| December 13, 2007 |
Vol 15, Issue
2 | |
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FAHSA
LINK | |
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| Welcome to this
week's edition of the FAHSA Link.
First
Series of FAHSA Regional Meetings Scheduled: Mark your calendar now
to participate in this exciting value-added
service --
One of the "Big Ideas" adopted by the FAHSA Board is to hold
periodic regional meetings throughout the state that give
members an opportunity to network and learn while earning
continuing education credit. At each of these
meetings, an educational presentation will be made on a topic
that is of interest to all members. In addition, attendees
will have the opportunity to participate in a roundtable
discussion for their membership type. The first group of
regional meetings will feature Morrison Senior Dining's "Voice
to the Silent Generation". Tentative dates for
these meetings are as follows:
- February
26-
Southeast Florida
Regional Meeting (Districts 7 and 8)
11:00am to 3:15pm,
John Knox Village of Florida, Pompano Beach
- February
27- Southwest Florida Regional Meeting (Districts 9, 10,
11 and 12)
11:00am to 3:15pm, Shell Point Retirement
Community, Ft. Myers
- February
28-
Central
Florida Regional Meeting (Districts 4, 5, 6, and 13)
11:00am to 3:15pm, Village on the Green, 500 Village
Place, Longwood
- February
29-
North
Florida Regional Meeting (Districts 1, 2, 3, and 14)
11:00am to 3:15pm, River Garden Hebrew Home for the
Aged,
Jacksonville |
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|

Taxation
and Budget Reform Commissioner Unveils Proposal at TaxWatch
Meeting -
Janegale
Boyd,
President/CEO, attended the Florida TaxWatch Board of
Directors meeting on
December 12th.
FAHSA is a member of TaxWatch, which is a 501 (c)(3)
nonprofit, nonpartisan research institute, focusing on
pertinent property tax, health care, and a wide variety of
issues which affect FAHSA members' services and care for
seniors. During
yesterday's TaxWatch presentations, Commissioner Carlos La
Casa of the Florida Taxation and Budget Reform Commission
spoke about his proposal for restructuring Florida's property
tax system. This
proposal would be a substitute for the proposed constitutional
amendment on property tax reform that passed during the last
special session of the Florida Legislature and would include
the following:
·
Homeowner receives
tax exemption worth half the property's market
value.
·
Increase state
sales tax from six cents to seven cents to cover resulting $12
billion loss to schools.
Would sunset in three years.
·
Non-homestead
property owner limit of assessed value growth to 5 percent
annually.
This does not
replace former Senate President John McKay's proposal to
eliminate some existing sales tax exemptions. Discussions were held
on how this would affect and change Florida's tax structure to
allow the collection of more revenue to meet state
obligations. From
FAHSA's membership perspective, elimination of certain sales
tax exemptions could be very detrimental to residents who are
service-dependent.
A periodic review would be more palliative.
Additionally,
FAHSA members Litha Berger, Secretary (Douglas Gardens Senior
Housing); David
Grofic, Associate Member Representative (Sandhill Cove); and
Sr. Mary Ann Dennehy and Thomas Peterson (Lourdes-Noreen
McKeen Residences) attended the Florida TaxWatch
luncheon.
Lieutenant Governor Jeff Kottkamp, Chief Financial
Officer Alex Sink and Speaker of the House Marco Rubio made
presentations. Members
attending thanked Alex Sink, CFO for office positive
intervention on member
issues.
HIV/AIDS
Education Glitch Bill Passes First House
Hurdle - Thanks to the
initiative of our House Sponsor, Joyce Cusack (D-DeLand), HB
153 was the first bill to be heard in the House Health Quality
Committee. HB
153, which would eliminate the biennial HIV/AIDS training
mandate for employees of facilities licensed under Chapters
395, 400, and 429, Florida Statutes, passed unanimously out of
its first committee of reference this week with 14 cosponsors.
Should the bill
become law, employers would still have the option of requiring
additional training on HIV/AIDS if they feel it is
necessary.
Legislative Committee Meetings Focus on Bills
Filed for 2008 Regular Session - Although the 2008
Legislative Session does not begin until March 4, several
bills on various topics were heard in substantive committees
this week. In
preparation for Session, the results of legislative Interim
Study Reports were also presented in the Senate. (See related article
on Home Health Agency Interim
Study.) | |
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| District and Membership News |
|
Annual Membership
Survey Underway - If you haven't filled out this
year's Annual Membership Survey, please take a moment to do so
now.Check your E-mail in-box for the Annual Membership Survey
link. This vital survey will help us better serve you in the
coming year.
