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HomeMy WebLinkAbout03-10-09IN THE COURT OF COMMON PLEAS -CUMBERLAND COUNTY ORPHANS' COURT DIVISION O.C. No. IN RE: GOLDIE M. HURLEY, Deceased PETITION FOR ACCOUNTING . AND TURN OVER OF BENEFITS Filed on Behalf of: Presbyterian Senior Living d/b/a Green Ridge Village Counsel of Record for This Party: SCHUTJER BOGAR LLC Nicole M. Kerns PA. I.D. #206827 (412) 281-3511 Marijane E. Treacy PA. I.D. #84070 (412) 281-3535 U.S. Steel Tower 600 Grant Street, Suite 3290 Pittsburgh, PA 15219 Fax (412) 281-0530 Chadwick O. Bogar PA. I.D. #83755 417 Walnut Street, 4th Floor Harrisburg, PA 17101 (717) 909-5920 Fax (717) 909-5925 ~~ 4~--, ~ :. ..; ._: ,,: -~, -,-, _ --_, ,~ - ~ ~ .. ~_ ~ c-~ G.,., . _ _. c7 ' ` IN THE COURT OF COMMON PLEAS -CUMBERLAND COUNTY ORPHANS' COURT DIVISION na ~~ ,.. ~,, 5.. .) T IN RE: GOLDIE M. HURLEY, ~ ~.-~ t -, Deceased O.C. No. a~ ~ ~ d~~ -`= ~ ` ~ --' ;:; -~-~ , __ ~. _- =- °.. .:~ ~ ; PETITION FOR ACCOUNTING AND TURN OVER OF BENEFITS Petitioner, Presbyterian Senior Living d/b/a Green Ridge Village ("Green Ridge Village"), is a creditor of Goldie M. Hurley ("Ms. Hurley"), and hereby respectfully represents that: 1. Ms. Hurley was admitted as a resident of Green Ridge Village, a skilled nursing facility, located at 210 Big Spring Road, Newville, Pennsylvania 17241, on or about April 24, 2007. A true and correct copy of the Admission Agreement (the "Agreement") is attached hereto as Exhibit "A." 2. On or about February 9, 2009, Ms. Hurley passed away. 3. Daryl Hurley is Ms. Hurley's son and her Power of Attorney before she died. A true and correct copy of the Power of Attorney is attached hereto as Exhibit "B." 4. Upon information and belief, at all times relevant hereto, Daryl Hurley exercised control over Ms. Hurley's monthly pension, annuity, and social security benefits, as agent-in-fact for her. 5. Presently, Ms. Hurley's account with Green Ridge Village has an outstanding balance of twenty-nine thousand, two hundred one dollars and thirty-seven cents ($29,201.37). This amount increased by approximately two thousand two hundred thirty-one dollars and one cent ($2,231.01) each month before Ms. Hurley's death as Daryl Hurley failed to forward it to Green Ridge Village. Said amount consisted of Ms. Hurley's monthly pension, annuity, and social security benefits as directed by the Cumberland County Assistance Office as a condition of her receipt of Medical Assistance benefits. A copy of the form PA 162 awarding Ms. Hurley Medical Assistance benefits retroactive to August 5, 2007, and outlining her monthly patient pay obligation is attached hereto as Exhibit "C." 6. Despite repeated requests, Ms. Hurley's agent-in-fact, Daryl Hurley, has refused to bring the above-referenced account current by turning over Ms. Hurley's monthly income, as required by the Medical Assistance Regulations. 7. Pursuant to the Admission Agreement, at all times material hereto, Green Ridge Village has had an immediate right to the possession of Ms. Hurley's monthly income. See Exhibit "A." 8. Upon information and belief, Daryl Hurley, Ms. Hurley's agent-in-fact, used Ms. Hurley's income for purposes other than paying for services provided to his mother by Green Ridge Village. 9. Daryl Hurley failed to use his mother's income for her support, which is a violation of his fiduciary duties as her agent-in-fact, and is the basis for the imposition of a surcharge against him. See In re: Paxson Trust I, 2006 Pa. Super 9, 893 A.2d 99 (2006); In re Estate of Novosieleski, 2007 Pa.Super. 292, 937 A.2d 449 (2007). WHEREFORE, Petitioner requests that this Honorable Court issue a citation directed to Daryl Hurley to show cause, if any there be, why an Order should not be entered requiring him to file a full and complete accounting of all transactions undertaken by him with respect to Ms. Hurley's monthly income from the time she was admitted to Green Ridge Village until Ms. Hurley's date of death on February 2, 2009, directing him to turn over to Green Ridge Village said income to bring Ms. Hurley's account balance current, and surcharging him for breach of his fiduciary duties as agent for Goldie Hurley. Dated: ~-~~" Q 2 bU~l Respectfully submitted, SCHUTJER BOGAR LLC By ~~Cc ~ e ~nJ Nicole M. Kerns PA. LD. #206827 (412) 281-3511 Marijane E. Treacy PA. I.D. #84070 (412) 281-3535 U.S. Steel Tower 600 Grant Street, Suite 3290 Pittsburgh, PA 15219 Fax (412) 281-0530 Chadwick O. Bogar PA. I.D. #83755 417 Walnut Street, 4th Floor Harrisburg, PA 17101 (717) 909-5920 Fax (717) 909-5925 Attorneys for Petitioner tJ>• f C S{~• ADM1 NT L®1`~G'TERIVI CARE ADIVIISSI~I~I AGREEI~ZEN~' I. INTRODUCTION L ~/ This A ~eement is betti~Jeen ~ ~~ ~`~ ` ~,~ u1~'~~ Resident, or ~ U ~ ,Resident's Representative (referred to as Resident in the Agreement) and ,~ ~(~-~,~ Health Center, a licensed Long Tenn Care Facility (refereed to as Health Center in this Agreement), for admission of Resident to the Health Center on , 20 ~ .Date) Resident requests occupancy of Room / , a room for occupancy of residents at a Daily Rate of $~_• Resident may request a room change and the Health Center will make every effort to honor such requests as soon as possible. However, a room change may result in a change in the Daily Rate upon occupancy of the new room. In the event of an increase in the Daily Rate, the Health Center will provide thirty (30) days' notice of any change, thereby giving Resident sufficient time to request a room change (for example from a private to asemi-private room) or to transfer to another nursing facility. The Health Center agrees to accept payments from Medicare and other contracted third party payers for Resident's stay if Resident meets all qualifications required by Medicare or other third party payer. Resident agrees to pay daily co-payment and/or deductibles as designated by Medicare or other third party payers. If Resident qualifies for Medical Assistance ("MA"), the Health Center agrees to accept the Patient Pay Liability (as defined below) as determined by the County Assistance Office with the balance of the payment for covered services coming from the MA Program. II. DEFINITIONS A. Daily Rate. The rate the Health Center charges a private pay resident for room and board, general nursing care, housekeeping services, linen services, nutrition management, limited in-room storage of Resident's personal belongs, and recreational programs for each day a Resident is at the Health Center. Physician sei-~~ices are not included in the Daily Rate. B, Healtl~.care Sierrogate. .An adult who is appointed to malte healthcaT-e decisions for Resident ~~~hen Resident becomes unable to make them for him/herself. C, ~1ledical Director. The physician designated by the Health Center to be responsible for resident care policies and the coordination of medical care in the IIealth Center. D. Clinical Records. All records (excluding financial recoi_ds) pertaining to a particular Resident that are prepared and maintained by Health Center. g. Patient Pay Liability. The amount of personal fields, as determined