StarlynnCare

California · Alameda

Waters Edge Lodge

RCFE

A Residential Care Facility for the Elderly (RCFE) is a non-medical residential care home licensed by California CDSS under Health & Safety Code §1560. Residents receive assistance with daily living activities such as bathing, dressing, meals, and medication management in a home-like setting. RCFEs are not hospitals or skilled nursing facilities — they do not provide round-the-clock medical care.

801 Island Drive · Alameda, 94502

Quick facts

Licensed beds120
Memory careYes
Last inspectionJan 2026
Last citationJan 2026
Operated byZimmerman, John & Christian
Map showing location of Waters Edge Lodge

Inspection comparison

Updated April 20, 2026

Compared to 23 California RCFE facilities, over the last 36 months. Bed-size filter relaxed due to small peer set.

Source: California Department of Social Services, Community Care Licensing Division. View raw inspection records →

Peer comparison

Percentile vs 23 similar California CA / rcfe_general facilities · higher = better

Severity
27th

Weighted citations per bed

Repeats
100th

Repeat deficiencies as share of total

Frequency
14th

Deficiencies per inspection

Tick mark at 50% = peer median

Citation severity over time

↑ worsening

Weighted severity score per month · 24 months

May 24peer medianApr 26

Weighted score (24mo)

32

Last citation

Jan 26

Finding distribution

6 total · 36 months

Scope × Severity (CMS A–L)

IsolatedPatternWidespreadJKLG2HID4EFABCSev 4 · IJSev 3Sev 2Sev 1

View inspections & citations

The rules that apply to this facility

California Title 22 requirements for this facility, with the specific regulation and a suggested question for each.

What dementia-care training must staff complete?22 CCR §87705 / HSC §1569.625

Because this facility markets dementia or Alzheimer's care, state law mandates higher training standards:

  • 12 hours initial dementia training — 6 hours before a staff member works independently with residents, 6 more within the first 4 weeks.
  • 8 hours annual dementia in-service — required every year thereafter.
  • Administrator CE — the administrator must include 8 hours of dementia-specific continuing education in every 2-year recertification cycle.

Training must cover individualized care plans, behavioral expressions, appropriate supervision, and the facility's dementia care philosophy.

Ask on tour: Ask how dementia training records are kept — families may request documentation.

How many staff must be on duty overnight?22 CCR §87415

Based on 120 licensed beds:

One awake caregiver on duty, one on-call caregiver physically on premises, and one additional on-call caregiver.

Violation pattern to watch for:A facility that documents a staff member as "on call" but with that person physically off-site — when the law requires on-premises presence — is in violation of this section.

Ask on tour: Ask the facility to walk you through their overnight staffing plan and confirm whether on-call staff are on premises or off-site.

What health conditions can this facility legally accept or refuse?22 CCR §87612–87615

Restricted — allowed with physician order + care plan

  • Supplemental oxygen
  • Insulin and injectable medications
  • Indwelling or intermittent catheters
  • Colostomy / ileostomy
  • Stage 1 and Stage 2 pressure injuries
  • Wound care (non-complex)
  • Incontinence
  • Contractures

Prohibited — facility must refuse or discharge

  • Stage 3 or Stage 4 pressure injuries
  • Feeding tubes (PEG, NG, or J-tube)
  • Tracheostomies
  • Active MRSA or communicable infections requiring isolation
  • 24-hour skilled nursing needs
  • Total ADL dependence with inability to communicate needs

A hospice waiver (HSC §1569.73) can allow continued care for residents on hospice who would otherwise fall into a prohibited category.

Ask on tour: Ask whether your loved one's specific care needs are restricted or prohibited, and what the facility's process is if needs change after admission.

What must this facility report to the state — and how fast?22 CCR §87211 / WIC §15630
  • ImmediateElopement, fire, epidemic outbreak, or poisoningImmediately
  • 2 hoursAbuse with serious bodily injury2-hour phone report + 2-hour written report — to the California Department of Social Services (CDSS), Adult Protective Services, and law enforcement
  • 24 hrsAbuse without serious bodily injuryWithin 24 hours
  • Next dayDeath of a residentPhone by next working day; written within 7 days
  • Next dayInjury requiring medical treatment beyond first aidPhone by next working day; written within 7 days
  • WrittenBankruptcy, foreclosure, eviction, or utility shutoff noticeWritten notice to CDSS and residents — $100/day penalty (max $2,000) for failure

Your enforcement lever:Incidents that aren't reported on time are themselves a separate violation. If you believe a reportable event wasn't filed, you can submit a complaint directly to the California Department of Social Services (CDSS).

