The Stratford

Type of visit: Required - 1 Year

LPA Audrey Jeung toured facility and grounds of this Continuing Care Retirement Community, consisting of studio, one, two and three bedroom apartments--each with full private bathrooms--on 10 floors. On the 2nd floor, there are 9 studio apartments which comprise the Laurel Wing, where up to 12 residents can receive assisted living services; there are 5 residents in the Laurel Wing with 2 caregivers and an LVN present. Hot water temperature is tested at 118 degrees F in Laurel Wing room. Facility provides 3 meals daily to those residents of the Laurel Wing. Dinner meal is provided to other residents, who are mostly independent. Food supplies of perishables for 2 days and non-perishables for 7 days are maintained. Common areas on the ground floor include living room, library, fitness room, sauna room, indoor pool, dining room. On the 11th floor, there is a large and small meeting room. No fire safety hazards are observed. First-aid kit is inspected and complete. Medications, toxins and sharps are stored appropriately and inaccessible to clients, a comfortable temperature is maintained, and lighting is sufficient for comfort and safety. Centrally Stored Medications Records are maintained. Toilet and bathing facilities are equipped with grab bars and nonskid flooring material. Liquid soap is available at all sinks. Emergency call system is installed in all rooms, including bathrooms; when cord is pulled, staff with cell phones are alerted, and a visual and audio alert appears on monitors at Laurel Wing nurses station and reception desk on ground level. An updated Disaster and Mass Casualty Plan is accessible and disaster drills are conducted and documented quarterly. Criminal record clearances or exemptions for facility staff or other individuals who have client contact have been reviewed. Executive director Janie Woo is an RCFE administrator (x 8/26) that oversees facility operations and resident care director/RN Lori Wolfe also maintains RCFE administrator certification. Staff and client records are reviewed, including Centrally Stored Medication Records. Staff training transcript reports and registered dietician consultation report dated 4/9/26 are provided to LPA today. Updated Administrative Organization (LIC309) & Personnel Report (LIC500) are requested BY 7/21/26. No deficiencies of the RCFE California Code of Regulations, Title 22, Division 6, Chapter 8 are observed. See Technical Advisory Note for additional information--one page.the state’s words, verbatim · CDSS document, Jul 7, 2026

Type of visit: Case Management - Other

LPA Jeung met with assisted living coordinator to deliver an amended Complaint Investigation Report for complaint #14-AS-20250801130031. See LIC9099Dthe state’s words, verbatim · CDSS document, Nov 20, 2025

Type of visit: Case Management - Incident

In response to Incident Report of 11/7/25 of a medication administration error, LPA Jeung met with resident care director/RN to obtain additional information. Nursing staff received remedial training, and proof of training is given to LPA today. Facility responded appropriately to medication error to prevent future errors and reported incident to client's physician, responsible party, as well as CCLD. No deficiency cited.the state’s words, verbatim · CDSS document, Nov 20, 2025

Allegation investigated: - Staff left resident in locked facility vehicle

***********This report is amended 11/20/25************ LPA Jeung discussed incident of 7/22/25 with administrator. CCLD was notified of incident on 7/24/25 and a Report of Suspected Elder Abuse (SOC341) was submitted. An Unusual Incident Report was submitted to CCLD on 7/25/25 with an updated SOC341. Information provided initially states that client and caregiver were left unattended in van for 5 minutes. The later SOC341 states that they were left in van unattended for 28 minutes. Another statement provided by facility reports that after caregiver contacted facility to report that they were trapped alone in the van, staff were sent to client's apartment. The written reports of incident from facility fail to explain how client and caregiver were locked in the van unattended: van driver exited the vehicle without communicating with his passengers. Client is confined to wheelchair, and complained that he had difficulty breathing. LPA interviewed private caregiver of client #1, who was in the van with client on 7/22/25. Resident could not recall the incident. Based on information reported by and obtained from facility staff and witnesses, this allegation is substantiated. The preponderance of evidence standard has been met. Deficiency of the California Code of Regulations, Title 22 is cited on a following page. Substantiatedthe state’s words, verbatim · CDSS document, Aug 5, 2025 · control 14-AS-20250801130031

From the deficiency page — Deficiency type: Type A · Section cited: CCR 87464(f)(1) · Plan of correction due date: Aug 5, 2025

BASIC SERVICES Basic services shall at a minimum include care and supervision as defined in Section 87101(c)(3) and HSC 1569.2(c). This requirement was not met, as staff failed to supervise client #1 on 7/22/25, when facility driver exited van, leaving client and private caregiver inside with no means to exit. In addition, when facility staff were notified that client was trapped inside the van, staff responded by going to client's apartment, instead of searching for the van. Licensee failed to ensure that client was supervised when staff left him in van for 28 minutes, which posed an immediate health, safety or personal rights risk to client in care.the state’s words, verbatim · CDSS document, Aug 5, 2025

Plan of correction: All staff managers received training on operation of van doors and lift gate, facility drivers received training on transportation safety procedures, and driver #1 received a disciplinary action for negligence and resident abuse. Documentation is provided today. Plan of correction is pending review.

