OIG
Avenal State Prison Cycle 7 Medical Inspection Report
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Cycle 7, Avenal State Prison | iii
Contents
Illustrations iv
Introduction 1
Summary: Ratings and Scores 3
Medical Inspection Results 5
Deficiencies Identified During Case Review 5
Case Review Results 5
Compliance Testing Results 6
Institution-Specific Metrics 6
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 13
Access to Care 13
Diagnostic Services 19
Emergency Services 23
Health Information Management 27
Health Care Environment 33
Transfers 41
Medication Management 48
Preventive Services 56
Nursing Performance 59
Provider Performance 64
Specialized Medical Housing 69
Specialty Services 74
Administrative Operations 80
Appendix A: Methodology 83
Case Reviews 84
Compliance Testing 87
Indicator Ratings and the Overall Medical Quality Rating 88
Appendix B: Case Review Data 89
Appendix C: Compliance Sampling Methodology 93
California Correctional Health Care Services’ Response 101
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Illustrations
Tables
1. ASP Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. ASP Master Registry Data as of November 2023 7
3. ASP Health Care Staffing Resources as of November 2023 8
4. ASP Results Compared With State HEDIS Scores 10
5. Access to Care 16
6. Other Tests Related to Access to Care 17
7. Diagnostic Services 21
8. Health Information Management 30
9. Other Tests Related to Health Information Management 31
10. Health Care Environment 39
11. Transfers 45
12. Other Tests Related to Transfers 46
13. Medication Management 53
14. Other Tests Related to Medication Management 54
15. Preventive Services 57
16. Specialized Medical Housing 72
17. Specialty Services 77
18. Other Tests Related to Specialty Services 78
19. Administrative Operations 81
A–1. Case Review Definitions 84
B–1. ASP Case Review Sample Sets 89
B–2. ASP Case Review Chronic Care Diagnoses 90
B–3. ASP Case Review Events by Program 91
B–4. ASP Case Review Sample Summary 91
Figures
A–1. Inspection Indicator Review Distribution for ASP 83
A–2. Case Review Testing 86
A–3. Compliance Sampling Methodology 87
Photographs
1. Indoor Waiting Area 33
2. Disorganized Medical Supplies 34
3. EMRB Expired Supply 35
4. EMRB Compromised Supply 35
5. Ceiling Damage in the Outpatient Housing Unit 37
6. Ceiling Damage in the Receiving and Release Area 37
7. Wound Cleanser 38
8. Wound Cleanser 38
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
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Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector
General (the OIG) is responsible for periodically reviewing and reporting on the delivery
of the ongoing medical care provided to incarcerated people1 in the California
Department of Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in
Cycle 6, including clinical case review and compliance testing. Together, these methods
assess the institution’s medical care on both individual and system levels by providing an
accurate assessment of how the institution’s health care systems function regarding
patients with the highest medical risk, who tend to access services at the highest rate.
Through these methods, the OIG evaluates the performance of the institution in
providing sustainable, adequate care. We continue to review institutional care using
15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection
tool (MIT). In addition, our clinicians complete document reviews of individual cases and
also perform on-site inspections, which include interviews with staff. The OIG
determines a total compliance score for each applicable indicator and considers the MIT
scores in the overall conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course
of caring for a patient. In the event we find errors, we determine whether such errors
were clinically significant or led to a significantly increased risk of harm to the patient.
At the same time, our clinicians consider whether institutional medical processes led to
identifying and correcting individual or system errors, and we examine whether the
institution’s medical system mitigated the error. The OIG rates each applicable indicator
proficient, adequate, or inadequate, and considers each rating in the overall conclusion of
the institution’s health care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single
overall institution rating. This change will clarify the distinctions between these differing
quality measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and
the OIG explicitly makes no determination regarding the constitutionality of care that the department provides
to its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected Healthcare
Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
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As we did during Cycle 6, our office continues to inspect both those institutions
remaining under federal receivership and those delegated back to the department. There
is no difference in the standards used for assessing a delegated institution versus an
institution not yet delegated. At the time of the Cycle 7 inspection of Avenal State Prison,
the institution had been delegated back to the department by the receiver.
We completed our seventh inspection of the institution, and this report presents our
assessment of the health care provided at this institution during the inspection period
from April 2023 to September 2023.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include emergency cardiopulmonary resuscitation reviews for January 2023 and death reviews between
December 2022 and April 2023.
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Summary: Ratings and Scores
We completed the Cycle 7 inspection of Avenal State Prison (ASP) in March 2024. OIG
inspectors monitored the institution’s delivery of medical care that occurred between
April 2023 and September 2023.
The OIG rated the case review The OIG rated the compliance
component of the overall health care component of the overall health care
quality at ASP adequate. quality at ASP inadequate.
OIG clinicians (a team of physicians and nurse consultants) reviewed 46 cases, which
contained 610 patient-related events. They performed quality control reviews; their
subsequent collective deliberations ensured consistency, accuracy, and thoroughness.
Our OIG clinicians acknowledged institutional structures that catch and resolve mistakes
that may occur throughout the delivery of care. After examining the medical records, our
clinicians completed a follow-up on-site inspection in March 2024 to verify their initial
findings. OIG physicians rated the quality of care for 20 comprehensive case reviews. Of
these 20 cases, our physicians rated zero proficient, 19 adequate, and one inadequate.
To test the institution’s policy compliance, our compliance inspectors (a team of
registered nurses) monitored the institution’s compliance with its medical policies by
answering a standardized set of questions that measure specific elements of health care
delivery. Our compliance inspectors examined 379 patient records and 1,081 data points,
and we used the data to answer 90 policy questions. In addition, we observed ASP’s
processes during an on-site inspection in November 2023.
The OIG then considered the results from both case review and compliance testing, and
drew overall conclusions, which we report in 13 health care indicators.5
5 The indicators for Reception Center and Prenatal and Postpartum Care did not apply to ASP.
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We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. ASP Summary Table: Case Review Ratings and Policy Compliance Scores
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Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm. Deficiencies can be
minor or significant, depending on the severity of the deficiency. An adverse event occurs
when the deficiency causes harm to the patient. All major health care organizations
identify and track adverse events. We identify deficiencies and adverse events to
highlight concerns regarding the provision of care and for the benefit of the institution’s
quality improvement program to provide an impetus for improvement.6
The OIG did not find any adverse events at ASP during the Cycle 7 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed 10 of the 13
indicators applicable to ASP. Of these 10 indicators, OIG clinicians rated two proficient,
eight adequate, and none inadequate. OIG physicians also rated the overall adequacy of
care for each of the 20 detailed case reviews they conducted. Of these 20 cases, none were
proficient, 19 were adequate, and one was inadequate. In the 610 events reviewed, we
identified 128 deficiencies, 22 of which OIG clinicians considered to be of such
magnitude that, if left unaddressed, would likely contribute to patient harm.
Our clinicians found the following strengths at ASP:
• The institution provided excellent overall access to providers, nurses, and
diagnostic services.
• ASP nurses often delivered good care for OHU, newly arrived, and hospital
return patients.
• ASP nurses provided good emergency care, frequently performing good
patient assessments, intervention, and documentation as well as responding
promptly to emergencies.
Our clinicians found the following weaknesses at ASP:
• Providers did not always perform thorough subjective or objective
assessments and needed improvement in sending complete patient test result
notification letters.
• Nurses intermittently completed transfer-out requirements for patients.
• Outpatient clinic nurse assessments and interventions needed improvement.
6 For a further discussion of an adverse event, see Table A–1.
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Compliance Testing Results
OIG compliance inspectors assessed 10 of the 13 indicators applicable to ASP. Of these
10 indicators, OIG compliance inspectors rated two proficient, one adequate, and seven
inadequate. We tested policy compliance in Health Care Environment, Preventive
Services, and Administrative Operations as these indicators do not have a case review
component.
ASP showed a high rate of policy compliance in the following areas:
• Staff performed well in offering immunizations and providing preventive
services for their patients, such as influenza vaccinations, annual testing for
tuberculosis, and colorectal cancer screenings.
• Staff performed well in providing TB medications and timely monitoring
patients taking TB medications.
• Staff performed well in scanning initial health care screening forms,
community hospital discharge reports, and specialist reports.
• Nursing staff processed sick call request forms, performed face-to-face
evaluations, and completed nurse-to-provider referrals within required time
frames. In addition, ASP housing units contained adequate supplies of health
care request forms.
ASP showed a low rate of policy compliance in the following areas:
• Nursing staff performed poorly in completing nursing assessments of
patients admitted to the specialized medical housing unit within required
time frames.
• Staff frequently failed to maintain medication continuity for chronic care
patients, patients discharged from the hospital, and patients admitted to
specialized medical housing unit. In addition, ASP maintained poor
medication continuity for patients who had a temporary layover at ASP.
• Providers often did not communicate results of diagnostic services timely.
Most patient letters communicating these results were missing the date of
the diagnostic service, the date of results, and whether the results were
within normal limits.
• Health care staff did not follow hand hygiene precautions before or after
patient encounters.
• Nurses did not regularly inspect emergency response bags.
Institution-Specific Metrics
Avenal State Prison (ASP), located in the city of Avenal, in Kings County, opened in 1987.
ASP is designated as a low- to medium-security institution and currently provides
housing for both general population and sensitive needs incarcerated people. The
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institution operates seven clinics in which staff handle nonurgent requests for medical
services, including six facility clinics and one specialty clinic. ASP also conducts patient
screenings in its receiving and release clinic (R&R), treats patients requiring urgent or
emergent care in its triage and treatment area (TTA), and houses patients who require
assistance with activities of daily living in its outpatient housing unit (OHU). California
Correctional Health Care Services (CCHCS) has designated ASP as a basic care institution.
Basic care institutions are located in rural areas, away from tertiary care centers and
specialty care providers whose services would likely be used frequently by higher-risk
patients. Basic care institutions can provide limited specialty medical services and
consultations for a patient population that is generally healthy.7
As of July 18, 2024, the department reports on its public tracker that 67 percent of ASP’s
incarcerated population is fully vaccinated for COVID-19 while 63 percent of ASP’s staff
is fully vaccinated for COVID-19.
In November 2023, the Health Care Services Master Registry showed that ASP had a total
population of 4,620. A breakdown of the medical risk levels of the ASP population as
determined by the department is set forth in Table 2 below.8
Table 2. ASP Master Registry Data as of November 2023
Medical Risk Level Number of Patients Percentage*
High 1 0 0
High 2 14 0.3%
Medium 1,815 39.3%
Low 2,791 60.4%
Total 4,620 100.0%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk levels were obtained from
the CCHCS Master Registry dated 11-13-23.
7 For more information, see the department’s statistics on its website page titled Population COVID‑19
Tracking.
8 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
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According to staffing data the OIG obtained from California Correctional Health Care
Services (CCHCS), as identified in Table 3 below, ASP had no vacant executive leadership
positions, 2.6 primary care provider vacancies, 2.2 nursing supervisor vacancies, and 16.5
nursing staff vacancies.
Table 3. ASP Health Care Staffing Resources as of November 2023
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 4.0 11.0 11.7 95.6 122.3
Filled by Civil Service 4.0 8.4 9.5 79.1 101.0
Vacant 0 2.6 2.2 16.5 21.3
Percentage Filled by Civil Service 100% 76.4% 81.2% 82.7% 82.6%
Filled by Telemedicine 0 0 0 0 0
Percentage Filled by Telemedicine 0 0 0 0 0
Filled by Registry 0 0 0 3.0 3.0
Percentage Filled by Registry 0 0 0 3.1% 2.5%
Total Filled Positions 4.0 8.4 9.5 82.1 104.0
Total Percentage Filled 100% 76.4% 81.2% 85.9% 85.0%
Appointments in Last 12 Months 1.0 3.0 1.0 21.5 26.5
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 0 0 3.0 3.0
Adjusted Total: Filled Positions 4.0 8.4 9.5 79.1 101.0
Adjusted Total: Percentage Filled 100% 76.4% 81.2% 82.7% 82.6%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes the classifications of Senior Psychiatric Technician and Psychiatric Technician.
‡ In Authorized Positions.
Notes: The OIG does not independently validate staffing data received from the department. Positions are based on
fractional time-base equivalents.
Source: Cycle 7 medical inspection preinspection questionnaire received on November 13, 2023, from California
Correctional
Health Care Services.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
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Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted above, the OIG
presents selected measures from the Healthcare Effectiveness Data and Information Set
(HEDIS) for comparison purposes. The HEDIS is a set of standardized quantitative
performance measures designed by the National Committee for Quality Assurance to
ensure the public has the data it needs to compare the performance of health care plans.
Because the Veterans Administration no longer publishes its individual HEDIS scores,
we removed them from our comparison for Cycle 7. Likewise, Kaiser (commercial plan)
no longer publishes HEDIS scores. However, through the California Department of
Health Care Services’ Medi‑Cal Managed Care Technical Report, the OIG obtained
California Medi-Cal and Kaiser Medi-Cal HEDIS scores to use in conducting our
analysis, and we present them here for comparison.
HEDIS Results
We considered ASP’s performance with population-based metrics to assess the
macroscopic view of the institution’s health care delivery. Currently, only two HEDIS
measures are available for review: poor HbA1c control, which measures the percentage
of diabetic patients who have poor blood sugar control, and colorectal cancer screening
rates for patients ages 45 to 75. We list the applicable HEDIS measures in Table 4.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—ASP’s
percentage of patients with poor HbA1c control was significantly lower, indicating very
good performance on this measure.
Immunizations
Statewide comparative data were not available for immunization measures; however, we
include these data for informational purposes. ASP had a 52 percent influenza
immunization rate for adults 18 to 64 years old. Data for the influenza immunization rate
for adults 65 years of age and older was not available.9 The pneumococcal vaccination rate
was also not available.10
Cancer Screening
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—ASP’s
colorectal cancer screening rate of 60 percent was higher than California Medi-Cal but
9 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable result.
