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Based on record review, observations and interview the facility failed to:

l. Develop Master Treatment Plans (MTP) that identified patient-centered short-term goals stated in observable, measurable, behavioral terms for eight (8) of eight (8) active patients (A1, A2, A3, A4, A5, A6, A7 and A8). Lack of measurable, patient specific goals hampers the treatment team's ability to assess changes in patients' condition as a result of treatment interventions and may contribute to failure to modify plans in response to patients' needs. (See B121)

ll. Identify in the MTP patient specific treatment interventions/modalities to address identified patient problems for eight (8) of eight (8) active sample patients (A1, A2, A3, A4, A5, A6, A7 and A8). Interventions listed on treatment plans were preprinted. The treatment interventions listed were stated in vague terms and were non-individualized generic discipline functions rather than individualized patient specific interventions. This deficiency results in failure to guide treatment staff regarding the specific treatment purpose of each intervention to achieve measurable behavioral outcomes for patients. (See B122)

lll. Provide active treatment including alternative interventions for three (3) of eight (8) active sample patients (A2, A3 and A8) who were unwilling to attend many of their assigned groups. Failure to provide active treatment results in affected patients being hospitalized without all interventions for recovery being delivered to them in a timely fashion, potentially hindering their improvement. (See B125)

Based on record review and interview the facility failed to ensure that one (1) of eight (8) sample patients (A5) received a psychiatric evaluation containing a mental status examination that is descriptive, with documentation to support the patient's diagnosis and establish a baseline sufficient for comparison of treatment outcomes. In addition, the absence of a mental status evaluation has the potential to make objective patient assessment data unavailable to the treatment team and can result in treatment staff being unable to accurately assess ongoing patient mental status and progress in treatment, potentially impacting adversely on decisions regarding patient care, treatment and disposition.

A. Record Review

Patient A5's psychiatric evaluation dated 4/27/2016 did not contain a mental status examination.

B. Interview

In an interview on 5/4/2016 the medical director concurred that the mental status examination part of the psychiatric evaluation was not present in the medical record.

Based on record review and interview, the facility failed to develop Master Treatment Plans (MTP) that identified patient-centered short-term goals stated in observable, measurable, behavioral terms for eight (8) of eight (8) active patients (A1, A2, A3, A4, A5, A6, A7 and A8). Lack of measurable, patient specific goals hampers the treatment team's ability to assess changes in patients' condition as a result of treatment interventions and may contribute to failure to modify plans in response to patients' needs.

Findings Include:

A. Specific Patient Findings

1. Patient A1was admitted on 4/15/16 with a diagnosis of "Major Depressive Disorder". The Master Treatment Plan (MTP) dated 4/18/16 for the problem, "Alteration in Mood" had the short-term goals, "[Patient] will verbalize and display a decrease in symptoms associated with hospitalization, such as: Pt. will report motivation for recommended treatment and remain medication compliant" and "will engage with staff to discuss symptoms, thoughts and behaviors."

3. Patient A3 was admitted on 4/28/16 with a diagnosis of "Schizophrenia". The MTP dated 4/29/16 for the problem, "Alteration in Thought" had the short-term goal, "[Patient] will gain insight into the need and importance of safe discharge planning."

4. Patient A4 was admitted on 4/25/16 with a diagnosis of "Bipolar Disorder". The MTP dated 4/26/16 for the problem, "Alteration in Thought" had the short-term goal, "[Patient] will gain insight into the need and importance of safe discharge planning."

5. Patient A5 was admitted on 4/7/16 with a diagnosis of "Bipolar I, PTSD (Post Traumatic Stress Disorder), Opiate Use Disorder". The MTP dated 4/8/16 for the problem, "Depression" had the short-term goals, "Denies SI (suicidal ideation)/, HI (homicidal ideation)/AVH (Auditory Visual Hallucinations), Decreased hopelessness/ helplessness" and "will engage in unit milieu as tolerated and practice identified coping skills."

6. Patient A6 was admitted on 4/26/16 with a diagnosis of "MDD (Major Depressive Disorder) Recurrent, Severe, R/O (Rule Out) Bipolar". The MTP dated 4/27/16 for the Problem, "Harm to Self" had the short-term goal, "will be free from harmful thoughts and/or behaviors toward self, such as: Deny SI/HI/AVH; contract for safety while at EMH (East Mountain Hospital)."