Type of visit: Case Management - Annual Continuation

To complete annual inspection of 6/17/25, LPA Jeung reviewed residents' medications recorded on Centrally Stored Medication Records, requested additional information for staff training, and tested hot water temperature in private bathroom of second floor Laurel Wing unit. Medications are observed to be complete, accurate and up to date. Hot water temperature tested at 118 degrees. More specific information on staff training is provided. No deficiencies are observed today.the state’s words, verbatim · CDSS document, Jul 1, 2025

Type of visit: Required - 1 Year

LPA Audrey Jeung toured facility and grounds of this Continuing Care Retirement Community, consisting of studio, one, two and three bedroom apartments--each with full private bathrooms--on 10 floors. On the 2nd floor, there are 9 studio apartments which comprise the Laurel Wing, where up to 12 residents can receive assisted living services; there are 5 residents in the Laurel Wing with 2 caregivers and an LVN present. Facility provides 3 meals daily to those residents of the Laurel Wing. Dinner meal is provided to other residents, who are mostly independent. Food supplies of perishables for 2 days and non-perishables for 7 days are maintained. Common areas on the ground floor include living room, library, fitness room, sauna room, indoor pool, dining room. On the 11th floor, there is a large and small meeting room. No fire safety hazards are observed. PPE supply is adequate and first-aid kit is inspected and complete. Medications, toxins and sharps are stored appropriately and inaccessible to clients, a comfortable temperature is maintained, and lighting is sufficient for comfort and safety. Centrally Stored Medications Records are maintained. Toilet and bathing facilities are equipped with grab bars and nonskid flooring material. Liquid soap is available at all sinks. Emergency call system is installed in all rooms; when cord is pulled, staff with cell phones are alerted, and a visual and audio alert appears on monitors at Laurel Wing nurses station and reception desk on ground level. An updated Disaster and Mass Casualty Plan is accessible. Criminal record clearances or exemptions for facility staff or other individuals who have client contact have been reviewed. Executive director Janie Woo is an RCFE administrator (x 8/26) that oversees facility operations and resident care director/RN Lori Wolfe also maintains RCFE administrator certification (x 5/26). Staff and client records are reviewed. Administrative Organization (LIC309) is requested to be submitted to CCLD BY 8/19/24: Personnel Reports (LIC 500) and Registered Dietician Consultation Report dated 4/23/25 are provided to LPA today. Deficiency of the RCFE California Code of Regulations, Title 22, Division 6, Chapter 8 is observed and cited on the following page.the state’s words, verbatim · CDSS document, Jun 17, 2025

From the deficiency page — Deficiency type: Type B · Section cited: CCR 87307(d)(2) · Plan of correction due date: Jul 1, 2025

PRSONAL ACCOMMODATIONS/SVCS The following space & safety provisions shall apply to all facilities: The premises shall be maintained in a state of good repair and shall provide a safe and healthful environment. This requirement was not met, as room #J in Laurel Wing is observed with minimal clear pathway, which poses a potential health and safety risk. Papers and newspapers in and out of paper bags are strewn throughout room and furnishings, including on the bed, on furniture and on floor, restricting safe access in and around room.the state’s words, verbatim · CDSS document, Jun 17, 2025

Plan of correction: Plan of correction to be submitted to CCLD BY DUE DATE.

Type of visit: Case Management - Annual Continuation

LPA Jeung reviewed random staff and client files to complete annual inspection of 8/5/24. RCFE administrator certificate for executive director was submitted to CCLD, along with other requested information: • LIC 308 Designation of Administrative Responsibility • Bedridden Plan of Operation • Medication Training requirements for staff • Board Resolution appointing administrator Janie Woo No deficiencies of the RCFE California Code of Regulations, Title 22, Division 6, Chapter 8 are observed. See also Technical Advisory Note.the state’s words, verbatim · CDSS document, Aug 27, 2024

Allegation investigated: - Staff not following resident physicians report - Facility Administrator is not certified

Based on client and facility records reviewed, information obtained from facility staff--including administrator-- and CDSS Administrator Certification Unit, these allegations are determined to be unsubstantiated. Although the allegations may have occurred or are valid, there is not enough evidence to prove the alleged violations did or did not occur. Four residents' physicians determined that they were unable to store and administer their medications, so facility provided this assisted living service until authorizations were obtained from MDs for their respective spouses to store and administer medications. However, facility failed to implement assisted living services in accordance with facility guidelines. See Facility Evaluation Report for deficiency. Executive director Janie Woo was appointed as facility administrator in November 2023. She applied for RCFE administrator certification approximately 6 months ago, but has not yet received administrator certificate. According to CDSS Administrator Certification Unit, status is pending. This could either mean that her application is pending review of information submitted or that information has been reviewed, approved, and that certificate is not yet processed/issued. Unsubstantiatedthe state’s words, verbatim · CDSS document, Aug 5, 2024 · control 14-AS-20240307142544