10 The pneumococcal vaccines administered are the 13, 15, and 20 valent pneumococcal vaccines (PCV13,
PCV15, and PCV20), or 23 valent pneumococcal vaccine (PPSV23), depending on the patient’s medical
conditions. For the adult population, the influenza or pneumococcal vaccine may have been administered at a
different institution other than where the patient was currently housed during the inspection period.
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lower than both Kaiser Northern California (Medi-Cal), and Kaiser Southern California
(Medi-Cal).
Table 4. ASP Results Compared With State HEDIS Scores
ASP California California
Kaiser Kaiser
Cycle 7 California NorCal SoCal
HEDIS Measure Results * Medi-Cal † Medi-Cal † Medi-Cal †
HbA1c Screening 94% – – –
Poor HbA1c Control (> 9.0%) ‡,§ 2% 36% 31% 22%
HbA1c Control (< 8.0%) ‡ 95% – – –
Blood Pressure Control (< 140/90) ‡ 89% – – –
Eye Examinations 84% – – –
Influenza – Adults (18 – 64) 52% – – –
Influenza – Adults (65 +) N/A – – –
Pneumococcal – Adults (65 +) N/A – – –
Colorectal Cancer Screening 60% 37% 68% 70%
Notes and Sources
* Unless otherwise stated, data were collected in November 2023 by reviewing medical records from a
sample of ASP’s population of applicable patients. These random statistical sample sizes were based on a
95 percent confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services publication
titled Medi-Cal Managed Care External Quality Review Technical Report, dated July 1, 2022 – June 30, 2023
(published March 2024); https://www.dhcs.ca.gov/dataandstats/reports/Documents/Medi-Cal-Managed-
Care-Technical-Report-Volume-1.pdf.
‡ For this indicator, the entire applicable ASP population was tested.
§ For this measure only, a lower score is better.
Source: Institution information provided by the California Department of Corrections and Rehabilitation.
Health care plan data were obtained from the CCHCS Master Registry.
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Recommendations
As a result of our assessment of ASP’s performance, we offer the following
recommendations to the department:
Diagnostic Services
• The department should develop and implement strategies to ensure
providers create patient letters that contain all elements required by CCHCS
policy when they endorse test results.
Health Care Environment
• Medical and nursing leadership should determine the root cause(s) for staff
not following all required universal hand hygiene precautions and should
implement necessary remedial measures.
• Nursing leadership should determine the root cause(s) for staff not ensuring
the EMRBs are inventoried or stocked appropriately and should implement
necessary remedial measures.
• ASP leadership should determine the root cause(s) for staff not following
adequate protocols for managing and storing bulk medical supplies and
should implement necessary remedial measures.
Transfers
• Nursing leadership should determine the challenges preventing nurses from
thoroughly completing the initial health screening process, including
documenting a complete set of vital signs, answering all questions, and
documenting an explanation for all “yes” answers before the patient is
transferred to the housing unit. Leadership should implement remedial
measures as appropriate.
• Nursing leadership should determine the challenges to ensuring nursing
staff complete screenings of patients transferring to another institution,
including documenting or communicating pending specialty appointments,
and should implement remedial measures as appropriate.
• Nursing leadership and custody staff should collaboratively strategize on
whether their processes require amendments to ensure nurses evaluate and
screen all patients before they transfer out of the institution. Leadership
should implement remedial measures as appropriate.
Medication Management
• The institution should develop and implement measures to ensure staff
timely make available and administer medications to chronic care and
hospital discharge patients, and staff document administering medications
for layover patients in the electronic health record system (EHRS) as
described in CCHCS policy and procedures.
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Nursing Performance
• Nursing leadership should determine the challenges to nurses completing
thorough patient assessments for face-to-face encounters and providing
appropriate interventions and should implement remedial measures as
appropriate.
Specialized Medical Housing
• Nursing and pharmacy leadership should determine the root cause of
challenges to patients receiving all ordered medications within required time
frames and should implement remedial measures as appropriate.
• Nursing leadership should also determine the challenges to staff completing
timely initial RN assessments upon patient admission to specialized medical
housing and should implement remedial measures as appropriate.
Specialty Services
• Medical leadership should determine the challenges to timely providing
specialty appointments and should implement remedial measures as
appropriate.
• Medical leadership should determine the challenges to ensuring specialty
reports are received, scanned, and endorsed in a timely manner and should
implement remedial measures as appropriate.
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Indicators
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing
patients with timely clinical appointments. Our inspectors reviewed scheduling and
appointment timeliness for newly arrived patients, sick calls, and nurse follow-up
appointments. We examined referrals to primary care providers, provider follow-ups, and
specialists. Furthermore, we evaluated the follow-up appointments for patients who
received specialty care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Proficient Adequate (83.3%)
Case review found ASP offered excellent access to care. Providers generally evaluated
patients within the required time frame for primary care appointments, sick-call
referrals, and follow-ups for post-specialty, post-hospitalization, and post-transfer
appointments. Likewise, clinic nursing had no delays with sick call and nurse follow-up
appointments. Both providers and nurses timely assessed specialized medical housing
patients. Considering all factors, the OIG rated the case review component of this
indicator proficient.
ASP’s performance in compliance testing was satisfactory. Access to providers was very
good for newly transferred patients as well as for patients who returned to ASP following
hospitalizations or specialty services appointments. Providers also performed
satisfactorily in timely evaluating patients with chronic care conditions. Nurses
frequently reviewed patient sick call requests within the required time frame. Based on
the overall compliance score result, the OIG rated the compliance component of this
indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 120 provider, nursing, urgent or emergent care (TTA), specialty,
and hospital events requiring the institution to generate appointments. We identified
four deficiencies relating to Access to Care, none of which were significant.11
Access to Care Providers
ASP provided variable access to clinic providers. Compliance testing showed chronic
care face-to-face follow-up appointments frequently occurred timely (MIT 1.001, 84.0 %).
Although compliance testing revealed only half the sick call follow-up provider
appointments occurred timely (MIT 1.006, 50.0%), compliance testing had only two
applicable samples to evaluate. Case review found routine provider and follow-up
11 Deficiencies occurred in cases 8, 13, and 20, none of which were significant.
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provider appointments generally occurred timely. We identified three provider access
deficiencies, none of which were significant.12
Access to Specialized Medical Housing Providers
ASP provided excellent access to specialized medical housing providers. Compliance
testing showed providers always completed history and physical (H&P) examinations
(MIT 13.002, 100%) timely. Similarly, case review identified no deficiencies related to
specialized medical housing provider access.
Access to Clinic Nurses
ASP also provided excellent access to clinic nurses. Compliance testing showed
registered nurses always reviewed patient requests for service within required time
frames (MIT 1.003, 100%), and they frequently assessed patients within one business day
after reviewing a sick call request (MIT 1.004, 90.0%). Our clinicians assessed 45 nursing
sick call requests and identified no deficiencies related to clinic nurse access.
Access to Specialty Services
ASP’s performance in referrals to specialty services varied. Compliance testing showed a
satisfactory completion rate of high-priority specialty services (MIT 14.001, 80.0%).
However, completion of medium-priority specialty services was poor (MIT 14.004, 46.7%),
and completion of routine-priority specialty services needed improvement (MIT 14.007,
73.3%). In contrast, specialist follow-up appointments generally occurred timely for high-
priority (MIT 14.003, 90.9%) and routine-priority specialty appointments (MIT 14.009,
85.7%) and always occurred timely for medium-priority specialty appointments (MIT
14.006, 100%). Case review clinicians found specialty appointments almost always
occurred within requested time frames; we identified only one deficiency, which was not
significant.13
Follow-Up After Specialty Services
Compliance testing revealed most provider appointments after specialty services
occurred within required time frames (MIT 1.008, 79.1%). OIG clinicians identified no
deficiencies related to provider appointments after specialty services.
Follow-Up After Hospitalization
Providers usually evaluated patients after hospitalizations timely. Compliance testing
showed the institution performed satisfactorily in timely providing provider follow-up
appointments following hospitalization (MIT 1.007, 80.0%). Case review identified no
deficiencies in this category.
12 Provider access deficiencies occurred in cases 8, 13, and 20, none of which were significant.
13 A deficiency occurred in case 8. This deficiency was not significant.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
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Follow-Up After Urgent or Emergent Care (TTA)
Providers generally evaluated their patients following a triage and treatment area (TTA)
event as medically indicated. OIG clinicians reviewed 18 TTA events and identified no
delays in provider follow-up.
Follow-Up After Transferring Into ASP
Access to care for patients who had recently transferred into ASP was similar for both
compliance testing and case review. Compliance testing showed the institution offered
very good access to intake appointments for newly arrived patients (MIT 1.002, 91.7%).
Case review did not find any deficiencies in this area; however, we only reviewed three
cases in which patients transferred into ASP from another institution, so the sample was
small.
Clinician On-Site Inspection
OIG clinicians attended all the morning huddles, which included those for patient care
teams and staff. Either all or some members of the executive management team attended
the huddles. ASP had six main clinics: A, B, C, D, E, and F. Clinics A and B, C and D, and
E and F were co-located as pairs, and their staff conducted their morning huddles
together. At the huddles, office technicians from each clinic reported they scheduled
about 10 to 12 appointments for each primary care provider per day.
On the first day of the on-site inspection, OIG clinicians attended the huddle for Clinics
A and B. After this huddle, the patient care team conducted a patient population
management meeting. The chief medical executive (CME) and the care coordinator ran
this meeting with input from the patient care team, the chief executive officer (CEO), the
chief physician and surgeon (CP&S), and the chief nurse executive (CNE). The attendees
pointed to an influx of patients as well as provider vacancies as driving the backlogs.
Even so, they also noted a downward trend in provider backlogs over the previous six
months.
In addition to its main clinics, ASP operated an OHU, a TTA, and specialty clinics. The
specialty clinics included optometry, audiology, orthotics, gastroenterology (colonoscopy
and endoscopy), and physical therapy.
Compliance On-Site Inspection
Five of six housing units randomly tested at the time of inspection had access to health
care services request forms (CDCR form 7362) (MIT 1.101, 83.3 %). In one housing unit,
custody officers did not have a system in place for reordering the forms. Custody officers
reported relying on medical staff to replenish the forms in the housing unit.
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Compliance Score Results
Table 5. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most recent chronic
care visit within the health care guideline’s maximum allowable interval or 21 4 0 84.0%
within the ordered time frame, whichever is shorter? (1.001)
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 22 2 1 91.7%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
30 0 0 100%
for service the same day it was received? (1.003)
Clinical appointments: Did the registered nurse complete a face-to-face visit
27 3 0 90.0%
within one business day after the CDCR Form 7362 was reviewed? (1.004)
Clinical appointments: If the registered nurse determined a referral to a
primary care provider was necessary, was the patient seen within the
11 1 18 91.7%
maximum allowable time or the ordered time frame, whichever is the
shorter? (1.005)
Sick call follow-up appointments: If the primary care provider ordered a
follow-up sick call appointment, did it take place within the time frame 1 1 28 50.0%
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
4 1 0 80.0%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
34 9 2 79.1%
occur within required time frames? (1.008) *
Clinical appointments: Do patients have a standardized process to obtain
5 1 0 83.3%
and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 83.3%
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Avenal State Prison | 17
Table 6. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the N/A N/A N/A N/A
required time frame? (12.003)
For patients received from a county jail: Did the patient receive a history
and physical by a primary care provider within seven calendar days (prior N/A N/A N/A N/A
to 07/2022) or five working days (effective 07/2022)? (12.004)
Was a written history and physical examination completed within the
10 0 0 100%
required time frame? (13.002)
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 12 3 0 80.0%
Request for Service? (14.001)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 10 1 4 90.9%
provider? (14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or the Physician Request 7 8 0 46.7%
for Service? (14.004)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 8 0 7 100%
(14.006)
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician Request 11 4 0 73.3%
for Service? (14.007)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care 6 1 8 85.7%
provider? (14.009)
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 18
Recommendations
The OIG offers no recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 19
Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s performance in timely
completing radiology, laboratory, and pathology tests. Our inspectors determined
whether the institution properly retrieved the resultant reports and whether providers
reviewed the results correctly. In addition, in Cycle 7, we examined the institution’s
performance in timely completing and reviewing immediate (STAT) laboratory tests.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Proficient Inadequate (60.0%)
In this indicator, case review found ASP performed excellently in diagnostic services. We
found ASP staff always timely completed diagnostic testing. Providers timely and
appropriately reviewed test results. As a result, the OIG rated the case review component
of this indicator proficient.
ASP’s overall compliance testing scored low for this indicator. Staff performed very well
in completing radiology and laboratory tests, and providers frequently endorsed
diagnostic results timely. However, ASP staff needed to improve in retrieving pathology
reports timely. Furthermore, providers rarely generated complete patient test result
notification letters with all required elements. Based on the overall compliance score
result, the OIG rated the compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 77 diagnostic related events and found 31 deficiencies related to
health information management, one of which was significant.14
For health information management, we consider test reports that were never retrieved
or reviewed to be as severe a problem as tests that were never performed. We discuss this
further in the Health Information Management indicator.
Test Completion
ASP staff performed very well in completing radiology services (MIT 2.001, 90.0%) and
satisfactorily in completing laboratory services (MIT 2.004, 80.0%) within required time
frames. Compliance testing did not have any STAT laboratory tests in the samples to be
evaluated (MIT 2.007, N/A). Case review found no deficiencies related to test completion.