How does CDSS enforce these rules?22 CCR §87755–87777 / HSC §1569.58
  1. 1Notice of DeficiencyWritten citation with a correction deadline. Facility must submit a Plan of Correction.
  2. 2Civil PenaltyStarts at $50/day for non-serious; $150/day for serious deficiencies — immediately, with no grace period. Repeats escalate to $150 first day + $50/day, then $1,000 first day + $100/day.
  3. 3Suspension of AdmissionsFacility cannot accept new residents until violations are corrected.
  4. 4Temporary Suspension or RevocationEmergency suspension for imminent danger; full revocation after administrative hearing.
  5. 5Exclusion OrderAdministrator and operator can be barred from all CDSS-licensed facilities — not just this one.

See how these rules have been applied to this specific facility:

View state inspection record and citations

Questions to ask on your tour

Based on Waters Edge Lodge's state inspection record.

  1. The facility has 2 serious citations on file across all inspections — can you provide your corrective-action plan for each cited item, and show families any documentation of remediation steps taken?

  2. 2 complaints are on file with CDSS — were any substantiated, and what remediation did the facility take in response to substantiated findings?

  3. The most recent inspection was conducted on 2026-01-07 and resulted in deficiency findings — can you provide the deficiency notice and your written corrective-action plan for each cited violation?

  4. The facility is licensed for 120 beds and operated by John & Christian Zimmerman — can you confirm the current license status is active and provide families with a copy of the current license certificate?

State records

California Dept. of Social Services · Community Care Licensing
License number
011440777
License type
RESIDENTIAL CARE ELDERLY
License status
LICENSED
License expires
Not yet indexed
Licensed beds
120
Operator
Zimmerman, John & Christian

Inspections & citations

10

reports on file

6

total deficiencies

2

Type A (actual harm)

InspectionJanuary 7, 2026
No deficiencies

Plain-language summary

This was a follow-up visit on January 7, 2026 to verify that the facility had corrected a staffing-related deficiency found during an annual inspection in December 2025. The facility had not submitted proof of correction by the required deadline, but when the inspector reviewed the updated personnel records during this visit, the deficiency was confirmed as corrected. No new violations were found.

View full inspector notes

On 01/07/2026 at 11:30 AM, Licensing Program Analyst (LPA) P.Manalo arrived unannounced to conduct a Plan of Correction (POC) Visit. LPA met with Associate Administrator, Arin Sartain, and Administrator, Stephen Zimmerman. Zimmerman gave verbal authorization for Sartain to sign the report. On 12/17/2025, LPA P. Manalo and K. Nguyen conducted an annual inspection where the facility was cited for deficiency section 87412(a)(4) due on 12/29/2025. Administrator did not submit the proof of correction on the due date. During the visit, LPA reviewed the updated Personnel Report (LIC500). The following deficiency were cleared during the visit: 87412(a)(4). No deficiencies cited. Exit interview and a copy of this report provided.

Other visitJanuary 7, 2026Type B
2 deficiencies

Plain-language summary

During an unannounced follow-up visit on January 7, 2026, inspectors found that five staff members working at the facility were not listed in the required staffing registry and two staff members had not completed required fingerprint clearance. The facility was assessed a $200 civil penalty and given notice that further failure to correct these staffing issues may result in additional penalties.

View full inspector notes

On 01/07/2026 at 10:05 AM, Licensing Program Analyst (LPA) P.Manalo arrived unannounced to conduct a Case Management visit to follow up on the facility's Personnel Report (LIC500) that was emailed to the LPA on 12/30/2025. LPA met with Associate Administrator Arin Sartain, and Administrator, Stephen Zimmerman. Zimmerman gave verbal authorization for Sartain to sign the report. During the visit, LPA reviewed LIC500, staff files, and Guardian roster. LPA observed 5 staff that are not associated with the facility on Guardian and 2 staff members that are not fingerprint cleared. A civil penalty of $200 is assessed on today's date. The deficiencies were observed (see LIC 809D) and cited from the California Code of Regulations, Title 22. Failure to correct deficiencies may result in civil penalties. Exit interview conducted with Sartain. A copy of this report, LIC421BG, and appeal rights provided.

