Christie E. Cuddeback and Lucille M. Cuddeback Memorial Fund - Page 30




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             The portion of the grants from petitioner's funds,                       
             $27,236, is small in relation to the value of the grants on              
             an annual basis, computed above.  The record does not                    
             provide the number of days each of the 31 grant recipients               
             participated in the program during 1999, but, clearly, it                
             was much less than a full year, at least on an overall                   
             basis.                                                                   
                  With respect to the daycare program, we are not told                
             what "services" Keswick provides to participants in the                  
             program or what costs Keswick incurs in providing such                   
             services.  We are not given any information concerning the               
             relationship between the domiciliary program and the                     
             daycare program, such as whether the two programs use the                
             same buildings or other facilities, whether they share the               
             same staff, etc.  We know the number of participants in                  
             the daycare program in 1996 and 1999 (viz, 149 and 139,                  
             respectively), but we do not know the number of days that                
             they participated in the program.  The administrative                    
             record does not provide sufficient information to evaluate               
             the financial impact of the daycare program on Keswick.                  
                  With respect to the grant program, the record does                  
             not explain how participants are made aware of the grant                 
             program, and whether participants must apply to receive a                
             grant.  The record does not explain how participants are                 
             selected to receive a grant, other than the fact that each               
             recipient must be a person who "could not afford to pay the              





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