US Representative Jeff Miller Visits
Azalea Trace - This week, Congressman Jeff Miller (R-
District 1) paid a quickly-arranged visit to Azalea
Trace. Miller
initiated the visit to the Panhandle continuing care
retirement community which he has toured in the past.
Executive Director Jeff Rock discussed a number of federal
funding issues with the Congressman, using a briefing paper on
nursing home and affordable housing funding prepared jointly
by FAHSA and AAHSA public policy staff. The staff and
administration at Azalea Trace always do a great job of
educating state and local elected officials about issues that
affect elder Floridians.
Vicar's Landing
Recommended for Gold Seal - Congratulations to
Vicar's Landing! At the December 10, 2007 meeting of the
Gold Seal Panel, the Vicar's Health Center was recommended for
Nursing Home Gold Seal Award.
District 5
Meeting a Success - Richard Lewis, District 5 Chair,
held their annual holiday luncheon on December 5. Eighteen FAHSA members
attended the meeting. The guest speaker was Michele Morales
from Quintairos, Prieto, Woods & Boyer, PA, who gave a
presentation on hiring the best employees to fulfill your
mission. Thanks and congratulations to Richard for an
interesting and successful meeting. District Chairs who are
interested in learning more about the topics presented at the
meeting and replicating the program locally should contact
their FAHSA staff liaison.
District 10
Meeting Held at Plymouth Harbor - FAHSA's District 10
Chair Dorothy Barichak hosted a holiday luncheon and District
10 meeting at Plymouth Harbor yesterday. Erwin Bodo, Ph.D.,
FAHSA's COO and Gail Matillo, FAHSA's Director of Housing and
Program Development gave an overview of Florida Senior Care,
affordable housing issues, and an update on FAHSA public
policy priorities. Approximately sixteen FAHSA members
attended the meeting.
State Senator
Addresses District 7 Members - Sen. Dave Aronberg
(D-Greenacres) spent 30 minutes with District 7 members who
met at the MorseLife campus for a luncheon meeting this
week. Aronberg, a
frequent visitor at Morse, discussed a number of public policy
issues with the eight facilities represented at the
meeting. In
addition, Teresa Lim from AON Work Solutions (a FAHSA
Preferred Business Associate) was on the agenda to speak. Congratulations to Mo
Funk for a planning a successful well-attended district
meeting.
Upcoming Membership Events:
- January
8 & 9 - FAHSA
Board of Trustees Meeting, Boca Raton Resort &
Club, Boca Raton
- January
15 & 16 - Advanced Leadership for Nurse Leaders,
Safety Harbor Resort & Spa, Safety Harbor
- February
26 - Southeast Florida
Regional Meeting (Districts 7 and 8)
11:00am to
3:15pm, John Knox Village of Florida, Pompano
Beach
- February
27 - Southwest Florida Regional Meeting
(Districts 9, 10, 11 and 12)
11:00am to 3:15pm, Shell
Point Retirement Community, Ft. Myers
- February
28 - Central Florida
Regional Meeting (Districts 4, 5, 6, and 13)
11:00am to 3:15pm, Village on the Green, 500 Village
Place, Longwood
- February
29 - North Florida
Regional Meeting (Districts 1, 2, 3, and 14)
11:00am to 3:15pm, River Garden Hebrew Home for the
Aged, Jacksonville
- April
14 - FAHSA Board of Trustees
Meeting, Wingate Inn, Tallahassee
- April
15 & 16 - FAHSA's Legislative
Workshop, Tallahassee Leon County Civic Center,
Tallahassee
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| Education News |
|
FAHSA's 5th
Annual Dynamic Directions Advanced Nurse Leadership
Workshop will be held on January 15-16, 2008 at the
Safety Harbor Resort & Spa. Don't miss this
opportunity to gain knowledge from the experts. READ THE
BROCURE and
REGISTER
ONLINE.
FAHSA's Next Webinar -- Medicaid Billing with
Florida's New Fiscal Agent, EDS, takes place on
January 22. The current Medicaid fiscal agent contract with
ACS will end on February 29, 2008. The new fiscal agent, EDS,
will begin claims processing on March 1, 2007, so it's
important to make this training a part of your "To Do" list.
