OIG
California City Correctional Facility Medical Inspection Report Cycle 4
Read the report at CDCR ↗
Robert A. Barton Office of the Inspector General
Inspector General
California City Correctional Facility
Medical Inspection Results
Cycle 4
January 2017
Medical Inspection Unit Page 1
Office of the Inspector General State of California
Office of the Inspector General
CALIFORNIA CITY CORRECTIONAL
FACILITY
Medical Inspection Results
Cycle 4
Robert A. Barton
Inspector General
Roy W. Wesley
Chief Deputy Inspector General
Shaun R. Spillane
Public Information Officer
January 2017
TABLE OF CONTENTS
Executive Summary ............................................................................................................................. i
Overall Assessment: Proficient ............................................................................................. iii
Clinical Case Review and OIG Clinician Inspection Results ............................................... iii
Compliance Testing Results.................................................................................................. iv
Population-Based Metrics ..................................................................................................... ix
Introduction ......................................................................................................................................... 1
About the Institution ........................................................................................................................... 1
Objectives, Scope, and Methodology.................................................................................................. 5
Case Reviews ................................................................................................................................... 6
Patient Selection for Retrospective Case Reviews .................................................................... 6
Benefits and Limitations of Targeted Subpopulation Review .................................................. 7
Case Reviews Sampled ............................................................................................................. 8
Compliance Testing ......................................................................................................................... 9
Sampling Methods for Conducting Compliance Testing .......................................................... 9
Scoring of Compliance Testing Results .................................................................................... 9
Dashboard Comparisons ......................................................................................................... 10
Overall Quality Indicator Rating for Case Reviews and Compliance Testing .............................. 10
Population-Based Metrics .............................................................................................................. 11
Medical Inspection Results ............................................................................................................... 12
Primary (Clinical) Quality Indicators of Health Care .................................................................... 12
Access to Care ......................................................................................................................... 13
Case Review Results ............................................................................................................ 13
Compliance Testing Results................................................................................................. 15
Recommendations ................................................................................................................ 16
Diagnostic Services ................................................................................................................. 17
Case Review Results ............................................................................................................ 17
Compliance Testing Results................................................................................................. 18
Recommendations ................................................................................................................ 18
Emergency Services................................................................................................................. 19
Case Review Results ............................................................................................................ 19
Recommendations ................................................................................................................ 21
Health Information Management (Medical Records) ............................................................. 22
Case Review Results ............................................................................................................ 22
Compliance Testing Results................................................................................................. 23
Recommendations ................................................................................................................ 24
Health Care Environment ....................................................................................................... 25
Compliance Testing Results................................................................................................. 25
Recommendation for CCHCS .............................................................................................. 27
Recommendations for CAC ................................................................................................. 27
California City Correctional Facility, Cycle 4 Medical Inspection Table of Contents
Office of the Inspector General State of California
Inter- and Intra-System Transfers ........................................................................................... 28
Case Review Results ............................................................................................................ 28
Compliance Testing Results................................................................................................. 30
Recommendation ................................................................................................................. 31
Pharmacy and Medication Management ................................................................................ 32
Case Review Results ............................................................................................................ 32
Compliance Testing Results................................................................................................. 34
Recommendations ................................................................................................................ 36
Preventive Services ................................................................................................................. 37
Compliance Testing Results................................................................................................. 37
Recommendations ................................................................................................................ 38
Quality of Nursing Performance ............................................................................................. 39
Case Review Results ............................................................................................................ 39
Recommendations ................................................................................................................ 42
Quality of Provider Performance ............................................................................................ 43
Case Review Results ............................................................................................................ 43
Recommendations ................................................................................................................ 45
Specialty Services .................................................................................................................... 46
Case Review Results ............................................................................................................ 46
Compliance Testing Results................................................................................................. 47
Recommendations ................................................................................................................ 47
Secondary (Administrative) Quality Indicators of Health Care..................................................... 48
Internal Monitoring, Quality Improvement, and Administrative Operations ......................... 49
Compliance Testing Results................................................................................................. 49
Recommendations ................................................................................................................ 51
Job Performance, Training, Licensing, and Certifications ..................................................... 52
Compliance Testing Results................................................................................................. 52
Recommendations ................................................................................................................ 53
Population-Based Metrics .............................................................................................................. 54
Appendix A — Compliance Test Results ......................................................................................... 57
Appendix B — Clinical Data ............................................................................................................ 70
Appendix C — Compliance Sampling Methodology ....................................................................... 73
California Correctional Health Care Services’ Response ................................................................. 80
California City Correctional Facility, Cycle 4 Medical Inspection Table of Contents
Office of the Inspector General State of California
LIST OF TABLES AND FIGURES
Health Care Quality Indicators ........................................................................................................... ii
CAC Executive Summary Table ..................................................................................................... viii
CAC Health Care Staffing Resources as of May 2016 ........................................................................ 2
CAC Master Registry Data as of May 9, 2016 .................................................................................... 3
Commonly Used Abbreviations .......................................................................................................... 4
CAC Results Compared to State and National HEDIS Scores .......................................................... 56
California City Correctional Facility, Cycle 4 Medical Inspection List of Tables and Figures
Office of the Inspector General State of California
EXECUTIVE SUMMARY
Pursuant to California Penal Code Section 6126, which assigns the Office of the Inspector General
(OIG) responsibility for oversight of the California Department of Corrections and Rehabilitation
(CDCR), the OIG conducts a comprehensive inspection program to evaluate the delivery of medical
care at each of CDCR’s 35 adult prisons. The OIG explicitly makes no determination regarding the
constitutionality of care in the prison setting. That determination is left to the Receiver and the
federal court. The assessment of care by the OIG is just one factor in the court’s determination
whether care in the prisons meets constitutional standards. The court may find that an institution the
OIG found to be providing adequate care still did not meet constitutional standards, depending on
the analysis of the underlying data provided by the OIG. Likewise, an institution that has been rated
inadequate by the OIG could still be found to pass constitutional muster with the implementation of
remedial measures if the underlying data were to reveal easily mitigated deficiencies.
The OIG’s inspections are mandated by the Penal Code and not aimed at specifically resolving the
court’s questions on constitutional care. To the degree that they provide another factor for the court
to consider, the OIG is pleased to provide added value to the taxpayers of California.
For this fourth cycle of inspections, the OIG added a clinical case review component and
significantly enhanced the compliance portion of the inspection process from that used in prior
cycles. In addition, the OIG added a population-based metric comparison of selected Healthcare
Effectiveness Data Information Set (HEDIS) measures from other State and national health care
organizations and compared that data to similar results for the California City Correctional Facility
(CAC).
The OIG performed its Cycle 4 medical inspection at CAC from May to July 2016. The inspection
included in-depth reviews of 51 inmate-patient files conducted by clinicians, as well as reviews of
documents from 318 inmate-patient files, covering 86 objectively scored tests of compliance with
policies and procedures applicable to the delivery of medical care. The OIG assessed the case
review and compliance results at CAC using 13 health care quality indicators applicable to the
institution, made up of 11 primary clinical indicators and 2 secondary administrative indicators. To
conduct clinical case reviews, the OIG employs a clinician team consisting of a physician and a
registered nurse consultant, while compliance testing is done by a team of deputy inspectors general
and registered nurses trained in monitoring medical policy compliance. Of the 11 primary
indicators, 6 were rated by both case review clinicians and compliance inspectors, 3 were rated by
case review clinicians only, and 2 were rated by compliance inspectors only; both secondary
indicators were rated by compliance inspectors only. See the Health Care Quality Indicators table
on page ii. Based on that analysis, OIG experts made a considered and measured overall opinion
that the quality of health care at CAC was proficient.
California City Correctional Facility, Cycle 4 Medical Inspection Page i
Office of the Inspector General State of California
Health Care Quality Indicators
All Institutions–
Fourteen Primary Indicators (Clinical) CAC Applicability
Applicability
Both case review
1–Access to Care All institutions
and compliance
Both case review
2–Diagnostic Services All institutions
and compliance
3–Emergency Services All institutions Case review only
4–Health Information Management Both case review
All institutions
(Medical Records) and compliance
5–Health Care Environment All institutions Compliance only
Both case review
6–Inter- and Intra-System Transfers All institutions
and compliance
Both case review
7–Pharmacy and Medication Management All institutions
and compliance
Female institutions
8–Prenatal and Post-Delivery Services Not Applicable
only
9–Preventive Services All institutions Compliance only
10–Quality of Nursing Performance All institutions Case review only
11–Quality of Provider Performance All institutions Case review only
Institutions with
12–Reception Center Arrivals Not Applicable
reception centers
All institutions with
13–Specialized Medical Housing
an OHU, CTC, SNF, Not Applicable
(OHU, CTC, SNF, Hospice)
or Hospice
Both case review
14–Specialty Services All institutions
and compliance
Two Secondary Indicators All Institutions–
CAC Applicability
(Administrative) Applicability
15–Internal Monitoring, Quality
Improvement, and Administrative All institutions Compliance only
Operations
16–Job Performance, Training, Licensing,
All institutions Compliance only
and Certifications
California City Correctional Facility, Cycle 4 Medical Inspection Page ii
Office of the Inspector General State of California
Overall Assessment: Proficient
Based on the clinical case reviews and compliance testing, the
OIG’s overall assessment rating for CAC was proficient. Of the
Overall Assessment
11 primary (clinical) quality indicators applicable to CAC, the
Rating:
OIG found 7 proficient, 4 adequate, and none inadequate. Of the
two secondary (administrative) quality indicators, the OIG found
Proficient
both inadequate. To determine the overall assessment for CAC,
the OIG considered individual clinical ratings and individual
compliance question scores within each of the indicator
categories, putting emphasis on the primary indicators. Based on that analysis, OIG experts made a
considered and measured overall opinion about the quality of health care observed at CAC.
Clinical Case Review and OIG Clinician Inspection Results
The clinicians’ case reviews sampled patients with high medical needs and included a review of 860
patient care events.1 Of the 11 primary indicators applicable to CAC, 9 were evaluated by clinician
case review; 2 were proficient, 7 were adequate, and none was inadequate. When determining the
overall adequacy of care, the OIG paid particular attention to the clinical nursing and provider
quality indicators, as adequate health care staff can sometimes overcome suboptimal processes and
programs. However, the opposite is not true; inadequate health care staff cannot provide adequate
care, even though the established processes and programs onsite may be adequate. The OIG
clinicians identify inadequate medical care based on the risk of significant harm to the patient, not
the actual outcome.
Program Strengths — Clinical
CAC providers delivered good care, making appropriate assessments and sound medical
plans for most patients. The chief medical executive (CME) and the chief physician &
surgeon (CP&S) were committed to patient care and quality improvement.
CAC had an effective specialty services department, and staff had established an effective
tracking process to ensure that patients received their appointments and diagnostic
procedures timely.
CAC provided effective access to care. Each of the three clinics had an office technician
who ensured that all provider and nursing appointments were completed.
CAC nursing staff and the interdisciplinary team had a valuable structured daily huddle. The
teams worked cooperatively to provide integrated primary care to patients. Each clinic was
1 Each OIG clinician team includes a board-certified physician and registered nurse consultant with experience in
correctional and community medical settings.
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Office of the Inspector General State of California
adequately staffed with two registered nurses (RNs) and two licensed vocational nurse
(LVN) care coordinators.
CAC nursing staff, custody, and office technicians maintained positive morale and felt they
had a constructive working relationship with nursing leadership. All the providers expressed
general job satisfaction with their positions.
Program Weaknesses — Clinical
There were two areas, the triage and treatment area (TTA) and the receiving and release
clinic (R&R), where the CAC nursing leadership team showed room for improvement in
monitoring and evaluating staff and improving the process of patient education and training.
This was evident with patients returning from outside hospitals, such as those who had
undergone invasive procedures, such as a cardiac catheterization. Some of these patients did
not receive any aftercare instructions. The TTA staff received and reviewed requests for
health care services, and there were cases in which nursing staff failed to recognize the need
to intervene emergently, resulting in delays of treatment.
Compliance Testing Results
Of the 13 health care indicators applicable to CAC, 10 were evaluated by compliance inspectors.2
There were 86 individual compliance questions within those 10 indicators, generating 981 data
points, which tested CAC’s compliance with California Correctional Health Care Services
(CCHCS) policies and procedures.3 Those 86 questions are detailed in Appendix A — Compliance
Test Results. The institution’s inspection scores in the 10 applicable indicators ranged from
58.3 percent to 95.0 percent, with the secondary indicator Job Performance, Training, Licensing,
and Certifications receiving the lowest score, and the primary indicator Preventive Services
receiving the highest. Of the eight primary indicators applicable to compliance testing, the OIG
rated seven proficient, one adequate, and none inadequate. Of the two secondary indicators, which
involve administrative health care functions, both were rated inadequate.