Type of visit: Case Management - Deficiencies

During complaint investigation, LPA Jeung observed a deficiency of the California Code of Regulations, Title 22. Deficiency is cited on a following page. According to Section 3.1.3.1. of facility's Continuing Care Residence Agreement, medication management is an assisted living service, and the provision of such service by facility is subject to a determination by the facility of the appropriateness or need for the service upon consultation with the resident or legal representative and his/her physician. In addition, the facility will determine "the extent of any services to be provided, and the proper setting." In at least 4 cases, the facility failed to adhere to Section 3.1.3.1., and implemented the storage and administration of residents' medications without first consulting the residents AND their physicians. Staff managed medications for client #5 for 4 weeks, for client #2 for 4 weeks, for client #3 for 10 weeks, for client #7 for over 25 weeks. Only when written MD authorizations were obtained did facility relinquish medications and management services to respective spouses.the state’s words, verbatim · CDSS document, Aug 5, 2024

From the deficiency page — Deficiency type: Type B · Section cited: CCR 87468.1(a)(16) · Plan of correction due date: Aug 19, 2024

PERSONAL RIGHTS Residents in all RCFEs shall have the right to receive or reject medical care or other services. This requirement was not met, as facility failed to follow their own policies and procedures regarding provision of assisted living services, which posed a potential health, safety or personal rights risk to residents in care. Residents' physicians were not consulted when facility assumed responsibility for medication management.the state’s words, verbatim · CDSS document, Aug 5, 2024

Plan of correction: Proof of correction shall be submitted to CCLD BY DUE DATE.

Type of visit: Required - 1 Year

LPA Audrey Jeung toured facility and grounds of this Continuing Care Retirement Community, consisting of studio, one, two and three bedroom apartments--each with full private bathrooms--on 10 floors. On the 2nd floor, there are 9 studio apartments which comprise the Laurel Wing, where up to 12 residents can receive assisted living services; there are 5 residents in the Laurel Wing with 2 caregivers and an LVN present. Facility provides 3 meals daily to those residents of the Laurel Wing. Dinner meal is provided to other residents, who are mostly independent. Food supplies of perishables for 2 days and non-perishables for 7 days are maintained. Common areas on the ground floor include living room, library, fitness room, sauna room, indoor pool, dining room. On the 11th floor, there is a large and small meeting room. No fire safety hazards are observed. PPE supply is adequate and first-aid kit is inspected and complete. Medications, toxins and sharps are stored appropriately and inaccessible to clients, a comfortable temperature is maintained, and lighting is sufficient for comfort and safety. Centrally Stored Medications Records are maintained. Toilet and bathing facilities are equipped with grab bars and nonskid flooring material. Liquid soap is available at all sinks. Emergency call system is installed in all rooms; when cord is pulled, staff with cell phones are alerted, and a visual and audio alert appears on monitors at Laurel Wing nurses station and reception desk on ground level. An updated Disaster and Mass Casualty Plan is accessible. Criminal record clearances or exemptions for facility staff or other individuals who have client contact have been reviewed. Executive director Janie Woo is an RCFE administrator and is assisted by resident care director/RN Lori Wolfe, who is a certified RCFE administrator (x 5/26). Staff and client records to be reviewed at a later date. The following updated forms/information are requested to be submitted to CCLD BY 8/19/24: • LIC 308 Designation of Administrative Responsibility • Bedridden Plan of Operation • Medication Training requirements for staff LPA is provided with the following information today: • LIC 500 Personnel Reports • LIC 610 Emergency Disaster Plan No deficiencies of the RCFE California Code of Regulations, Title 22, Division 6, Chapter 8 are observed.the state’s words, verbatim · CDSS document, Aug 5, 2024

Allegation investigated: Sunrise has lower standards for consumer protection for its residents than required for HOA residents. Sunrise residents should have the same consumer protections as HOA residents.

• A review of the continuing care contract executed by both the Provider and the residents revealed that the Provider made plain in its contracts that the residents may not have the same protections as HOA residents. • Specifically, the contract states that the Department of Real Estate “…may not have imposed some requirements on this project which would, in the absence of concurrent jurisdiction with the Department of Social Services, normally be imposed on a condominium project.” • Residents executed the contracts acknowledging the possibility of reduced requirements or protections. • Further – It has been determined that This Department is not responsible for enforcing Department of Real Estate Regulations. The declarations and contracts set out that Sunrise is operating a CCRC and has an exclusive easement to do so. So long as the facility is operated consistent with CDSS’ statutes and regulations, the department has no basis for taking action based on a violation of real estate licensing requirements. Unfoundedthe state’s words, verbatim · CDSS document, Nov 13, 2023 · control 14-AS-20230630154615

Allegation investigated: Civil Code section 5380 requires Sunrise to deposit funds paid into an account under the control of the homeowner’s association. Sunrise is not doing so and therefore is in violation of Civil Code section 5380.