Type BCCR §87355(c)

Regulation

87355(c) A licensee or applicant for a license may request a transfer of a criminal record clearance from one state licensed facility to another, or from Trust Line to a state licensed facility by providing the following documents to the Department: This requirement is not met as evidenced by:

Inspector finding

Based on observation and record review, the licensee did not comply with the section cited above by not having 5 of 5 staff members not associated with the facility which poses a potential safety risk to persons in care.

Type BCCR §87355(e)

Regulation

87355(e)All individuals subject to a criminal record review pursuant to Health and Safety Code Section 1569.17(b) shall prior to working, residing or volunteering in a licensed facility: This requirement is not met as evidenced by:

Inspector finding

Based on observation and record review, the licensee did not comply with the section cited above by not having 2 of 2 staff members fingerprint cleared which poses a potential safety risk to persons in care.

InspectionDecember 17, 2025Type A
4 deficiencies

Plain-language summary

During a routine annual inspection on December 17, 2025, inspectors found several safety and cleanliness problems: medications and hazardous items like knives and cleaning sprays were left unlocked in residents' rooms, a bathroom toilet was heavily soiled with feces and a diaper left in the sink, one staff member was below the required age, and inspectors discovered bugs in dry food storage and fruit flies in the kitchen. The facility's lighting, temperature, grab bars, fire safety equipment, and emergency procedures were all in acceptable condition. The facility was cited for these violations and given a deadline to correct them.

View full inspector notes

On 12/17/2025 at 9:30 AM, Licensing Program Analysts (LPAs) P. Manalo and K. Nguyen arrived unannounced to conduct 1-Year Annual Required inspection. LPA met with Administrator, Stephen Zimmerman, and explained the purpose of the visit. LPA toured the facility inside and out including but not limited to 6 residents' apartments, bathrooms, activity rooms, kitchen, and courtyards. LPA observe lighting in all rooms is adequate for the comfort and safety of the residents. Hallway temperature was maintained at 75 degrees F. The hot water temperature in a sample of residents shared bathroom were measured at 110.6, 110, 112, 109.8 degrees Fahrenheit. Residents’ bathrooms are equipped with grab bars and non-skid shower pans. There is a minimum of one week supply of nonperishable and 2-day of perishable foods. Smoke detectors and carbon monoxide detectors were in operating condition during visit. Fire extinguisher was last serviced on 08/07/2025. Emergency disaster drill was last conducted on 12/03/2025. At 10:31 AM, LPA reviewed 7 residents records. At 11:20 AM, LPA reviewed 7 staff records and 6 of 7 have current first aid training. LPA reviewed a sample of resident’s medications. Continue to LIC809-C... 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Continue from LIC809... THE FOLLOWING DEFICIENCIES WERE OBSERVED DURING VISIT: At 12:45 PM, LPAs observed unlocked medications such as Systane eyedrops, knife, Lysol spray, etc. in R3’s room and Probiotic, Airborne, and Clean Smart Disinfectant Spray in R4’s room. At 12:53 PM, LPAs observed R5's bathroom toilet covered in feces and a diaper was left in the sink. At 2:53 PM, LPAs observed that S5 is under the age requirements. At 12:24 PM, LPAs observed multiple bugs in the flour and tempura flakes. LPAs observed fruit flies around the kitchen. The Facility was cited from the California Code of Regulations, Title 22 and/or Health and Safety Code Failure to correct deficiencies by POC date may result in additional Civil Penalties. Exit interview conducted with Administrator. Appeal Rights and a copy of this report provided.

Type ACCR §87309(a)

Regulation

(a) Except as specified in subsection (b), the licensee shall ensure that disinfectants, cleaning solutions, poisonous substances, knives, matches, tools, sharp objects, and other similar items which could pose a danger to residents are in locked storage and are not left unattended if outside the locked storage.

