation, indicating recovery from the epidural and return of sensation. This is confirmed in interview on 8/20/13 at 3:20 PM with Dir G, adding the CRNAs do the evaluation, but it is not documented.

Pt #18's MR review on 8/21/13 at 2:10 PM revealed Pt #18 had an epidural for relief of pain in labor on 7/5/13. There is no documentation of a post anesthesia evaluation, indicating recovery from the epidural and return of sensation. This is confirmed in interview on 8/21/13 at 2:10 PM with Dir G, adding the CRNAs do the evaluation, but it is not documented.

Based on review of P&P and interview with staff, in 1 of 1 interview (B) the facility failed to ensure the visitor policy included the Pt rights for visitors. This deficient practice has the potential to affect all Pts treated at this facility.

Findings include:

On 8/21/2013 at 3:00 PM reviewed P&P titled "Visitors to St. Croix Regional Medical Center" dated 4/2011. The P&P does not include information related to Pt visitor rights addressing any restrictions or their choice of visitors and their right to change their visitor choice. This is confirmed in interview with VP of Pt Services B on 7/21/2013 at 3:00 PM.

Based on interview with staff, in 1 of 1 interview (B) the facility failed to ensure there is a visitor policy that includes all Pts may choose visitor without discrimination and said visitors have equal visitation rights. This deficiency potentially affects all Pts treated at the facility.

Findings include:

On 8/21/2013 in the PM reviewed P&P titled "Visitors to St. Croix Regional Medical Center" dated 4/2011. The policy does not include information that all Pts may have visitors as they choose, and they will not be discriminated against based on sex, gender identity, race, color, national origin, religion, sexual orientation or disability; and all visitors are treated equally. This is confirmed in interview with VP of Pt Services B on 7/21/2013 in 3:00 PM.