Health Information Management
Staff retrieved laboratory and diagnostic results promptly and sent them to providers for
review. Compliance testing showed providers frequently endorsed both radiology (MIT
14 Deficiencies occurred in cases 4, 10–16, 18, 19, 21, and 44. A significant deficiency occurred in case 12.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 20
2.002, 90.0%) and laboratory (MIT 2.005, 90.0%) results timely. However, compliance
testing showed ASP had a mixed performance in retrieving and reviewing pathology
reports as well as timely and properly communicating the results. While providers always
reviewed and endorsed pathology reports (MIT 2.011, 100%), staff needed improvement in
retrieving pathology reports (MIT 2.010, 70.0%), and providers never properly
communicated pathology results with complete test result notification letters within
specified time frames (MIT 2.012, zero). Similarly, case review identified 29 deficiencies
related to incomplete, late, or missing results letters, and three deficiencies related to late
or missing provider endorsements.15 We discuss and consider these letter deficiencies
further in the Health Information Management indicator.
Clinician On-Site Inspection
OIG clinicians met with providers, the correctional health services administrator (CHSA),
and the senior laboratory assistant, who reported being fully staffed with no vacancies for
the laboratory and radiology staff during the review period. Although ASP did not have
an on-site laboratory, providers reported no difficulty in obtaining laboratory services
and generally did not order STAT laboratory tests. Instead, providers often sent patients
to a higher level of care when patients clinically required STAT laboratory tests.
The CHSA reported general X-ray, magnetic resonance imaging (MRI), computerized
tomography (CT), and ultrasound (US) examinations as available on-site imaging services.
In addition, the CHSA reported completing low-dose lung cancer screening CT scans
was challenging due to patient refusals.
15 Deficiencies occurred in cases 4, 9–16, 18, 19, 21, and 44. A significant deficiency occurred in case 12.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 21
Compliance Score Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
9 1 0 90.0%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
9 1 0 90.0%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
2 8 0 20.0%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
8 2 0 80.0%
specified in the health care provider’s order? (2.004)
Laboratory: Did the health care provider review and endorse the laboratory
9 1 0 90.0%
report within specified time frames? (2.005)
Laboratory: Did the health care provider communicate the results of the
0 10 0 0
laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and receive
N/A N/A N/A N/A
the results within the required time frames? (2.007)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frames? (2.008)
Laboratory: Did the health care provider endorse the STAT laboratory
N/A N/A N/A N/A
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report within the
7 3 0 70.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
10 0 0 100%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 10 0 0
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 60.0%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Avenal State Prison | 22
Recommendations
• The department should develop and implement strategies to ensure
providers create patient letters that contain all elements required by CCHCS
policy when they endorse test results.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 23
Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Our
clinicians reviewed emergency medical services by examining the timeliness and
appropriateness of clinical decisions made during medical emergencies. Our evaluation
included examining the emergency medical response, cardiopulmonary resuscitation
(CPR) quality, triage and treatment area (TTA) care, provider performance, and nursing
performance. Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) performance in identifying problems with its emergency services.
The OIG assessed the institution’s emergency services solely through case review.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
Similar to Cycle 6, case review determined ASP delivered satisfactory emergency services.
ASP providers and nurses provided good emergency care. We found nursing staff
responded immediately to emergencies and frequently performed good patient
assessments, interventions, and documentation. In addition, EMRRC reviewed
emergency events as required, identified issues, and provided staff training. Overall, the
OIG rated this indicator adequate.
Case Review Results
We reviewed 18 urgent and emergent events and found eight emergency care
deficiencies, two of which were significant.16
Emergency Medical Response
ASP staff responded promptly to emergencies throughout the institution. Our clinicians
reviewed 13 emergency medical events requiring responses from first medical
responders.17 First medical responders frequently performed thorough assessments and
documentation. They mostly intervened as required. The following examples were
exceptions:
• In case 2, OIG clinicians identified a delay in care. In July 2023, the patient
arrived at the prior D Yard clinic, which staff referred to as the “old” clinic,
at 7:30 a.m., complaining of severe left lower abdominal pain and vomiting.
The LVN referred the patient to the D Yard clinic nurse. The patient arrived
at the new D Yard clinic at 8:04 a.m., over 30 minutes later, and the clinic RN
assessed the patient and referred the patient to the TTA for further care. At
10:11 a.m., over two hours later, the patient arrived in the TTA, and the TTA
16 Urgent and emergent events occurred in cases 1–4, 12–16, and 18–21. Deficiencies occurred in cases 1–4, 12
and 13. Significant deficiencies occurred in case 2.
17 First medical responder events occurred in cases 1–4, 12–14, and 19–21.
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Cycle 7, Avenal State Prison | 24
provider evaluated the patient at 10:23 a.m. At 11:00 a.m., over three and a
half hours after the patient’s initial report of symptoms, the patient was
transferred out to a higher level of care via ambulance.
• In case 2, ASP staff activated a medical alarm for a patient with abdominal
pain. However, the LVN first responder did not assess the patient’s level of
pain. In addition, the nurse used an inappropriate mode of transportation to
transfer the patient. The patient with abdominal pain walked from the
housing unit to the clinic and then from the clinic to the TTA, instead of
being transported via wheelchair or gurney.
During our on-site inspection, nursing staff agreed with the above deficiencies and
provided staff training regarding the timely transfer of patients from the clinic to the
TTA and the use of the appropriate mode of transportation for patients experiencing
severe pain.
Cardiopulmonary Resuscitation Quality
OIG clinicians reviewed two cases in which staff initiated CPR.18 Custody and nursing
staff initiated CPR without delay and notified emergency medical services and TTA staff
as required. In both cases, nurses applied the AED promptly, administered Narcan, and
continued CPR until EMS arrived. We did not identify any significant deficiencies related
to CPR events.
Provider Performance
ASP providers performed well in urgent and emergent situations, and in after-hours care.
Providers usually made accurate diagnoses, completed documentation, and made
appropriate triage decisions. Our clinicians identified three deficiencies related to
emergency care, none of which were significant.19
Nursing Performance
Overall, TTA nurses performed well during emergency events. They frequently
completed thorough patient assessments, provided appropriate and timely interventions
during emergencies, and notified the provider as required. We identified one significant
deficiency as detailed below:
• In case 2, staff activated a medical alarm for a patient with abdominal pain.
The first medical responder and the clinic nurse assessed the patient.
However, when the patient arrived in the TTA, the TTA nurse did not
perform a patient assessment.
Nursing Documentation
TTA nurses and first medical responders often thoroughly documented emergency
events, including event timelines. While case review identified some deficiencies, the
18 CPR events occurred in cases 3 and 4.
19 Emergency deficiencies occurred in cases 1 and 13.
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Cycle 7, Avenal State Prison | 25
deficiencies did not affect overall patient care.20 Examples of missing nursing
documentation included medication administration, patient response to Narcan, the time
the patient left the TTA, and the nursing protocol used.
Emergency Medical Response Review Committee
Our clinicians reviewed nine EMRRC cases and found the EMRRC met monthly and
reviewed emergency response care within required time frames.21 Required staff
performed timely clinical reviews, frequently identified opportunities for improvement,
and provided staff training. In contrast, compliance testing showed the EMRRC event
checklists were often incomplete, and in a few cases, the institution did not review the
emergency event within the required time frame (MIT 15.003, 25.0%).
Clinician On-Site Inspection
TTA staff reported nursing morale was good, and they worked well with custody staff.
They did not have any issues with supplies, equipment, or pharmacy. We also interviewed
the supervising registered nurse (SRN) who was covering for this area. The SRN reported
TTA staff had good teamwork. They had monthly staff meetings during which they
provided needed staff training and addressed any new concerns. The SRN expressed
having great, very supportive administrative leadership.
At the time of our inspection, the TTA had two beds and two emergency response
vehicles. The TTA was staffed with two nurses on each shift. The second shift had a
medical assistant assigned to the TTA. One provider was assigned to the TTA with on-
call provider coverage for nonbusiness hours. Providers also performed special
procedures, such as wound care and toenail removals in the TTA.
At ASP, the medication LVNs are the first responders to emergencies. They gather
information and notify TTA staff if TTA nursing response is needed.
20 TTA nursing documentation deficiencies occurred in cases 2–4 and 12.
21 Cases 1–4, 12, 14, 16, and 19 had EMRRC events.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
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Recommendations
We offer no specific recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 27
Health Information Management
In this indicator, OIG inspectors evaluated the flow of health information, a crucial link
in high-quality medical care delivery. Our inspectors examined whether the institution
retrieved and scanned critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical record in a timely
manner. Our inspectors also tested whether clinicians adequately reviewed and endorsed
those reports. In addition, our inspectors checked whether staff labeled and organized
documents in the medical record correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (87.3%)
Case review found ASP performed sufficiently in health information management (HIM).
HIM staff almost always timely retrieved and appropriately processed medical records.
While we identified a pattern of incomplete or delayed patient notification letters, we
found providers often reviewed diagnostic results timely. After reviewing these factors,
the OIG rated the case review component of this indicator adequate.
Compliance testing showed ASP performed very well in this indicator. Staff always
scanned patient health care request forms. They performed exceptionally in scanning,
labeling, and filing medical documents in the appropriate patient file. Although staff
retrieved most hospital records, they needed improvement in timely scanning specialty
reports. Based on the overall compliance score result, the OIG rated the compliance
component of this indicator proficient.
Case Review and Compliance Testing Results
OIG clinicians reviewed 610 events and found 37 deficiencies related to health
information management, three of which were significant.22
Hospital Discharge Reports
Compliance testing showed ASP staff often timely retrieved and scanned hospital records
into the EHRS (MIT 4.003, 80.0%). In addition, hospital reports always contained key
elements, and ASP providers always reviewed them timely (MIT 4.005, 100%). OIG
clinicians reviewed 16 off-site emergency department and hospital encounters and found
one deficiency, which was significant as shown below:
• In case 13, ASP staff scanned the patient’s 52-page hospital report into the
EHRS. However, they did not forward this report to the ASP provider for
review.
22 Deficiencies occurred in cases 4, 9–16, 18–21, 44, and 46. Significant deficiencies occurred in cases 12, 13, and
46.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
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Specialty Reports
ASP had a mixed performance in managing specialty reports. Compliance testing showed
staff needed improvement in retrieval of specialty reports (MIT 4.002, 56.7%) and provider
endorsement of high-priority specialty reports (MIT 14.002, 66.7%). Furthermore,
compliance testing revealed poor performance with provider endorsement of medium-
priority (MIT 14.005, 46.7%) and routine-priority (MIT 14.008, 42.9%) specialty reports.
OIG clinicians reviewed 36 specialty reports and identified five deficiencies, one of which
was significant as follows:23
• In case 46, the maxillofacial surgery dental specialist evaluated the patient at
an off-site follow-up appointment. However, the ASP HIM staff did not
obtain this specialist’s report.
We also discuss these findings in the Specialty Services indicator.
Diagnostic Reports
ASP also had a mixed performance in diagnostic reports management. Compliance
showed providers always reviewed and endorsed pathology reports timely (MIT 2.011,
100%). However, providers performed poorly when communicating pathology results with
patient letters (MIT 2.012, zero). Compliance testing did not have any STAT laboratory
tests in the samples available for its evaluation (MIT 2.007, N/A).
Case review identified 32 deficiencies; 29 related to incomplete, late, or missing results
letters, and three related to late or missing provider endorsements.24 We identified only
one significant deficiency as described below:
• In case 12, the hepatitis B laboratory results were available for review.
However, the provider never reviewed the results.
Additional details are discussed in Diagnostic Services indicator.
Urgent and Emergent Records
OIG clinicians reviewed 18 emergency care events and found ASP nurses and providers
documented these events adequately. Providers also recorded their emergency care
sufficiently, including off-site telephone encounters. Case review identified only one
deficiency related to provider documentation, which was not significant.25 Please refer to
the Emergency Services indicator for additional information regarding emergency care
documentation.
23 Specialty health information management deficiencies occurred in cases 9, 19, 20, and 46. A significant
deficiency occurred in case 46.
24 Deficiencies occurred in cases 4, 9–16, 18, 19, 21, and 44. A significant deficiency occurred in case 12.
25 A deficiency occurred in case 1, which was not significant.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 29
Scanning Performance
Staff performed excellently with the scanning process. Compliance testing showed
perfect scanning, labeling, and filing performance (MIT 4.004, 100%). OIG clinicians
identified two deficiencies related to mislabeled, misfiled, or duplicate medical
documents, neither of which was significant.26
Clinician On-Site Inspection
The OIG physician met with the correctional health services administrator (CHSA) and
the medical records supervisor to discuss HIM processes. The medical records supervisor
described the process of retrieving documents from on-site and off-site reports and
routing them to providers for review. The medical records supervisor reported difficulty
in obtaining reports from cardiology and neurology specialists and having access to the
electronic health records database of only one hospital.
The medical records supervisor relayed the process of ensuring providers reviewed
reports and results timely. HIM staff checked the message center in the EHRS daily. In
addition, the supervisor reviewed a weekly audit of unsigned reports and results. The
supervisor involved the chief medical executive (CME) and the chief physician and
surgeon (CP&S) after the second or third day if no provider had endorsed the report or
result. The supervisor stated providers had no issues with responding timely.
Last, the OIG physician discussed staffing with the CHSA and the medical records
supervisor. They reported the HIM staff vacancies that were present during the case
review period had been filled by the time of the OIG’s inspection.