READ
THE BROCHURE and REGISTER ONLINE.
Upcoming
Educational Events:
- January 15
& 16 - Advanced Leadership for Nurse Leaders, Safety Harbor
Resort & Spa, Safety Harbor
- January 22
- Webinar - Medicaid Billing with Florida's New
Fiscal Agent - EDS,
2:00 p.m. EST
- January 29
- Webinar - FAHSA's CCRC Occupancy Issues, 2:00
p.m. EST
- April 15 &
16 - FAHSA's Legislative Workshop,
Tallahassee Leon County Civic Center,
Tallahassee
FAHSA Calendar of
Events |
| General
News |
|
User
Fees Likely to Replace Lost Revenues from Property Tax Cuts -
It looks like some cities will be adopting user fees
and special assessments to replace lost property tax revenues.
Seven cities in Volusia County recently announced that they
are looking at an assessment for fire and medical rescue
services to cover expenditures that traditionally have been
paid with general property taxes. Elsewhere, cities are
considering new fees or increases in existing fees for water,
sewer use, storm water drainage, garbage pickup, development
impacts, building permits, burial plots, library use, park and
pool use -- and more.
For many local
governments, last summer's legislative-mandated cuts in
property taxes were manageable. But the upcoming statewide
Jan. 29 ballot issue that further lowers taxes for homesteaded
properties could cut into funding for basic services.
Estimates suggest the Jan. 29 plan, if passed by voters, would
save a homesteaded property owner an average of $240 in the
first year. There is a possibility that some residents could
end up paying more in user fees.
Now is the time
to keep an eye on what is happening in your city and county.
If a user fee or special assessment is proposed, attend public
hearings with your residents and testify about the impact on
your organization and the elders you serve. Ask for your
community to be exempt or assessed a lower fee. If you provide
affordable housing with below-market rents, you probably have
a fair chance of obtaining relief. Most importantly, don't
think that someone else will carry the message for you.
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| Housing
News |
|
FAHSA Members Meet with
HUD Officials - On Monday, December 10, Janegale
Boyd, FAHSA's President/CEO; Gail Matillo, Director of
Housing; Alma Ballard, FAHSA's Chair and Executive Director of
Family Housing Management, Inc.; Litha Berger, FAHSA's
Secretary and Director of Douglas Gardens Senior Housing;
James F. Emerson, AAHSA's Housing Cabinet and CEO of
Westminster Communities of Florida; and Steve Protulis, CEO of
EHDOC met with the following Jacksonville HUD Office
staff: James
Branson, Field Director, Laurelei McKnight, Supervisory
Project Manager, and Vonceil Williams, Project Manager. Our members discussed
preservation of affordable housing units, the sale of
non-profit buildings, and the loss of points in funding
competition.
By the year 2014, more
than 18,000 units of affordable housing stock could possibly
disappear to companies that are eager to purchase the property
to build luxurious condominiums or to "flip" the buildings in
a few years to make a large profit. FAHSA is concerned
about the low-income residents living in these communities,
especially if the new owners begin changing to a variable rent
structure, or tiered rent structure to include higher-income
tenants.
Developers are contacting some boards of directors of
FAHSA-member communities directly about possibly purchasing
your property. If
you receive any calls from companies wishing to purchase your
property, please notify Gail Matillo by E-mail: gmatillo@fahsa.org.
Two New Items of
Interest on HUD Web site -- HUD has posted two new
items on its multifamily housing Web site. The first is
a national list of physical inspection scores, and the second
is a link where sites can post information about housing
vacancies. Look up your most recent
score. You can also look for where owners and management
agents can list vacant units at HUD insured/assisted
properties on for the new Rental Vacancies
System.
FAHSA Housing Alert
Page |
| Home
and Community-Based Services News |
|
Senate Interim
Report Recommends Cap on Licenses for New Home Health Agencies
- This week, the Senate Committee on Health
Regulation was provided with a presentation by its staff on
the results of an Interim Study on regulatory requirements for
home health agencies.
As expected, legislative staff is recommending a
time-limited cap or moratorium on the licensure of new
agencies by geographic region. The cap would slow the
growth in home health agencies that has occurred since the
certificate of need requirement was repealed in 2000. (As of Aug. 23, 2007,
there were 1,865 licensed home health agencies.)