by the Conmionwealth County Assistance Office, that a Resident who is receiving MA must pay monthly to the Health Center in addition to the payment from the MA program. F. Personal Needs Ser-vices. Personal services such as telephone ser~~ice, laundry, beauty and hair care (exclusive of routine assistance with grooming), and newspaper delivery provided by the Health Center to Residents for their convenience at Residents' expense. G. Private Pay Resident. A Resident who pays the Daily Rate and all other fees of the Health Center from his/her own resources (including private insurance and Medicare Part B) and who is not covered by or has exhausted Medicare Part A and MA coverage. H. Resident Funds. Personal funds of a Resident that the Resident has authorized in writing that the Health Center shall manage for the Resident. I. Resident's Representative. A person who is responsible for malting decisions on behalf of the Resident and has been so designated in witting by the Resident or a court of competent jurisdiction. If a Guarantor Agreement is attached to this Agreement, the Resident's Representati~~e is only obligated to make payment from the Resident's personal funds. Reference in this Agreement to Resident shall also include, as appropriate, the Resident's Representative or other person authorized to act on Resident's behalf. T, Skilled N~.crsing Care. Professionally supervised nursing care and related medical and other health services provided to an individual not in need of hospitalization, but whose needs are above the level of room and board and can only be rnet in a long-tend care nursing facility on au inpatient basis because of a.ge, illness, disease, injury, convalescence or physical or mental infinlzity. K. Specialt~~ Care Ser-vr'ces. Medical services ordered by a physician for a Resident that are not included in the Daily Rate. Medicare and Medicaid each include certain Specialty Care Services in the per diem rates, but neither include all such services. L. Transfer acid discharge. Movement of a resident to a bed outside of the certified facility or unit whether that bed is in the same physical plant or not: Transfer and discharge do not refer to movement of a resident within the same certified facility. III. HEALTH CENTER OBLIGATIONS: The Health Center will: A, provide, as part of the Daily Rate, room and board, general nursing care, housekeeping services, linen services, nutrition management, limited in-room storage of Resident's personal belongings, and recreational programs. General nursing care does not include private duty nursing. B. provide Specialty Care Services ordered by Resident's treating or attending physician. Although additional fees for specialty services m.ay be covered by third party payers, the Specialty Care Services identified on Exhibit A are not included in the daily rate, and are billed at the rates set forth in Exhibit A. Any items ordered by a physician, v~~hich are not identified on the Exhibit A will Ue provided at charges identified by the Health Center prior to the delivery of the service. C. provide Personal Needs Services, at Resident's expense (at the rates set forth on the Fee Schedule attached as Exhibit A) and at Resident's request, including but not limited to: 1. Beauty/Barber Services 2. Neti~jspaper delivery and personal reading materials 3. Local and Long Distance Telephone Services 4. Cable Services, depending on cable provider 5. Personal laLUldry, dry cleaning and mending 6. Personal clothing. D. provide safekeeping of Resident Funds, if authorized in writing by the Resident, and make those funds available, at Resident's request, during normal business hours. 1. Resident may manage his/her financial resources if (s)he wishes. 2. Residents may keep a limited amount of funds at the Health Center, the maximum amount, which is specified from time to time by the Health Center. 3. Requests for withdrawals in excess of $50.00 require advance notice to assure availability of cash at the Health Center. Resident Funds shall be retained in compliance with State and Federal regulations. Resident Funds exceeding $50.00 shall be placed in an interest bearing account. A written quarterly statement of these funds shall be provided to Resident. Resident agrees to retuni signed copy to facility if required. E. provide refunds of unused advance payments and Resident Funds within thirty (30) days after deductions for payment of any outstanding bills or other amounts due the Health Center after Resident's discharge or death. In the event of Resident's death, refunds ti~~ill be made to the authorized representative of Resident's estate. F, assist Resident in applying for and obtaining p2-ivate insurance and/or public benefits to cover the cost of the Resident's care. G. transfer or discharge Resident out of the Medicare or Medicaid certified portion of the Health Center only for medical reasons, for Resident's welfare, because the safety or health of individuals in the Health Center is endangered, because the Resident has failed, after reasonable notice, to pay for a stay at the Health Center, or with the voluntary consent of Resident. Except in emergency situations, at~ least 11112-~y (30) days' notice will be provided to Resident and Resident's Representative to assure that the transfer is safe and orderly. The Health Center reserves the right and discretion to move Resident to another morn or bed within certified parts of the Health Center consistent with the safety, care and welfare needs of the Resident. H. arrange for Resident's transfer or discharge upon the order of Resident's personal physician when he/she dee2ns it necessary to receive services the Health Center is not qualified to provide or at Resident's request. I. honor Resident's Rights as outlined in the Department of Public Welfare Ad2nissions Notice Packet (MA 401). J. to the extent permitted by law, hold Resident responsible to pay for any damages or injuries caused by Resident to other persons, residents or staff. To the extent pernitted by law, Resident shall indemnify and hold the Health Center harmless ' from any claims, actions or proceedings against the Health Center resulting from Resident's actions or omissions. Health Center will be responsible for loss of or damage to Resident's personal property by Health Centex staff. K. provide Resident with a locked drawer or box for Resident's valuables or for medications retained for self-administration. Resident may self-administer medications only in certain circumstances and may not have medications in his/her room z~~ithout physician authorization. L. provide Resident with a choice of pharmacy if Resident does not wish to utilize the pharmacy provider desib rated by the Health Center. ~~~ith this choice, pharmacy must provide medications in compliance «~ith all applicable laws and under a delivery s}stem that is consistent with the one used by the Health Center, must provide a monthly ~~~ritten profile of all drugs provided to the IIealth Center's consultant pharmacist, and must be delivered fiom the provider pharmacy in tamper-proof containers, directly