26 Deficiencies occurred in cases 19 and 20, none of which were significant.
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Cycle 7, Avenal State Prison | 30
Compliance Score Results
Table 8. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s electronic
20 0 10 100%
health record within three calendar days of the encounter date? (4.001)
Are specialty documents scanned into the patient’s electronic health record
17 13 15 56.7%
within five calendar days of the encounter date? (4.002)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 4 1 0 80.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
24 0 0 100.0%
and included in the correct patients’ files? (4.004)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 5 0 0 100.0%
review the report within five calendar days of discharge? (4.005)
Overall percentage (MIT 4): 87.3%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Avenal State Prison | 31
Table 9. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
9 1 0 90.0%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the laboratory
9 1 0 90.0%
report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frame? (2.008)
Pathology: Did the institution receive the final pathology report within the
7 3 0 70.0%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
10 0 0 100%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 10 0 0
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 10 5 0 66.7%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 7 8 0 46.7%
frame? (14.005)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 6 8 1 42.9%
frame? (14.008)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Cycle 7, Avenal State Prison | 33
Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting areas, infection
control, sanitation procedures, medical supplies, equipment management, and
examination rooms. Inspectors also tested clinics’ performance in maintaining auditory
and visual privacy for clinical encounters. Compliance inspectors asked the institution’s
health care administrators to comment on their facility’s infrastructure and its ability to
support health care operations. The OIG rated this indicator solely on the compliance
score. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall compliance rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (56.6%)
Overall, ASP performed poorly with respect to its health care environment. We found
disorganized medical supplies. In addition, medical supply storage areas contained
unidentified or inaccurately labeled medical supplies. Several clinics did not meet the
requirements for essential core medical equipment and supplies. Staff did not regularly
sanitize or wash their hands during patient encounters. Emergency medical response
bags (EMRB) contained expired medical supplies as well as compromised medical supply
packaging and had not been properly inventoried. Based on the overall compliance score
result, the OIG rated this indicator inadequate.
Compliance Testing
Results
Patient Waiting Areas
We inspected only indoor
waiting areas as ASP had no
outdoor waiting areas.
Health care and custody
staff reported the existing
waiting areas contained
sufficient seating capacity
(see Photo 1). During our
inspection, we did not
observe overcrowding in any
of the clinics’ indoor
waiting areas.
Photo 1. Indoor waiting area (photographed on 11-30-23).
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Cycle 7, Avenal State Prison | 34
Clinic Environment
Nine of 10 applicable clinic environments were sufficiently conducive to the practice of
medical care. They provided reasonable auditory privacy, appropriate waiting areas,
wheelchair accessibility, and nonexamination room workspace (MIT 5.109, 90.0%). In one
clinic, the blood-draw station was within close proximity to the patient waiting area,
which hindered auditory privacy.
Of the 10 clinics we observed, nine contained appropriate space, configuration, supplies,
and equipment to allow their clinicians to perform proper clinical examinations
(MIT 5.110, 90.0%). The remaining clinic had an examination chair with a torn vinyl
cover.
Clinic Supplies
Three of the 10 clinics
followed adequate medical
supply storage and
management protocols (MIT
5.107, 30.0%). We found one
or more of the following
deficiencies in seven clinics:
expired medical supplies;
compromised medical
supplies; unidentified,
inaccurately labeled, or
disorganized medical
supplies (see Photo 2); or
cleaning materials stored
with medical supplies.
Five of the 10 clinics met
requirements for essential
core medical equipment and Photo 2. Disorganized medical supplies (photographed on 11-28-23.
supplies (MIT 5.108, 50.0%).
The remaining five clinics
lacked medical supplies. The
missing items included lubricating jelly and tips for an otoscope. We found the Snellen
eye chart was either placed at an improper distance or missing a clearly established and
identified distance line. Moreover, ASP staff did not properly log the results of the
defibrillator performance test or glucometer quality control test within the last 30 days.
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We examined EMRBs to determine whether they contained all essential items. We
checked whether staff inspected the bags daily and inventoried them monthly. Only three
of the eight EMRBs passed our test (MIT 5.111, 37.5%). We found one or more of the
following deficiencies with five EMRBs: staff had not inventoried the EMRBs when the
seal tags were replaced; EMRBs contained expired or compromised medical supplies (see
Photo 3 and Photo 4, below); and staff failed to accurately log EMRB glucometer daily
quality control performance results.
Photo 3. EMRB expired supply (photographed on 11-28-2023).
Photo 4. EMRB compromised supply (photographed on 11-30-23).
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Medical Supply Management
None of the medical supply storage areas located outside the medical clinics stored
medical supplies adequately (MIT 5.106, zero). The warehouse manager did not monitor
the temperature or maintain a temperature log for medical supplies with manufacturer
temperature guidelines stored in the warehouse.
According to the CEO, the institution did not have any concerns about the medical
supply process. Health care and warehouse managers expressed no concerns about the
medical supply chain or their communication process with the existing system in place.
Infection Control and Sanitation
Staff appropriately, cleaned, sanitized, and disinfected seven of 10 clinics (MIT 5.101,
70.0%). In one clinic, staff did not maintain the cleaning logs. In the other two clinics, we
found unsanitary health care areas.
Staff in four of seven applicable clinics properly sterilized or disinfected medical
equipment (MIT 5.102, 57.1%). In three clinics, staff did not mention disinfecting the
examination table as part of their daily start-up protocol.
We found operating sinks and hand hygiene supplies in the examination rooms in six of
10 clinics (MIT 5.103, 60.0%). The patient restrooms in four clinics lacked either
antiseptic soap or disposable hand towels.
We observed patient encounters in eight clinics. In five clinics, clinicians did not wash
their hands before or after examining their patients, after removing gloves, before
performing a blood draw, or during subsequent regloving (MIT 5.104, 37.5%).
Health care staff in all clinics followed proper protocols to mitigate exposure to blood-
borne pathogens and contaminated waste (MIT 5.105, 100%).
Physical Infrastructure
At the time of our medical inspection, the institution’s administrative team reported no
ongoing health care facility improvement program construction projects. Various areas
had ceiling damage, including the OHU, R&R, and medical warehouse (see Photo 5 and
Photo 6, next page). According to health care management and the plant operations
manager, these damages did not hinder health care services. The plant operations
manager reported the leaks had been repaired and the cosmetic repairs were ongoing
(MIT 5.999).
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 37
Photo 5. Ceiling damage in the
outpatient housing unit
(photographed on 11-30-23).
Photo 6. Ceiling damage in the
receiving and release area
(photographed on 11-28-23).
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 38
Compliance On-Site Inspection and Discussion
In addition to the above findings, in one
clinic, our compliance inspectors found a
wound cleanser for single-patient use
without a label, which had been
prescribed for a specific patient. Staff
reported the cleanser was utilized for
multiple patients (see Photo 7 and
Photo 8).
Photo 7. Wound cleanser
(photographed on 11-28-23).
Photo 8. Wound cleanser
(photographed on 11-28-23).
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 39
Compliance Score Results
Table 10. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately disinfected,
7 3 0 70.0%
cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable invasive
and noninvasive medical equipment is properly sterilized or disinfected as 4 3 3 57.1%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
6 4 0 60.0%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
3 5 2 37.5%
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
10 0 0 100%
borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the medical
supply management process adequately support the needs of the medical 0 1 0 0
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
3 7 0 30.0%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
5 5 0 50.0%
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
9 1 1 90.0%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
9 1 0 90.0%
providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency crash
carts inspected and inventoried within required time frames, and do they 3 5 2 37.5%
contain essential items? (5.111)
Does the institution’s health care management believe that all clinical areas
This is a nonscored test. Please see the
have physical plant infrastructures that are sufficient to provide adequate
indicator for discussion of this test.
health care services? (5.999)
Overall percentage (MIT 5): 56.6%
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 40
Recommendations
• Medical and nursing leadership should determine the root cause(s) for staff
not following all required universal hand hygiene precautions and should
implement necessary remedial measures.
• Nursing leadership should determine the root cause(s) for staff not ensuring
the EMRBs are inventoried or stocked appropriately and should implement
necessary remedial measures.
• ASP leadership should determine the root cause(s) for staff not following
adequate protocols for managing and storing bulk medical supplies and
should implement necessary remedial measures.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 41
Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions.
For newly arrived patients, our inspectors assessed the quality of health care screenings
and the continuity of provider appointments, specialist referrals, diagnostic tests, and
medications. For patients who transferred out of the institution, inspectors checked
whether staff reviewed patient medical records and determined the patient’s need for
medical holds. They also assessed whether staff transferred patients with their medical
equipment and gave correct medications before patients left. In addition, our inspectors
evaluated the performance of staff in communicating vital health transfer information,
such as preexisting health conditions, pending appointments, tests, and specialty
referrals; and inspectors confirmed whether staff sent complete medication transfer
packages to receiving institutions. For patients who returned from off-site hospitals or
emergency rooms, inspectors reviewed whether staff appropriately implemented
recommended treatment plans, administered necessary medications, and scheduled
appropriate follow-up appointments.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (74.5%)
Case review found ASP performed well for the transfer-in process. Receiving and release
(R&R) nurses completed initial health screenings thoroughly, ensured medication
continuity, and scheduled nurse and provider follow-up appointments as required. ASP
also performed very well for hospital returns. Nurses mostly completed good
assessments, and the institution provided continuity of hospital recommended
medications. The transfer-out process, however, needed improvement. Nursing only
sometimes completed the required screening for patients transferring out of the
institution. Factoring in all the information, the OIG rated the case review component of
this indicator adequate.
In compliance testing, ASP’s performance was mixed for this indicator. ASP performed
excellently in completing the assessment and disposition sections of the screening
process. Staff also performed well in medication continuity for newly transferred patients
arriving at ASP. Even so, ASP staff needed to improve in completing the initial health
screening form. Based on the overall compliance score result, the OIG rated the
compliance component of this indicator inadequate.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 42
Case Review and Compliance Testing Results
We reviewed 27 events in 17 cases in which patients transferred into or out of the
institution or returned from an off-site hospital or emergency room. We identified eight
deficiencies, three of which were significant.27
Transfers In
Case review analyzed four events in which patients transferred into the facility from
other institutions. We identified one deficiency, which was not significant.28
Compliance testing showed patients received their medications without interruption
most of the time (MIT 6.003, 82.4%). Case review similarly found patients arriving at ASP
received medications without a break in continuity. Medication continuity for patients
transferring from yard to yard within the institution was also sufficient (MIT 7.005,
84.0%).
OIG clinicians found the R&R nurses completed the initial health screening thoroughly,
scheduled required nurse and provider follow-up appointments, and educated patients as
required. R&R nurses almost always completed the assessment and disposition section of
the initial health screening form (MIT 6.002, 91.7%). However, nurses performed poorly in
completing the initial health screening thoroughly (MIT 6.001, 24.0%). The low score
mostly resulted from incomplete vital signs and nurses not documenting an explanation
when patients answered “yes” to the question asking whether they had ever been treated
for mental illness.
Compliance testing showed providers nearly always evaluated patients who arrived at
ASP within the required time frame (MIT 1.002, 91.7%). However, specialty services
appointments for patients arriving at ASP only intermittently occurred within the
required time frame (MIT 14.010, 50.0%). Specialty appointments at times either did not
occur or were not scheduled timely.
Transfers Out
OIG clinicians reviewed seven transfer-out events and found four deficiencies, two of
which were significant.29 We found nurses intermittently ensured all transfer
requirements were met. The following are examples of significant deficiencies:
• In case 25, the patient transferred out of ASP to Pleasant Valley State Prison.
However, the nurse did not ensure the patient was medically cleared for
transfer. When we discussed this case with nursing leadership, they informed
us custody staff did not bring the patient to the R&R nurse for medical
clearance prior to transfer.
27 Deficiencies occurred in cases 4, 13, 23–25, 44, and 45. Significant deficiencies occurred in cases 13, 25, and
45.
28 Transfer-in events occurred in cases 4, 13, and 22. A deficiency occurred in case 4.
29 Transfer-out events occurred in cases 23–25, and 45. Deficiencies occurred in cases 23–25, and 45. Significant
deficiencies occurred in cases 25 and 45.
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Cycle 7, Avenal State Prison | 43
• In case 45, the patient transferred out of ASP to Kern Valley State Prison.
The nurse did not perform either a transfer screening or COVID-19
screening, did not ensure the patient’s medications were not expiring within
five days, and did not ensure all keep-on-person (KOP) medications were
placed in the transfer packet.30
During our on-site inspection, the institution agreed with the above deficiencies and
provided staff training. Compliance tested three relevant samples and determined staff
always sent required medications, durable medical equipment (DME), and documents
with the transfer packets in each sample (MIT 6.101, 100%).
Case review found opportunities for improvement in nurses documenting and
communicating with the receiving institution about pending specialty appointments.31
Hospitalizations
Patients returning from an off-site hospitalization or emergency room are at high risk for
lapses in care quality. These patients typically experience severe illness or injury. They
require more care and place a strain on the institution’s resources. In addition, because
these patients have complex medical issues, successful health information transfers are
necessary for good quality care. Any transfer lapses can result in serious consequences
for these patients.
Our clinicians reviewed 14 events in 11 cases in which patients returned from off-site
hospitalizations or emergency room encounters. We identified three deficiencies, one of
which was significant.32
Case review found ASP nurses performed excellently. Nurses almost always conducted
thorough patient assessments when patients returned from the hospital. Patients
frequently received provider follow-up appointments timely (MIT 1.007, 80.0%). In
addition, providers always reviewed the hospital discharge documents within required
time frames (MIT 4.005, 100%). Case review identified one significant deficiency related
to reviewing hospital discharge documents. Please refer to the Health Information
Management indicator for further details. Most of the time, ASP staff scanned hospital
or emergency room summary reports into the EHRS and made them available timely
(MIT 4.003, 80.0%).
Results for medication continuity differed between case review and compliance testing.
Case review did not identify any deficiencies related to patients receiving hospital
discharge medications timely. Compliance testing, however, revealed poor results (MIT
7.003, 20.0%). Please refer to the Medication Management indicator for further
discussion.
30 KOP means “keep on person” and refers to medications that a patient can keep and self-administer according
to the directions provided.