Other staff
recommendations included in the report are as
follows:
·
Require both the
home health agency and director of nursing to notify the
Agency for Health Care Administration (AHCA) of a change in
the director of nursing prior to or on the date of
change.
·
Require the
Department of Health and the AHCA to cooperatively develop a
rule addressing standards of care related to
responsibilities of a director of nursing for home health
agencies.
·
Limit the number
of patients for which a director of nursing may be
responsible.
·
Require AHCA to
conduct surveys of home health agencies more frequently,
especially within the first 9-15 months of
operation.
·
Enhance the
administrative penalties that may be imposed for
deficiencies.
·
Require AHCA to
review the pre-certification process for authorizing visits
by home health agencies in excess of the 60 visits per
lifetime cap, conduct an audit of the contract provider
performing this function, and modify contractor performance
expectations.
·
Require AHCA to
assure that the Medicaid payment system disallows payment
for home health services paid for by Medicare to a
dually-eligible recipient during the same 60-day
episode.
View the report, which
contains an excellent summary of home health agency regulatory
requirements.
AHCA
Calls for More Stringent Regulation of HHAs Including Hefty
Fine for In-Kind Services to ALF Residents - A
spokesperson for AHCA addressed the Senate Health Regulation
Committee this week.
He talked about the proliferation of home health
agencies, particularly in Miami Dade County since the
certificate of need was abolished in 2000. He spoke about
cavalier attitudes of licensees and a decline in the quality
of care. Among
other things, AHCA is recommending limiting new licenses to
five per month in each AHCA service area; increasing fines for
violations; limiting administrators and directors of nursing
to serving no more that two agencies simultaneously; creating
a $5,000 fine for failure to follow a physician order;
creating a fine of up to $1,500 for providing in-kind services
to ALFs and adult day care centers in return for referrals;
and adding fines for falsely billing and falsifying documents
related to staff training and health status.
Health
Regulation Chair Senator Jeff Atwater (R-N. Pam Beach) asked
if a bill could be drafted by January. The allegations of
fraud and other problems were considered to be alarming by
committee members and in need of immediate action by AHCA and
the Legislature.
Hospice
Rule Revisions Proposed -
The November 30 issue of the Florida Administrative Weekly
contains a proposed hospice rule that does the
following:
·
Expands
information that must be included in an application for change
of ownership.
·
Amends
administrative policy to require that verbal orders for
treatment or medication must be signed by the physician within
30 calendar days from the date of the order.
·
Effective
2009, requires hospices to electronically file an annual
report no later than March 31 with the Dept. of Elder Affairs
on outcome measures.
·
Adopts
form H-002 (Hospice Demographic and Outcome Measures Report).
The FORM may be downloaded
from DOEA's Web site.
·
Requires
hospices to conduct the National Hospice and Palliative Care
Organization Patient Family Satisfaction Survey. The
acceptable measure for satisfaction is an affirmative response
of at least 50% on pain control management and recommending
the hospice to others.
·
Mandates
that hospices maintain documentation of compliance with
national initiatives by the Centers for Medicare and Medicaid
Services.
·
For
the purpose of quality assurance, provides examples of "high
risk" and "problem prone" activities.
·
Incorporates
advance directive Form SCHS-4-2006 into the rule by
reference.
If
requested, a rule hearing will be held on January 3, 2008. READ THE
RULE
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| Legislative News |
|
Update
on Federal Legislative Issues
- This past
week, Congressman Jeff Miller (R) visited Azalea Trace, a
Pensacola continuing care retirement community. In preparation
for the meeting, Barbara Gay (AAHSA Director of Advocacy
Information) provided us with an update on affordable housing
and elder care issues pending in Congress. The summary, to be use
when speaking with members of Florida's Congressional
Delegation, follows:
·
Nursing
Home Survey Revisit User Fee: Revisits occurring
between October 1 and December 14 are subject to the user fee.
AAHSA is making every effort to get the fee terminated, but if
there is another continuing resolution to keep the government
in operation while Congress and the President work out
spending issues, the user fee may get continued along with
current funding for federal programs.