7. Patient A7 was admitted on 4/26/16 with a diagnosis of "MDD recurrent severe; Alc (alcohol)/Opiate use disorder". The MTP dated 4/ 27/16 for the problem, "Depressed Mood, SI (Suicidal Ideation)" had the short-term goal, "will verbalize and display a decrease in symptoms associated with hospitalization, such as suicidal ideations and depressed mood; decreased motivation."


8. Patient A8 was admitted on 4/29/16 with a diagnosis of "Bipolar I dx (diagnosis) manic episode". The MTP dated 5/2/16 for the problem, "Alteration in Mood; Depression" had the short-term goal, "will verbalize and display a decrease in symptoms associated with hospitalization, such as: Deny SI, HI, AVH; Contract for Safety."

B. Interview

1. During interview on 5/3/16 at 3:00 PM, the Director of Nursing acknowledged that the short-term goals presented were not measureable or observable.

2. During interview on 5/4/16 at 9:45 AM, the Clinical Director concurred that the short-term goals were generic and not measureable.

3. During interview on 5/4/16 at 11:00 AM, the Director of Social Work stated that the short-term goals were not measureable or observable and were written as generic goals.

Based on record review and interview, the facility failed to identify in the MTP patient specific treatment interventions/modalities to address identified patient problems for eight (8) of eight (8) active sample patients (A1, A2, A3, A4, A5, A6, A7 and A8). Interventions listed on treatment plans were preprinted. The treatment interventions listed were stated in vague terms and were non-individualized generic discipline functions rather than individualized patient specific interventions. This deficiency results in failure to guide treatment staff regarding the specific treatment purpose of each intervention to achieve measurable behavioral outcomes for patients.

Findings Include:

1. Patient A1was admitted on 4/15/16 with a diagnosis of "Major Depressive Disorder". The Master Treatment Plan (MTP) dated 4/18/16 for the problem, "Alteration in Mood" had the short-term goals, "[Patient] will verbalize and display a decrease in symptoms associated with hospitalization, such as: Pt. will report motivation for recommended treatment and remain medication compliant" and "will engage with staff to discuss symptoms, thoughts and behaviors." The treatment interventions listed were "Social Worker/Counselor will assess patient history and needs" and "RN will encourage patient to use identified coping skills and attend assigned groups daily" and "RN will inform LIP [Licensed Independent Practitioner] of patient progress".

2. Patient A2 was admitted on 4/19/16 with a diagnosis of "Schizoaffective Disorder". The MTP dated 4/20/16 for the problem, "Alteration in Thought" had the short-term goals, "Will verbalize and display a decrease in symptoms associated with hospitalization such as: Deny SI/HI/AVH (Suicidal Ideation, Homicidal Ideation, Auditory Visual Hallucinations), [Decreased] Anxiety" and "will engage daily with staff to discuss symptoms, thoughts and behaviors." Treatment interventions listed were "Social Worker/Counselor will engage in reorientation as needed", "RN will engage in reorientation as needed" and "RN will inform LIP of patient's progress."

3. Patient A3 was admitted on 4/28/16 with a diagnosis of "Schizophrenia". The MTP dated 4/29/16 for the problem, "Alteration in Thought" had the short-term goal, "[Patient] will gain insight into the need and importance of safe discharge planning." Treatment interventions listed included "Social worker/Counselor will assess patient history and needs" and "RN will inform LIP of patient's progress."

4. Patient A4 was admitted on 4/25/16 with a diagnosis of "Bipolar Disorder". The MTP dated 4/26/16 for the problem, "Alteration in Thought" had the short-term goal, "[Patient] will gain insight into the need and importance of safe discharge planning." Treatment interventions listed included "Social Worker/Counselor will engage in reorientation as needed" and "RN will inform LIP of patient's progress."

5. Patient A5 admitted on 4/7/16 with a diagnosis of "Bipolar I, PTSD (Post Traumatic Stress Disorder), Opiate Use Disorder" had listed on the MTP dated 4/8/16 for the Problem of "Depression" the following short term goals: "Denies SI (suicidal ideation)/, HI (homicidal ideation)/AVH (Auditory Visual Hallucinations), Decreased hopelessness/ helplessness" and "will engage in unit milieu as tolerated and practice identified coping skills." The treatment interventions listed were "RN will inform LIP of patient's progress" and Social Worker/Counselor will assess patient history and needs."