to the Health Center's licensed nursing staff. M. provide Resident with a choice of attending physician who will provide medical care during the Resident's stay at the Health Center and who shall comply with the Health Center's rules, regulations, policies and procedures and all applicable laws and credentialling standards. Resident may also designate an alternate attending physician in the event that the primary attending physician is unavailable. In the event that Resident's attending physician(s) are unavailable, the Resident authorizes Health Center's Medical Director or other physician designated by the Health Center to issue appropriate orders. IV. RESIDENT OBLIGATIONS The Resident agrees to: A. by signing this Agreement, Resident certifies that (s)he is competent, and has never been adjudged incompetent, and is entering into this Agreement of his/her own free will. 1. I11 the event Resident has been adjudged incompetent, Resident's healthcare suizogate will attest, in a separate document that (s)he has the legal authority to act on behalf of the Resident. B. provide the Health Center with all information about Resident's health status and financial resources. Failtu-e to accurate]y identify resources and income, or the submission of false infonnatioil may amount to a violation of law and may result in the termination of this Agreement by and at the option of the Health Center. C, provide the Health Center wit11 a copy of all cun-ent insurance cards. Resident will provide the Health Center with changes in insurance coverage or financial status in a timely warmer, and will update the information provided to the Health Center from time to till~e, as requested. Resident understands that making incomplete or inaccurate disclosures will be considered a breach of this Agreement. D. authorize the Health Center to provide care and treatment to Resident consistent with the terms of this Agreement and to carry out the orders of the Resident's treating or attending physician or of the physician designated by the Health Center. Resident also authorizes the Health Center to obtain all necessary clinical and/or financial information from the hospital or nursing facility from which Resident may be transfemng. E. authorize the Health Center to make Resident's Clinical Records available to Health Center staff and agents. Resident also authorizes the release of the Resident's Clinical Records to any other health care provider from whom Resident receives treatment, to third-party payors of health services, and to any managed care organization (MCO) in which Resident maybe enrolled. Resident also authorizes the release to the Health Center of records prepared and maintained by any third-party payor of health care services pertaining to health care ser-vices rendered to the Resident by the Health Center. Resident also acknowledges receipt of the "Release for Electronic Transmission of Minimum Data Set" ("MDS"), which explains the MDS system of records using Resident data. Resident's Clinical Records will remain otherwise confidential, and shall not be made available to anyone other than Resident or authorized agents of the state or federal govennnents without the express written authorization of Resident or without a subpoena or other judicial order. F. cooperate firlly wrth the Health Center and any third party payer to secure pa}~rllent. Resident authorizes the Health Center to collect any payments made by third parties on Resident's behalf directly fi-om the third party payer. Resident also authorizes the Health Center to make claims, file appeals or d ievances, and take other actions necessary and appropriate to secure receipt of third-party pa}~Inents to reimburse the Health Center for its charges for the stay and care of Resident to the fullest extent permitted by law. Provided that Resident may, but shall not be required to authorize the Health Center to pursue grievances or appeals on Resident's behalf under Pemisylvania's Quality ~Iealth Care Accountability arld Protection Act, to the fullest extent pernitted by law and as security for payment of the Health Center's charges, Resident hereby assigns to the Health Center all of Resident's rights to any third-party payments now or subsequently payable for services rendered by or provided under arrangement through the Health Center. G. pay the Daily Rate established for the accommodation requested. Payment is due 30 days in advance, and Resident agrees to make full payment by the first of each month. Collection procedures are initiated after thirty (30) days of unpaid balances. Interest shall be charged on unpaid balances. 1. If the Health Center initiates any legal actions to collect payments due from Resident under this Agreement, Resident shall be responsible to pay all attorney's fees and costs incurred by the Health Center in enforcing Resident's financial obligations under the•Agreement. 2. This Agreement shall serve as an assignment to the Health Center of as much of Resident's property as equals the amount of any unpaid obligations under this Agreement, and this assigriznent shall be an obligation of Resident's estate that may be enforced against Resident's estate. Resident's estate shall be liable to and shall pay to the Health Center an amount equivalent to any unpaid obligations of Resident under this Agreement. This liability shall apply whether or not Resident is occup}ping the Health Center at the time of Resident's death. H, pay for additional items, services and equipment not included in the Daily Rate as identified by the Fee Schedules, attached as Exhibit A. I, understand that Resident will Ue notified thirty (30) days in advance of changes in the Daily Rate except when Resident requests room change, changes in charges for Specialty Care Services or Personal Needs Services, or changes in billing procedures, and agree that the changes will be effective upon the .date designated by the Health Center. J. understand that the Resident may continue to live at the Health Center as long as Resident continues to pay the Daily Rate. Resident may be discharged for non- payment of incurred charges or transferred for the benefit of the Resident or others, as set forth in Section III(H) of this Agreement. K. acknowledge that non-payment of the Daily Rate for a private room will result in a room change. L. acknowledge that the Health Center has the discretion, with thiri:y (30) days' notice, to transfer Resident to another room or bed within the Health Center consistent with the safety, care and welfare needs of Resident. The Health Center also has the discretion, upon thirty (30) days' advance notice, to transfer or change Resident's roommate, if any, at any trine consistent with the needs of the Health Center. M. terminate this Agreement upon written notice to the Health Center, but if Resident leaves for any reason other than a medical emergency or death, Resident must give reasonable advance written notice to the Health Center. N. notify the Health Center at least tu~o months before the Resident has insufficient resources, funds or income to meet