Definitions – systemic deficiency – “violations that demonstrate multiple or repeat defects in the operation of one or more services”

1. 1. 1. Systemic being defined as basically “2 or more” is not a true picture of a systemic issue, especially considering the size of some agencies. For very large agencies, it would be a much higher possibility to be routinely in systemic violation as opposed to a very small agency based on volume of staff and volume of individuals served.