Program Strengths — Compliance
As the CAC Executive Summary Table on page viii indicates, the institution’s compliance ratings
were proficient, scoring above 85 percent, in the following seven primary indicators: Access to
Care, Health Information Management (Medical Records), Health Care Environment, Inter- and
Intra-System Transfers, Pharmacy and Medication Management, Preventive Services, and Specialty
Services. The following are some of CAC’s strengths based on its compliance scores on individual
questions in all the primary health care indicators:
2 The OIG’s compliance inspectors are trained deputy inspectors general and registered nurses with expertise in CDCR
policies regarding medical staff and processes.
3 The OIG used its own clinicians to provide clinical expert guidance for testing compliance in certain areas where
CCHCS policies and procedures did not specifically address an issue.
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Office of the Inspector General State of California
Patients had a standardized process to obtain and submit request forms for health care
services; nursing staff timely reviewed patients’ requests and timely completed face-to-face
visits with patients.
Providers conducted timely appointments with patients referred for a follow-up visit by a
provider and with patients who were released from a community hospital and returned to the
institution.
Health records staff timely scanned Initial Health Screening forms (CDCR Form 7277),
health care services request forms, handwritten progress notes, specialty reports, hospital
discharge reports, and medication administration records into patients’ electronic medical
records.
Providers timely reviewed hospital discharge reports when patients returned to the
institution.
All clinics were appropriately disinfected, cleaned, and sanitized, and each contained
operable sinks and sufficient hand hygiene supplies. Clinical staff properly controlled
exposure to blood-borne pathogens and contamination, and properly sterilized or disinfected
medical equipment.
The institution followed adequate protocols for managing and storing bulk medical supplies
in its clinical areas and warehouse.
For patients newly arriving at CAC from other CDCR institutions, nursing staff properly
documented an assessment and disposition on the initial health screening forms, and signed
and dated the form on the same day the patient arrived at the institution.
Nursing staff ensured that patients transferred from CAC to other institutions with complete
transfer packets and all applicable medications, and that specialty service appointments were
identified on the Health Care Transfer Information form (CDCR Form 7371).
Nursing staff timely delivered or administered prescribed medications without interruption
for patients who suffered with chronic care conditions, patients with newly ordered
medications, patients who returned to the institution from hospitals, and patients who
transferred from one housing unit to another.
Nurses employed appropriate administrative controls and followed proper protocols while
preparing patients’ medications.
In its main pharmacy, CAC followed general security, organization, and cleanliness
management protocols; properly stored and monitored refrigerated, frozen, and
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Office of the Inspector General State of California
non-refrigerated medications; properly accounted for narcotic medications; and followed
key medication error reporting protocols.
The institution timely offered or provided patients with required tuberculosis medications,
immunizations, and colorectal cancer screenings.
Patients at the highest risk of contracting valley fever were timely transferred out of the
institution.
When a specialty service was performed, providers timely reviewed the specialist’s report;
when providers’ specialty services requests were denied, the denial occurred within the
required time frame, and the provider timely communicated the denial to the patient.
The following are some of the strengths identified within the two secondary administrative
indicators:
CAC promptly processed patients’ initial medical appeals during the most recent 12 months
and addressed all appealed issues when responding to patients’ second-level medical
appeals.
All nursing staff who administered medications possessed current clinical competency
validations.
Program Weaknesses — Compliance
The institution received no ratings of inadequate, scoring below 75 percent, in the primary
indicators, but did receive inadequate ratings in both secondary indicators, Internal Monitoring,
Quality Improvement, and Administrative Operations; and Job Performance, Training, Licensing,
and Certifications. The following are some of the weaknesses identified by CAC’s compliance
scores for individual questions in all the primary health care indicators:
Providers did not always timely see newly arrived patients who were referred to them as a
result of nurses’ initial health care assessments.
Most clinics were lacking some essential equipment and supplies in the common areas and
exam rooms, and many clinics had exam rooms that did not have an environment conducive
to providing adequate medical services.
Sampled patients who transferred into CAC from other institutions with previously approved
or scheduled specialty service appointments often received their appointments late.
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Office of the Inspector General State of California
The following are some of the weaknesses identified within the two secondary administrative
indicators:
Emergency Medical Response Review Committee incident review packages and emergency
response drill packages lacked required documentation.
Clinical supervisors did not complete structured performance appraisals of providers and
appropriate periodic reviews of nursing staff.
Nursing staff did not receive new employee orientation training within 30 days of being
hired.
The CAC Executive Summary Table on the following page lists the quality indicators the OIG
inspected and assessed during the clinical case reviews and objective compliance tests, and provides
the institution’s rating in each area. The overall indicator ratings were based on a consensus
decision by the OIG’s clinicians and non-clinical inspectors.
California City Correctional Facility, Cycle 4 Medical Inspection Page vii
Office of the Inspector General State of California
CAC Executive Summary Table
Case
Compliance Overall Indicator
Primary Indicators (Clinical) Review
Rating Rating
Rating
Access to Care Proficient Proficient Proficient
Diagnostic Services Adequate Adequate Adequate
Emergency Services Adequate Not applicable Adequate
Health Information Management
Adequate Proficient Proficient
(Medical Records)
Health Care Environment Not applicable Proficient Proficient
Inter- and Intra-System Transfers Adequate Proficient Proficient
Pharmacy and Medication Management Adequate Proficient Proficient
Preventive Services Not applicable Proficient Proficient
Quality of Nursing Performance Adequate Not applicable Adequate
Quality of Provider Performance Adequate Not applicable Adequate
Specialty Services Proficient Proficient Proficient
The Prenatal and Post-Delivery Services, Reception Center Arrivals, and Specialized Medical
Housing (OHU, CTC, SNF, and Hospice) indicators did not apply to this institution.
Case
Compliance Overall Indicator
Secondary Indicators (Administrative) Review
Rating Rating
Rating
Internal Monitoring, Quality Improvement,
Not applicable Inadequate Inadequate
and Administrative Operations
Job Performance, Training, Licensing, and
Not applicable Inadequate Inadequate
Certifications
Compliance results for quality indicators are proficient (greater than 85.0 percent), adequate
(75.0 percent to 85.0 percent), or inadequate (below 75.0 percent).
California City Correctional Facility, Cycle 4 Medical Inspection Page viii
Office of the Inspector General State of California
Population-Based Metrics
The institution performed adequately as measured by population-based metrics. Statewide, the
institution outperformed Medi-Cal in all five comprehensive diabetic care measures, and
outperformed Kaiser in four of the five measures; CAC scored lower than Kaiser did in blood
pressure control for diabetic patients. Nationally, CAC outperformed Medicaid, Medicare, and
commercial health plans in all five diabetic measures; the institution outperformed or matched the
United States Department of Veterans Affairs (VA) in three of the four applicable measures, and
scored only 1 percentage point lower than the VA in diabetic patient eye exams.
With regard to influenza shots for younger adults, the institution performed more poorly than all
statewide and national health care organizations. However, CAC offered the immunization to all
patients sampled, but 55 percent of them refused it, which negatively affected the institution’s score.
The institution outperformed or matched all statewide and national health care organizations for
colorectal cancer screenings.
Overall, CAC’s performance calculated by population-based metrics demonstrated a generally
adequate chronic care and preventive services program. The institution could improve some scores
by making interventions to lower patients’ refusal rates.
California City Correctional Facility, Cycle 4 Medical Inspection Page ix
Office of the Inspector General State of California
INTRODUCTION
Under the authority of California Penal Code Section 6126, which assigns the Office of the
Inspector General (OIG) responsibility for oversight of the California Department of Corrections
and Rehabilitation (CDCR), and at the request of the federal Receiver, the OIG developed a
comprehensive medical inspection program to evaluate the delivery of medical care at each of
CDCR’s 35 adult prisons. For this fourth cycle of inspections, the OIG augmented the breadth and
quality of its inspection program used in prior cycles, adding a clinical case review component and
significantly enhancing the compliance component of the program.
The California City Correctional Facility (CAC) was the 30th Medical Inspection of Cycle 4.
During the inspection process, the OIG assessed the delivery of medical care to patients in 11
primary clinical health care indicators and 2 secondary administrative health care indicators
applicable to the institution. It is important to note that while the primary quality indicators
represent the clinical care being provided by the institution at the time of the inspection, the
secondary quality indicators are purely administrative and are not reflective of the actual clinical
care provided.
The OIG is committed to reporting on each institution’s delivery of medical care to assist in
identifying areas for improvement, but the federal court will ultimately determine whether any
institution’s medical care meets constitutional standards.
ABOUT THE INSTITUTION
The California City Correctional Facility was activated December 2013 and primarily houses
low-level general population inmates. CAC is committed to protecting public safety, ensuring the
safety of CDCR personnel, and providing proper care and supervision of all offenders under its
jurisdiction while offering opportunities for successful reentry into society.
The institution operates seven clinics in which staff members handle non-urgent requests for
medical services, including six facility clinics and a specialty clinic. CAC also conducts screenings
in its receiving and release clinical area (R&R) and treats patients needing urgent or emergency care
in its triage and treatment area (TTA). Patients who require a higher level of inpatient care are
transferred to other nearby institutions. California Correctional Health Care Services (CCHCS) has
designated CAC a “basic” care institution. Basic 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 institutions have the capability to provide limited specialty medical
services and consultation for a generally healthy inmate-patient population.
At the time of this report, CAC had not yet received a review from the Commission on
Accreditation for Corrections, a professional peer review process based on national standards set by
the American Correctional Association. The institution’s first review was planned for late
November 2016.
California City Correctional Facility, Cycle 4 Medical Inspection Page 1
Office of the Inspector General State of California
Based on staffing data the OIG obtained from the institution, CAC’s vacancy rate among medical
managers, providers, nursing supervisors, and non-supervisory nurses was six percent in May 2016,
with all the vacancies for non-supervisory nursing staff. As indicated below, CAC showed that two
staff members were redirected to non-patient care areas as of May 2016. Those positions
represented two staff members who were temporarily loaned to other institutions; both of them had
returned to CAC by September 2016.
CAC Health Care Staffing Resources as of May 2016
Primary Care Nursing
Management Nursing Staff Totals
Providers Supervisors
Description Number % Number % Number % Number % Number %
Authorized
5 8% 4.7 8% 8.3 13% 44.6 71% 62.6 100%
Positions
Filled Positions 5 100% 4.7 100% 8.3 100% 41 92% 59 94%
Vacancies 0 0% 0 0% 0 0% 3.6 8% 3.6 6%
Recent Hires
(within 12 4 80% 1 21% 2 24% 9 22% 16 27%
months)
Staff Utilized
0 0% 0 0% 0 0% 0 0% 0 0%
from Registry
Redirected Staff
(to Non-Patient 1 20% 0 0% 1 12% 0 0% 2 3%
Care Areas)
Staff on
Long-term 1 20% 0 0% 0 0% 2 5% 3 5%
Medical Leave
Note: CAC Health Care Staffing Resources data was not validated by the OIG.
California City Correctional Facility, Cycle 4 Medical Inspection Page 2
Office of the Inspector General State of California
As of May 9, 2016, the Master Registry for CAC showed that the institution had a total population
of 1,828. Within that total population, zero percent were designated as high medical risk, Priority 1
(High 1), and 0.2 percent were designated as high medical risk, Priority 2 (High 2). Patients’
assigned risk levels are based on the complexity of their required medical care related to their
specific diagnoses, frequency of higher levels of care, age, and abnormal labs and procedures. High
1 has at least two high-risk conditions; High 2 has only one. Patients at high medical risk are more
susceptible to poor health outcomes than are those at medium or low medical risk. Patients at high
medical risk also typically require more health care services than do patients with lower assigned
risk levels. The chart below illustrates the breakdown of the institution’s medical risk levels at the
start of the OIG medical inspection.