6. Patient A6 admitted on 4/26/16 with a diagnosis of "MDD (Major Depressive Disorder) Recurrent, Severe, R/O (Rule Out) Bipolar" had listed on the MTP dated 4/27/16 the problem, "Harm to Self" the following short term goals: "will be free from harmful thoughts and/or behaviors toward self, such as: Deny SI/HI/AVH; contract for safety while at EMH (East Mountain Hospital)." Treatment interventions listed were "RN will engage patient every shift to assess thoughts and urges to harm self, maintain on ordered status" and "RN will educate patient on medications available for sx [symptom] management, by using teach back method and providing care notes."

7. Patient A7 admitted on 4/26/16 with a diagnosis of "MDD recurrent severe; Alc (alcohol)/Opiate use disorder" had listed on the MTP dated 4/ 27/16 for the problem of "Depressed Mood, SI (Suicidal Ideation)" the following short term goals: "will verbalize and display a decrease in symptoms associated with hospitalization, such as suicidal ideations and depressed mood; decreased motivation." Treatment interventions listed included "RN will inform LIP of patient's progress" and "Social worker will assess patient history and needs."

8. Patient A8 admitted on 4/29/16 with a diagnosis of "Bipolar I dx (diagnosis) manic episode" had listed on the MTP dated 5/2/16 for the problem of "Alteration in Mood; Depression" the following short term goals: "will verbalize and display a decrease in symptoms associated with hospitalization, such as: Deny SI, HI, AVH; Contract for Safety." Treatment interventions listed included "RN will inform LIP of patient's progress" and "Social Worker/Counselor will assess patient history and needs."

B. Interview

1. During interview on 5/3/16 at 3:00 PM, the Director of Nursing acknowledged that the treatment interventions were frequently generic and not related to patient's specific needs.

2. During interview on 5/4/16 at 9:45 AM, the Clinical Director concurred that the treatment interventions were generic and not patient specific.

3. During interview on 5/4/16 at 11:00 AM, the Director of Social Work stated that the treatment interventions were generic and did not reflect individualized patient needs.

Based on record review, observation and interview the facility failed to provide active treatment including alternative interventions for three (3) of eight (8) active sample patients (A2, A3 and A8) who were unwilling to attend many of their assigned groups. Failure to provide active treatment results in affected patients being hospitalized without all interventions for recovery being delivered to them in a timely fashion, potentially hindering their improvement.

A. Specific Patient Findings

1. Patient A2 was admitted on 4/19/16 with a diagnosis of "Schizoaffective Disorder". The patient was hearing voices and had attempted suicide. Review of the Weekly Patient Group Participation Record for 4/25/16-5/1/16 revealed that 43 groups were scheduled and Patient A2 had attended 18 (40.8%). Review of the MTP updated 4/27/16 did not address Patient A2's non-attendance at groups nor were alternative treatment options presented.

Observations on the patient care unit on 5/2/16 revealed the following:

At 11:30 AM, Patient A2 was observed standing at the nursing station while a Psychoeducation Group was in session.

At 1:25 PM, Patient A2 was observed walking the halls while a Psychotherapy Group was in session.

At 3:30 PM, Patient A2 was observed walking in the hallway while a Recovery/Wellness Group was in session.

Observations on the patient care unit on 5/3/16 revealed the following:

At 10:00 AM, Patient A2 was observed pacing the hallway while a Community Group was in session.

At 11:30 AM, Patient A2 was observed in bed while a Medication Group was in session.

At 3:30 PM, Patient A2 was observed at the nursing station while a Wellness Group was in session.

During Interview on 5/2/16 at 11:40 AM, Patient A2 stated that he/she didn ' t feel like going to groups but had gone to some groups.

2. Patient A3 was admitted on 4/28/16 with a diagnosis of "Schizophrenia". The patient was admitted after found wandering the streets, screaming and responding to auditory hallucinations. Review of the Weekly Patient Group Participation Record for 4/28/16-5/1/16 revealed that 18 groups were offered after Patient A3 was admitted. Patient A3 attended 5 of the 18 groups (27.7%). Patient A3's MTP dated 4/29/16 did not list alternate activities in the event of group refusals.

Observations on the patient care unit on 5/2/16 revealed the following:

At 1:30 PM, Patient A3 was observed in bed while a Psychotherapy Group was in session.

At 3:30 PM, Patient A3 was observed sitting in his/her room while a Recovery Group was in session.