his/her financial obligations and to apply for MA benefits timely. If Resident is no longer able to pay the Daily Rate and is not eligible for MA, Resident ab -ees to vacate the Health Center. p, pay co-payments and/or deductibles for services cohered by the Medicare Program or other third party payer, and pay the Health Center within thirty (30) days of receipt of services for those services not covered by the Medicare Program or other third party payer. p, pay for items and services requested by Resident and not covered by MA within thirty days of receiving the non-covered service. Q. to the extent otherwise pemlitted by la~~,~, assume responsibility for any damages or injtu-ies caused by acts or omissions of the Resident to other persons, residents or staff' . R. comply with reasonable rules, regulations, policies and procedures that the Health Center establishes fiom time to time alld makes available to Residents, subject to reasonable accommodation of Resident's individual needs and preferences. The Health Center's rules, regulations, policies and procedures are for purposes of internal management and shall not be construed as imposing contractual obligations on the Health Center and are subject to change from time to time. S. acknowledge receipt of the Resident Handbook, a document that provides Residents with Health Center rules, regulations, policies and procedures. T. acknowledge receipt of infomlation on Advance Directives in the absence of providing the Health Center with an existing Advance Directive or Living Will. U. provide the Health Center with a copy of any and all Durable Powers of Attorney, Guardianships, and/or Advance Directives pertaining to the Resident. V . aclaiowledge that (s)he has read and understands the teens of this Agreement, that the teens have been explained to them by a representative of the Health Center, and that (s)he has had an opportunity to ask questions about the Agreement. V. MDDICARE AND A'IEDICAID The Health Center is certified to participate in the Medicare and Medicaid Programs. The Health Center's participation in these programs is subject to termination by either the Health Center or the responsible government entity. The Pemzsylvania Departillent of Public Welfare (DPW) is responsible for administering benefits under the Medicaid Program and the Centers for Medicare and Medicaid Services (CMS) is responsible for administering the Medicare program tluough an intermediary. The Resident aclalowledges that the Health Center is not responsible for and has made no representations regarding the actions or decisions of DPVd, CMS or the Medicare intermediary in administering these programs. A. Medicare If Resident is eligible for benefits under the Medicare Program, Resident understands that certain skilled nursing and related health care services maybe covered by Medicare. The Health Center will bill Medicare Part A on behalf of the Resident for skilled nursing services and payment will be made by Medicare Part A directly to the Health Center for services received by Resident. When the Health Center notifies Resident that the nursing services being provided to the Resident no longer qualify as a skilled service, the Resident may request that the Health Center bill Medicare anyway. If Medicare denies coverage, Resident agrees to be responsible for the charges incurred on the Medicare Part Anon-covered days. The following describes coverage under the Medicare Part A Program: 1. Medicare Part A covers from one (1) to one hundred (100) days at the Health Center. Coverage is not guaranteed and is limited to the unused days in the Resident's benefit period. Conditions stipulated by Medicare must be met for coverage to begin and remain in force. 2. The Medicare Part A Program pays for all covered charges from day one (1) through day twenty (20) if the criteria for skilled service is met. 3. The Medicare Part A Program pays a portion Uut not all of the charges from day twenty-one (21) through day one hundred (100). The Resident is responsible for and shall pay any co-insurance or deductible amounts as determined by the Medicare Part A program. Depending on the circumstances, this payment may be made by personal health insurance, MA, Or personal filllds. 4. The Medicare Part A Progu-am covers the following sen~ices: room alld board, linens, meals, most prescription medications, therapy services, most medical supplies, non-private duty nursing services, most recreational sen~ices, most social services, and most personal hygiene items provided by the Facility. (Note: only the t}~~e and brand of personal h}~giene items provided bythe I-Iealth Center are included.) 5. Some items and sei~~ices not covered by the Medicare Pact A Program include, but are not limited to: personal clothing, eyeglasses, hearing aids, services of a beautician or barber, guest meals, special or altenla.tive meals not required for therapeutic purposes or as a nutritional substitute, services not deemed medically necessary, and personal telephone service. The Fee Schedule for items and services provided to Medicare Part A eligible Residents that are not covered by Medicare Part A is attached as Exhibit A. 6. Bed hold days are not covered by the Medicare Part A Program. (See Section VIL) 7. Residents covered by Medicare Part A should not go out on overnight leave as this may disqualify them from further coverage by Medicare Part A. 8. Residents may be covered for therapy and other ancillary services under the Medicare Part B Program. The Health Center or provider approved by Health Center will Uill Medicare Part B directly for these services. The Residents are responsible for the annual deductible and the co-insurance payment for Medicare Part B covered services. 9. Resident is responsible to pay the Health Center for services and supplies not covered by the Medicare Program. 10. Ili the event that Medicare coverage is changed b}~ law, those changes v,Jill control and take precedence over any contrary provision in this Agreement. B. Medicare AZaua~ed Care The Health Center participates as a. provider of skilled nursing services under some, but not all Medicare MCOs. 1. Requirements for eligibility for Medicare payments, deductibles and co- insurance may be different from those discussed in Section V(A). Pre- authorization of services is required by Medicare MCOs, and if the., Resident chooses to have services which the MCO refitses to pre- autllorize, Resident shall pay the Health Center for those sen~ices. If t11e MCO refuses coverage on the grounds that it does not consider an item or service to be medically necessary, Health Center or MCO will provide an Advance Beneficiary Notice of that determination. The Health Center will communicate directly with .Resident's Medicare MCO to obtain authorization for continued Medicare managed care coverage. 