CAC Master Registry Data as of May 9, 2016
Medical Risk Level # of Inmate-Patients Percentage
High 1 0 0.0%
High 2 3 0.2%
Medium 332 18.2%
Low 1,493 81.6%
Total 1,828 100.0%
California City Correctional Facility, Cycle 4 Medical Inspection Page 3
Office of the Inspector General State of California
Commonly Used Abbreviations
ACLS Advanced Cardiovascular Life Support HIV Human Immunodeficiency Virus
AHA American Heart Association HTN Hypertension
ASU Administrative Segregation Unit INH Isoniazid (anti-tuberculosis medication)
BLS Basic Life Support IV Intravenous
CBC Complete Blood Count KOP Keep-on-Person (in taking medications)
CC Chief Complaint LPT Licensed Psychiatric Technician
CCHCS California Correctional Health Care Services LVN Licensed Vocational Nurse
CCP Chronic Care Program MAR Medication Administration Record
California Department of Corrections and
CDCR MRI Magnetic Resonance Imaging
Rehabilitation
CEO Chief Executive Officer MD Medical Doctor
CHF Congestive Heart Failure NA Nurse Administered (in taking medications)
CME Chief Medical Executive N/A Not Applicable
CMP Comprehensive Metabolic (Chemistry) Panel NP Nurse Practitioner
CNA Certified Nursing Assistant OB Obstetrician
CNE Chief Nurse Executive OHU Outpatient Housing Unit
C/O Complains of OIG Office of the Inspector General
COPD Chronic Obstructive Pulmonary Disease P&P Policies and Procedures (CCHCS)
CP&S Chief Physician and Surgeon PA Physician Assistant
CPR Cardio-Pulmonary Resuscitation PCP Primary Care Provider
CSE Chief Support Executive POC Point of Contact
CT Computerized Tomography PPD Purified Protein Derivative
CTC Correctional Treatment Center PRN As Needed (in taking medications)
DM Diabetes Mellitus RN Registered Nurse
Directly Observed Therapy (in taking
DOT Rx Prescription
medications)
Dx Diagnosis SNF Skilled Nursing Facility
Subjective, Objective, Assessment, Plan,
EKG Electrocardiogram SOAPE
Education
ENT Ear, Nose and Throat SOMS Strategic Offender Management System
ER Emergency Room S/P Status Post
eUHR electronic Unit Health Record TB Tuberculosis
FTF Face-to-Face TTA Triage and Treatment Area
History and Physical (reception center
H&P UA Urinalysis
examination)
HIM Health Information Management UM Utilization Management
California City Correctional Facility, Cycle 4 Medical Inspection Page 4
Office of the Inspector General State of California
OBJECTIVES, SCOPE, AND METHODOLOGY
In designing the medical inspection program, the OIG reviewed CCHCS policies and procedures,
relevant court orders, and guidance developed by the American Correctional Association. The OIG
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, CDCR, the Office of the Attorney General,
and the Prison Law Office to discuss the nature and scope of the OIG’s inspection program. With
input from these stakeholders, the OIG developed a medical inspection program that evaluates
medical care delivery 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.
To maintain a metric-oriented inspection program that evaluates medical care delivery consistently
at each State prison, the OIG identified 14 primary (clinical) and 2 secondary (administrative)
quality indicators of health care to measure. The primary quality indicators cover clinical categories
directly relating to the health care provided to patients, whereas the secondary quality indicators
address the administrative functions that support a health care delivery system. The 14 primary
quality indicators are Access to Care, Diagnostic Services, Emergency Services, Health Information
Management (Medical Records), Health Care Environment, Inter- and Intra-System Transfers,
Pharmacy and Medication Management, Prenatal and Post-Delivery Services, Preventive Services,
Quality of Nursing Performance, Quality of Provider Performance, Reception Center Arrivals,
Specialized Medical Housing (OHU, CTC, SNF, Hospice), and Specialty Services. The two
secondary quality indicators are Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications.
The OIG rates each of the quality indicators applicable to the institution under inspection based on
case reviews conducted by OIG clinicians and compliance tests conducted by OIG deputy
inspectors general and registered nurses. The ratings may be derived from the case review results
alone, the compliance test results alone, or a combination of both these information sources. For
example, the ratings for the primary quality indicators Quality of Nursing Performance and Quality
of Provider Performance are derived entirely from the case review results, while the ratings for the
primary quality indicators Health Care Environment and Preventive Services are derived entirely
from compliance test results. As another example, primary quality indicators such as Diagnostic
Services and Specialty Services receive ratings derived from both sources. At CAC, 13 of the
quality indicators were applicable, consisting of 11 primary clinical indicators and 2 secondary
administrative indicators. Of the 11 primary indicators, six were rated by both case review
clinicians and compliance inspectors, three were rated by case review clinicians only, and two were
rated by compliance inspectors only; both secondary indicators were rated by compliance inspectors
only.
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Office of the Inspector General State of California
Consistent with the OIG’s agreement with the Receiver, this report only addresses the conditions
found related to medical care criteria. The OIG does not review for efficiency and economy of
operations. Moreover, if the OIG learns of an inmate-patient needing immediate care, the OIG
notifies the chief executive officer of health care services and requests a status report. Additionally,
if the OIG learns of significant departures from community standards, it may report such departures
to the institution’s chief executive officer or to CCHCS. Because these matters involve confidential
medical information protected by State and federal privacy laws, specific identifying details related
to any such cases are not included in the OIG’s public report.
In all areas, the OIG is alert for opportunities to make appropriate recommendations for
improvement. Such opportunities may be present regardless of the score awarded to any particular
quality indicator; therefore, recommendations for improvement should not necessarily be
interpreted as indicative of deficient medical care delivery.
CASE REVIEWS
The OIG has added case reviews to the Cycle 4 medical inspections at the recommendation of its
stakeholders. At the conclusion of Cycle 3, the federal Receiver and the Inspector General
determined that the health care provided at the institutions was not fully evaluated by the
compliance tool alone, and that the compliance tool was not designed to provide comprehensive
qualitative assessments. Accordingly, the OIG added case reviews in which OIG physicians and
nurses evaluate selected cases in detail to determine the overall quality of health care provided to
the inmate-patients. The OIG’s clinicians perform a retrospective chart review of selected patient
files to evaluate the care given by an institution’s primary care providers and nurses. Retrospective
chart review is a well-established review process used by health care organizations that perform
peer reviews and patient death reviews. Currently, CCHCS uses retrospective chart review as part
of its death review process and in its pattern-of-practice reviews. CCHCS also uses a more limited
form of retrospective chart review when performing appraisals of individual primary care providers.
PATIENT SELECTION FOR RETROSPECTIVE CASE REVIEWS
Because retrospective chart review is time consuming and requires qualified health care
professionals to perform it, OIG clinicians must carefully sample patient records. Accordingly, the
group of patients the OIG targeted for chart review carried the highest clinical risk and utilized the
majority of medical services. As there were only three patients at PVSP classified by CCHCS as
high-risk, the majority of the patients selected for retrospective chart review were patients with
chronic care illnesses, including diabetes, that were classified as medium-risk. The reason the OIG
targeted these patients for review is twofold:
1. The goal of retrospective chart review is to evaluate all aspects of the health care system.
Statewide, high-risk and high-utilization patients consume medical services at a
disproportionate rate; 11 percent of the total patient population are considered high-risk and
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account for more than half of the institution’s pharmaceutical, specialty, community
hospital, and emergency costs.
2. Selecting this target group for chart review provides a significantly greater opportunity to
evaluate all the various aspects of the health care delivery system at an institution.
Underlying the choice of high-risk patients for detailed case review, the OIG clinical experts made
the following three assumptions:
1. If the institution is able to provide adequate clinical care to the most challenging patients
with multiple complex and interdependent medical problems, it will be providing adequate
care to patients with less complicated health care issues. Because clinical expertise is
required to determine whether the institution has provided adequate clinical care, the OIG
utilizes experienced correctional physicians and registered nurses to perform this analysis.
2. The health of less complex patients is more likely to be affected by processes such as timely
appointment scheduling, medication management, routine health screening, and
immunizations. To review these processes, the OIG simultaneously performs a broad
compliance review.
3. Patient charts generated during death reviews, sentinel events (unexpected occurrences
involving death or serious injury, or risk thereof), and hospitalizations are mostly of
high-risk patients.
BENEFITS AND LIMITATIONS OF TARGETED SUBPOPULATION REVIEW
Because the selected patients utilize the broadest range of services offered by the health care
system, the OIG’s retrospective chart review provides adequate data for a qualitative assessment of
the most vital system processes (referred to as “primary quality indicators”). Retrospective chart
review provides an accurate qualitative assessment of the relevant primary quality indicators as
applied to the targeted subpopulation of high-risk and high-utilization patients. While this targeted
subpopulation does not represent the prison population as a whole, the ability of the institution to
provide adequate care to this subpopulation is a crucial and vital indicator of how the institution
provides health care to its whole patient population. Simply put, if the institution’s medical system
does not adequately care for those patients needing the most care, then it is not fulfilling its
obligations, even if it takes good care of patients with less complex medical needs.
Since the targeted subpopulation does not represent the institution’s general prison population, the
OIG cautions against inappropriate extrapolation of conclusions from the retrospective chart
reviews to the general population. For example, if the high-risk diabetic patients reviewed have
poorly-controlled diabetes, one cannot conclude that the entire diabetic population is inadequately
controlled. Similarly, if the high-risk diabetic patients under review have poor outcomes and require
significant specialty interventions, one cannot conclude that the entire diabetic population is having
similarly poor outcomes.
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Nonetheless, the health care system’s response to this subpopulation can be accurately evaluated
and yields valuable systems information. In the above example, if the health care system is
providing appropriate diabetic monitoring, medication therapy, and specialty referrals for the
high-risk patients reviewed, then it can be reasonably inferred that the health care system is also
providing appropriate diabetic services to the entire diabetic subpopulation. However, if these same
high-risk patients needing monitoring, medications, and referrals are generally not getting those
services, it is likely that the health care system is not providing appropriate diabetic services to the
greater diabetic subpopulation.
CASE REVIEWS SAMPLED
As indicated in Appendix B, Table B–1: CAC Sample Sets, the OIG clinicians evaluated medical
charts for 51 unique inmate-patients. Appendix B, Table B–4: CAC Case Review Sample Summary,
clarifies that both nurses and physicians reviewed charts for 22 of those patients, for 73 reviews in
total. Physicians performed detailed reviews of 30 charts, and nurses performed detailed reviews of
17 charts, totaling 47 detailed reviews. For detailed case reviews, physicians or nurses looked at all
encounters occurring in approximately six months of medical care. Nurses also performed a limited
or focused review of medical records for an additional 25 inmate-patients. These generated 860
clinical events for review (Appendix B, Table B–3: CAC Event-Program). The inspection tool
provides details on whether the encounter was adequate or had significant deficiencies, and
identifies deficiencies by programs and processes to help the institution focus on improvement
areas.
While the sample method specifically pulled only 3 chronic care patient records, i.e., 3 diabetes
patients (Appendix B, Table B–1: CAC Sample Sets), the 51 unique inmate-patients sampled
included patients with 114 chronic care diagnoses, including 8 additional patients with diabetes, for
a total of 11 (Appendix B, Table B–2: CAC Chronic Care Diagnoses). The OIG’s sample selection
tool allowed evaluation of many chronic care programs because the complex and high-risk patients
selected from the different categories often had multiple medical problems. While the OIG did not
evaluate every chronic disease or health care staff member, the overall operation of the institution’s
system and staff were assessed for adequacy. The OIG’s case review methodology and sample size
matched other qualitative research. The empirical findings, supported by expert statistical
consultants, showed adequate conclusions after 10 to 15 charts had undergone full clinician review.
In qualitative statistics, this phenomenon is known as “saturation.” The OIG asserts that the
physician sample size of 30 detailed reviews certainly far exceeds the saturation point necessary for
an adequate qualitative review. With regard to reviewing charts from different providers, the case
review is not intended to be a focused search for poorly performing providers; rather, it is focused
on how the system cares for those patients who need care the most. Nonetheless, while not sampling
cases by each provider at the institution, the OIG inspections adequately review most providers.
Providers would only escape OIG case review if institutional management successfully mitigated
patient risk by having the more poorly performing providers care for the less complicated,
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low-utilizing, and lower-risk patients. The OIG’s clinicians concluded that the case review sample
size was more than adequate to assess the quality of services provided.
Based on the collective results of clinicians’ case reviews, the OIG rated each quality indicator as
either proficient (excellent), adequate (passing), inadequate (failing), or not applicable. A separate
confidential CAC Supplemental Medical Inspection Results: Individual Case Review Summaries
report details the case reviews OIG clinicians conducted and is available to specific stakeholders.
For further details regarding the sampling methodologies and counts, see Appendix B — Clinical
Data, Table B–1; Table B–2; Table B–3; and Table B–4.
COMPLIANCE TESTING
SAMPLING METHODS FOR CONDUCTING COMPLIANCE TESTING
From May to July 2016, deputy inspectors general and registered nurses attained answers to 86
objective medical inspection test (MIT) questions designed to assess the institution’s compliance
with critical policies and procedures applicable to the delivery of medical care. To conduct most
tests, inspectors randomly selected samples of inmate-patients for whom the testing objectives were
applicable and reviewed their electronic unit health records. In some cases, inspectors used the same
samples to conduct more than one test. In total, inspectors reviewed health records for 318
individual inmate-patients and analyzed specific transactions within their records for evidence that
critical events occurred. Inspectors also reviewed management reports and meeting minutes to
assess certain administrative operations. In addition, during the week of May 23, 2016, field
inspectors conducted a detailed onsite inspection of CAC’s medical facilities and clinics;
interviewed key institutional employees; and reviewed employee records, logs, medical appeals,
death reports, and other documents. This generated 981 scored data points to assess care.