Inspector finding

Based on observations at 12:45 PM and record review, the licensee did not comply with the section cited above by having unlocked medications such as Systane eyedrops, knife, Lysol spray, etc. in R3’s room and Probiotic, Airborne, and Clean Smart Disinfectant Spray in R4’s room which poses an immediate health and safety risk to persons in care. POC Due Date: 12/18/2025 Plan of Correction 1 2 3 4 The Administrator agrees to review residents’ physician reports and remove the items in the room. P…

Type ACCR §87555(b)(27)

Regulation

(b) The following food service requirements shall apply: (27) All kitchen areas shall be kept clean and free of litter, rodents, vermin and insects.

Inspector finding

Based on observation at 12:24 PM, the licensee did not comply with the section cited above in having multiple bugs found in the flour, tempura flakes, and having fruit flies around the kitchen area which poses a potential safety risk to persons in care. POC Due Date: 12/18/2025 Plan of Correction 1 2 3 4 The Administrator will call the pest company and discard the items found with bugs. Proof of correction will be sent to CCLD by POC date.

Type BCCR §87303(a)(1)

Regulation

(a) The facility shall be clean, safe, sanitary and in good repair at all times. Maintenance shall include provision of maintenance services and procedures for the safety and well-being of residents, employees and visitors. (1) Floor surfaces in bath, laundry and kitchen areas shall be maintained in a clean, sanitary, and odorless condition.

Inspector finding

Based on observations at 12:53 PM, the licensee did not comply with the section cited above by having R5’s toilet covered in feces and diaper left in the bathroom sink which poses a potential safety risk to persons in care. POC Due Date: 12/19/2025 Plan of Correction 1 2 3 4 The Administrator agrees to clean the bathroom and send proof to CCLD by POC date.

Type BCCR §87412(a)(4)

Regulation

(a) The licensee shall ensure that personnel records are maintained on the licensee, administrator and each employee. Each personnel record shall contain the following information: (4) Written verification that the employee is at least 18 years of age, including, but not necessarily limited to, a copy of his/her birth certificate or driver's licen…

Inspector finding

Based on observations and record review at 2:53 PM, the licensee did not comply with the section cited above by having S5 working at the facility under the age requirements which poses a potential safety risk to persons in care. POC Due Date: 12/29/2025 Plan of Correction 1 2 3 4 The Administrator will remove the staff and send an updated LIC500 to CCLD by POC date.

ComplaintOctober 7, 2025· Unsubstantiated
No deficiencies

Inspector: Gregory Clark

Unsubstantiated — the California Department of Social Services (CDSS) investigated and did not find a violation.

Plain-language summary

A complaint alleged that staff were not meeting residents' needs for incontinence care, bathing, and pest control. Investigators reviewed care documentation, toured resident apartments, and interviewed staff and residents; they found no evidence supporting these allegations—care notes showed regular diaper changes, shower schedules were in place and documented, and pest control issues were handled promptly when reported.

View full inspector notes

Allegation: Staff do not ensure residents’ incontinent care needs are being met W1 alleged that R2 is often in a wet diaper when she comes on shift and that he smells of urine. LPA interviewed R2 in the dining room of the facility. R2 was in a good mood and enjoying his lunch. LPA observed R2 to be order free. LPA also toured R2’s apartment at the facility and observed a urinal by R2’s bedside and a pile of chucks at the foot of his bed. R2’s care plan states that R2 is a “Level 3” for incontinence care meaning his diaper is changed every 2 hours. LPA reviewed R2’s care notes which document that R2’s is receiving a high level of care on a daily basis. S2 stated that she reviews care plans to ensure that staff are following them as written. Allegation: Staff do not ensure residents’ bathing needs are being met W1 did not have any specific information on which residents she felt were not receiving their showers as needed. She felt most of the staff were lazy and not doing their jobs. S1 stated that all of the assisted living residents have shower schedules and staff document that they have given the resident their shower. S1 also stated that he is certain that if a resident did not get a shower as scheduled he would hear about it from the resident or their family and if a shower is missed it gets rescheduled. Allegation: Staff do not ensure facility is kept free of pets S1 stated that from time to time some apartments do have an issue with ants and when told about it S1 alerts the pest control company who come out and spray the affected apartment. In addition, the facility has a contract with the pest control company for regular and routine pest control. LPA toured apartments 112 and 262 and interviewed the residents residing in those apartments, R3 and R4. LPA did not observe any ants in either apartment. Both residents stated that they did have ants and that the facility handled the issue promptly. Both residents were happy with the service they received. This agency has investigated the above allegations. We have found that the complaint was unsubstantiated. Although the allegations may have happened or are valid, there is not a preponderance of evidence to prove the alleged violations did or did not occur, therefore the allegations are UNSUBSTANTIATED . Exit interview conducted, a copy of this report provided.