Observations on the patient care unit on 5/3/16 revealed the following:

At 11:30 AM, Patient A3 was observed in bed while a Medication Group was in session.

At 3:30 PM, Patient A3 was observed in bed while a Wellness Group was in session.

During interview on 5/2/16 at 2:00PM, Patient A3 stated that he/she goes to group "sometimes".

3. Patient A8 was admitted on 4/29/16 with a diagnosis of "Bipolar 1 Disorder manic episode". The patient was described as having made suicidal threats and homicidal threats toward (his/her) mother. He/She was not on his/her medications "right now". Review of the Weekly Patient Group Participation Report for the week 5/2/1/16-5/8/16 revealed that 10 groups were scheduled for days 5//2/16 and 5/3/16 and Patient A8 attended none (0%) of the groups. Patient A8's MTP dated 5/2/16 did not list alternate activities in the event of group refusals.

Observation of the Patient A8 on 5/2/16 at 11:40 AM the patient was noted to be in his/her room asleep.

While attempting to locate Patient A8, on 5/3/16 at 1:40 PM, RN1indicated that if the patient was not in group he/she would be in his/her room.

In an interview on 5/3/126 at 1:45 PM Patient A8 indicated his/her dislike of groups and his/her desire not to be forced to take medications.

Observation of Patient A8 on 5/3/16 at 3:15 PM surveyor noted Patient A8 was outside playing basketball. Staff escorted Patient A8 onto the unit where he/she went to his/her room rather than going to the Wellness Group in session.

B. Interview

1. During interview on 5/2/16 at 11:40 AM, MHT3 stated that patients have a choice to either go to group or stay in their room. When asked about alternate therapeutic activities he/she indicated patients were offered coloring, drawing, journaling, or reading.

2. During interview on 5/2/16 at 3:20 PM, MHT1 stated that patients either stay in their room to do "reflections" or go to group. MHT1 further stated that during group time the leisure room doors are locked and the phone are turned off.

3. In an interview on 5/3/16 at 2:00 PM, SW1 stated that if patients did not attend groups they were to be in their rooms. In addition, she noted some patients would rather be in bed sleeping than in groups.

4. During interview on 5/3/16 at 2:30 PM, SW2 stated that she encouraged patients to go to group but if they did not go to group there were no therapeutic alternatives offered.

5. During interview on 5/4/16 at 11:15 AM, the Director of Nursing verified that all patients were expected to attend the groups being offered on the unit.

Based on medical record review, observation and interview, the Medical Director failed to:

1. Ensure that one (1) of eight (8) sample patients (A5) received a psychiatric evaluation containing a mental status examination that is descriptive, with documentation to support the patient's diagnosis and establish a baseline sufficient for comparison of treatment outcomes. In addition, the absence of a mental status evaluation has the potential to make objective patient assessment data unavailable to the treatment team and can result in treatment staff being unable to accurately assess ongoing patient mental status and progress in treatment, potentially impacting adversely on decisions regarding patient care, treatment and disposition (See B113).

2. Ensure the development of Master Treatment Plans (MTP) that identified patient-centered short-term goals stated in observable, measurable, behavioral terms for eight (8) of eight (8) active patients. (A1, A2, A3, A4, A5, A6, A7 and A8) Lack of measurable, patient specific goals hampers the treatment team's ability to assess changes in patients' condition as a result of treatment interventions and may contribute to failure to modify plans in response to patients' needs, (See B 121).

3. Ensure the identification on the MTP of patient specific treatment interventions/modalities to address the identified patient problems for eight (8) of eight (8) active sample patients (A1, A2, A3, A4, A5, A6, A7 and A8). Interventions listed on treatment plans were preprinted. The treatment interventions listed were stated in vague terms and were non-individualized generic discipline functions rather than individualized patient specific interventions. This deficiency results in failure to guide treatment staff regarding the specific treatment purpose of each intervention to achieve measurable behavioral outcomes for patients. (See B122)

4. Ensure the provision of active treatment including alternative interventions for 3 of 8 active sample patients (A2, A3 and A8) who were unwilling to attend many of their assigned groups. Failure to provide active treatment results in affected patients being hospitalized without all interventions for recovery. (See B125)

Interview

In an interview on 5/4/2016 at 9:45 AM the medical director concurred that Master Treatment Plans lacked measurable patient specific goals and patient specific interventions. The medical director further concurred that there was a problem engaging patients in active treatment and/or providing alternatives to groups if patients refused. In addition the medical director acknowledged the absence of a mental status examinations for patient A5.