In addition to the scored questions, the OIG obtained information from the institution that it did not
score. This included, for example, information about CAC’s plant infrastructure, protocols for
tracking medical appeals and local operating procedures, and staffing resources.
For details of the compliance results, see Appendix A — Compliance Test Results. For details of the
OIG’s compliance sampling methodology, see Appendix C — Compliance Sampling Methodology.
SCORING OF COMPLIANCE TESTING RESULTS
The OIG rated the institution in the following eight primary (clinical) and two secondary
(administrative) quality indicators applicable to the institution for compliance testing:
Primary indicators: Access to Care, Diagnostic Services, Health Information Management
(Medical Records), Health Care Environment, Inter- and Intra-System Transfers, Pharmacy
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and Medication Management, Preventive Services, and Specialty Services (OHU, CTC,
SNF, and Hospice).
Secondary indicators: Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications.
After compiling the answers to the 86 questions, the OIG derived a score for each primary and
secondary quality indicator identified above by calculating the percentage score of all Yes answers
for each of the questions applicable to a particular indicator, then averaging those scores. Based on
those results, the OIG assigned a rating to each quality indicator of proficient (greater than
85 percent), adequate (between 75 percent and 85 percent), or inadequate (less than 75 percent).
DASHBOARD COMPARISONS
In the first ten medical inspection reports of Cycle 4, the OIG identified where similar metrics for
some of the individual compliance questions were available within the CCHCS Dashboard, which is
a monthly report that consolidates key health care performance measures statewide and by
institution. However, there was not complete parity between the metrics due to differing time
frames for data collecting and differences in sampling methods, rendering the metrics unable to be
compared. The OIG has removed the Dashboard comparisons to eliminate confusion. Dashboard
data is available on CCHCS’s website, www.cphcs.ca.gov.
OVERALL QUALITY INDICATOR RATING FOR CASE REVIEWS AND COMPLIANCE
TESTING
The OIG derived the final rating for each quality indicator by combining the ratings from the case
reviews and from the compliance testing, as applicable. When combining these ratings, the case
review evaluations and the compliance testing results usually agreed, but there were instances when
the rating differed for a particular quality indicator. In those instances, the inspection team assessed
the quality indicator based on the collective ratings from both components. Specifically, the OIG
clinicians and deputy inspectors general discussed the nature of individual exceptions found within
that indicator category and considered the overall effect on the ability of patients to receive
adequate medical care.
To derive an overall assessment rating of the institution’s medical inspection, the OIG evaluated the
various rating categories assigned to each of the quality indicators applicable to the institution,
giving more weight to the rating results of the primary quality indicators, which directly relate to the
health care provided to inmate-patients. Based on that analysis, OIG experts made a considered and
measured overall opinion about the quality of health care observed.
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POPULATION-BASED METRICS
The OIG identified a subset of Healthcare Effectiveness Data Information Set (HEDIS) measures
applicable to the CDCR inmate-patient population. To identify outcomes for CAC, the OIG
reviewed some of the compliance testing results, randomly sampled additional inmate-patients’
records, and obtained CAC data from the CCHCS Master Registry. The OIG compared those results
to HEDIS metrics reported by other statewide and national health care organizations.
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MEDICAL INSPECTION RESULTS
PRIMARY (CLINICAL) QUALITY INDICATORS OF HEALTH CARE
The primary quality indicators assess the clinical aspects of health care. As shown on the Health
Care Quality Indicators table on page ii of this report, 11 of the OIG’s primary indicators were
applicable to CAC. Of those 11 indicators, six were rated by both the case review and compliance
components of the inspection, three were rated by the case review component alone, and two were
rated by the compliance component alone.
The CAC Executive Summary Table on page viii shows the case review and compliance ratings for
each applicable indicator.
Summary of Case Review Results: The clinical case review component assessed 9 of the 11
primary (clinical) indicators applicable to CAC. Of these nine indicators, OIG clinicians rated two
proficient, seven adequate, and none inadequate.
The OIG physicians rated the overall adequacy of care for each of the 30 detailed case reviews they
conducted. Of these 30 cases, none was proficient, 29 were adequate, and one was inadequate. In
the 860 events reviewed, there were 176 deficiencies, of which 20 were considered to be of such
magnitude that, if left unaddressed, they would likely contribute to patient harm.
Adverse Events Identified During Case Review: Medical care is a complex dynamic process with
many moving parts, subject to human error even within the best health care organizations. Adverse
events are typically identified and tracked by all major health care organizations for the purpose of
quality improvement. They are not generally representative of medical care delivered by the
organization. The OIG identified adverse events for the dual purposes of quality improvement and
the illustration of problematic patterns of practice found during the inspection. Because of the
anecdotal description of these events, the OIG cautions against drawing inappropriate conclusions
regarding the institution based solely on adverse events.
There were no unsafe conditions or sentinel events identified in the case reviews at CAC.
Summary of Compliance Results: The compliance component assessed 8 of the 11 primary
(clinical) indicators applicable to CAC. Of these eight indicators, OIG inspectors rated seven
proficient, one adequate, and none inadequate. The results of those assessments are summarized
within this section of the report. The test questions used to assess compliance for each indicator are
detailed in Appendix A.
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ACCESS TO CARE
This indicator evaluates the institution’s ability to provide
Case Review Rating:
inmate-patients with timely clinical appointments. Areas specific to
Proficient
inmate-patients’ access to care are reviewed, such as initial
Compliance Score:
assessments of newly arriving inmates, acute and chronic care
Proficient
follow-ups, face-to-face nurse appointments when an inmate-patient (87.9%)
requests to be seen, provider referrals from nursing lines, and Overall Rating:
follow-ups after hospitalization or specialty care. Compliance Proficient
testing for this indicator also evaluates whether inmate-patients have
Health Care Services Request forms (CDCR Form 7362) available
in their housing units.
Case Review Results
The OIG clinicians reviewed 455 outpatient provider and nursing encounters and identified eight
minor deficiencies. CAC performed well with regard to Access to Care, and the OIG clinicians
rated this indicator proficient.
Nurse-to-Provider Referrals
Sick call nurses were required to refer the patient to a provider when the condition required a higher
level of care. Within the 232 outpatient nursing encounters reviewed, there were two instances in
which provider appointments did not occur timely and one in which the appointment did not occur.
In case 8, a nurse evaluated a patient for constipation and requested a provider appointment
within 14 days. This appointment occurred more than two months later.
In case 9, a nurse evaluated a patient for arm pain and requested a provider appointment in
three to five days. The appointment occurred ten days later.
In case 35, a nurse evaluated the patient for ear pain and requested a routine provider
appointment. This appointment did not occur.
Nursing Follow-up Appointments
CAC performed well with nursing follow-up appointments, but there were two deficiencies:
In case 9, a nurse treated cuts on the patient’s feet. The requested follow-up in one week did
not occur.
In case 16, a nurse treated earwax impaction and requested that the patient follow up in 48
hours. The appointment did not occur.
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Provider-to-Provider Follow-up Appointments
The institution performed well with provider-ordered follow-up appointments, which are among the
most important aspects of the Access to Care indicator.
Provider Follow-up After Specialty Service
The providers generally evaluated their patients timely after specialty services appointments, but
there was one delay:
In case 16, the patient had an esophagogastroduodenoscopy (imaging of the esophagus and
stomach). The 14-day provider follow-up appointment did not occur until six weeks later.
Specialty Service Appointments
CAC performed well with specialty service appointments, but there were two deficiencies, one of
which was significant (case 42):
In case 38, a provider requested a general surgery evaluation, but the patient was seen by an
ear, nose, and throat (ENT) specialist.
In case 42, a provider requested to have the patient, with gastrointestinal bleeding, follow up
with the gastroenterologist in four weeks. The appointment occurred 11 weeks later.
Intra-System Transfer
Nurses at CAC assessed patients transferring in and appropriately referred them to a provider, and
providers evaluated the patients timely.
Follow-up After Hospitalization
Fifteen hospital or outside emergency department events were reviewed. The providers timely
assessed all patients returning from higher levels of care.
Clinician Onsite Inspection
The OIG clinicians interviewed CAC staff regarding issues with access to care. Each of the three
clinics had an office technician who attended the morning huddles and used a tracking process to
ensure provider follow-up appointments were completed. The providers reported seeing 15 patients
each day, and the clinic nurses saw about six patients each day on the nurse line. There were no
backlogs in the three clinics.
Conclusion
CAC performed well with regard to Access to Care. The case review rating for CAC in this
indicator was proficient.
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Compliance Testing Results
The institution performed in the proficient range in the Access to Care indicator, with a compliance
score of 87.9 percent. CAC scored 100 percent on five of the six test areas, as described below:
Inmates had access to health care services request forms at all six housing units inspected
(MIT 1.101).
Inspectors sampled 30 health care services request forms submitted by patients across all
facility clinics. Nursing staff reviewed all forms on the same day they were received and
completed a face-to-face encounter with all 30 patients within one business day of reviewing
the request form (MIT 1.003, 1.004).
All six patients sampled who were referred to and seen by a provider, and for whom the
provider ordered a sick call follow-up appointment, received a timely follow-up
appointment (MIT 1.006).
CAC offered a follow-up appointment with a provider to patients within five days of
discharge from a community hospital for all 12 patients sampled (MIT 1.007).
Among seven health care services request forms sampled on which nursing staff referred the
patient for a provider appointment, six patients (86 percent) received a timely appointment.
One patient’s form indicated a routine referral to a provider, but the related Nursing
Assessment Protocol indicated no referral was needed. Inspectors did not find evidence that
the patient was seen by a provider or that the patient refused the appointment (MIT 1.005).
The institution performed adequately in the two areas below:
When the OIG reviewed recent appointments for 30 sampled patients with chronic care
conditions, 25 patients (83 percent) received timely provider follow-up appointments. Four
patients received chronic care appointments from 9 to 148 days late. For one patient, there
was no evidence the appointment occurred at all (MIT 1.001).
Inspectors sampled 24 patients who received a high-priority or routine specialty service; 19
of them (79 percent) received a timely follow-up appointment with a provider. Five patients
received follow-up appointments from 6 to 20 days late (MIT 1.008).
The institution showed opportunity for improvement in the following test area:
Among seven patients sampled who had transferred into CAC from another institution and
been referred to a provider based on nursing staff’s initial healthcare screening, only three
(43 percent) received their follow-up appointments timely. Four patients received their
follow-up appointments from 8 to 14 days late (MIT 1.002).
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Recommendations
No specific recommendations.
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DIAGNOSTIC SERVICES
This indicator addresses several types of diagnostic services.
Case Review Rating:
Specifically, it addresses whether radiology and laboratory services
Adequate
were timely provided to inmate-patients, whether the primary care
Compliance Score:
provider timely reviewed the results, and whether the results were
Adequate
communicated to the inmate-patient within the required time (77.3%)
frames. In addition, for pathology services, the OIG determines
Overall Rating:
whether the institution received a final pathology report and
Adequate
whether the provider timely reviewed and communicated the
pathology results to the patient. The case reviews also factor in the
appropriateness, accuracy, and quality of the diagnostic test(s) ordered and the clinical response to
the results.
Case Review Results
The OIG clinicians reviewed 105 events in diagnostic services and found 12 minor deficiencies.
Most deficiencies were related to the health information management process, and one was related
to scheduling. Most reviewed tests were performed as ordered, reviewed timely by providers, and
relayed quickly to patients. The case review rating for Diagnostic Services was adequate.
Ten deficiencies occurred when x-ray reports were not retrieved or scanned into the eUHR.
However, the providers were aware of the reports on follow-up visits, so this did not affect
patient care.
One laboratory report was not retrieved or scanned into the eUHR.
One STAT lab (urgently done) was ordered but not done.
Conclusion
The OIG rated Diagnostic Services at CAC adequate, as the improperly processed diagnostic orders
were infrequent.
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Compliance Testing Results
The institution received an adequate compliance score of 77.3 percent in the Diagnostic Services
indicator, which encompasses radiology, laboratory, and pathology services. For clarity, each type
of diagnostic service is discussed separately below:
Radiology Services
All ten of the radiology services sampled were timely performed (MIT 2.001). Providers
properly evidenced their review of the radiology results for eight of the ten patients
(80 percent). For two patients, there was no evidence the provider reviewed the reports
(MIT 2.002). Providers communicated the radiology results timely to nine of the ten patients
(90 percent); the provider communicated the results eight days late to one patient
(MIT 2.003).