31 Documentation and communication of pending specialty appointment deficiencies occurred in cases 23–25.
32 Patients returned from a hospitalization or emergency room encounters occurred in cases 1, 12–16, 19, 21, and
44–46. Deficiencies occurred in cases 13 and 44. A significant deficiency occurred in case 13.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 44
Clinician On-Site Inspection
During our on-site inspection, we interviewed the R&R nurse, who was knowledgeable
about the transfer processes. The R&R staffing consisted of one RN assigned to the
second watch and one to the third watch. Another RN was scheduled from 4:00 a.m. to
12:00 p.m. Staff informed us the number of patients arriving to and transferring out of
ASP recently varied, with an average weekly rate of 60 to 70 patients arriving and 25
patients transferring out. Nursing staff reported one issue they encountered with patient
transfers was missing DME and DME receipts. Nursing stated they had a basic supply of
DME available in the R&R, which they provided to patients as needed. The R&R did not
have an automated drug delivery system (ADDS) available.33 However, the nurse reported
the R&R could obtain medications from the TTA ADDS if needed. The nurse also stated
the R&R had no problems with the pharmacy or equipment and reported good nursing
morale as well as supportive administration.
Compliance On-Site Inspection
R&R nursing staff ensured all three patients transferring out of the institution had their
required medications, transfer documents, and assigned DME (MIT 6.101, 100%).
33 The automated drug delivery system (ADDS), also known as an automated dispensing cabinet, is used to
provide drug security, and tracking for controlled substances to meet all federal and state requirements.
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 45
Compliance Score Results
Table 11. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Did nursing
staff complete the initial health screening and answer all screening 6 19 0 24.0%
questions within the required time frame? (6.001)
For endorsed patients received from another CDCR institution: When
required, did the RN complete the assessment and disposition section of
the initial health screening form; refer the patient to the TTA if TB signs and 22 2 1 91.7%
symptoms were present; and sign and date the form on the same day staff
completed the health screening? (6.002)
For endorsed patients received from another CDCR institution: If the patient
had an existing medication order upon arrival, were medications 14 3 8 82.4%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer packet 3 0 0 100%
required documents? (6.101)
Overall percentage (MIT 6): 74.5%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Avenal State Prison | 46
Table 12. Other Tests Related to Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 22 2 1 91.7%
patient seen by the clinician within the required time frame? (1.002)
Upon the patient’s discharge from the community hospital: Did the patient
receive a follow-up appointment with a primary care provider within the 4 1 0 80.0%
required time frame? (1.007)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 4 1 0 80.0%
(4.003)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 5 0 0 100%
review the report within five calendar days of discharge? (4.005)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient 1 4 0 20.0%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
21 4 0 84.0%
medications continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications 0 2 0 0
administered or delivered without interruption? (7.006)
For endorsed patients received from another CDCR institution: If the
patient was approved for a specialty services appointment at the sending
5 5 0 50.0%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, Avenal State Prison | 47
Recommendations
• Nursing leadership should determine the challenges preventing nurses from
thoroughly completing the initial health screening process, including
documenting a complete set of vital signs, answering all questions, and
documenting an explanation for all “yes” answers before the patient is
transferred to the housing unit. Leadership should implement remedial
measures as appropriate.
• Nursing leadership should determine the challenges to ensuring nursing
staff complete screenings of patients transferring to another institution,
including documenting or communicating pending specialty appointments,
and should implement remedial measures as appropriate.
• Nursing leadership and custody staff should collaboratively strategize on
whether their processes require amendments to ensure nurses evaluate and
screen all patients before they transfer out of the institution. Leadership
should implement remedial measures as appropriate.
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Cycle 7, Avenal State Prison | 48
Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in
administering prescription medications on time and without interruption. The inspectors
examined this process from the time a provider prescribed medication until the nurse
administered the medication to the patient. In addition to examining medication
administration, our compliance inspectors also tested many other processes, including
medication handling, storage, error reporting, and other pharmacy processes.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (55.9%)
Case review found ASP performed satisfactorily, similar to Cycle 6. ASP performed
excellently with new medication prescriptions, chronic care medications, hospital
discharge medications, specialized housing medications, and medication administration.
Factoring in all the information, the OIG rated the case review component of this
indicator adequate.
Compliance testing showed ASP needed improvement with this indicator. ASP scored
low in providing patients with chronic care medications, community hospital discharge
medications, and medications for patients temporarily housed at the institution. ASP
needed further improvement in timely providing medications for patients admitted to the
specialized medical housing unit and thoroughly documenting medication
administration for layover patients in the EHRS. Based on the overall compliance score
results, the OIG rated the compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 129 events in 27 cases related to medications and found nine medication
deficiencies, four of which were significant.34
New Medication Prescriptions
Case review found ASP staff performed excellently with new prescription medications.35
Patients received their newly ordered medications timely. Conversely, compliance testing
revealed only 19 out of 25 patients received their medications within the required time
frames (MIT 7.002, 76.0%).
34 Deficiencies occurred in cases 6, 8, 16, 21, and 44–46. Significant deficiencies occurred in cases 6, 21, and 46.
35 A new medication deficiency occurred in case 16.
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Chronic Medication Continuity
During this review period, case review found ASP’s performance was excellent for
chronic medication continuity.36 Out of 129 events reviewed, we identified only four
deficiencies, three of which were significant as described below:
• In case 6, the patient did not receive his chronic medication, aspirin, during
June, July, and August 2023. The order for the aspirin expired in June 2023
and was not renewed.
• In case 21, during June 2023, the patient did not receive his automatically
refilled cholesterol medication. The medication documentation stated, “Not
done; refill not requested,” despite being ordered to refill automatically.
• In case 46, during the month of May 2023, the patient did not receive his
chronic medication for high cholesterol.
In contrast, compliance testing revealed poor performance for chronic medication
continuity (MIT 7.001, 33.3%). Results showed pharmacy staff were often not timely in
filling and dispensing KOP medications as ordered.
Hospital Discharge Medications
ASP showed insufficient performance for patients receiving their discharge medications
on return from an off-site hospitalization or emergency room encounter (MIT 7.003,
20.0%). The sample size for compliance testing consisted of five patients. One patient
received medication timely. One patient received his blood thinning medication two days
late. The other three patients received their prescribed medications less than two hours
late.
Case review found better performance with hospital discharge medications. We reviewed
14 hospital or emergency room events and did not identify any delays in patients
receiving their hospital discharge medications timely.
Specialized Medical Housing Medications
Patients received their medications without delay upon admission to the outpatient
housing unit (OHU). In reviewing cases involving patients in the OHU, case review found
four deficiencies related to medication management. One of these was significant37 as
explained below:
• In case 21, during September 2023, the patient did not receive his chronic care
medication for high cholesterol.
Compliance testing showed OHU staff performed poorly for medication management
(MIT 13.003, 44.4%). An analysis of the compliance results for the 10-patient sample set
showed patients received their medications several minutes to one day late. Staff
36 Patients did not receive their chronic care medications timely in cases 6, 8, 21, and 46.
37 Deficiencies occurred in cases 21, 44, and 45. A significant deficiency occurred in case 21.
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Cycle 7, Avenal State Prison | 50
administered an ordered antibiotic and Tylenol one day late. Staff delayed less than three
hours in administering the remaining medications.
Transfer Medications
OIG clinicians determined ASP’s performance for transfer medications was excellent.
Case review did not identify any medication deficiencies for patients transferring into or
out of the institution. Compliance testing revealed satisfactory performance (MIT 6.003,
82.4%) for new arrival medications. When patients transferred within the institution,
compliance testing showed good performance (MIT 7.005, 84.0%). Patients mostly
received their medications timely. For patients transferring out of the institution, ASP
always included required medications and documents (MIT 6.101, 100%). In two samples
for patients who were on layover and temporarily housed at ASP, compliance testing
revealed nurses documented on the wrong institution medication administration record
(MAR) summary (MIT 7.006, zero).
Medication Administration
Compliance testing showed nurses performed well in administering tuberculosis (TB)
medications (MIT 9.001, 88.0%) and always monitored patients on TB medications as
required (MIT 9.002, 100%). We did not identify any problems with medication
administration.
Clinician On-Site Inspection
While on site, we interviewed the pharmacist and medication nurses for Yards A and D.
The nurses were knowledgeable about various processes, including KOP medications,
patients transferring to another institution and within the institution, and patient
noncompliance with medications. The nurses reported each yard has two licensed
vocational nurses (LVNs) assigned on the second watch and one LVN on the third watch,
except for Yard A, which has two LVNs assigned on the third watch. The medication
LVNs reported they receive medications timely from the pharmacy.
As LVNs do not carry radios, custody staff notifies the LVNs for medical emergencies.
The second watch LVN staff informed us LVNs were the first medical responders for
medical emergencies in their assigned yards, and they request TTA nurses or call 9-1-1 as
needed. During clinic hours, clinic providers either evaluate patients or refer them to the
TTA for further evaluation.
Medication LVNs reported they worked well with custody staff, found their
administration to be supportive, and believed nursing morale was good.
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in seven of eight
clinic and medication line locations (MIT 7.101, 87.5%). In one location, narcotic
medications were not properly and securely stored as required by CCHCS policy.
ASP appropriately stored and secured nonnarcotic medications in four of eight clinic and
medication line locations (MIT 7.102, 50.0%). In four locations, we observed one or more
of the following deficiencies: nurses did not maintain unissued medication in its original
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Cycle 7, Avenal State Prison | 51
labeled packaging; the treatment cart log had incomplete daily security check entries; and
the medication storge area was unsanitary.
Staff kept medications protected from physical, chemical, and temperature
contamination in four of the eight clinic and medication line locations (MIT 7.103, 50.0%).
In three locations, staff did not consistently record the room and refrigerator
temperatures. In the remaining location, staff did not store internal and external
medications separately.
Staff successfully stored valid, unexpired medications in all applicable medication line
locations (MIT 7.104, 100%).
Nurses exercised proper hand hygiene and contamination control protocols in four of six
applicable locations (MIT 7.105, 66.7%). In two locations, some nurses neglected to wash
or sanitize their hands when required. These occurrences included before each
subsequent regloving and when gloves were compromised.
Staff in all six applicable medication preparation and administration areas showed
appropriate administrative controls and protocols when preparing medications for
patients (MIT 7.106, 100%).
Staff in five of six applicable medication areas used appropriate administrative controls
and protocols when distributing medications to their patients (MIT 7.107, 83.3%). In one
location, the medication nurse did not reliably observe patients while they swallowed
direct observation therapy medications.
Pharmacy Protocols
ASP always followed general security, organization, and cleanliness management
protocols for nonrefrigerated medication stored in its pharmacy (MIT 7.108 and 7.109,
100%).
The institution did not properly store refrigerated or frozen medications in the pharmacy.
We found expired refrigerated medications. As a result, the institution scored zero for
this test (MIT 7.110).
The pharmacist in charge (PIC) did not thoroughly review monthly inventories of
controlled substances in the institution’s clinic and medication storage locations.
Specifically, the PIC or designee did not complete the medication area inspection
checklists (CDCR Form 7477) in one location. In addition, the PIC or designee did not
show evidence that a narcotic discrepancy was investigated. These errors resulted in a
score of zero for this test (MIT 7.111).
We examined nine medication error reports. For two reports, the PIC was not able to
provide a completed pharmacy error follow-up form. For the remaining seven reports, the
PIC did not document the reason why neither the patient nor the provider was notified of
the error. As a result, ASP received a score of zero for this test (MIT 7.112).
Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our inspectors
also follow up on any significant medication errors found during compliance testing. We
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Cycle 7, Avenal State Prison | 52
did not score this test; we provide these results for informational purposes only. At ASP,
the OIG did not find any applicable medication errors (MIT 7.998).
ASP did not have restricted housing units; therefore, we did not determine whether
patients had immediate access to their prescribed rescue medications (MIT 7.999).
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Compliance Score Results
Table 13. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required time frames
6 12 7 33.3%
or did the institution follow departmental policy for refusals or no‑shows? (7.001)
Did health care staff administer, make available, or deliver new order prescription
19 6 0 76.0%
medications to the patient within the required time frames? (7.002)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient within 1 4 0 20.0%
required time frames? (7.003)
For patients received from a county jail: Were all medications ordered by the
institution’s reception center provider administered, made available, or delivered to N/A N/A N/A N/A
the patient within the required time frames? (7.004)
Upon the patient’s transfer from one housing unit to another: Were medications
21 4 0 84.0%
continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily housed
patient had an existing medication order, were medications administered or 0 2 0 0
delivered without interruption? (7.006)
All clinical and medication line storage areas for narcotic medications: Does the
institution employ strong medication security controls over narcotic medications 7 1 2 87.5%
assigned to its storage areas? (7.101)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution properly secure and store nonnarcotic medications in the assigned 4 4 2 50.0%
storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution keep nonnarcotic medication storage locations free of contamination in 4 4 2 50.0%
the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution safely store nonnarcotic medications that have yet to expire in the 8 0 2 100%
assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ and
follow hand hygiene contamination control protocols during medication 4 2 4 66.7%
preparation and medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications for 6 0 4 100%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 5 1 4 83.3%
to patients? (7.107)
Pharmacy: Does the institution employ and follow general security, organization,
1 0 0 100%
and cleanliness management protocols in its main and remote pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
1 0 0 100%
medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
0 1 0 0
medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
0 1 0 0
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting protocols?
0 9 0 0
(7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the OIG This is a nonscored test. Please see the indicator
find that medication errors were properly identified and reported by the institution?
(7.998) for discussion of this test.
Pharmacy: For Information Purposes Only: Do patients in restricted housing units This is a nonscored test. Please see the indicator
have immediate access to their KOP prescribed rescue inhalers and nitroglycerin
medications? (7.999) for discussion of this test.
Overall percentage (MIT 7): 55.9%
Source: The Office of the Inspector General medical inspection results.