During the course of the investigation into this allegation, the following was determined: • The only funds Sunrise accepts belonging to the association is $70.00 per resident per month collected by Sunrise at the association’s request pursuant to Continuing Care Residence Agreement. • As previously stated, The Department suggests the HOA communicate directly with Sunrise to obtain information about HOA dues paid to Sunrise. The HOA can also rescind its delegation of collecting HOA dues to Sunrise if it desires. Unfoundedthe state’s words, verbatim · CDSS document, Nov 13, 2023 · control 14-AS-20230630154615

The state marks this report as 3 pages; the online copy we transcribed has 1. You can request the full file from the county licensing office.

Allegation investigated: Transfer fees should not be allowed since the provider is not a broker. In the alternative, transfer fees should be limited in accordance with Civil Code section 4575.

During the Course of the investigation into this allegation, the following was determined: The Transfer Fee is clearly outlined in the Continuing Care Contract and CC&Rs. Residents executed these contracts thereby agreeing to pay a transfer fee upon the sale of their unit. In addition, the department does not interpret the “transfer fee” to be a brokerage fee. The continuing care contract statutes recognize the purchase price of a condominium unit to be an entrance fee and the fees charged upon the sale of the condominium unit to be a resale fee. (See HSC section 1771 subdivisions (e)(3) and (r)(4).) Resale fees or “transfer fees” based on a set fee and appreciation of the unit are not unique to Sunrise. Similar arrangements exist in other equity projects. (See Health and Safety Code (HSC) section 1771(e)(6) [defining “equity project”].) Further, analogous forms of compensation from the sale of a refundable or repayable CCRC unit are standard in the industry. Therefore, the department does not recognize such fees to be brokerage fees. (Cont.....) Unfoundedthe state’s words, verbatim · CDSS document, Nov 13, 2023 · control 14-AS-20230630154615

Allegation investigated: The attorney for the HOA contends residents should have a vote in selection of a management company, including whether to extend the contract with the current management company.

During the course of the investigation into this allegation, the following was determined: • In a CCRC, the residents are not a party to the management agreement, even in equity projects. • The provider, as the licensee, is fully responsible for selecting and paying management. In the context of the Stratford, Sunrise’s right act as a provider and to select managers appears to derive from its ownership of certain easements. • The Department understands these easements to be sufficient to establish Sunrise’s control over the community such that it can be licensed and granted a certificate of authority. • The Department is responsible for approving and licensing any management company hired to manage a continuing care retirement community. • It cannot approve of the HOA selecting managers of a licensed community when the HOA does not hold the license. That responsibility lies solely with the licensee, Sunrise. Note that HOAs are prohibited from holding CCRC Certificates of Authority (Health and Safety Code section 1771(p)(10)). Unfoundedthe state’s words, verbatim · CDSS document, Nov 13, 2023 · control 14-AS-20230630154615

Allegation investigated: There is no governing body as such that makes decisions about The Stratford on which a resident might serve, either as a resident representative or a full-fledged member. The regional and local managers employed by Sunrise Senior Living Management, Inc. (a subsidiary of Sunrise Senior Living LLC) make decisions regarding matters like fee increases, expansion and contraction of services, or other charges that would result in budget variance. The Stratford is therefore unable to have two resident owners participate on a Sunrise Governing body.

During the course of the investigation into this allegation, the following was determined: • The providers are limited liability companies, therefore there is no governing body for the residents to serve on as contemplated by 1771.8, subdivisions (i) and (j). Instead, • Sunrise is required to comply with HSC section 1771.8(s)(2)(A), which provides the provider appoint a select committee of its members to meet in a location that has been designated in the notice of the meeting with the resident association or a resident-elected committee of residents at each of its facilities semiannually and at least 60 days prior to any financial or administrative changes…” Sunrise contends they have met with residents under 1771.8(s)(2)(A), but meeting with just one resident at a time doesn’t appear to comply with the statutes since it requires they meet with, “…the resident association or a resident-elected committee of residents…” NOTE: While the reps are not members of the provider entities, given the structure of Sunrise, the Department accepted those representatives to satisfy this requirement. Unfoundedthe state’s words, verbatim · CDSS document, Nov 13, 2023 · control 14-AS-20230630154615

The state marks this report as 3 pages; the online copy we transcribed has 1. You can request the full file from the county licensing office.