Laboratory Services
Laboratory services were completed within the time frame specified in the provider’s order
for eight of ten patients sampled (80 percent). Two patients’ laboratory services were
performed one and seven days late (MIT 2.004). Providers’ properly evidenced their review
of laboratory test results for all ten patients sampled within two business days of receipt
(MIT 2.005). Providers timely communicated laboratory test results to nine of the ten
patients (90 percent); the provider communicated the results two days late to one patient
(MIT 2.006).
Pathology Services
CAC received the final pathology report timely for only five of nine inmate patients sampled
(56 percent). Three reports were received from 15 to 158 days late, and one pathology report
was not found in the eUHR for one patient (MIT 2.007). Providers timely reviewed the
pathology test results for six of the seven applicable reports (86 percent). For one patient, the
provider did not initial and date the report to evidence his timely of the results (MIT 2.008).
Providers timely communicated the final pathology results to only one of the seven patients
sampled (14 percent). Providers communicated the pathology results to four patients from 3
to 210 days late. For two patients, there was no evidence found in eUHR that the pathology
results were communicated at all (MIT 2.009).
Recommendations
No specific recommendations.
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EMERGENCY SERVICES
An emergency medical response system is essential to providing
Case Review Rating:
effective and timely emergency medical response, assessment,
Adequate
treatment, and transportation 24 hours per day. Provision of
Compliance Score:
emergency care is based on a patient’s emergent situation, clinical
Not Applicable
condition, and need for a higher level of care. The OIG reviews
emergency response services including first aid, basic life support Overall Rating:
(BLS), and advanced cardiac life support (ACLS) consistent with Adequate
the American Heart Association guidelines for cardiopulmonary
resuscitation (CPR) and emergency cardiovascular care, and the provision of services by
knowledgeable staff appropriate to each individual’s training, certification, and authorized scope of
practice.
The OIG evaluates this quality indicator entirely through clinicians’ reviews of case files and
conducts no separate compliance testing element.
Case Review Results
The OIG clinicians reviewed 20 urgent or emergent events and found 14 deficiencies, four
significant (three in case 1 and one in case 32). The OIG rated Emergency Services at CAC
adequate.
Provider Performance
The providers generally evaluated patients timely and made appropriate assessments and plans
during urgent or emergent events. The OIG identified two minor deficiencies, which are also
described in the Quality of Provider Performance indicator:
In case 32, there was no provider progress note documenting an emergent event of chest
pain.
In case 41, there was no provider progress note documenting an emergent event when the
patient presented at the TTA with fever, shortness of breath, and a productive cough.
Nursing Performance
The nursing care provided during emergency medical response incidents was generally adequate.
There were 12 deficiencies in this area. While most nursing deficiencies were minor, some TTA
encounters demonstrated inadequate assessment, response time delays, and insufficient
interventions or monitoring. In several instances, assessment and monitoring by the first medical
responder did not occur or was not documented. The following examples demonstrated these case
review findings:
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In case 1, the TTA RN failed to refer the patient with testicular pain to a provider. Six days
later, the patient was sent to a higher level of care.
During another encounter in case 1, there was a significant delay of 30 minutes in
transferring the patient to the TTA after the initial evaluation by the RN of a patient with
facial and eye injuries. After the evaluation, the RN released the patient back to custody and
failed to obtain vital signs, to assess the neurological status, and to document the reason the
patient was released back to custody. When the patient was brought to the TTA, the severity
of the multiple facial injuries and lacerations, bruising, swelling, and active bleeding to his
eye required a transfer to a higher level of care. The patient was sent to the hospital and was
diagnosed with a sub-conjunctival hemorrhage (small blood vessel breaks in the eye).
In case 5, the RN did not assess the patient with severe abdominal pain and vomiting in the
TTA. The RN called the provider and received telephone orders to administer medication
and transfer the patient to a higher level of care. The RN should have included the
assessment of the patient and specific roles and actions of medical and custody staff, and
documented the time and the mode of transportation.
In case 19, on two separate occurrences, the first responders did not document the initial
notification of time or assessment. In one occurrence, the patient arrived in the TTA with
complaints of dizziness. In the other occurrence, the RN and supervisor were the first
responders and did not document the time of their arrival or what actions they took for a
patient found down in the shower, with head and facial injuries, and impaired vision. The
patient required a higher level of care.
In case 27, the patient was transferred to the hospital with abdominal pain and vomiting.
There was a delay of 35 minutes for TTA nursing staff to notify the physician on call.
In case 32, significant deficiencies occurred. The RN assessed the patient with a one-week
history of chest pain, but did not administer aspirin, nitroglycerin, or start an intravenous
fluid access line. Also, the RN contacted the physician on call, but failed to document any
orders.
In case 43, the nurse failed to recheck the patient’s vital signs for 81 minutes. In addition,
there was a 21-minute delay notifying the on-call physician upon the patient’s arrival to the
TTA.
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Emergency Medical Response Review Committee
CAC conducted timely EMRRC meetings with good attendance by custody and health care team
representatives. CAC staff performed and analyzed routine emergency drills and identified areas for
improvement. There was one deficient case:
In case 1, the EMRRC failed to address the 30-minute delay of medical intervention, and did
not request a rationale for the return back to his cell for a patient with significant injuries.
Onsite Clinical Inspection
The TTA was readily accessible from each yard. There were two nurses on each shift and one
provider during business hours. The TTA had two beds and adequate space for patient evaluation,
with working areas for both nurses and providers. The TTA also had ample lighting and was
stocked well with medications and medical equipment, such as an automated external defibrillator
(AED) and an emergency crash cart.
The TTA staff duties included responding to medical emergencies in the clinics. First watch RNs
were responsible for collecting requests for health care services out in the housing units and
reviewing them for severity of the complaints. According to the chief nurse executive (CNE) and
supervising RN (SRNIII), nurses new to CCHCS and hired within the most recent four months were
assigned to the TTA. These nurses did not have emergency nursing experience, and one of the
nurses informed the OIG staff that her nursing background was in a skilled nursing facility. In
addition, the new employees’ education files lacked any specific TTA emergency training for these
nurses. However, the CNE recognized the need to improve the emergency response at CAC. The
CNE described quality improvement plans to provide trauma emergency training through the local
ambulance company for all of the nursing staff.
Conclusion
Providers, nurses, and custody staff at CAC provided timely and appropriate urgent and emergent
care in a coordinated process. The OIG clinicians rated Emergency Services at CAC adequate.
Recommendations
No specific recommendations.
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HEALTH INFORMATION MANAGEMENT (MEDICAL RECORDS)
Health information management is a crucial link in the delivery of
Case Review Rating:
medical care. Medical personnel require accurate information in
Adequate
order to make sound judgments and decisions. This indicator
Compliance Score:
examines whether the institution adequately manages its health care Proficient
information. This includes determining whether the information is (87.2%)
correctly labeled and organized and available in the electronic unit
Overall Rating:
health record (eUHR); whether the various medical records (internal
Proficient
and external, e.g., hospital and specialty reports and progress notes)
are obtained and scanned timely into the inmate-patient’s eUHR;
whether records routed to clinicians include legible signatures or stamps; and whether hospital
discharge reports include key elements and are timely reviewed by providers.
In this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance review resulting in a proficient
score. The OIG’s internal review process considered those factors that led to both scores. The
clinicians indicated some diagnostic reports were not retrieved or scanned into the eUHR; however,
the providers were aware of the report results in most cases. As a result, the OIG’s medical
inspection team concluded that the appropriate overall score for this indicator should be proficient.
Case Review Results
The OIG clinicians identified 34 deficiencies related to health information management. The OIG
clinicians rated this indicator adequate.
Hospital Records
Fifteen hospital or outside emergency department events were reviewed, and the hospital records
were timely retrieved, reviewed, and scanned into the eUHR.
Missing Documents (Progress Notes and Forms)
Most pertinent documents, nursing and provider progress notes were scanned into the eUHR. There
was one missing document. In case 48, a provider prescribed an antibiotic, and there was no
keep-on-person (KOP) medication administration record indicating that the patient received the
medication.
Scanning Performance
There were 14 misfiled documents. In case 40, a hospital discharge summary of a different patient
was scanned into the eUHR. This was the only significant deficiency in this indicator.
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Specialty Services Reports
Most specialty services reports were retrieved, reviewed, and scanned into the eUHR. However,
there were five reports not retrieved or scanned into the eUHR. In case 43, a positron emission
tomography (PET) scan and a computed tomography (CT) scan were not retrieved or scanned into
the eUHR.
Diagnostic Reports
The OIG clinicians found 11 diagnostic reports were not retrieved or scanned into the eUHR.
However, the providers documented reviewing the reports and addressed the findings on follow-up
visits. There were ten x-ray reports not retrieved or scanned into the eUHR. This is also discussed in
the Diagnostic Services indicator.
Legibility
Most provider and nursing progress notes were dictated or legible.
Clinician Onsite Inspection
CAC medical record staff were prompt in retrieving and scanning specialty reports and hospital
discharge summaries. The reports were timely scanned into the eUHR after being reviewed by the
providers.
Conclusion
CAC performed well with its retrieval of specialty reports and hospital discharge summaries.
Although x-ray reports were not always retrieved or scanned into the eUHR, the providers were
aware of the reports. The OIG clinicians rated this indicator adequate.
Compliance Testing Results
CAC scored in the proficient range in the Health Information Management (Medical Records)
indicator, receiving a compliance score of 87.2 percent.
On the following four tests, CAC scored 100 percent and timely scanned documents into the
patient’s eUHR file: all 20 sampled initial health screening forms, health care services
request forms, and non-dictated progress notes (MIT 4.001); all 20 sampled MARs
(MIT 4.005); all 20 sampled specialty service consultant reports (MIT 4.003); and all 11
sampled hospital discharge reports (MIT 4.004).
The eUHR files for 11 out of 12 patients sent or admitted to the hospital were complete and
reviewed by providers within three calendar days of discharge (92 percent). For one patient,
there was no evidence a final discharge summary report was received; instead, the provider
reviewed and signed a hospital admission progress report, which did not include key
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Office of the Inspector General State of California
elements of a discharge report, including the date of admission, diagnosis, discharge date, or
medications ordered upon discharge (MIT 4.008).
The institution performed in the adequate range in the following area:
CAC scored 75 percent in its labeling and filing of documents scanned into patients’
eUHRs. For this test, the OIG bases its score on 12 mislabeled or misfiled documents; three
documents were scanned under the wrong date (MIT 4.006).
The institution showed room for improvement in the following area:
When the OIG reviewed various medical documents such as hospital discharge reports,
initial health screening forms, certain medication records, and specialty services reports to
ensure that clinical staff legibly documented their names on the forms, only 14 of 32
samples (44 percent) showed compliance. Eighteen of the samples did not include clinician
name stamps, and the signatures were illegible (MIT 4.007).
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
HEALTH CARE ENVIRONMENT
This indicator addresses the general operational aspects of the Case Review Rating:
institution’s clinics, including certain elements of infection control Not Applicable
and sanitation, medical supplies and equipment management, the Compliance Score:
Proficient
availability of both auditory and visual privacy for inmate-patient
(86.4%)
visits, and the sufficiency of facility infrastructure to conduct
comprehensive medical examinations. Rating of this component is Overall Rating:
based entirely on the compliance testing results from the visual Proficient
observations inspectors make at the institution during their onsite
visit.
Clinician Comments
Although OIG clinicians did not rate the health care environment at CAC, they obtained the
following information during their onsite visit:
The three medical clinics were centrally located, had ample lighting, and were stocked well
with medications and medical equipment.
The TTA had two beds and adequate space for patient evaluation, with working areas for
both nurses and providers. The TTA also had ample lighting and was sufficiently stocked
with medications and medical equipment, such as an automated external defibrillator (AED)
and an emergency crash cart.
Compliance Testing Results
The institution received a proficient compliance score of 86.4 percent in the Health Care
Environment indicator. The institution performed at a proficient level in 8 of the indicator’s 11 test
areas, as described below:
All nine clinics were appropriately disinfected, cleaned, and sanitized, and all had operable
sinks and sufficient quantities of hygiene supplies in the clinical areas (MIT 5.101, 5.103).
CAC was compliant at all nine clinics regarding mitigation of exposure to blood-borne
pathogens and contaminated waste (MIT 5.105).
The non-clinic medical storage area in CAC’s main medical storage warehouse generally
met the supply management process and support needs of the medical health care program.
CAC scored 100 percent on this test (MIT 5.106).
All nine clinics inspected followed adequate medical supply storage and management
protocols in their clinical areas (MIT 5.107).
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Clinical health care staff at eight of the nine applicable clinics (89 percent) ensured that
reusable invasive and non-invasive medical equipment was properly sterilized and
disinfected. At one clinic, inspectors determined that various equipment items designated as
sterilized and ready for use were not date stamped, included expired date stamps, or were
stored in torn sealed packages, breaching the instruments’ sterility (MIT 5.102).