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Table 14. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: If the
patient had an existing medication order upon arrival, were medications 14 3 8 82.4%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer- 3 0 0 100%
packet required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
22 3 0 88.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 25 0 0 100%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 4 5 1 44.4%
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• The institution should develop and implement measures to ensure staff
timely make available and administer medications to chronic care and
hospital discharge patients, and staff document administering medications
for layover patients in the electronic health record system (EHRS) as
described in CCHCS policy and procedures.
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Preventive Services
In this indicator, OIG compliance inspectors tested whether the institution offered or
provided cancer screenings, tuberculosis (TB) screenings, influenza vaccines, and other
immunizations. If the department designated the institution as being at high risk for
coccidioidomycosis (Valley Fever), we tested the institution’s performance in transferring
out patients quickly. The OIG rated this indicator solely according to the compliance
score. Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Proficient (87.6%)
ASP performed very well in preventive services. Staff performed well to excellently in
administering and monitoring patients on TB medications, screening patients annually
for TB, offering patients an influenza vaccine for the most recent influenza season, and
offering colorectal cancer screening for patients from ages 45 through 75. In addition,
ASP almost always timely transferred patients at the highest risk for coccidioidomycosis.
However, ASP only occasionally offered required immunizations to chronic care patients.
These findings are set forth in the table on the next page. Based on the overall
compliance score result, the OIG rated the compliance component of this indicator
proficient.
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Compliance Score Results
Table 15. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
22 3 0 88.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 25 0 0 100%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
25 0 0 100%
(9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the patient
23 2 0 92.0%
offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the patient
N/A N/A N/A N/A
offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was patient
N/A N/A N/A N/A
offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care
3 5 17 37.5%
patients? (9.008)
Are patients at the highest risk of coccidioidomycosis (Valley Fever)
24 1 0 96.0%
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 87.6%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Nursing Performance
In this indicator, OIG clinicians evaluated the quality of care delivered by the
institution’s nurses, including registered nurses (RN), licensed vocational nurses (LVN),
psychiatric technicians (PT), certified nursing assistants (CNA), and medical assistants
(MA). Our clinicians evaluated nurses’ performance in making timely and appropriate
assessments and interventions. We also evaluated the institution’s nurses’ documentation
for accuracy and thoroughness. Clinicians reviewed nursing performance across many
clinical settings and processes, including sick call, outpatient care, care coordination and
management, emergency services, specialized medical housing, hospitalizations,
transfers, specialty services, and medication management. The OIG assessed nursing care
through case review only and performed no compliance testing for this indicator.
When summarizing nursing performance, our clinicians understand nurses perform
numerous aspects of medical care. As such, specific nursing quality issues are discussed
in other indicators, such as Emergency Services, Specialty Services, and Specialized
Medical Housing.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
ASP nurses provided good nursing care, which was similar to Cycle 6 findings. Nurses
mostly performed good assessments, intervened timely, and generally documented well.
However, we identified an opportunity for improvement in the outpatient clinic area for
nursing assessments and interventions. Factoring in all the information, the OIG rated
this indicator adequate.
Case Review Results
We reviewed 169 nursing encounters in 44 cases and identified 36 nursing performance
deficiencies, seven of which were significant.38
Outpatient Nursing Assessment and Interventions
A critical component of nursing care is the quality of nursing assessment, which includes
both subjective (patient interviews) and objective (observation and examination)
elements. A comprehensive assessment allows nurses to gather essential information
about their patients and to develop appropriate interventions.
Seventy-eight nursing encounters occurred in the outpatient setting, 44 of which were
sick call requests. In these encounters, our clinicians identified 19 deficiencies, two of
38 We reviewed nursing events in cases 1-4, 6, and 8–48. Deficiencies occurred in cases 2–4, 9, 10, 12, 13, 21, 23–
26, 31, 37, 38, 40, 42–45. Significant deficiencies occurred in cases 2, 10, 12, 25, and 45.
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which were significant.39 Clinic nurses mostly triaged sick calls appropriately, timely
evaluated patients, and performed good patient assessments. They also generally
intervened appropriately and scheduled timely provider follow-up appointments.
However, nursing assessments and interventions showed room for improvement. Case
review found a pattern of missing components for patient assessments and inappropriate
interventions.40 The following are examples:
• In case 12, the clinic nurse assessed the patient during a scheduled follow-up
for a wound evaluation. In this encounter, the patient reported he had started
stuttering three days ago, but the nurse did not notify a provider. The nurse
ordered a provider follow-up within seven days. However, the nurse should
have consulted with a provider the same day. The stuttering was a new
symptom onset and could have been related to a neurologic event, such as a
stroke.
• In case 13, the clinic nurse assessed the patient for hives, redness, and
swelling affecting his lower extremities. However, the nurse did not listen to
the patient’s lung sounds to assess for severe allergic reaction, which could
have led to respiratory distress.
• In case 40, the clinic nurse assessed the patient for a persistent cough, a sore
throat, and pain with swallowing. However, the nurse did not assess the
patient’s throat for further abnormalities.
Outpatient Nursing Documentation
Complete and accurate nursing documentation is an essential component of patient care.
Without proper documentation, health care staff can overlook changes in patients’
conditions. Although outpatient clinic nurses mostly documented well, we identified a
pattern of missing documentation.41 The following are examples:
• In case 12, the clinic nurse assessed the patient for complaints of pain in
both feet. The nurse documented a provider follow-up within 14 days.
However, the nurse did not place an order for the provider follow-up.
• In case 43, the clinic nurse assessed the patient for chest pain, performed an
EKG, and used the nursing protocol for chest wall pain.42 However, the nurse
did not place an order for the EKG.
39 We reviewed nursing sick call events in cases 4, 8–15, 18–20, and 26–43. Deficiencies occurred in case 2, 4, 9,
10, 12, 13, 26, 31, 37, 38, 40, 42, and 43. Significant deficiencies occurred in case 12.
40 Incomplete nursing assessments occurred in cases 12, 13, 31, 37, 38, 40, and 41. Clinic nurses did not
intervene appropriately in cases 2 and 12.
41 Outpatient documentation deficiencies occurred in cases 4, 9, 10, 12, 26, 42, and 43.
42 An EKG is an electrocardiogram. This non-invasive test measures and records the electrical impulses from
the heart and is used to help diagnose heart problems.
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Wound Care
We reviewed four cases involving wound care orders. Nurses frequently performed
wound care as ordered.43
Emergency Services
We reviewed 18 urgent or emergent events. Overall, nurses responded promptly to urgent
and emergent events, performed good assessments, mostly intervened as required, and
documented well. Please refer to the Emergency Services indicator for further
discussion.
Hospital Returns
We reviewed 14 events involving patient returns from off-site hospitals or emergency
rooms. ASP nurses frequently performed good nursing assessments and documented
well, which we detailed further in the Transfers indicator.
Transfers
We reviewed 11 events involving transfer-in and transfer-out processes. ASP nurses
evaluated patients appropriately and initiated provider appointments within required
time frames. However, when patients transferred out of the institution, nurses did not
always ensure all transfer requirements were met. Please refer to the Transfers indicator
for further details.
Specialized Medical Housing
We reviewed 25 nursing events. OHU nurses performed well with patient assessments,
communicated with the provider as required, and provided good documentation. For
details, please refer to the Specialized Medical Housing indicator.
Specialty Services
OIG clinicians reviewed 28 events in which patients returned from off-site specialty
appointments.44 ASP nurses generally performed well. They frequently performed good
assessments, reviewed specialty recommendations, and scheduled provider follow-up
appointments as required. We identified three deficiencies, one of which was significant.
Please refer to the Specialty Services indicator for further discussion.
Medication Management
OIG clinicians examined 129 events involving medication management. ASP performed
well in this area. We identified nine deficiencies, four of which were significant. For
further details, please refer to the Medication Management indicator.
43 Wound care occurred in cases 4, 13, 16, 20, and 26. A deficiency occurred in case 26.
44 Specialty services nursing encounters occurred in cases 1, 9, 10, 15, 17–21, and 44–46. Deficiencies occurred in
cases 10 and 44. A significant deficiency occurred in case 10.
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Clinician On-Site Inspection
We inspected various areas including the TTA, the OHU, outpatient clinics, R&R, and
medication areas. Clinical staff in each area were knowledgeable about processes
pertaining to their areas. We attended well-organized huddles. Nursing and medical staff
were familiar with their patients, and all staff participated in discussions regarding
patient care. Medication nurses also attended morning huddles and relayed medication
concerns to providers. In addition, we interviewed nurses, supervisors, and nursing
leadership. Staff reported nursing morale was generally good, they felt supported by their
supervisors and nursing leadership, and they had good relationships with custody staff.
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Recommendations
• Nursing leadership should determine the challenges to nurses completing
thorough patient assessments for face-to-face encounters and providing
appropriate interventions and should implement remedial measures as
appropriate.
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Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of care delivered by the
institution’s providers: physicians, physician assistants, and nurse practitioners. Our
clinicians assessed the institution’s providers’ performance in evaluating, diagnosing,
and managing their patients properly. We examined provider performance across several
clinical settings and programs, including sick call, emergency services, outpatient care,
chronic care, specialty services, intake, transfers, hospitalizations, and specialized
medical housing. We assessed provider care through case review only and performed no
compliance testing for this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
Similar to Cycle 6, ASP providers continued to deliver good care in this cycle. Providers
usually made proper assessments, ordered appropriate follow-up appointments, and
referred patients to specialists as medically indicated. They referred patients to a higher
level of care when necessary and managed chronic medical conditions effectively.
Although we identified a pattern of incomplete patient notification letters, these
deficiencies were not significant. Overall, the OIG rated this indicator adequate.
Case Review Results
OIG clinicians reviewed 106 medical provider encounters and identified 40 deficiencies,
seven of which were significant.45 In addition, our clinicians examined the quality of care
in 20 comprehensive case reviews. Of these 20 cases, we found 19 adequate and one
inadequate.46
Outpatient Assessment and Decision-Making
Providers generally made appropriate assessments and sound decisions for their patients.
Most of the time, they took good histories, formulated differential diagnoses, ordered
appropriate tests, provided care with the correct diagnosis, and referred patients to
proper specialists when needed. However, case review identified 32 deficiencies related
to an incorrect diagnosis, insufficient assessments, not ordering appropriate follow-up,
and poor decision-making.47 Six significant deficiencies are described below:
45 Deficiencies occurred in cases 1, 2, 4–7, 9, 10, 12, 13, 16–21, and 26. Significant deficiencies occurred in cases
2, 6, 9, 10, 13, 18, and 20.
46 We rated case 13 inadequate.
47 The provider did not make a correct diagnosis in case 17. Providers performed insufficient examinations in
cases 1, 4, 7, 9, 10, 12, 13, 16, and 18–21. Providers did not order appropriate follow-up in cases 5 and 13.
Providers made questionable or poor decisions in cases 2, 13, and 17. Significant deficiencies occurred in cases
2, 9, 19, and 20.
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• In case 2, the provider evaluated the patient at a follow-up appointment after
the patient’s emergency room encounter. The patient’s emergency room
laboratory tests showed an abnormally elevated kidney function. However,
the provider did not order a recheck of the patient’s kidney function
laboratory test to ensure continued improvement.
• In case 9, the provider evaluated the patient at a follow-up appointment to
discuss the patient’s lung CT scan results. However, the provider did not
perform a subjective and objective assessment and did not review vital signs.
• In case 10, the provider evaluated the patient at a chronic care appointment
for abnormal laboratory tests results follow-up. The patient had a history of
pancytopenia and had a pending appointment with the hematology
specialist.48 However, the provider did not perform a subjective examination
to inquire about signs of bleeding and did not complete an objective
examination of the patient. In addition, the provider did not review the
patient’s vital signs.
• In case 13, the provider evaluated the patient at a chronic care and nurse co-
consultation appointment for the patient’s, “persistent right foot pain and
swelling secondary to abscess.” The provider documented the patient as
having, “significant swelling and area of erythema approximately 7 to 8 cm
with a large central bulla and straight incision line.”49 The patient reported
having self-performed the incision on the affected area. Despite the
significance of these findings and the risk for severe infection, the provider
did not order an appointment for a close follow-up, review vital signs, or
review medications.50
• In case 18, the nurse co-consulted with the provider about the patient’s
complaints of dizziness, headache, and hot flashes. The nurse ordered an
episodic care appointment to occur that same day with the provider.
However, the provider only reviewed orthostatic vital signs and did not
otherwise perform an objective assessment of the patient to further evaluate
these complaints.
• In case 20, the provider evaluated the patient to follow up on the patient’s
appointment with an orthopedic specialist. The specialist recommended the
patient have a cervical spine MRI to evaluate for cervical radiculopathy.51
However, the provider did not perform a subjective or objective examination
to evaluate for cervical radiculopathy and did not consider ordering the MRI.
48 Pancytopenia is a medical condition in where all types of blood cells are low, including white blood cells, red
blood cells, and platelets. A hematology specialist evaluates and treats disorders of the blood.
49Erythema is redness of the skin caused by dilation of the capillary blood vessels. A bulla is a blister or sac
containing fluid.
50 The risk of infection is increased when a patient attempts to make an incision without proper medical
training, sanitized equipment, and sterile environment.
51 Cervical radiculopathy is a medical condition in which a pinched nerve in the neck causes tingling, pain,
numbness, or weakness in the arm or hand.
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Outpatient Review of Records
Providers usually reviewed medical records carefully. Our clinicians identified only one
deficiency involving a specialty report, which was not significant.52
Emergency Care
Providers made appropriate triage decisions when patients arrived at the TTA for
emergency treatment. However, although providers were available for consultation with
TTA nursing staff, they did not always document progress notes, order appropriate
follow-up timely, or perform an adequate physical examination. Our clinicians identified
three deficiencies related to emergency care, none of which were significant.53
Chronic Care
Providers usually performed well in managing chronic medical conditions, such as
hypertension, diabetes, asthma, hepatitis C infection, and cardiovascular diseases. We
identified four deficiencies involving chronic care.54 The following deficiency was a
significant example:
• In case 6, the provider evaluated the patient at a chronic care appointment
and documented the patient’s elevated diabetic test result. The provider
decreased the patient’s metformin total daily dosage and stopped the
patient’s glipizide prescription.55 Due to the patient’s uncontrolled diabetes,
these medication changes increased the risk of worsening the overall blood
sugar level, affecting its control.