2. The Health Center will accept payment from the Medicare MCO as payment in full only for those services and supplies covered by the Medicare MCO. Resident is responsible for any copayments or other. costs assigned to Resident or not covered by the MCO under the specific teens of the managed care plan. 3. Resident aclnowledges that an MCO for which the Health Center is not an authorized provider may not approve payment for services provided by the Health Center, so that Resident maybe required to pay the Health Center directly. Resident also acknowledges that the Health Center is not responsible for and has made no representations regarding the actions or decisions of any MCO for which the Health Center is an authorized provider, including decisions relating to a deiual of coverage or refusal to pay on behalf of the Resident. 4. The Health Center reserves the right to stop its participation in any MCO at any time and in its sole discretion. To the extent practicable, the Health Center will provide advance notice to Residents em-olled in a particular managed care plan or insurance program of its decision to stop participation in that managed care plan or insurance pro grain. C. Medical Assistance Program 1. Residents who qualify for coverage under the MA Program must apply for and be approved for these services at the County Assistance Office, It is ,Resident's responsibility to pursue MA coverage. Until approval of MA coverage is obtained, the Health Center will consider Resident to be a Private Pay Resident. 2. Resident will be required to use the Patient Pay Liability to pay the Health Center for the Resident's stay in conjunction with the MA Program. Periodic adjustments in the Patient Pay Liability are made by the County Assistance Office and when issued, will supersede all previous determinations. Resident shall arrange, if possible, for the designation of the Health Center for direct deposit of any Social Security or related benefits or any other income sources of the Resident in an amount not to exceed the Patient Pay Liability. 3. MA program coverage includes the following: room and board, prescrption and non-prescription medications, meals, linen service, nursing services, incontinence care, social services, recreational activities, personal laundry, a hair cut every six (6) weeks, a shampoo and set every two (2) weeks, one permanent per year, and personal hygiene items provided by the Health Center. (Note that only the type and brand of personal hygiene items provided by the Health Center are included.) The MA Program limits the fiequency of coverage for the purchase of eyeglasses, hearing aids, and dentures. 4. The Health Center will not charge, solicit, accept or receive monies fi-om or on behalf of Resident for bed hold days covered by MA Program, except for the Patient Pay Liability, to cover the cost of Resident's stay or as a condition of admitting a Resident under the MA Program. 5. Some items and services not covered by the MA Program include, but are not limited to: personal telephone service, personal clothing, guest meals, brand name personal hygiene items, and additional services provided by a beautician other than those listed above. Resident is responsible for charges incurred for these services at the rates listed on the Fee Schedule attached as Exhibit A in addition to the patient pay liability amount. 6. Residents receiving MA coverage are permitted to keep the amount that has been designated as the Resident's personal needs allowance for personal spending. Personal funds maybe given to the Health Center for safekeeping (see Health Center Obligations in Section III). 7. The MA Program provides for bed hold days for limited periods of time during Resident's stay. a) Up to fifteen days bed hold days are allowed when Resident is transferred to a hospital. b) Up to thirty days bed hold days are allowed annually for intermittent therapeutic leave from the Health Center. c) The bed hold days referenced above are based upon the law in effect at this time, and may be subject to change if the governing state law is changed. 8. The Health Center provides equal access to its services to all individuals, regardless of payor source. VI. TI3IRD-PARTY PAYMENTS A. If Resident is or becomes eligible to receive financial assistance or reimbursement from any third pasties (such as private insurance, employee benefit plans, MA, Medicare, managed care coverage, supplemental medical or other health insurance, supplemental security income insurance, or old-age survivors' or disability insurance), the Health Center resen~es the right to collect such payments directly from the third-party. Resident shall cooperate fully with the Health Center and each third-party payor to secure payment, a11d Resident shall designate the Health Center, to the extent permitted bylaw, as the recipient of direct deposit for receipt of Federal Social Security benefits or any other Federal or State govenunent assistance, reimbursement, or benefits to the extent of all amounts due the Health Center. B. Resident authorizes the Health Center to inalce claims and to take necessary actions to secure receipt of third-party payments to reimburse the Health Center for its charges for the stay and care of Resident. To the fiillest extent permitted by law, as security for payment.of the Health Center's charges, Resident agrees to assign to the Health Center Resident's rights to any third-party payments now or subsequently payable to satisfy all charges. due under this Agreement. Resident shall endorse and turn over to the Health Center any payments received from third-party payor to the extent necessary to satisfy the charges under this Agreement. C. In the event of any denial of coverage by the Resident's insurance company, Resident shall pay the facility for all non-covered services retroactive to the date of the initial delivery of services. VII. RT+~ADIVIISSION -BED HOLD POLICY A. A Health Center representative shall corrununicate with Resident regarding his/her desire to continue to occupy the Health Center bed during hospitalization or therapeutic leave. Verbal consent shall be given to the Health Center representative who shall document this consent in the clinical record. Written consent shall Ue obtained following the verbal consent. See Fee Schedule (Exhibit A) for bed-hold rates. B. Bed holds- for Residents eru-olled in the MA Pro~-am are subject to the provisions of Section 5(C)(7). C. Resident's belongings shall be removed fiom the Health Center within 24 hours if Resident does not execute a bed hold authorization. Belongings not removed in a timely fashion play be packed and stored. VIII. CIVIL RIGHTS COMPLIANCE All Presb}~terian Homes, hic. facilities, including the Health Center, are open to all in need of sei-~~ices and are not'restricted to members of the Presb}~terian Church. It is the policy of PHI facilities to achi~it and to treat all residents without regard to race, color, national origin, age, ancestry, sex, religious creed, handicap, limited English proficiency, or disability. The same requirements for admission are applied to all; and residents are assigned without regard to race, color, national origin, age, ancestry, sex, sexual orientation, marital status, religious creed, handicap, limited English proficiency, or disability. There is no distinction