·
Medicare
Payment Freeze: The freeze was removed from the
Children's Health Insurance Program bill, and that legislation
was vetoed in the end. Nursing homes and home health agencies
received their annual payment update October 1. This issue has
resurfaced, however, because the Senate Finance Committee is
working on Medicare legislation to prevent a big pay cut for
doctors. President Bush does not want to offset the cost of
the doctor fix with any cuts to Medicare Advantage plans, so
Congress may fall back on cuts to skilled nursing facilities
(SNFs) and home health by canceling the payment update they
received. AAHSA is urging Congress not to cut payments to SNFs
or home health. Congressional action on this issue is
anticipated this week or next.
·
Medicare
Therapy Caps: While AAHSA believes that Congress
should repeal these caps, their current effort is to get the
exceptions process extended for another year. This allows
beneficiaries who have a demonstrated medical need for therapy
above the level of the caps to have the excess covered by
Medicare. AAHSA expects that Congress will incorporate an
extension of the therapy caps exceptions process into the
Medicare legislation fixing doctor reimbursement.
·
Funding
for Senior Housing and Home and Community-Based
Services: Congress is probably going to pass a large
omnibus spending bill covering most federal programs including
Section 202 housing and the Older Americans Act. AAHSA is urging
Congress not to cut funding for these programs below 2007
levels. AAHSA staff continues to point out that the need for
services continues to grow rapidly.
·
Section
202 Housing Reform Legislation: The good news is that
last week the House passed the legislation AAHSA initiated, HR
2930, to preserve the current supply of affordable senior
housing and encourage the development of more units. Rep. Tim Mahoney
(D-16) from Florida is the primary sponsor of HR 2390. Rep. Ginny Brown-Waite
(R-5), also from Florida, is one of the co-sponsors. The bill
would permit owners to refinance for rehabilitation or
improvement of current Section 202 housing, and would also
allow more flexibility to use savings for supportive services
to tenants. The bill passed under suspension on a voice vote
and must now be introduced in the
Senate. |
| Nursing
Home News |
|
Medicaid
Director Tom Arnold Assumes New Role -- Last week,
Tom Arnold (Florida's Medicaid Director) resigned. He will be assuming
the position of Deputy Secretary of the Department of
Health. Tom has
worked with FAHSA public policy staff for many years. He has always been
receptive to our comments and suggestions and has been
especially helpful with reimbursement issues. We look forward
to working with Tom in his new position.
Senate
Health Regulation Committee Focuses on NH Regulation &
Corporate Business Models - This week, AHCA Long-Term
Care Bureau Chief Molly McKinstry presented the outcome on an
internal review and report on nursing homes to members of the
Senate Health Regulation Committee. The study was
completed after a major newspaper article disclosed the
pending sale of Manor Care to Carlisle, a private equity
company. The New
York Times article alleged cutbacks in staffing, care, and
services in Carlisle-owned homes and other homes owned by
private equity companies. Read more about this
issue and those listed below in the latest Nursing Home Alert,
NH 07-35.
Other
Nursing Home Issues:
·
AAHSA Survey &
Certification Task Force Recommendations
·
Latest Florida
QIS Status
·
AAHSA Response to CMS
Distribution of Complete List of SFFs
·
Lawmakers Call
for Release of Complete List of Poor Performing Nursing
Homes
·
Enforceability
of Residency Arbitration Agreement
·
Florida Senior Care Web
Page Updated
·
MedWatch Alerts
and Warnings
·
Advisory Group
Recommends Freeze on Medicare Marketbasket for Nursing Homes
in 2009
·
US Senator
Grassley Calls for Probe into Nursing Home Use of
Antipsychotics
·
Three Drugs Lead
to Elderly Hospitalizations
·
Governor Crist
Appoints Moore to BONHA
|
| Preferred Business Associates
News |
|
FAHSA Welcomes Newest PBA
-- FAHSA's Provider/Shared Services Committee recently
approved Plante & Moran Clinical Group, LLC
as a new Preferred Business Associate (PBA).
The Plante & Moran
Clinical Group would like to introduce all FAHSA Members to
the MxManage tool, called
MxManage Quality and Financial STAT
(pronounced 'Max-Manage'), a Web-based, real-time,
MDS analytical tool compatible with any MDS software. For more
details about Plante & Moran Clinical Group and
MxManage click HERE.
Congratulations
and welcome to Plante & Moran Clinical
Group!