InspectionDecember 10, 2024
No deficiencies

Inspector: Gregory Clark

Plain-language summary

During a routine annual inspection on December 10, 2024, inspectors found the facility in compliance with all safety and operational standards, including adequate lighting and temperature control, functioning smoke and carbon monoxide detectors, secured medications and hazardous materials, and complete resident and staff records. The facility maintained appropriate food supplies, grab bars and non-skid mats in bathrooms, and a fully stocked first aid kit. No violations were cited.

View full inspector notes

On 12/10/24, Licensing Program Analyst (LPA) Greg Clark arrived unannounced to conduct 1-Year Annual Required inspection. LPA met with Lauren Zimmerman Cook, Administrator and explained the purpose of the visit. LPA toured the facility including but not limited to residents’ apartments, bathrooms, activity rooms, kitchen, common area and courtyard. There are no bodies of water observed. LPA observed lighting in all rooms are adequate for the comfort and safety of the residents. Hallway temperature was maintained at 70 degrees F. The hot water temperature in a hallway bathroom was measured at 107.2 degrees Fahrenheit. Residents’ bathrooms are equipped with grab bars and non-skid mats. There is a minimum of one week supply of nonperishable and 2-day of perishable foods. Centrally stored medications, sharps and toxic are locked and inaccessible to residents in care. Smoke detectors and carbon monoxide detectors were in operating condition during visit. Fire extinguisher was last serviced on 8/28/24. Emergency Disaster Plan was last posted on 12/19/23. First aid kit was observed to be complete. LPA reviewed 5 residents records and 5 staff records, and all were complete. LPA also reviewed a sample of resident’s medications. No deficiencies cited during visit. Exit interview conducted and a copy of this report provided.

InspectionDecember 12, 2023
No deficiencies

Inspector: Gregory Clark

Plain-language summary

A routine annual inspection was conducted on December 12, 2023, and no violations were found. The inspector toured the facility, checked resident apartments, bathrooms, kitchen, and common areas, and confirmed that safety features like smoke detectors, fire extinguishers, grab bars, and locked medication storage were in place and working properly. Staff and resident records were complete, and food supplies were adequate.

View full inspector notes

On 12/12/23 at 10:30 a.m.,Licensing Program Analyst (LPA) Greg Clark arrived unannounced to conduct 1-Year Annual Required inspection. LPA met with Administrator, Marie Ann Lagasca-Cruz and explained the purpose of the visit. The facility’s fire clearance was approved for 120 residents. LPA toured facility including but not limited to 5 resident apartments, bathrooms, kitchen, common area and backyard. All outdoor and indoor passageways are kept free of obstruction. There are no bodies of water observed. A comfortable temperature is maintained at 70 degrees Fahrenheit. LPA observed lighting in all rooms are adequate for the comfort and safety of the residents. The hot water temperature in the residents’ bathrooms was measured at 107.5, 107.8 and 112.5 degrees Fahrenheit. Residents’ bathrooms are equipped with grab bars and non-skid mats. There is a minimum of one week supply of non-perishable and 2 day of perishable foods. Centrally stored medication and sharps were locked and inaccessible to residents. Smoke detectors and carbon monoxide detectors were in operating condition during visit. Fire extinguisher was last serviced on 8/10/23. First aid kit was observed to be complete. LPA reviewed 5 residents records and 5 staff records; all were complete. LPA also reviewed a sample of resident’s medications. Updated copies of the following document was requested for facility file and are to be submitted to CCL by 12/19/23: LIC 610E Emergency Disaster Plan No deficiencies cited during visit. Exit interview conducted and a copy of this report provided.

Other visitJanuary 9, 2023
No deficiencies

Inspector: Gregory Clark

Plain-language summary

An unannounced infection control inspection was conducted on January 9, 2023, and no violations were found. The facility had proper screening procedures at the entrance, adequate supplies of food and protective equipment, staff were wearing appropriate protective gear, and infection control information was posted throughout the facility. The facility maintained records of routine health screenings for residents and staff.