Based on record review, observation and interview, the Director of Nursing failed to:

1. Ensure the provision of active treatment including alternative interventions for three (3) of eight (8) active sample patients (A2, A3 and A8) who were unwilling to attend many of their assigned groups. Failure to provide active treatment results in affected patients being hospitalized without all interventions for recovery. (See B125)

2. Ensure that nursing interventions listed on patients' MTPs addressed individualized patient needs for eight (8) of eight (8) active patients (A1, A2, A3, A4, A5, A6, A7 and A8). Instead, the interventions were preprinted, stated in vague terms and were non-individualized, generic discipline functions rather than individualized patient specific nursing interventions. This deficiency results in a failure to guide nursing staff regarding the specific treatment purpose of each intervention and limits the therapeutic nursing interventions available to patients.

Findings include:

A. Specific Patient Findings

1. Patient A1was admitted on 4/15/16 with a diagnosis of "Major Depressive Disorder". The Master Treatment Plan (MTP) dated 4/18/16 for the problem, "Alteration in Mood" had the short-term goals, "[Patient] will verbalize and display a decrease in symptoms associated with hospitalization, such as: Pt. will report motivation for recommended treatment and remain medication compliant" and "will engage with staff to discuss symptoms, thoughts and behaviors." The treatment interventions listed were "RN will encourage patient to use identified coping skills and attend assigned groups daily" and "RN will inform LIP [Licensed Independent Practitioner] of patient progress".

2. Patient A2 was admitted on 4/19/16 with a diagnosis of "Schizoaffective Disorder". The MTP dated 4/20/16 for the problem, "Alteration in Thought" had the short-term goals, "Will verbalize and display a decrease in symptoms associated with hospitalization such as: Deny SI/HI/AVH (Suicidal Ideation, Homicidal Ideation, Auditory Visual Hallucinations), [Decreased] Anxiety" and "will engage daily with staff to discuss symptoms, thoughts and behaviors." Treatment interventions listed were "RN will engage in reorientation as needed" and "RN will inform LIP of patient's progress."

3. Patient A3 was admitted on 4/28/16 with a diagnosis of "Schizophrenia". The MTP dated 4/29/16 for the problem, "Alteration in Thought" had the short-term goal, "[Patient] will gain insight into the need and importance of safe discharge planning." Treatment interventions listed included "RN will inform LIP of patient's progress."

4. Patient A4 was admitted on 4/25/16 with a diagnosis of "Bipolar Disorder". The MTP dated 4/26/16 for the problem, "Alteration in Thought" had the short-term goal, "[Patient] will gain insight into the need and importance of safe discharge planning." Treatment interventions listed included "RN will inform LIP of patient's progress."

5. Patient A5 admitted on 4/7/16 with a diagnosis of "Bipolar I, PTSD (Post Traumatic Stress Disorder), Opiate Use Disorder" had listed on the MTP dated 4/8/16 for the Problem of "Depression" the following short term goals: "Denies SI (suicidal ideation)/, HI (homicidal ideation)/AVH (Auditory Visual Hallucinations), Decreased hopelessness/ helplessness" and "will engage in unit milieu as tolerated and practice identified coping skills." The treatment interventions listed included "RN will inform LIP of patient's progress."

6. Patient A6 admitted on 4/26/16 with a diagnosis of "MDD (Major Depressive Disorder) Recurrent, Severe, R/O (Rule Out) Bipolar" had listed on the MTP dated 4/27/16 the problem, "Harm to Self " the following short term goals: "will be free from harmful thoughts and/or behaviors toward self, such as: Deny SI/HI/AVH; contract for safety while at EMH (East Mountain Hospital)." Treatment interventions listed were "RN will engage patient every shift to assess thoughts and urges to harm self, maintain on ordered status" and "RN will educate patient on medications available for sx [symptom] management, by using teach back method and providing care notes."

7. Patient A7 admitted on 4/26/16 with a diagnosis of "MDD recurrent severe; Alc (alcohol)/Opiate use disorder" had listed on the MTP dated 4/ 27/16 for the problem of "Depressed Mood, SI (Suicidal Ideation)" the following short term goals: "will verbalize and display a decrease in symptoms associated with hospitalization, such as suicidal ideations and depressed mood; decreased motivation." Treatment interventions listed included "RN will inform LIP of patient's progress."