Specialized Medical Housing
Providers appropriately completed OHU admission H&P examinations thoroughly and
timely. They also evaluated patients at clinically appropriate intervals and made
appropriate assessments, sound decisions, and regular follow-up appointments. We
found four minor deficiencies related to incomplete examinations.56
Specialty Services
Providers appropriately referred patients for specialty consultations when needed. When
specialists made recommendations, providers followed recommendations appropriately
and communicated with the specialists as needed. We found no deficiencies related to the
untimely review of specialty reports.
We discuss providers’ specialty performance further in the Specialty Services indicator.
52 The deficiency occurred in case 8, which was not significant.
53 A deficiency in emergency care documentation occurred in case 1. A deficiency about not ordering
appropriate follow-up occurred in case 13. A deficiency about not performing an adequate physical examination
occurred in case 13.
54 Deficiencies occurred in cases 1, 4, 6. A significant deficiency occurred in case 6.
55 Metformin and glipizide are diabetic medications used to treat diabetes and reduce blood sugar.
56 The deficiencies occurred in case 21.
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Documentation Quality
Documentation is important because it shows the provider’s thought process during
clinical decision-making. When contacted by nurses, providers frequently documented
the interactions. Our clinicians found only three undocumented interactions.57 In these
three undocumented interactions, nurses co-consulted with providers.
Patient Notification Letters
Providers needed improvement in relaying diagnostic test results to their patients as they
did not send patient notification letters or sent incomplete patient notification letters.
These deficiencies are discussed in the Diagnostic Services indicator.
Provider Continuity
Generally, the institution offered good provider continuity. Providers were assigned to
specific clinics and to the OHU to ensure continuity of care.
Clinician On-Site Inspection
The OIG physician met with the CME, the CP&S, and providers. The CME and the CP&S
reported no problems retaining providers and were in the process of hiring more
providers. We asked the CME and the CP&S about providing care at the institution, and
they identified three challenges. First, they described ASP as being located far from
hospitals and specialists. Second, since ASP was a reception center, they explained the
population was in flux, with patients being admitted to the institution and then soon
paroling. Third, the CME and the CP&S identified the ISUDT program as a factor that
contributed to increasing the overall work burden.58
All providers reported high morale and easy access to their CME and CP&S to be able to
voice any concerns. Multiple providers shared the opinion that leadership emphasized
the importance of family and work-life balance. ASP had instituted the four 10-hour days
work week schedule, and providers covered for one another during regularly scheduled
days off.
57 Documentation deficiencies occurred in cases 1, 12, and 26, none of which were significant.
58 ISUDT is the Integrated Substance Use Disorder Treatment program.
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Recommendations
The OIG offers no recommendations for this indicator.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the specialized medical
housing units. We evaluated the performance of the medical staff in assessing,
monitoring, and intervening for medically complex patients requiring close medical
supervision. Our inspectors also evaluated the timeliness and quality of provider and
nursing intake assessments and care plans. We assessed staff members’ performance in
responding promptly when patients’ conditions deteriorated and looked for good
communication when staff consulted with one another while providing continuity of
care. At the time of our inspection, ASP’s specialized medical housing consisted of an
outpatient housing unit (OHU).
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (41.1%)
Case review findings showed ASP performed better in this cycle, compared with Cycle 6,
for medical care of patients in specialized medical housing. Nursing performance
improved as well. OHU nurses frequently completed thorough patient assessments,
notified providers as required, and created good documentation. Providers performed
well and delivered good patient care. When patients were admitted to the OHU, patients
received medications without interruption. Factoring in all the information, OIG rated
the case review component of this indicator adequate.
In compliance testing, ASP performed poorly in this indicator. Although, staff timely
completed H&P examinations, staff needed to improve in completing admission
assessments and in administering medications to newly admitted patients. Due to a
nonfunctional call light system, nursing staff needed to conduct and document 30-minute
patient safety rounds; however, staff did not document entries timely in the safety
rounding log for the call system. Based on the overall compliance score result, the OIG
rated the compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 73 OHU events including 24 provider events and 25 nursing events. Due to
the frequency of nursing and provider contacts in specialized medical housing, we
bundled up to two weeks of patient care into a single event. We identified 11 deficiencies,
one of which was significant.59
Provider Performance
One provider was assigned to the OHU. This provider delivered good care and generally
performed thorough H&P examinations, evaluations, made sound medical plans, and
59 OHU events occurred in cases 14, 15, 18, 19, 21, 44–46. Deficiencies occurred in cases 21, 44, and 45. A
significant deficiency occurred in case 21.
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reviewed test results and consultations timely. Case review identified four minor
deficiencies related to performing an incomplete physical examination, none of which
were significant.60
Nursing Performance
Case review found OHU nurses performed sufficiently. We reviewed 25 nursing events
and identified three deficiencies related to nursing performance, none of which were
significant. Two deficiencies related to missing components of an assessment, and one
related to not obtaining a patient’s weight upon admission.61 OHU nurses frequently
completed thorough patient assessments, notified the provider as required, and
performed good documentation. OHU nurses conducted rounds on patients as required
and ensured patient safety.
Case review found OHU nurses performed initial patient assessments timely.
Compliance testing, however, revealed most initial assessments were not completed
timely (MIT 13.001, 20.0%). They were completed the following day.
Medication Administration
Case review did not identify any deficiencies in administering medications for patients
newly admitted to the OHU.62 Upon admission, patients received their medications
without a break in continuity. Compliance testing, however, found patients newly
admitted to the OHU only occasionally received their medications timely (MIT 13.003,
44.4%). Examples of medications administered up to one day late included an antiviral
medication and an antibiotic.
Case review identified four deficiencies related to medication management in the OHU,
one of which was significant.63 Please refer to the Medication Management indicator for
further discussion.
Clinician On-Site Inspection
While on site, we toured the OHU and interviewed nursing staff and the SRN. The OHU
had 28 beds and was staffed with an RN, a CNA, and an MA on the second watch. The
first and third watches had an LVN. In addition, the third watch had a CNA assigned.
The OHU had a designated provider. The average patient census in the OHU was 11 to
12. During our inspection, the OHU housed one patient. The provider and the RN made
daily patient rounds in the OHU.
The CEO informed us a new nurse call system was to be installed in the OHU. The CEO
expressed hope of a possible renovation to add a medication room in the OHU. At the
time of our inspection, the OHU nurses conducted rounds on patients every 30 minutes.
60 Deficiencies occurred in case 21 four times, none of which were significant.
61 Nursing performance deficiencies occurred in cases 21, 44, and 45.
62 We reviewed patients newly admitted to the OHU in cases 15, 21, 45, and 46.
63 OHU medication management deficiencies occurred in cases 21, 44, and 45. A significant deficiency occurred
in case 21.
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Nursing staff reported they had no issues with supplies, equipment, or pharmacy. Nurses
and the OHU SRN reported a good rapport with custody staff and found their
administrative staff to be supportive and approachable.
Compliance On-Site Inspection and Discussion
During the on-site inspection, the OHU did not have an operational call light
communication system in place (MIT 13.101, N/A). Although the institution had a local
operating procedure in an event the call light system was inoperable, staff in the OHU
did not perform safety checks timely for all patients admitted into the OHU (MIT 13.102,
zero).
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Compliance Score Results
Table 16. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Did the registered nurse complete an initial
2 8 0 20.0%
assessment of the patient on the day of admission? (13.001)
Was a written history and physical examination completed within the
10 0 0 100%
required time frame? (13.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 4 5 1 44.4%
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call 0 0 1 N/A
system? (13.101)
For specialized health care housing (CTC, SNF, hospice, OHU): Do health
care staff perform patient safety checks according to institution’s local 0 1 0 0
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): 41.1%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing and pharmacy leadership should determine the root cause of
challenges to patients receiving all ordered medications within required time
frames and should implement remedial measures as appropriate.
• Nursing leadership should also determine the challenges to staff completing
timely initial RN assessments upon patient admission to specialized medical
housing and should implement remedial measures as appropriate.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. OIG
clinicians focused on the institution’s performance in providing needed specialty care.
Our clinicians also examined specialty appointment scheduling, providers’ specialty
referrals, and medical staff’s retrieval, review, and implementation of any specialty
recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (70.7%)
Case review found ASP performed very well in specialty services. Staff usually provided
specialty services within required time frames. Providers also generally evaluated
patients for follow-up appointments without delay, and specialty-return nursing care was
usually appropriate. However, OIG clinicians identified deficiencies with nursing
performance and health information management. Overall, the OIG rated the case review
component of this indicator adequate.
In this cycle, compliance testing showed ASP needed improvement in specialty services
compared with Cycle 6. Access to specialists ranged from excellent to poor, depending on
the appointment priority. Preapproved specialty referrals for newly arrived patients
occasionally occurred within recommended time frames. In addition, both retrieval of
specialty reports and timely provider endorsements needed significant improvements.
Based on the overall compliance score results, the OIG rated the compliance component
of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 72 events related to specialty services, which included 36 specialty
consultations and procedures and 28 nursing encounters. OIG clinicians identified 10
deficiencies in this category, two of which were significant.64
Access to Specialty Services
ASP’s performance in this area was mixed. Compliance testing showed the institution
performed satisfactorily in completing most high-priority (MIT 14.001, 80.0%) specialty
appointments within required time frames. However, completion of specialty
appointments ordered as medium-priority was poor (MIT 14.004, 46.7%), and routine-
priority appointment work needed improvement (MIT 14.007, 73.3%). In addition,
compliance testing revealed transfer continuity of specialty services was also poor (MIT
64 Deficiencies occurred in cases 8–10, 13, 19, 20, 44, and 46. Significant deficiencies occurred in cases 10 and 46.
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14.010, 50.0%). Case review identified only one deficiency related to timely specialty
appointment completion, which was not significant.65
Provider Performance
Compliance testing showed ASP completed timely provider follow-up appointments after
specialty consultations (MIT 1.008, 79.1%). Case review found providers generally ordered
appropriate specialty consultations and followed specialty recommendations. We
identified no deficiencies related to provider follow-up after specialty services.
Nursing Performance
ASP nurses performed well in assessing patients who returned to the facility from
specialty off-site appointments. We identified two deficiencies related to nursing
assessment, neither of which was significant.66 We identified one significant deficiency
related to ordering a provider follow-up appointment:
• In case 10, the patient returned from an urgent off-site abdominal ultrasound
appointment. The nurse did not order a five-day provider follow-up for the
high-priority off-site appointment.
We discuss this further in the Nursing Performance indicator.
Health Information Management
Compliance testing revealed providers struggled with timely review of specialty reports
for routine-priority (MIT 14.008, 42.9%), medium-priority (MIT 14.005, 46.7%), and high-
priority (MIT 14.002, 66.7%) specialty services. Similarly, ASP staff only intermittently
scanned specialty reports into the EHRS in a timely manner (MIT 4.002, 56.7%).
OIG clinicians identified five deficiencies of different types, such as not sending one
patient a test result notification letter, not timely retrieving or scanning two specialty
reports into the EHRS, not properly labeling one report, and not properly scanning one
specialty report.67 Only one of these deficiencies was significant.68
We discuss this further in the Health Information Management indicator.
Clinician On-Site Inspection
We discussed specialty processes with the supervising registered nurse (SRN) for
specialty services. The SRN described the process for timely completing specialty
appointments. Staff routinely reviewed the specialty services dashboard and discussed
any issues each day. If staff were unable to secure a specific specialty appointment, such
as telemedicine, they would then attempt to secure an off-site face-to-face specialty
appointment. The SRN described challenges to obtaining telemedicine urology and
65 A deficiency occurred in case 8 and was not significant.
66 Two deficiencies occurred in case 44, neither of which was significant.
67 Specialty health information management deficiencies occurred in cases 9, 19, 20, and 46.
68 A significant deficiency occurred in case 46.
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neurology as well as off-site ENT specialty services.69 The SRN also identified ASP’s
remote location as a reason for off-site specialty access difficulties. When the specialty
report did not return with the patient, the off-site nurse would then follow-up with the
specialist within 24 to 48 hours. Afterward, if the nurse was still unable to obtain the
report, the nurse would reach out to the HIM department for assistance.
The specialty services department was staffed with one on-site, one telemedicine, and
one off-site nurse, each of whom cross-trained in one another’s duties. When any of these
nurses were not available, the appeals and utilization management nurses provided
coverage.
69 An ENT specialist is an Ear, Nose, and Throat specialist.
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Compliance Score Results
Table 17. Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive the high-priority specialty service within 14 calendar
days of the primary care provider order or the Physician Request for 12 3 0 80.0%
Service? (14.001)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 10 5 0 66.7%
frame? (14.002)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 10 1 4 90.9%
(14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or Physician Request for 7 8 0 46.7%
Service? (14.004)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 7 8 0 46.7%
frame? (14.005)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 8 0 7 100%
(14.006)
Did the patient receive the routine-priority specialty service within 90
calendar days of the primary care provider order or Physician Request for 11 4 0 73.3%
Service? (14.007)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 6 8 1 42.9%
frame? (14.008)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 6 1 8 85.7%
(14.009)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
5 5 0 50.0%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Did the institution deny the primary care provider’s request for specialty
15 5 0 75.0%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
18 2 0 90.0%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 70.7%
Source: The Office of the Inspector General medical inspection results.
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Table 18. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up visits
34 9 2 79.1%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
17 13 15 56.7%
within five calendar days of the encounter date? (4.002)
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the challenges to timely providing
specialty appointments and should implement remedial measures as
appropriate.