View full inspector notes

On 1/09/23 at 1:35 p.m., Licensing Program Analyst (LPA) Greg Clark arrived unannounced to conduct Infection Control Inspection. LPA met with David Ballerini, Director of Marketing and explained the purpose of the visit. During the Infection Control Inspection, LPA toured facility including but not limited to: front entrance, screening station, bathrooms, bedrooms, common areas, kitchen and backyard. Facility has a sufficient 2-day perishable and one week non-perishable food supply. Visitors policy is posted on the front entrance. There is one central entry point for universal screening for staff, residents and visitors. A sign-in policy, thermometer and hand sanitizer were observed at screening station. Cough/sneeze etiquette, social distancing and hand washing posters were observed. Facility staff were observed to be wearing proper PPE. Facility has a 30-day supply of PPE maintained at central location and easily accessible for staff. Facility has a mitigation plan and maintains record of routine screening for residents and staff. No deficiencies cited during visit. Exit interview conducted and a copy of this report provided.

Other visitNovember 9, 2022
No deficiencies

Inspector: Catherine Lin

Plain-language summary

On November 9, 2022, an unannounced case management visit was conducted to check on residents who had recently moved from Grand Lake Gardens to Waters Edge Lodge. The inspector met with two residents now living at the facility, both of whom reported feeling safe, and found adequate supplies and stable staffing with no immediate health or safety concerns.

View full inspector notes

On 11/9/22 at 11:15AM, Licensing Program Analyst (LPA) C. Lin conducted an unannounced case management visit as a result of receiving residents from Grand Lake Gardens (GLG) and check on residents. LPA met with Marketing Director and explained the purpose of the visit. During visit, LPA obtained Waters Edge Lodge (WEL) staff schedules. Total of 2 residents from GLG are currently living in WEL. 1 resident discharged and moved to Piedmont Gardens on 11/7/22. LPA met with them again, they both stated safe in the facility. Supplies were adequate and staffing is stable. There was no imminent health/safety concerns on today's date. Exit interview conducted with Marketing Director and copy of this report provided.

Other visitNovember 2, 2022
No deficiencies

Inspector: Catherine Lin

Plain-language summary

On November 2, 2022, licensing staff made an unannounced visit to check on three residents who had recently moved from another facility. Staff reviewed schedules, spoke with one resident and her family member who reported satisfaction, and confirmed that food, supplies, and personal protective equipment were adequate.

View full inspector notes

On 11/2/22 at 3:05PM, Licensing Program Analyst (LPA) C. Lin conducted an unannounced case management visit as a result of receiving residents from Grand Lake Gardens (GLG) and check on residents. LPA met with Marketing Director and explained the purpose of the visit. During visit, LPA obtained Waters Edge Lodge (WEL) staff schedules. Total of 3 residents from GLG are currently living in WEL. LPA met with 1 resident who just moved in today and her family member stated that she was happy. Food, paper, PPE supplies were adequate. Exit interview conducted with Marketing Director and copy of this report provided.

ComplaintOctober 28, 2022
No deficiencies

Inspector: Catherine Lin

Plain-language summary

A licensing analyst visited Waters Edge Lodge on October 28, 2022 to check on two residents who had recently moved from another facility. The analyst interviewed both residents, who reported feeling safe and having their needs met, and found adequate food, supplies, and protective equipment with no health or safety concerns at the time of the visit.

View full inspector notes

On 10/28/22 at 2:40PM, Licensing Program Analyst (LPA) C. Lin conducted an unannounced case management visit as a result of receiving residents from Grand Lake Gardens (GLG) and check on residents. LPA met with Marketing Director and explained the purpose of the visit. During visit, LPA obtained Waters Edge Lodge (WEL) staff schedules. Total of 2 residents from GLG had moved in to WEL. LPA interviewed 2 residents who stated that they felt safe living at WEL and their needs were met. Food, paper, PPE supplies were adequate. There was no imminent health/safety concerns on today's date. Exit interview conducted with Marketing Director and copy of this report provided.

Federal summary

CMS Care Compare

Not a CMS-certified facility

California RCFEs (residential care facilities for the elderly) are licensed by the state, not by CMS. CMS data only applies to skilled nursing facilities or to CCRCs that operate a licensed SNF wing.

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