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Rogers, Tankersly, and Worley attended State and national
home care association meetings, entertained and recruited
clients, visited exhibit halls to see what vendors were offering,
and shared the information they obtained with each other. In
1990, petitioner's board of directors included: Rogers,
president/CEO; Tankersly, vice president/CFO; and Worley,
executive vice president/secretary.
D. Petitioner's Services
Petitioner provides its clients with a team of employees who
have advanced skills and knowledge in dealing with Medicare and
Medicaid regulations. The team conducts a mock survey to
determine whether the clients are in compliance with State
licensing, Federal conditions of participation, and the rules of
other accrediting bodies and recommends ways to comply or
improve. Rogers developed the parameters for the mock survey
team and, together with Worley, developed the product line for
the mock survey. The mock survey replicates the annual
inspection required by State and Federal regulatory authorities,
and as a result of the mock survey, petitioner's clients have
exceptional records with respect to their inspections.
Petitioner has policy manuals that discuss petitioner's
products and explain how services are to be provided to its
clients. The policy manuals are periodically revised. By 1989,
petitioner had 8 policy manuals, and by 1992 petitioner had 11
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