• Medical leadership should determine the challenges to ensuring specialty
reports are received, scanned, and endorsed in a timely manner and should
implement remedial measures as appropriate.
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Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care administrative
processes. Our inspectors examined the timeliness of the medical grievance process and
checked whether the institution followed reporting requirements for adverse or sentinel
events and patient deaths. Inspectors checked whether the Emergency Medical Response
Review Committee (EMRRC) met and reviewed incident packages. We investigated and
determined whether the institution conducted required emergency response drills.
Inspectors also assessed whether the Quality Management Committee (QMC) met
regularly and addressed program performance adequately. In addition, our inspectors
determined whether the institution provided training and job performance reviews for its
employees. We checked whether staff possessed current, valid professional licenses,
certifications, and credentials. The OIG rated this indicator solely based on the
compliance score. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (71.5%)
ASP’s performance was mixed in this indicator. While ASP scored well in some
applicable tests, it needed improvement in several areas. The Emergency Medical
Response Review Committee (EMRRC) intermittently completed the required checklists
and reviewed the cases within required time frames. In addition, the institution
conducted medical emergency response drills with incomplete documentation, missing
required emergency response drill forms, and without participation of custody staff.
Physician managers sporadically completed probationary and annual performance
appraisals in a timely manner. Last, nursing managers did not ensure all newly hired
nurses received the required onboarding. These findings are set forth in the table on the
next page. Based on the overall compliance score results, the OIG rated the compliance
component of this indicator inadequate.
Compliance Testing Results
Nonscored Results
At ASP, the OIG did not have any applicable adverse sentinel events requiring root cause
analysis during our inspection period (MIT 15.001).
We obtained CCHCS mortality case review reporting data. In our inspection, for one
patient, we found no evidence in the submitted documentation the preliminary mortality
report had been completed. The report was overdue at the time of OIG’s inspection (MIT
15.998).
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Compliance Score Results
Table 19. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the This is a nonscored test. Please refer to the
institution meet RCA reporting requirements? (15.001) discussion in this indicator.
Did the institution’s Quality Management Committee (QMC) meet
6 0 0 100%
monthly? (15.002)
For Emergency Medical Response Review Committee (EMRRC) reviewed
cases: Did the EMRRC review the cases timely, and did the incident
3 9 0 25.0%
packages the committee reviewed include the required documents?
(15.003)
For institutions with licensed care facilities: Did the Local Governing Body
(LGB) or its equivalent meet quarterly and discuss local operating N/A N/A N/A N/A
procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during each
watch of the most recent quarter, and did health care and custody staff 0 3 0 0
participate in those drills? (15.101)
Did the responses to medical grievances address all of the patients’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial patient death reports to the
1 0 0 100%
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
10 0 0 100%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
3 6 0 33.3%
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 16 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR), Basic Life
Support (BLS), and Advanced Cardiac Life Support (ACLS) certifications? 2 0 1 100%
(15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy maintain a 5 0 2 100%
valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
Agency (DEA) registration certificates, and did the pharmacy maintain valid 1 0 0 100%
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
0 1 0 0
onboarding and clinical competency training? (15.110)
Did the CCHCS Death Review Committee process death review reports
This is a nonscored test. Please refer to the
timely? Effective 05/2022: Did the Headquarters Mortality Case Review
discussion in this indicator.
process mortality review reports timely? (15.998)
What was the institution’s health care staffing at the time of the OIG This is a nonscored test. Please refer to Table 3
medical inspection? (15.999) for CCHCS-provided staffing information.
Overall percentage (MIT 15): 71.5%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with stakeholders to review
CCHCS policies and procedures, relevant court orders, and guidance developed by the
American Correctional Association. We also reviewed professional literature on
correctional medical care; reviewed standardized performance measures used by the
health care industry; consulted with clinical experts; and met with stakeholders from the
court, the receiver’s office, the department, the Office of the Attorney General, and the
Prison Law Office to discuss the nature and scope of our inspection program. With input
from these stakeholders, the OIG developed a medical inspection program that evaluates
the delivery of medical care by combining clinical case reviews of patient files, objective
tests of compliance with policies and procedures, and an analysis of outcomes for certain
population-based metrics.
We rate each of the quality indicators applicable to the institution under inspection based
on case reviews conducted by our clinicians or compliance tests conducted by our
registered nurses. Figure A–1 below depicts the intersection of case review and
compliance.
Figure A–1. Inspection Indicator Review Distribution for ASP
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Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of
its stakeholders, which continues in the Cycle 7 medical inspections. Below, Table A–1
provides important definitions that describe this process.
Table A–1. Case Review Definitions
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The OIG eliminates case review selection bias by sampling using a rigid methodology.
No case reviewer selects the samples he or she reviews. Because the case reviewers are
excluded from sample selection, there is no possibility of selection bias. Instead,
nonclinical analysts use a standardized sampling methodology to select most of the case
review samples. A randomizer is used when applicable.
For most basic institutions, the OIG samples 20 comprehensive physician review cases.
For institutions with larger high-risk populations, 25 cases are sampled. For the
California Health Care Facility, 30 cases are sampled.
Case Review Sampling Methodology
We obtain a substantial amount of health care data from the inspected institution and
from CCHCS. Our analysts then apply filters to identify clinically complex patients with
the highest need for medical services. These filters include patients classified by CCHCS
with high medical risk, patients requiring hospitalization or emergency medical services,
patients arriving from a county jail, patients transferring to and from other departmental
institutions, patients with uncontrolled diabetes or uncontrolled anticoagulation levels,
patients requiring specialty services or who died or experienced a sentinel event
(unexpected occurrences resulting in high risk of, or actual, death or serious injury),
patients requiring specialized medical housing placement, patients requesting medical
care through the sick call process, and patients requiring prenatal or postpartum care.
After applying filters, analysts follow a predetermined protocol and select samples for
clinicians to review. Our physician and nurse reviewers test the samples by performing
comprehensive or focused case reviews.
Case Review Testing Methodology
An OIG physician, a nurse consultant, or both review each case. As the clinicians review
medical records, they record pertinent interactions between the patient and the health
care system. We refer to these interactions as case review events. Our clinicians also
record medical errors, which we refer to as case review deficiencies.
Deficiencies can be minor or significant, depending on the severity of the deficiency. If a
deficiency caused serious patient harm, we classify the error as an adverse event. On the
next page, Figure A–2 depicts the possibilities that can lead to these different events.
After the clinician inspectors review all the cases, they analyze the deficiencies, then
summarize their findings in one or more of the health care indicators in this report.
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Figure A–2. Case Review Testing
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Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and compliance
inspectors. Analysts follow a detailed selection methodology. For most compliance
questions, we use sample sizes of approximately 25 to 30. Figure A–3 below depicts the
relationships and activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT) questions to
determine the institution’s compliance with CCHCS policies and procedures. Our nurse
inspectors assign a Yes or a No answer to each scored question.
OIG headquarters nurse inspectors review medical records to obtain information,
allowing them to answer most of the MIT questions. Our regional nurses visit and
inspect each institution. They interview health care staff, observe medical processes, test
the facilities and clinics, review employee records, logs, medical grievances, death
reports, and other documents, and obtain information regarding plant infrastructure and
local operating procedures.
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Scoring Methodology
Our compliance team calculates the percentage of all Yes answers for each of the
questions applicable to a particular indicator, then averages the scores. The OIG
continues to rate these indicators based on the average compliance score using the
following descriptors: proficient (85.0 percent or greater), adequate (between 84.9 percent
and 75.0 percent), or inadequate (less than 75.0 percent).
Indicator Ratings and the Overall Medical
Quality Rating
The OIG medical inspection unit individually examines all the case review and
compliance inspection findings under each specific methodology. We analyze the case
review and compliance testing results for each indicator and determine separate overall
indicator ratings. After considering all the findings of each of the relevant indicators, our
medical inspectors individually determine the institution’s overall case review and
compliance ratings.
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Appendix B: Case Review Data
Table B–1. ASP Case Review Sample Sets
Sample Set Total
CTC/OHU 3
Death Review/Sentinel Events 1
Diabetes 3
Emergency Services – CPR 1
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 5
Intrasystem Transfers In 1
Intrasystem Transfers Out 3
RN Sick Call 18
Specialty Services 5
46
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Table B–2. ASP Case Review Chronic Care Diagnoses
Sample Set Total
Anemia 1
Arthritis/Degenerative Joint Disease 3
Asthma 4
COPD 2
COVID-19 3
Cancer 1
Cardiovascular Disease 2
Chronic Kidney Disease 1
Coccidioidomycosis 1
Diabetes 5
Gastroesophageal Reflux Disease 6
Hepatitis C 7
Hyperlipidemia 16
Hypertension 11
Mental Health 21
Sleep Apnea 2
Substance Abuse 10
Thyroid Disease 1
97
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Table B–3. ASP Case Review Events by Program
Diagnosis Total
Diagnostic Services 83
Emergency Care 29
Hospitalization 27
Intrasystem Transfers In 4
Intrasystem Transfers Out 7
Outpatient Care 306
Specialized Medical Housing 73
Specialty Services 81
610
Table B–4. ASP Case Review Sample Summary
Sample Set Total
MD Reviews Detailed 20
MD Reviews Focused 3
RN Reviews Detailed 12
RN Reviews Focused 27
Total Reviews 62
Total Unique Cases 46
Overlapping Reviews (MD & RN) 16
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Appendix C: Compliance Sampling Methodology
Avenal State Prison
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least one
Patients condition per patient — any risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003 – 006 Nursing Sick Call 30 Clinic • Clinic (each clinic tested)
(6 per clinic) Appointment List • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 5 OIG Q: 4.005 • See Health Information Management
Community (Medical Records) (returns from
Hospital community hospital)
MIT 1.008 Specialty Services 45 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 6 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001 – 003 Radiology 10 Radiology Logs • Appointment date
(90 days – 9 months)
• Randomize
• Abnormal
MITs 2.004 – 006 Laboratory 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 0 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology-related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 30 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 5 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for • Any misfiled or mislabeled document
any tested identified during
incarcerated OIG compliance review
person (24 or more = No)
MIT 4.005 Returns From 5 CADDIS off-site • Date (2 – 8 months)
Community Hospital admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101 – 105 Clinical Areas 10 OIG inspector • Identify and inspect all on-site clinical
MITs 5.107 – 111 on-site review areas
Transfers
MITs 6.001 – 003 Intrasystem Transfers 25 SOMS • Arrival date (3 – 9 months)
• Arrived from (another departmental
facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 3 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 • See Access to Care
Medication • At least one condition per patient —
any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of IPs tested in
MIT 7.001
MIT 7.003 Returns From 5 OIG Q: 4.005 • See Health Information Management
Community Hospital (Medical Records) (returns from
community hospital)
MIT 7.004 RC Arrivals — N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2 – 8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 2 SOMS • Date of transfer (2– 8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101 – 103 Medication Storage Varies OIG inspector • Identify and inspect clinical & med
Areas by test on-site review line areas that store medications
MITs 7.104 – 107 Medication Varies OIG inspector • Identify and inspect on-site clinical
Preparation and by test on-site review areas that prepare and administer
Administration Areas medications
MITs 7.108 – 111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 9 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication error
reports (recent 12 months)
MIT 7.999 Restricted Unit N/A at this On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications institution medication listing medications for IPs housed in
restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001 – 007 Recent Deliveries N/A at this OB Roster • Delivery date (2 – 12 months)
institution • Most recent deliveries (within date
range)
Pregnant Arrivals N/A at this OB Roster • Arrival date (2 – 12 months)
institution • Earliest arrivals (within date range)
Preventive Services
MITs 9.001 – 002 TB Medications 25 Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months
or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior to
Annual Screening inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior to
Vaccinations inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior to
Screening inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior to
institution inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs. prior to
institution inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require vaccination(s)
MIT 9.009 Valley Fever 25 Cocci transfer • Reports from past 2 – 8 months
status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001 – 007 RC N/A at this SOMS • Arrival date (2 – 8 months)
institution • Arrived from (county jail, return from
parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001 – 003 Specialized Health 10 CADDIS • Admit date (2 – 8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
• Rx count
• Randomize
MITs 13.101 – 102 Call Buttons 1 OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001 – 003 High-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care / addiction
medication, narcotic treatment
program, and transgender services
• Randomize
MITs 14.004 – 006 Medium-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care/addiction
medication, narcotic treatment
program, and transgender services
• Randomize
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 98
Quality No. of
Indicator Sample Category Samples Data Source Filters
Specialty Services (continued)
MITs 14.007 – 009 Routine-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care/addiction
medication, narcotic treatment
program, and transgender services
• Randomize
MIT 14.010 Specialty Services 10 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – 012 Denials 20 InterQual • Review date (3 – 9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events events report (2 – 8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC 12 EMRRC meeting • Monthly meeting minutes
minutes (6 months)
MIT 15.004 LGB N/A at this LGB meeting • Quarterly meeting minutes
institution minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
MIT 15.103 Death Reports 1 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 99
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations (continued)
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 9 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 16 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site certification • All staff
Response tracking logs • Providers (ACLS)
Certifications • Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
MIT 15.109 Pharmacy and All On-site listing of • All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
document
MIT 15.110 Nursing Staff New All Nursing staff • New employees (hired within last
Employee training logs 12 months)
Orientations
MIT 15.998 CCHCS Mortality 1 OIG summary log: • Between 35 business days &
Case Review deaths 12 months prior
• California Correctional Health Care
Services mortality reviews
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 100
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Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7, Avenal State Prison | 101
California Correctional Health Care Services’
Response
Office of the Inspector General, State of California Inspection Period: April 2023 – September 2023 Report Issued: February 2025
Cycle 7
Medical Inspection Report
for
Avenal State Prison
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
STATE of CALIFORNIA
February 2025
OIG