in eligibility for, or in the manner of providing, any service provided by or through the facility. All facilities -are available without distinction to all residents and visitors, regardless of race, color, national origin, age, ancestry, sex, sexual orientation, marital status, religious creed, handicap, limited English proficiency, or disability. Roommate preference requests, staff assigmnent to residents and resident ancestry, sex, sexual orientation, marital status, religious creed, handicap, limited English proficiency or disability. All persons and orgaiuzations that have occasion either to make referrals for admission or reconunend a PHI facility are advised to do so without regard to race, color, national origin, age, ancestry, sex, sexual orientation, marital status, religious creed, handicap, limited English proficiency, or disability. IX. REGULATION The Health Center and Resident recognize that Health Center is licensed by the Pennsylvania Department of Health and is regulated by the DPW. The Health Center and Resident recognize that Health Center is also regulated by CMS of the United States Department of Health and Human Services. Both pasties recognize that regulatory changes nlay alter the conditions of this agreement. ~. G7E2IE~'ANCI+; PROCEDURE If Resident believes that Resident is being mistreated in any way or Resident's riglrts have been or are being violated by staff or another resident, on in any other way, Resident play submit a complaint to the Health Center's Director of Nursing and/or Administrator, and follow the Health Center's grievance procedure as described in the Resident Handbook. The Health Center's grievance procedure does not preclude Residents from pursuing grievances with appropriate regulatory agencies. ~I. ARBITRATION Any controversy, dispute or disagreement arising out of, or relating to this Agreement, or concealing any rights arising thereunder or the breach thereof shall be settled e~:clusively by arbitration, which shall be conducted at the Health Center in accordance «~ith the American Health Lawyers Association Alternative Dispute Resolution Service Rules of Procedure for Arbitration. Judgment on the av~rard rendered by the arbitrator shall be binding on both parties and may be entered in any court having jurisdiction thereof. Provided, however, that this arbitration clause is not intended to limit or supersede hearing rights that are guaranteed to a resident under the Medicare or MA programs or an applicable state law. XII. GOVERNING LAW This Agreement shall be governed by and construed in accordance with the laws of the Commonwealth of Pennsylvania. The Agreement shall be binding upon and inure to the benefit of each of the undersigned parties and their respective heirs, personal representatives, successors and assigns. XIII. SEVERABILITY The various provisions of this Agreement shall be severable one from another. If any provision of this Agreement is found by a court or administrative body of proper jurisdiction to be invalid, the other provisions shall remain in full force and effect as if the invalid provision had not been a part of this Agreement. XIV. ENTIRE AGREEMENT This Agreement represents the entire understanding between the parties, and supersedes all previous representations, understandings or agreements, oral or «Tritten, between the parties. ~V. 1!'IODII'ICATIONS The Health Center has the right to modify unilaterally the terms of this Agreement to the extent necessary to confonll to subsequent changes in law or regulation. To the extent practicable, the Health Center will give Resident and Resident's Representative thin}~ (30) days advance written notice of any such modifications. ~~TI. WAIVER OE PROVISIONS The Health Center Executive Director reserves the right to waive any obligation of Resident under the provisions of this Agreement in its sole and absolute discretion. No tei~il, provision or obligation of this Agreement shall be deemed to have been waived by the Health Center unless and except to the extent that such waiver is in writing by the Health Center. Any waiver by the Health Center shall not be deemed a waiver of any other term, provision or obligation of this Agreement, and the other obligations of Resident and this Agreement shall remain in full force and effect. Signatures This Agreement and any addenda to this A,~ -eeinent constitute the entire Agreement and understanding between the Health Center and the Resident with respect to the subject matter of this Agreement and supersede all prior Agreements and understandings. There are no Agreements, understandings, restrictions, warranties, or representations bet«~een the Health Center and the Resident other than those set Forth in this Ab-eement, or incorporated in this Agreement by reference. This Agreement play be amended only by a document in writing sib led by the Resident and the Admii>istrator or Executive Director, gild no act or omission of any employee or agent of the Health Center shall alter, change or modify any of the provisions of this Agreement. ~ ~-~.~ A 'nistrator or Executive Director Date Resident Date ` I .(~~ ~~ x / d~ Reside~:t Repre tative Date ~~~~~~ ~ Witness Dat I, GOLDIE M. BURLEY; widow, of 2178 Newville Road; Carlisle; Pennsylvania, do hereby nominate, constitute, and appoint my son, DARYI: L: $URLEF, of 466 Crossroad School Road, Carlisle, Pennsylvania, my true and lawful attorney-in-fact, to aci in, manage, and coirducE all my estate and all my affairs, for me and in my name, place, and. stead, and for my bene£rt, and as my act and deed; to do and perform any that I miglrt legally perform through an attorney-in-fact or that I myself might perform if I were present, including, but not limited to, the following; 1. To buy, receive, lease, accept, or otherwise acgnire;. to sell, convey, mortgage, hypothecate, ledge, gratclaim, or otherwise eneutnber or dispose of or to contract or agree for the acquisition, disposal or encumbrance of; any property wltatsoeyer and wheresoever situated, be it real, personal or mixed, or any custody, possession, interest, or right therein or pertaining thereto, upon such taints as my said attorney shall tltinkproper, real 2. To take, hold, possess, invest, lease, or Iet, or otherwise manage any or art of my , Personal, or mixed property, or any inteaest therein; to create a trust for my benefit; to eject remove, or relieve tenants or other persons from; and recover possession of, such property by all lawful means; ar_d to maintain, protect, Preserve, insure, remove, store, transport, repair, rebuiid, modify or improve the same or any part thereof; 3. To make, do, transact all and every kind of business of what nature or kind soever, including the receipt, recovery, rgllecdon, payment, compromise, settlement, and adjustment of aII accounts, legaaes, bequests, interest, dividends, annuities, demands, debts, taxes and obligations, which may now or hereafter be due, owing, or payable by me or to me•, 4. To make, endorse, accept, receive, sign, seal, execute, aclmowledge, and deliver