Clinicians adhered to universal hand hygiene protocols in eight of the nine clinics
(89 percent). At one clinic, a nurse did not wash or sanitize her hands after patient contact
(MIT 5.104).
Clinic common areas at eight of nine clinics had an environment conducive to providing
medical services (89 percent); one clinic did not provide auditory privacy at the blood draw
station (MIT 5.109).
CAC received an adequate score in the following area:
Inspectors examined emergency response bags to determine if institution staff inspected the
bags daily and inventoried them monthly, and whether the bags contained all essential items.
Emergency response bags were compliant at five of the six applicable clinical locations
(83 percent). At one location, the inspector found the bag compartments unsealed prior to
the inspection (MIT 5.111).
The institution showed room for improvement in the two areas below:
Only six of nine clinic exam rooms
observed (67 percent) had appropriate
space, configuration, supplies, and
equipment to allow clinicians to perform a
proper clinical examination. Three clinics
lacked auditory privacy by allowing two
patients to be examined in the same exam
room at the same time (Figure 1). In
addition, in one of those three clinics, the
otoscope was not easily accessible for use
Figure 1: No auditory privacy for two patients
at the exam table (MIT 5.110).
examined at the same time.
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Some clinics’ common areas and exam rooms were missing core equipment or other
essential supplies necessary to conduct a comprehensive exam. As a result, only three of the
nine clinic locations were compliant (33 percent). Equipment and supply deficiencies in six
clinics’ common areas or exam rooms consisted of the following: three clinics did not have a
nebulization unit; two clinics lacked tongue depressors; one clinic lacked an otoscope and
tips, hemoccult cards and developer, and lubricating jelly, and the thermometer lacked a
calibration sticker; and the receiving and release (R&R) clinical area lacked an exam table
and Snellen chart (MIT 5.108).
Other Information Obtained from Non-Scored Results
The OIG gathered information to determine if the institution’s physical infrastructure was
maintained in a manner that supported health care management’s ability to provide adequate health
care. The OIG did not score this question. When OIG inspectors interviewed health care managers,
they did not express concerns about the facility’s infrastructure or its effect on staff’s ability to
provide adequate health care. Pending lease approval, the institution had three proposed
infrastructure projects: additional medical administrative space, dental area improvements, and a
pharmacy area fume hood. Upon the lease approval, the estimated completion for all three projects
is March 2017 (MIT 5.999).
Recommendation for CCHCS
The OIG recommends that CCHCS develop a statewide policy to identify required core equipment
and supplies for each type of clinical setting, including primary care clinics, specialty clinics, TTAs,
and R&Rs.
Recommendations for CAC
The OIG recommends that CAC develop local operating procedures that ensure the following:
All clinical areas maintain a full complement of core medical equipment that includes
nebulization units and a Snellen vision chart, and all exam rooms have an exam table in the
immediate area, tongue depressors, an otoscope and tips, lubricating jelly, and hemoccult
cards and developer.
Staff members regularly monitor medical equipment to ensure applicable equipment is
currently calibrated and reusable invasive medical equipment is properly sterilized.
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INTER- AND INTRA-SYSTEM TRANSFERS
This indicator focuses on the management of inmate-patients’
Case Review Rating:
medical needs and continuity of patient care during the inter- and
Adequate
intra-facility transfer process. The patients reviewed for Inter- and Compliance Score:
Intra-System Transfers include inmates received from other CDCR Proficient
facilities and inmates transferring out of CAC to another CDCR (94.8%)
facility. The OIG review includes evaluation of the institution’s
Overall Rating:
ability to provide and document health screening assessments,
Proficient
initiation of relevant referrals based on patient needs, and the
continuity of medication delivery to patients arriving from another
institution. For those patients, the OIG clinicians also review the timely completion of pending
health appointments, tests, and requests for specialty services. For inmate-patients who transfer out
of the facility, the OIG evaluates the ability of the institution to document transfer information that
includes pre-existing health conditions, pending appointments, tests and requests for specialty
services, medication transfer packages, and medication administration prior to transfer. The OIG
clinicians also evaluate the care provided to patients returning to the institution from an outside
hospital and check to ensure appropriate implementation of the hospital assessment and treatment
plans.
In this indicator, the OIG’s case review and compliance testing processes yielded different results,
with the case review giving an adequate rating and the compliance review resulting in a proficient
score. The OIG’s internal review process considered those factors that led to both scores. The
clinicians found a low number of deficiencies related to the assessment and disposition section of
the transfer forms and determined that the compliance score of proficient was a more appropriate
overall rating for this indicator.
Case Review Results
The OIG clinicians reviewed 22 encounters for Inter- and Intra-System Transfers. The OIG
reviewed three encounters for inmates transferring out of CAC to other institutions, and four for
inmates transferring into CAC from other institutions. The OIG reviewed 15 encounters for patients
returning to CAC from a community hospital or emergency department. There were 14 deficiencies,
two of which were significant (cases 1 and 24). In general, the transfer processes at CAC were
adequate.
Transfers In
The OIG clinicians found a few minor deficiencies for inmates transferring into CAC from other
CDCR institutions, primarily related to incomplete documentation and inadequate assessments.
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In case 21, the nurse failed to obtain the history of the patient’s recent infection, the reason
for the patient’s current antibiotic regimen, and the patient’s history of alcohol abuse. The
nurse also failed to document the patient’s denture appliances.
In case 22, the nurse failed to assess the patient’s elevated risk criteria for
coccidioidomycosis (valley fever).
In case 23, the nurse failed to document the patient had a positive tuberculosis (TB) skin
test. The information was corrected two months later.
Transfers Out
Deficiencies found with patients transferring out of CAC were largely due to incomplete nursing
documentation of significant medical information on the Health Care Transfer Information form
(CDCR Form 7371). One significant deficiency occurred when there was a lapse in nursing
assessment prior to transferring the patient, which placed the patient at a risk of harm (case 24).
In case 24, the nurse failed to assess the patient on the day of transfer. The receiving
institution sent the patient to the TTA with possible TB, after discovery of a cough for six
days and prior TB. In this same case, the nurse failed to document the date of the last chest
x-ray and a significant food allergy to mustard on the health care transfer form.
In case 25, the nurse did not document the TB code, date of the last chest x-ray, and lab
results on the health care transfer form.
In case 32, the nurse did not document the next provider visit date, the specialty service
appointment, and the reason for twice-per-week nursing visits on the health care transfer
form.
Hospitalizations
Patients returning from hospitalizations are some of the highest-risk encounters due to two factors.
First, these patients are generally hospitalized for a severe illness or injury. Second, they are at risk
due to potential lapses in care that can occur during any transfer. The R&R and TTA RNs processed
patients who were discharged from the hospital upon their return to CAC. The majority of the
patients were processed in the TTA.
Most hospital reports were retrieved and scanned into the eUHR within acceptable time frames.
However, some were not received timely or not received at all (further discussed in Health
Information Management and Specialty Services). In the majority of cases, RNs appropriately
reviewed the discharge medications and plans of care and obtained physician orders.
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The quality of most nursing care was adequate. However, there were cases that illustrated how the
lack of attention to detail can result in transfer errors or risk of harm for patients returning from the
hospital.
In case 1, the patient returned from the hospital with facial injuries and required dressing
changes to his eye. The RN failed to adequately assess the severity of the injuries, failed to
educate the patient on wound care, and failed to obtain antibiotic orders from the provider.
In case 2, the RN failed to adequately assess the patient with an abnormal heart rhythm upon
the patient’s return from an outside medical facility. The nurse failed to document
medications or the discharge plan.
In case 4, the patient returned from the hospital with significant facial and eye swelling and
a broken nose. The nurse in the TTA failed to follow hospital recommendations, which were
to help the patient keep his head elevated and to apply ice to the swollen area. The next day
his condition had worsened, he complained of a severe headache and dizziness, and his eye
was swollen shut. This resulted in readmission to the hospital and an overnight stay.
Onsite Visit
There were two nurses assigned to the R&R, with one on second watch and one on third. These
nurses were responsible for assessing intra-system transfers and patients returning from offsite
medical specialty service appointments.
The R&R nurses indirectly referred patients to the providers via the chronic care nurses in the
clinic. The providers were notified of the new patient arrivals during the morning huddle. The
OIG’s case reviews showed this process to work well, as patients were seen timely by providers.
When patients transferred out, all medications were accounted for and verified prior to transferring.
If a medication was not received, the nurse retrieved the medication from the Omnicell (electronic
storage). All medication orders were processed timely.
During the onsite visit, the R&R nurse could not describe the new CCHCS transfer policy for a
medical hold.
Compliance Testing Results
The institution obtained a proficient compliance score of 94.8 percent in the Inter- and Intra-System
Transfers indicator. The institution scored in the proficient range on all five tests, as follows:
CAC scored 100 percent when the OIG tested one patient who transferred out of CAC
during the OIG’s onsite inspection to determine whether his transfer package included the
required medications and related documentation. Although three inmates transferred out on
the testing day, only one was prescribed medications (MIT 6.101).
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The OIG tested 30 patients who transferred into CAC from another CDCR institution;
nursing staff completed an initial health screening assessment form on the same day of the
patient’s arrival for 29 of the patients (97 percent). In one instance, nursing staff neglected to
answer all applicable questions on the patient’s initial health screening form (MIT 6.001).
Nursing staff timely completed the assessment and disposition sections of the screening
form for 29 of 30 patients (97 percent). For one patient, nursing staff failed to answer if a
provider referral was required (MIT 6.002).
Inspectors tested 20 patients who transferred out of CAC to another CDCR institution to
determine whether their scheduled specialty service appointments were listed on the health
care transfer form. CAC nursing staff identified the scheduled appointments on the transfer
forms for 19 of the samples tested (95 percent). For one patient, nursing staff did not
document a pending specialty service on the transfer form (MIT 6.004).
Of seven sampled patients who transferred into CAC with an existing medication order, six
(86 percent) received their medications without interruption upon arriving at CAC. One
patient did not receive his prescribed KOP medication, which did not arrive until the next
day (MIT 6.003).
Recommendation
The OIG recommends that CAC provide training for all TTA, R&R, and utilization management
staff on the CCHCS revision of the health care transfer medical hold policy.
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Office of the Inspector General State of California
PHARMACY AND MEDICATION MANAGEMENT
This indicator is an evaluation of the institution’s ability to provide
Case Review Rating:
appropriate pharmaceutical administration and security management, Adequate
encompassing the process from the written prescription to the Compliance Score:
administration of the medication. By combining both a quantitative Proficient
(92.1%)
compliance test with case review analysis, this assessment identifies
issues in various stages of the medication management process,
Overall Rating:
including ordering and prescribing, transcribing and verifying, Proficient
dispensing and delivering, administering, and documenting and
reporting. Because effective medication management is affected by
numerous entities across various departments, this assessment considers internal review and
approval processes, pharmacy, nursing, health information systems, custody processes, and actions
taken by the prescriber, staff, and patient.
In this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance review resulting in a proficient
score. The OIG’s internal review process considered those factors that led to both scores. Case
reviews focused on medication administration as secondary processes, while compliance reviewers
considered medication administration as well as medication storage, pharmacy protocols, and other
factors to arrive at a rating for this indicator. As a result, the compliance review rating of proficient
was deemed a more appropriate reflection of the overall indicator rating.
Case Review Results
The OIG clinicians evaluated pharmacy and medication management as secondary processes as
they related to the quality of clinical care provided. From a clinical perspective, pharmacy
performance and medication administration were adequate. There were 49 medication and
pharmacy events reviewed. There were 16 deficiencies, one of which was significant (case 39).
Medication errors found during case reviews were rare.
Medication administration
During their onsite visit, the OIG clinicians met with medical and nursing representatives regarding
case review findings. The majority of the patients received self-administered medications.
Nurse-administered (NA) and direct observation therapy (DOT) medications were given at pill
lines, where there were 40 to 50 patients in the morning and evening lines but just one or two
patients in the noon lines. The medication staff stated that they received copies of orders timely.
The nurse educators were able to provide staff education files that demonstrated competency testing
in medication management for a random selection of nursing staff. However, the following
deficiencies were found during case review:
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Documentation
In case 13, the nurse failed to document the dosage of the vaccine and the method of its
administration.
In case 21, the nurse documented that the patient received a meningitis vaccine, but the
provider had ordered a pneumonia vaccine.
In case 42, the nurse illegibly documented the date the patient received the medication.
In case 37, the patient refused vaccination, but the vaccination form showed that the patient
received the vaccination.
Failure to Administer or Notify
In case 6, the licensed psychiatric technician failed to administer insulin on two different
dates; on another occasion, another licensed psychiatric technician did not evaluate the
patient for signs and symptoms of elevated blood glucose and failed to report it to or notify
the registered nurse.