Play it Safe this Holiday at the ATM
-- As holiday shopping season gets under way, you may
find yourself in need of extra cash. ATMs can be an easy
target for criminals. Click HERE to read these
safety tips the next time you visit the ATM for some quick
cash. This article was provided by Hunt Insurance Group, one
of FAHSA Preferred Business Associates.
FAHSA's Preferred Business Associates
Program (PBAs) -- A list of PBAs can be found by on
the FAHSA Web site www.fahsa.org and
selecting Preferred Business Associates from the left side
menu bar or clicking on the FAHSA Preferred Business
Associates Page hyperlink. FAHSA members can also use the
on-line directory to search for PBAs by specialty.
|
| Sponsor |
Hunt Insurance Group, LLC / Hilb Rogal & Hobbs
- Hunt Insurance Group, located in Tallahassee,
Florida, has business affiliations throughout the State of
Florida and Southeast. As a Hilb, Rogal & Hobbs company
(the 7 th largest Broker in the U.S.) we are a
recognized leader in the development and administration of
alternative insurance programs and services for governmental
and select special risk clients. For more details
about Hunt Insurance click HERE. |
| Job-Mart |
| FAHSA is pleased to provide an opportunity for
you to advertise your "position wanted" or "position
available" through the FAHSA Link newsletter and on our
Web Page.
FAHSA members may use the Job Mart services at no charge. A
nominal fee of $25 will be charged to nonmembers.
Your Job Mart advertisement will be displayed on our Web
site for approximately three months. The FAHSA Link is
published weekly and distributed to our membership which is
comprised of nursing homes, CCRCs, HUD housing, assisted
living facilities, independent living facilities and
companies/firms.
To reserve advertisement space in our Job Mart program,
please complete the application and fax it
to FAHSA at (850) 671-3790 or E-mail Erin Steele at esteele@fahsa.org
|
|
FAHSA's Group Purchasing Organizations
|
|
FAHSA is pleased to tell
you about the FAHSA Group Purchasing Organization (GPO). The GPO program
further enhances the value you receive from your membership
and is required for us to be in compliance with
Medicare Safe Harbor requirements The FAHSA GPO program, in
conjunction with the AAHSA, Care Purchasing (CPSI), and FMS
Purchasing and Services (FMS) GPOs offer you the opportunity
to save daily purchases from over 200 vendor partners. To view these vendor partners
please click on the Preferred
Business Associated Guide and go to pages
22-25.
FAHSA members participating in these programs
are saving from seven to 50% off list prices. In addition to these
savings, your participation allows FAHSA to receive non-dues
revenue based on your purchases. This revenue assists
FAHSA to provide the educational programs and advocacy you
expect while keeping membership dues' to a
minimum.
There is no obligation or
commitment on your part to participate in the FAHSA GPO
programs. This is simply a value added member benefit.
Our program is
also not exclusive; you can belong to one or all three
GPOs. We simply
ask that you look at all of the FAHSA programs and decide the
best savings for you.
We
have three (3) Enrollment Agreements and ask that you
complete one or all and fax the completed enrollment to the
GPO at the number listed on the form. Click below to
obtain the enrollment form.
- AAHSA
Enrollment Form
- Care
Purchasing Enrollment Form
- FMS
Purchasing & Services Enrollment Form
If you are
already enrolled in one of the GPOs, you are still required to
complete a new enrollment form in order to have the FAHSA GPO
covered under the Medicare Safe Harbor Laws.
If you have any questions, please call Julie
Copeland, Vendor Relations Coordinator or Janegale Boyd,
President/CEO (850) 671-3700. Thank you for your
continued support of
FAHSA. |
| Save
10% |
Use FAHSA's
Self-Study Training Modules to Meet Regulatory Requirements -
If your
community is looking for an efficient and cost-effective way
to ensure that new and existing staff meet mandatory
educational training requirements, consider purchasing one or
more of FAHSA's training
Videos/DVDs:
·
HIV/AIDS Prevention &
Treatment
·
Domestic
Violence
·
Medical
Errors
·
OSHA Universal Precautions
& Infection Control
·
Resident Abuse
Prevention Program
The
advantage of using the training series is that individuals can
work at their own pace and complete the training on their own
or as part of a group.
For new hires, this option in invaluable. It not only saves
time, it saves money in regulatory
problems!
To order please click HERE for order
form. |
| Offer
Expires: December 31,
2007 |
| |