deeds, assignments, agreements, certificates, hypothecations; checks, notes, bonds, vouchers, receipts, and such other instruments in writing of whatever kind and nature°as may be necessary. convenient, or propel in the Premises; • S. To deposit and withdraw far the purposes hereof, in either my said attorney's name or my name or jointly in both names, or in a trust far my benefit, is or firm any banking or other institution, any funds, negotiable paper, or taoneys, either principal or income, which may come into my said attorney's hands as such attorney or which I now or hereafer may have on depositor be entitled to; 6. To institute, prosecute, defend, compromise, arbitrate, and dispose of Iegal, equitable or administrative hearings, actions, suits, attachments, arrests, distresses or other proceedings or otherwise engage in litigation in cormection with the premises; 7. To act as my attorney or proxy in respect to any stocks, shazes, bonds, or other investments, right or interests, I may now or hereafter hold; 8, To engage and dismiss agents, counsel, and employees, and. to appoint and remove at pleasure any substitute for, or agenYofmy said attorney. is respect to all or any of the matters or things herein mentioned and upon such terms as nzy attorney shall ~~ fi~ 9. To execute vouchers in my behalf for any and ~ allowances and reimbursements properly payable to me by the United States including but not restricted to allowances and reimbursements for trarrsportation of dependents or for shipment of household effects as authoriud by law or armed forges regulations, and to receive, endorse, and collect the proceeds of checks payable to the order of the undersigned drawn on the Trcasurerof the United States; orts, a~ li ado amaze' execute' and file income and other tax returns, and other government ~ PP ns. requests, and documents; 1 I . To take possession, and order the nemovat and shiP~4 of an of m any post, warehouse, depot, dock, or ether 1 Y Y Property from pnvaie; and to execute and deliver an reI P a~ of storage or safe keeping, governmental or other instrument necessary or convenient for pipo~' ~rpt' ~PPn°g ~~' cernficate, or 12. I direct my attorney not sell any of my household goods or furnishing unless it shall be necessary in order to provide adequate funds to pay for my reasonable living and medical expenses. I direct that my attorney shall retain all such household goods and fi2rttishings as my attorney believes I may crnzently need or need in the future In the event my attorney decors it necessary to dispose of any household goods or furnishings not needed to be sold to raise money for my care and not deemed to be needed by me currently or in the future, then I direct that all such household goods and furnishings be given ro the person or persons to whom I have provided that they pass either specifically or as part of the residue of my estate in my most recently executed Last Will and Testament and that none be sold. 13. To do or perform those ppooveers enumerated and authorized by Pennsylvania Statute pursuant to the Probate, Estates and liditciaries Code (20 Pa.C.S.A. ~ 5601 et seq.), including: a. To make gifts or limited gifts; b. To create a trust for my benefit and to make additions to an existing oust for my benefit; c. To claim an elective share of the estate of my deceased spouse; d. To disclaim any interest in property; e. To renounce fiduciary positions; f. To withdraw and receive the income or corpus of a trust, g. To anthorize~my admission to a medical, nursing, residential or similar facility and to enter into agreements for my care and to authorize medical and surgical procedures. GIVING' AND GRANTING unto my said attorney full power and authority ro do and perform all and every act, deed, matter and thing whatsoever in and about my estate, property, and ~~ as fly and effectually to all intents and purposes as I might or could do in trry own proper person if personally present, the above spxtally enumerated powers being in aid and exem~liftt:ation of the full, let and general power herein granted and not in limitation or definition theaeoi and here Y ratify ng all that my said attorney shall lawfully do or cause to be done by virtue of these presents. AND I hereby declare that any act or thing lawfully done hereunder by said attorney shall be bindixg on myself, and my heirs, legal and personal representatives, and assigns whether the same shall have been done before or after my death, or other revocation of this instnimenty unless and until tellable intelligence or notice thereof shall have been received by my said attorney. DURABLE POWER OF ATTORNEX: THIS POWER OF ATTORNEY SHALL NOT BE AFFECTED BY MY SUBSEQUENT DISABILITY OR INCAPACITY. ff ineompeteneY proceedings for my person or estate are instituted, I here nominate my attorney-in-fact above namtd as guardian of my person and estate. ~ IN WITNESS WHEREOF, I have hereunto set my hand and seal this 3rd day of 7une,1993. WITNESS: ~~ ~_ ~- ~1_ ffff,~.~ GoIdie M. Hurley Social Secunty No.: 202-20-6988 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CIIMBEItLAND } ss On this the 3rd day of June, 1993, before me, the undersigned officer, personally appeared Goldie M. Hurley, widow, known to me to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. tt0?AFJ.Rf. stu. ~^IISTA xr,:s. rzarAar Puauc CAFW.StE. CUTSE~ERLdfiD COfIHTY, PA 11Y C017AfF55tON £XPbZF'S JtfiiE 27, 79@4 v IYIL/1 V/11/ P.o. sox V599" ELIGIBLE 33 'WESTMINSTER DRIVE CARLISLE PA 17013-0599 NOTICE CAO RETURN ADDRESS CSLD 0036 *09090000000* SCHUTJER BOGAR LLC ATTN: MARIE MARCUS-BRYAN 305 N.FRONT STREET STE 401 HARRISBURG PA 17101 ~~v a~~.c iv aL /.~7t517 'CO ;-RECORD`. DLST-~. CAT'--.GG :P5-'" 21 0115019 0 TAN 5 00 WORKER: s PEIPER TELEPHONE: (717) 240-2700 MAIL DATE: 04/18/2008 NOT: 985 OPT: J TYPE: E rvu w ~rv/ unutKSlaNU OUR DECISION OR HAVE ANY PUESTIONS, PLEASE CONTACT YOUR WORKER IMMEDIATELY. PAGE 1 OF 1 You have been determined eligible for benefits effective 08/05/2007 to 08/31/2007. You disposed of a total of $ 6684.71 in assets without receiving fair market value. This transfer results in a period of ineligibility for payment of Medicaid/Services in a Long Term Care (LTC) facility. You are not eligible for payment towards the cost of Medicaid/Services in an LTC facility beginning on 08/05/07 and ending on 09/02/07 During this period, you will be responsible to pay the LTC facility for the LTC services you receive. You are eligible for all other Medicaid benefits. You can request an undue hardship waiver if the denial of payment of Medicaid/Services in an LTC facility would deprive you of medical care which would endanger your health or life or if the denial of payment of Medicaid/Services in an LTC facility would deprive you of food, clothing, shelter, or other necessities of life. Citations: Pub. L. 109-171, 6011 and 601678.104 (d) Pub. L. 31, No_ 21 41.5 and 55 Pa. Code 178.104 (d) It you disagree with our decision, you have the right to appeal. See attached form for a complete expalnation of your right to appeal and to a fair hearing. If you are currently receiving benefits and your oral request for a hearing is received in the County Assistance Office or your written request is postmarked or received on or before 05/01/2008 your assistance will continue pending the hearing decision, except when the change is due to State or Federal law. GOLDIE HURLEY SWAIM HEALTH CENTER 210 BIG SPRING ROAD NEWVILLE PA 17241 • ~~ CUMBERLAND CAO P.O. BOX 599 33 WESTMINSTER DRIVE CARLISLE PA 17013-0599 MIDPENN LEGAL SERVICES 401-405 LOUTHER STREET CARLISLE PA 17013 Notice ID: 82759819 C0.';" ", RECD.6D D45T C'qT, GG P5 21 0115019 0 TAN 5 00 WORKER: s PEIPER APPEAL: 05/01/2008 TELEPHONE: (717) 240-2700 MAIL DATE: 04/18/2008 NOT: 985 OPT: J TYPE: E !F YOU WISH TO APPAL, C~N[PLETE, THE BACK OFT ~. FORM AND RET~7RhF THE BOTTONf - PpRTI ON TO CAC . , PA NIAts2A ..CONTINUED nN RFVFRC~ cin~ ....