In case 15, a medication administration record for phenytoin (seizure medication) was
incorrectly filed.
In case 22, there was a three-day delay in the patient receiving self-administered
medications.
In case 26, the pharmacy failed to deliver a prescribed medication, and the nursing staff
failed to verify the patient’s medications and identify that this medication had not been
delivered.
In case 31, the provider discontinued a medication, but the nurse did not verify the patient’s
new prescription order and continued to administer the medication.
In case 35, the nurse failed to inform the provider that the patient did not show up for the
medication on multiple days.
In case 37, the nurse failed to address the patient’s request for a renewal of diabetic
medication, causing a lapse in medication continuity.
In case 39, after returning from an offsite hospitalization for severe constipation, the patient
did not receive his prescribed medication. This placed the patient at risk of requiring another
hospitalization.
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Conclusion
The OIG clinicians rated the Pharmacy and Medication Management indicator adequate.
Compliance Testing Results
The institution received a proficient compliance score of 92.1 percent in the Pharmacy and
Medication Management indicator. For discussion purposes below, this indicator is divided into
three sub indicators: medication administration, observed medication practices and storage controls,
and pharmacy protocols.
Medication Administration
This sub indicator consists of four applicable questions in which the institution received a proficient
score of 97.0 percent and scored in the proficient range in each of the following areas:
CAC timely administered or delivered new medication orders to all 30 patients sampled
(MIT 7.002).
The institution ensured that all 21 patients sampled received their medications without
interruption when they transferred from one housing unit to another (MIT 7.005).
Nursing staff timely dispensed long-term chronic care medications to 28 of the 29 patients
sampled (97 percent). One patient did not receive one month of his KOP medication during
the OIG’s three-month testing period (MIT 7.001).
CAC timely provided new and previously prescribed medications to 11 of 12 sampled
patients upon their return to the institution from a community hospital (92 percent). One
patient received his medication one day late (MIT 7.003).
Observed Medication Practices and Storage Controls
In this sub-indicator, the institution received an adequate average score of 82 percent, but scored a
proficient 100 percent in the following test:
Nursing staff at all four of the sampled medication preparation and administration locations
employed appropriate administrative controls and protocols when preparing patients’
medication (MIT 7.105).
CAC scored in the adequate range in the five tests below:
The OIG interviewed nursing staff and inspected narcotics storage areas at six applicable
clinic and pill line locations to assess narcotic security controls. Nursing staff had strong
medication security controls over narcotic medications at five locations (83 percent). For
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one clinic, on the day of inspection, the narcotics logbook was not counter-signed by two
nursing staff during the shift change (MIT 7.101).
CAC properly stored non-narcotic medications that did not require refrigeration at eight of
the ten applicable clinics and medication line storage locations sampled (80 percent).
Inspectors found the following deficiencies: the crash cart seal number did not correspond to
the crash cart logbook at one location; at a second location, a bottle of hydrogen peroxide
was not labeled with the date the bottle was opened (MIT 7.102).
Nursing staff followed appropriate administrative controls and protocols when distributing
medications to patients at four of five applicable medication preparation and administrative
locations (80 percent). At one location, nursing staff did not discontinue a patient’s
medications per the provider’s order (MIT 7.106).
Non-narcotic refrigerated medications were properly stored in six of eight clinics and
medication line storage locations (75 percent). Two locations stored batteries in the
refrigeration unit against the battery manufacturer’s recommendation (MIT 7.103).
Nursing staff at only three of the four sampled medication preparation and administration
locations (75 percent) followed proper hand hygiene contamination control protocols during
the medication preparation and administrative processes. At one location, nursing staff did
not have access to non-latex gloves during medication administration (MIT 7.104).
Pharmacy Protocols
For this sub-indicator, the institution scored 100 percent in each of the five test areas:
In its main pharmacy, CAC followed general security, organization, and cleanliness
management protocols; properly stored and monitored non-narcotic medications that
required refrigeration and those that did not; and maintained adequate controls and properly
accounted for narcotic medications (MIT 7.107, 7.108, 7.109, 7.110).
CAC’s pharmacist in charge timely processed all 26 inspector-sampled medication error
reports (MIT 7.111).
Non-Scored Tests
In addition to testing reported medication errors, OIG inspectors follow up on any
significant medication errors found during the case reviews or compliance testing to
determine whether the errors were properly identified and reported. The OIG provides those
results for information purposes only. At CAC, the OIG did not find any applicable
medication errors subject to this test (MIT 7.998).
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The OIG tested patients housed in isolation units to determine if they had immediate access
to their prescribed KOP rescue asthma inhalers and nitroglycerin medications. One
applicable patient confirmed he had physical possession of his rescue medication
(MIT 7.999).
Recommendations
No specific recommendations.
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PREVENTIVE SERVICES
This indicator assesses whether various preventive medical services Case Review Rating:
are offered or provided to inmate-patients. These include cancer Not Applicable
screenings, tuberculosis screenings, and influenza and chronic care Compliance Score:
Proficient
immunizations. This indicator also assesses whether certain
(95.0%)
institutions take preventive actions to relocate inmate-patients
identified as being at higher risk for contracting coccidioidomycosis Overall Rating:
(valley fever). Proficient
The OIG rates this indicator entirely through the compliance testing
component; the case review process does not include a separate qualitative analysis for this
indicator.
Compliance Testing Results
The institution performed in the proficient range in the Preventive Services indicator, with a
compliance score of 95.0 percent. Six test areas scored in the proficient range, including five scores
of 100 percent, as described below:
CAC timely administered tuberculosis medications to all four sampled patients with
tuberculosis (MIT 9.001).
The institution was compliant in offering annual influenza vaccinations to all 30 sampled
patients (MIT 9.004).
CAC offered colorectal cancer screenings to all 30 sampled patients subject to the annual
screening requirement (MIT 9.005).
The OIG tested whether CAC offered vaccinations for influenza, pneumonia, and hepatitis
to patients who suffered from a chronic care condition; all eight sampled patients received
recommended vaccinations at the required interval (MIT 9.008).
The OIG tested five patients at high risk for contracting coccidioidomycosis infection
(valley fever), identified as medically restricted and ineligible to reside at CAC, to determine
if they were transferred out of the institution within 60 days from the time they were deemed
ineligible. Inspectors found that CAC timely transferred all five patients (MIT 9.009).
The institution scored 90 percent for conducting annual tuberculosis (TB) screenings. CAC
timely screened all 30 sampled patients for tuberculosis within the prior year. All 15 of the
patients classified as Code 22 (requiring a TB skin test in addition to signs and symptoms
screenings) were properly tested. In addition to the sampled Code 22 patients, inspectors
sampled 15 patients classified as Code 34 (those who had previously tested for TB and
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subject only to an annual signs and symptoms screening). For three patients, nursing staff
did not complete the history section of the Tuberculin Testing/Evaluation Report (CDCR
Form 7331) (MIT 9.003).
The institution scored in the adequate range in the following area:
Three of the four patients sampled (75 percent) were properly monitored while taking TB
medications. One patient’s required TB monitoring evaluation form was completed but it
was not timely scanned into their eUHR after the evaluation occurred (MIT 9.002).
Recommendations
No specific recommendations.
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QUALITY OF NURSING PERFORMANCE
The Quality of Nursing Performance indicator is a qualitative
Case Review Rating:
evaluation of the institution’s nursing services. The evaluation is
Adequate
completed entirely by OIG nursing clinicians within the case
Compliance Score:
review process, and, therefore, does not have a score under the
Not Applicable
compliance testing component. The OIG nurses conduct case
reviews that include reviewing face-to-face encounters related to Overall Rating:
nursing sick call requests identified on the Health Care Services Adequate
Request form (CDCR Form 7362), urgent walk-in visits, referrals
for medical services by custody staff, RN case management, RN utilization management, clinical
encounters by licensed vocational nurses (LVNs) and licensed psychiatric technicians (LPTs), and
any other nursing service performed on an outpatient basis. The OIG case review also includes
activities and processes performed by nursing staff that are not considered direct patient encounters,
such as the initial receipt and review of health care services request forms and follow-up with
primary care providers and other staff on behalf of the patient. Key focus areas for evaluation of
outpatient nursing care include appropriateness and timeliness of patient triage and assessment,
identification and prioritization of health care needs, use of the nursing process to implement
interventions including patient education and referrals, and documentation that is accurate,
thorough, and legible. Nursing services provided in the triage and treatment area (TTA) or related to
emergency medical responses are reported under Emergency Services.
Case Review Results
OIG nursing clinicians rated the Quality of Nursing Performance at CAC adequate. The OIG
evaluated 860 events during case review. Of these, approximately 210 were outpatient encounters
from sick call requests and primary care clinic nurse follow-up visits. In general, nursing performed
well. In all, 72 deficiencies were found in outpatient nursing services, the majority of which were
minor and unlikely to contribute to patient harm. Nevertheless, these deficient areas are clearly
established in CCHCS policy as requirements for nursing care and practice and, therefore, require
quality improvement strategies. Eight cases had significant deficiencies with the potential for
adverse outcomes or unnecessary delays in needed health care services.
Nursing Sick Call
The majority of sick call RNs appropriately assessed complaints and symptoms, and provided
necessary interventions for patients presenting with medical issues in the outpatient nurse clinics.
There were 8 significant deficiencies (two in case 44 and one each in cases 18, 27, 30, 31, 36, and
41). The quality of nursing performance was affected by patterns of deficiencies in the form of
lacking assessments or providing inadequate assessments. There was also improper implementation
of or delays in interventions based on assessment.
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The following examples demonstrated intervention delays and either no assessment or inadequate
assessment:
In case 18, the patient had a painful, red eye and blurry vision. The nurse did not perform an
adequate assessment, and instructed the patient to complete a sick call request to be seen by
the clinic nurse. The nurse also failed to contact the provider emergently. When the patient
was seen the following day, he was transferred by the provider to an offsite eye center for an
eye infection.
In case 19, on several different encounters, the sick call nurse failed to assess the patient for
symptoms such as dizziness or toothache.
Nurses also failed to assess patients with medical symptoms in cases 13, 16, and 39. Incomplete
nursing assessment also occurred in cases 10, 11, 15, 20, 22, 32, 37, 38, and 42.
In case 6, the licensed psychiatric technician failed to evaluate a patient with elevated blood
sugar readings, and did not contact the RN.
In case 41, the patient submitted a sick call request for immediate help for lack of energy
and feelings of passing out. The nurse reviewed the sick call request form and
inappropriately deferred to the clinic nurse two days later. The next day, the patient was sent
to the TTA with an elevated temperature, cough, and body aches. The patient was
transferred to the hospital, where he underwent eight days of care for pneumonia.
In case 43, the nurse saw the patient for a rash, possibly related to an allergic reaction. The
nurse failed to contact the provider for consultation. Five days later, the patient submitted
another sick call request form, and the nurse failed to adequately assess the severity of the
rash and integrity of the skin. One month later, the provider saw the patient for cellulitis
(skin infection) and ordered wound checks by the nurse for seven days. The nurse failed to
check the wound on two of the seven days, and on two other days, the nurse failed to
adequately assess and describe the measurement of the wound.
In case 44, the nurse failed to notify the provider of abnormal vital signs and wheezing in a
patient with a cough and uncontrolled diabetes. The patient was given the nursing protocol
medications of acetaminophen and chlorpheniramine (allergy medication) for viral rhinitis
(common cold), and sent back to his housing unit.
The following case involved a patient death, which was not preventable:
In case 27, the nurse inadequately assessed the patient with severe abdominal pain and
vomiting, sent him back to his housing unit, and made a routine referral to the provider. The
nurse failed to intervene and immediately notify the provider at the time of the sick call visit.
Twelve hours later, the patient was taken to the TTA and sent out to the hospital. The patient
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had sepsis (infection in the blood system), acute pancreatitis, and kidney failure. The patient
died at the hospital ten days later. The OIG review felt this deficiency did not affect the
patient outcome, and the death was not preventable.
The failure to refer or notify the provider of significant abnormal findings or vital signs was also
found in cases 8, 23, and 40.
At times, nurses failed to provide an adequate assessment upon a patient’s return from an offsite
specialty service procedure, as illustrated in the following examples:
In case 16, the nurse failed to assess the patient after the patient returned from a specialty
service, an endoscopic stomach biopsy, that was performed offsite.
In case 33, the nurse failed to assess the patient after return from another endoscopic biopsy.
In case 30, upon return from an offsite intravenous cardiac catheterization angiogram
(procedure to view the heart’s arteries), the nurse did not examine the intravenous site and
did not instruct the patient on post-procedure care.