8. Patient A8 admitted on 4/29/16 with a diagnosis of "Bipolar I dx (diagnosis) manic episode" had listed on the MTP dated 5/2/16 for the problem of "Alteration in Mood; Depression" the following short term goals: "will verbalize and display a decrease in symptoms associated with hospitalization, such as: Deny SI, HI, AVH; Contract for Safety." Treatment interventions listed included "RN will inform LIP of patient's progress".

B. Interview

During interview on 5/3/16 at 3:00 PM, the Director of Nursing acknowledged that the treatment interventions were frequently generic and not related to patient's specific needs.

Based on document review and interview the facility failed to provide a Therapeutic Activities Program. All leisure activities were provided by the Mental Health Technicians (MHTs) and consisted of coloring, bingo, walking and playing music. Failure to have a Therapeutic Activities Program that can provide adaptive skills and therapeutic leisure activities limits the patients' ability to attain knowledge and skills that can be learned and utilized after discharge.

Findings include:

A. Document Review

Review of the Unit Schedule and the Weekly Patient Group Participation Record revealed that MHTs offered two (2) leisure groups a day during the week (Creative Expressions and Life Skills) and two (2) leisure groups a day on the week-end (Life Skills and Coping Skills). The only groups offered on the week-ends were those provided by MHTs.

B. Interview

1. During interview on 5/2/16 at 3:30 PM, the Executive Director stated that the MHTs were "in charge of activities" and that the facility did not employ Activity Therapists. When asked what activities the MHTs provided, the Director stated that they had an arts and crafts cart and sometimes took patients for walks.

2. During interview on 5/3/6 at 2:50 PM, MHT2 stated that leisure activities consisted of playing bingo, playing music or doing something with arts and crafts.

3. During interview on 5/3/16 at 3:00 PM, the Executive Director stated that the MHTs did not have any training in offering leisure activities and instead learned "on the job".

Based on document review and interview, the facility failed to provide a Therapeutic Activities Program to consistently provide individualized therapeutic activities and rehab services based on patient needs. Failure to provide individualized therapeutic activities and rehab services can lead to unmet patient needs potentially leading to poorer outcomes and longer hospitalization.

Findings include:

A. Document Review

Review of the Unit Schedule and the Weekly Patient Group Participation Record revealed that MHTs offered two (2) leisure groups a day during the week (Creative Expressions and Life Skills) and two (2) leisure groups a day on the week-end (Life Skills and Coping Skills). The only groups offered on the week-ends were those provided by MHTs.

B. Interview

1. During interview on 5/2/16 at 3:30 PM, the Executive Director stated that the MHTs were "in charge of activities" and that the facility did not employ Activity Therapists. When asked what activities the MHTs provided, the Director stated that they had an arts and crafts cart and sometimes took patients for walks.

2. During interview on 5/3/6 at 2:50 PM, MHT2 stated that leisure activities consisted of playing bingo, playing music or doing something with arts and crafts.

3. During interview on 5/3/16 at 3:00 PM, the Executive Director stated that the MHTs did not have any training in offering leisure activities and instead learned "on the job".

Based on document review and interview, the facility failed to ensure that adequate numbers of qualified therapist and support personnel were available to provide comprehensive therapeutic activities to meet the individualized needs of each patients' active treatment program. Failure to meet the needs of patients can lead to longer hospitalization.

Findings include:

A. Document Review

Review of the Unit Schedule and the Weekly Patient Group Participation Record revealed that MHTs offered two (2) leisure groups a day during the week (Creative Expressions and Life Skills) and two (2) leisure groups a day on the week-end (Life Skills and Coping Skills). The only groups offered on the week-ends were those provided by MHTs.

B. Interview

1. During interview on 5/2/16 at 3:30 PM, the Executive Director stated that the MHTs were "in charge of activities" and that the facility did not employ Activity Therapists. When asked what activities the MHTs provided, the Director stated that they had an arts and crafts cart and sometimes took patients for walks.

2. During interview on 5/3/6 at 2:50 PM, MHT2 stated that leisure activities consisted of playing bingo, playing music or doing something with arts and crafts.

3. During interview on 5/3/16 at 3:00 PM, the Executive Director stated that the MHTs did not have any training in offering leisure activities and instead learned "on the job".