__. ___ P.O/uBOX ~599~V ~v~~vi~,r-~u 33 `WESTMINSTER DRIVE ELIGIBLE CARLISLE PA 17013-0599 NOTICE CAO RETURN ADDRESS CSLD 0036 *07090000000* SCHUTJER BOGAR LLC ATTN. MARIE MARCUS-BRYAN 305 N.FRONT STREET STE 401 HARRISBURG PA 17101 rvvucC w• 25L /5y /Sy CO RECORD'.'- DIST ,: CAT Y'GG:,.PS 21 0115019 0 TAN 4 00 WORKER: s PEIPER TELEPHONE: (717) 240-2700 MAIL DATE: 04/18/2008 NOT: 985 OPT: s TYPE: E IF YOU DO NOT UNDERSTAND OUR DECISION OR HAVE ANY OllESTIDNS, PLEASE CONTACT YOUR WORKER IMMEDIATELY. You have been determined eligible for benefits effective 09/01/2007 to 09/30/2007. You disposed of a total of $ 6684.71 in assets without receiving fair market value. This transfer results in a period of ineligibility for payment of Medicaid/Services in a Long Term Care (LTC) facility. You are not eligible for payment towards the cost of Medicaid/Services in an LTC facility beginning on 08/05/07 and ending on 09/02/07 During this period, you will be responsible to pay the LTC facility for the LTC services you receive. You are eligible for all other Medicaid benefits. You can request an undue hardship waiver if the denial of payment of Medicaid/Services in an LTC facility would deprive you of medical care which would endanger your health or life or if the denial of payment of Medicaid/Services in an LTC facility would deprive you of food, clothing, shelter, or other necessities of life. Citations: Pub. L. 109-171, 6011 and 601678.104 (d) Pub. L. 31, No. 21 41.5 and 55 Pa. Code 178.104 (d) If you disagree with our decision, you have the right to appeal. fnr ~ rr....r.l..~.. ...... _~__..__ currently receiving benefits and "" ""' "' '°" "eann li you are your oral request for a hearing is received in the County Assistance Office or your written request is postmarked or received on or before 05/01/2008 your assistance will continue pending the hearing decision, except when the change is due to State or Federal law. GOLDIE HURLEY SWAIM HEALTH CENTER 210 BIG SPRING ROAD NEWVILLE PA 17241 •_~r~ CUMBERLAND CAO P.O. BOX 599 33 WESTMINSTER DRIVE CARLISLE PA 17013-0599 I .~ ; it y>•~u, WISH TO APP~AE, CQMPLETE THE: BACK, t~,` T}~i! PO~tfiiON TO'~~AO.=.. MIDPENN LEGAL SERVICES 401-405 LOUTHER STREET CARLISLE PA 17013 PAGE 1 OF 1 Notice ID: 82759719 ~ CO RECORD _- -UIST -CAT - GG- PS ' ~~ 21 0115019 0 TAN 4 00 ~~ ~ WORKER: s PEIPER c ~. ~ ~~ ~ c ~ c APPEAL: 05/01/2008 ~ a TELEPHONE: ~~ c ~~ '' (717) 240-2700 ~ MAIL DATE: ~~ ~ 04/18/2008 NOT: 985 OPT: J TYPE: E ~~ )RI~I AND :RETURN. THE. B' TT' }VI -. --- - -~ ---- .__ PAMA162A ~. _, , CONTIIIlI IFII nfu RCV~o~~ ~~.,~ 719 • THE FOLLOWING PERSON IS AFFECTED BY THE ACTION ON THE FRONT OF THIS NOTIC LINE FIRST NAME ACCESS/INDIVIDUAL NUMBER E O1' GOLDIE 430190141 1 • THE FOLLOWING AMOUNTS WERE USED TO COMPUTE YOUR MONTHLY CONTRIBUTION TOWARDS LONG TERM CARE (LTC) . YOUR COST OF Calculation of Gross Monthly Income Calculation of Contribution t d owar Cost of Care Begin Date 09/03/2007 - - - - -- - Begin Date Earned Income ~ _ - ~ 09/03/2007 - - - ---- -- ---- ----- --. Gross Monthl I _ --- - - - - y ncome Wages. Salary 00 --- --------------- . Total Earned Income . 0 0 Self Employment oo . Total Unearned Income 2369.51 Rental Income o 0 Income available first month . 00 Other . 0 0 ---- -- -- Deductions Total Earned _ -- _J Income: • 00 __ _ _ _ ___ Personal Needs Allowance 45.00 Unearned ~ - - InCOme I Guardianship Fee .00 Social Security 882 s0 Total Allowance for Spouse / Dependant .oo SSI . oo Home Maintenance .oo Veteran's Benefits .0o Contribution towards Cost of Care: 2324. sl Pension 1487 . oo The LTC facility will deduct the following medical expense from your contribution towards Cost of Care Railroad Benefits 00 . Medicare Premium 93.50 Workmen's Comp o0 . Other Insurance Premium .00 Black Lung 00 The LTC facility may deduct additional medical bills Annuity/Trust Payment • 00 including supplemental health insurance premiums, provided they are verified. Interest /Dividend . of Other (Rental, etc.) . 0 0 Total Unearned Income: 2369 - sl IF YOU WISH TO APPEAL THE ABOVE COMPUTATION, PLEASE COMPLETE AND RETURN THE BOTTOM OF THIS FORM. •---- DETACH HERE DETACH HERE ------• Please check one of the boxes to show which type of hearin ^ I want a ^ 1 want a g you want: telephone hearing. face-to-face hearing. ^ Please check if you require any necessary and reasonable accommodation because of a hearing impairment or other disability. Please describe your disability: ^ Please check if you need an interpreter What language? NOTE: If you ask for an interpreter but later get your own interpreter, please call the Bureau of Hearings and Appeals (717) 783-39s0 I WANT TO REQUEST A HEARING BECAUSE: (Attach additional pages if necessary.) CLIENT SIGNATURE ADDRESS TELEPHONE NO. DATE CLIENT REP.SIGNATURE ADDRESS TELEPHONE NO. DATE PALTC162B VERIFICATION The undersigned hereby verifies that the statements of fact in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Dated: ~ ~ Q ~~' \ t '~ Jeff Davis; CF~ \~,,%' Presbyterian S nior Living d/b/a Green Ridge Village BOGAR E mall: Isc isciani~sc h utjerbogar.com Direct Dtal: (412) 281-0965 Fax (412) 281-0530 www.schutjerbogar.com March 9, 2009 Va UPS OverniPht Delivery Glenda Farner Strasbaugh Register of Wills and Clerk Of Orphans' Court Cumberland County 1 Courthouse Square, Room 102 Carlisle, PA 17013 Re: Goldie M. Hurley, Deceased Dear Ms. Strasbaugh: Enclosed are the original and one copy of the Petition for Accounting and Turn Over of Benefits for filing in the above-referenced matter. Please date stamp the copy and return it along with a copy of the signed Order to me in the self-addressed, prepaid envelope provided herein. An addressed, prepaid envelope for mailing the Preliminary Decree and/or CITATION to Mr. Daryl Hurley, the deceased's Power of Attorney, is also provided herein. In addition, enclosed is our firm check in the amount of $30.00 which represents the $15.00 filing fee, and the $15.00 Automation and JCP fees. Thank you for your assistance in this matter. Should you have any questions, or need additional information, please do not hesitate to call me at the above-referenced telephone number. Very truly yours, enclosures SCHUTJER BOGAR LLC `_~ Linda L. Scisciani ~--= o ,. ~, Paralegal ~? ~~ ~~. ~-- ,,_ - -- .. ~~ _-~ -U 4 --i ..~ a~ 0 -~ .~