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services were provided by front desk staff one of the main
functions was to address the emergency-pull-cord system. In
making the allocation, Mr. Dalton assumed that the allocable cost
of front desk staff to monitor the system would be an average
hourly rate for one person for 24 hours a day for 365 days a
year. Mr. Dalton explained that the expenditures for the system
are not set out in a specific account but are charged to a
general ledger account. Specifically, he testified that the
payroll and benefits for a person monitoring the system would be
found under the resident services expense category, which
includes certain expenses related to the staffing of the front
desk.
After reviewing the financial information and the ad hoc
committee’s report, we find that no amount from the resident
services expense account (other than the committee’s allocation
for the pull-cord system) was included by either Mr. Powell or
the committee in their medical expense calculations. Respondent
does not challenge the amount of the allocation by Mr. Dalton for
medical expenses associated with the emergency-pull-cord system,
and we find the calculation to be reasonable based on the
evidence in the record. Because respondent has not raised any
other arguments on this issue or specifically argued or presented
adequate evidence that the other upward adjustments are
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