In case 31, the patient had an MRI (magnetic resonance imaging) examination with contrast
dye. The nurse failed to reinforce specific discharge instructions about drinking water every
hour. Failure of nurses to ensure that all post-procedure instructions are reinforced and that
supplies are available can place patients at risk of harm and complications. This patient also
had two sick call encounters, and the nurse failed to notify the provider of severe leg pain.
The nurse did not refer the patient urgently to the provider. Six days later, the patient
transferred to the hospital for leg swelling from poor circulation of the leg veins. In addition,
the nurse failed to contact the provider upon the patient’s return from the hospital to discuss
the type of housing for the patient.
Clinical Onsite Visit
The OIG clinicians visited all yard clinics. The clinics were clean and organized. The main medical
clinic, which was separate from the clinic yards, was in a central location. This clinic was staffed
with physicians, LVNs, RNs, medication nurses, and supervisors. It was observed that the
physicians and nursing staff had excellent medical equipment, with new Welch-Allen diagnostic
wall units (instruments for eye and ear examinations) for the nurses and the providers. The OIG
clinicians attended the morning huddle during their onsite visit. The entire medical and support staff
attended and discussed specific patient panels as outlined in the huddle script. All huddles were
brief and succinct.
The clinics were well staffed. The two RNs in each clinic conducted the face-to-face sick call visits
and routine primary care management visits for chronic care patients. The LVN care coordinators
completed wound care, blood pressure checks, and care coordination reviews for preventive
vaccinations and patient education needs; and obtained laboratory results, diagnostic reports, and
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other information needed for the RN visits. At the time of the onsite inspection, in clinics A and B,
one RN shared an office with two LVNs and did not have a private and confidential space to assess
patients, and used a folding screen when necessary. The other RN had a private office down the
hall.
At CAC, the providers and clinical staff frequently communicated via e-mail. In some instances,
this was ineffective and, as a result, wound care and medication orders did not always occur. In
addition, blood pressure checks were not communicated to the provider as requested. When staff
was asked about this communication gap, they could not explain or give a reason. The nurses onsite
were asked to explain how referrals were tracked. On Yard B, the nurse stated that referrals were
documented on the daily appointment sheet, and informed the patient to return to the clinic if he did
not receive a ducat (appointment slip) for the appointment. On Yard C, appointments were
confirmed through the Strategic Offender Management System database. The schedulers in the
main medical clinic stated Med-SATS (scheduling and aging tracking system) was used to schedule
and check referrals and appointments.
Conclusion
The outpatient nursing care at CAC was adequate. Although some cases lacked adequate nursing
assessment, intervention, and documentation, strategies for ongoing quality improvement and
monitoring of nursing services was evident.
Recommendations
The OIG recommends that CAC management implement the following:
Evaluate the processes currently in place for orienting, mentoring, and monitoring the
performance of nursing staff at all levels.
Develop quality improvement projects that include ongoing education, monitoring,
evaluation, and feedback methods to ensure that nurses at all levels are aware of and
involved in improving nursing performance and services.
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QUALITY OF PROVIDER PERFORMANCE
In this indicator, the OIG physicians provide a qualitative
Case Review Rating:
evaluation of the adequacy of provider care at the institution.
Adequate
Appropriate evaluation, diagnosis, and management plans are
Compliance Score:
reviewed for programs including, but not limited to, nursing sick Not Applicable
call, chronic care programs, TTA, and specialty services. The
assessment of provider care is performed entirely by OIG Overall Rating:
physicians. There is no compliance testing component associated Adequate
with this quality indicator.
Case Review Results
OIG clinicians reviewed 224 medical provider encounters and identified 25 deficiencies related to
provider performance. Of those 25 deficiencies, three were considered significant deficiencies (two
in case 44 and one in case 46). As a whole, CAC provider performance was rated a strong adequate,
bordering proficient.
Assessment and Decision-Making
In most cases, CAC providers made appropriate assessments and sound medical plans. There was
one significant deficiency:
In case 46, the provider documented that the patient had a calculated 19.2 percent 10-year
risk of heart disease or stroke but did not prescribe the recommended high intensity
cholesterol lowering medication. The failure to prescribe a statin placed the patient at risk
for cardiovascular events.
Emergency Care
Providers generally made appropriate triage decisions when patients presented emergently to the
TTA. In addition, the providers generally were available for consultation with the TTA nursing
staff. However, there were two minor deficiencies identified related to the quality of provider care
in emergency services. The cases below are also discussed in the Emergency Services indicator:
In case 32, there was no provider progress note documenting the emergent event for a
patient with chest pain.
In case 41, there was no provider progress note documenting the emergent event for a
patient in the TTA with fever, shortness of breath, and productive cough.
Hospital Return
CAC providers properly signed hospital discharge summaries and timely addressed all the
recommendations.
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Chronic Care
Chronic care performance was adequate as most providers demonstrated good care in regard to
hypertension, asthma, hepatitis C infection, and cardiovascular disease. The providers’ thorough
documentation showed sound assessments and plans.
The OIG clinicians identified the following deficiencies in the chronic care program:
In case 34, the oversight committee had recommended hepatitis C virus treatment. The
provider evaluating the patient more than a month later failed to review and address the
recommendation.
In case 36, the provider ordered blood pressure checks for two weeks. On the follow-up
visit, the provider did not address the elevated blood pressure readings. In addition, the
provider documented that the patient’s previously ordered cholesterol lowering medication
should be continued, but the medication had expired five days prior to the visit and was not
renewed.
In case 52, the provider did not address two elevated blood pressure readings during a
patient visit.
The management of diabetes was adequate. Most providers demonstrated excellent diabetic
management skills. However, the OIG clinicians identified the following two significant
deficiencies in diabetic care:
In case 44, the patient had poorly controlled diabetes with average fasting blood glucose of
174 mg/dL. The provider failed to adjust the basal insulin, and the 90-day follow-up was too
long for a diabetic patient not at goal.
Also in case 44, a nurse consulted a provider for a critical high blood glucose level of 479
mg/dL; the provider should have ordered a next-day follow-up appointment, requesting that
a provider conduct a thorough evaluation and assessment of diabetic control.
Specialty Services
CAC providers generally referred appropriately and reviewed specialty reports timely. Not all the
reports were properly signed by the providers; however, all specialist recommendations were timely
addressed. There was one minor deficiency:
In case 30, after reviewing a normal cardiac catheterization, indicating that chest pain was
not due to coronary artery disease, the provider inappropriately requested cardiology
follow-up for chest pain.
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Health Information Management
The providers generally documented outpatient and TTA encounters on the same day. Most
progress notes were dictated and generally legible.
Clinician Onsite Inspection
At the time of the OIG inspection, there was no provider vacancy. All CAC providers were
enthusiastic about their work and expressed satisfactions with nursing, specialty, and diagnostic
services. Each provider was mainly assigned to one clinic to ensure continuity of care. The three
clinics were centrally located, and this enabled the providers to easily consult with each other.
Morning huddles were productive, and led by providers, attended by nurses, care coordinators,
custody staff, and office technicians. The chief medical executive (CME) and chief physician and
surgeon were committed to patient care and quality improvement. All the providers expressed
general job satisfaction with their positions, and morale was good overall.
Conclusion
The providers at CAC delivered good care in the majority of the physician-reviewed cases. Among
the 30 cases, 29 were adequate, and one was inadequate. The OIG rates CAC provider performance
as adequate.
Recommendations
No specific recommendations.
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SPECIALTY SERVICES
This indicator focuses on specialist care from the time a request for
Case Review Rating:
services or physician’s order for specialist care is completed to the
Proficient
time of receipt of related recommendations from specialists. This Compliance Score:
indicator also evaluates the providers’ timely review of specialist Proficient
records and documentation reflecting the patients’ care plans, (88.6%)
including course of care when specialist recommendations were not
Overall Rating:
ordered, and whether the results of specialists’ reports are
Proficient
communicated to the patients. For specialty services denied by the
institution, the OIG determines whether the denials are timely and
appropriate, and whether the inmate-patient is updated on the plan of care.
Case Review Results
The OIG clinicians reviewed 90 events regarding Specialty Services. There were just eight
deficiencies in this category, only one of which was significant (case 42). Most of the deficiencies
were related to the health information management process. The case review rating for Specialty
Services was proficient.
Provider Performance
Case review showed that patients were generally referred to specialists appropriately by the
providers, except on one occasion; this episode is discussed further in the Quality of Provider
Performance indicator. The providers also timely reviewed and addressed specialists’
recommendations.
Specialty Access
On one occasion, a specialty service did not occur within the requested time frame:
In case 42, a provider requested to have the patient follow-up with the gastroenterologist in
four weeks for an evaluation of anemia (a low blood count), but the appointment occurred
11 weeks later.
On one occasion, specialty services appointments did not occur:
In case 38, a provider requested for a general surgery evaluation, but the patient was actually
seen by an ear, nose, and throat (ENT) specialist.
Health Information Management
The OIG identified five specialty reports that were not retrieved or scanned into the eUHR;
however, providers were aware of the reports during follow-up visits.
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Clinician Onsite Inspection
At the time of the OIG inspection, the specialty services staff had established an effective tracking
process to ensure that patients received their necessary specialty appointments and diagnostic
procedures timely. CAC also had an effective process to ensure specialty reports were retrieved and
scanned into the eUHR.
Conclusion
Missed or delayed specialty appointments were rare, and most specialty reports were retrieved and
available for review. The OIG clinicians rated the Specialty Services indicator at CAC proficient.
Compliance Testing Results
The institution received a proficient compliance score of 88.6 percent in the Specialty Services
indicator. CAC scored 100 percent for five of the six test areas, as described below:
Providers timely received and reviewed the specialists’ reports for all patients who received
a routine and high-priority specialty service (MIT 14.002, 14.004).
For all 12 patients sampled, denials of providers’ specialty services requests occurred within
the required time frame and the providers timely communicated the denial status for the
requested services to the patients (MIT 14.006, 14.007).
All 15 patients sampled received their routine specialty services appointment within 90
calendar days of the provider’s order. For 13 of the 15 patients sampled (87 percent), the
high-priority specialty services appointment occurred within 14 calendar days of the
provider’s order. One patient received the service appointment two days late. While another
patient refused the specialty appointment but it was scheduled 12 days late (MIT 14.003,
14.001).
The institution scored within the inadequate range on the following test:
When patients are approved or scheduled for specialty services appointments at one
institution and then transfer to another institution, policy requires that the receiving
institution timely schedule and hold the patient’s appointment. Two of the six patients
sampled who transferred to CAC with an approved specialty service appointment
(33 percent) received it within the required time frame. Four patients received their specialty
appointments from 2 to 39 days late (MIT 14.005).
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
SECONDARY (ADMINISTRATIVE) QUALITY INDICATORS OF HEALTH CARE
The last two quality indicators (Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications) involve health care
administrative systems and processes. Testing in these areas applies only to the compliance
component of the process. Therefore, there is no case review assessment associated with either of
the two indicators. As part of the compliance component of the first of these two indicators, the OIG
does not score several questions. Instead, the OIG presents the findings for informational purposes
only. For example, the OIG describes certain local processes in place at CAC.
To test both the scored and non-scored areas within these two secondary quality indicators, OIG
inspectors interviewed key institutional employees and reviewed documents during their onsite visit
to CAC in May 2016. They also reviewed documents obtained from the institution and from
CCHCS prior to the start of the inspection. Of these two secondary indicators, OIG compliance
inspectors rated both inadequate. The test questions used to assess compliance for each indicator are
detailed in Appendix A.
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INTERNAL MONITORING, QUALITY IMPROVEMENT, AND ADMINISTRATIVE OPERATIONS
This indicator focuses on the institution’s administrative health care
Case Review Rating:
oversight functions. The OIG evaluates whether the institution
Not Applicable
promptly processes inmate-patient medical appeals and addresses
Compliance Score:
all appealed issues. Inspectors also verify that the institution follows Inadequate
reporting requirements for adverse/sentinel events and inmate (68.8%)
deaths, and whether the institution is making progress toward its
Overall Rating:
Performance Improvement Work Plan initiatives. In addition, the
Inadequate
OIG verifies that the Emergency Medical Response Review
Committee (EMRRC) performs required reviews and that staff
perform required emergency response drills. Inspectors also assess whether the Quality
Management Committee (QMC) meets regularly and adequately addresses program performance.
For those institutions with licensed facilities, inspectors also verify that required committee
meetings are held.
Compliance Testing Results
The institution scored within the inadequate range in the Internal Monitoring, Quality
Improvement, and Administrative Operations indicator, receiving a compliance score of
68.8 percent, showing need for improvement in the following three areas:
The OIG reviewed documentation for 12 emergency medical response incidents addressed
by the institution’s Emergency Medical Response Review Committee (EMRRC) during the
prior six-month period and found that the required EMRRC Event Checklist forms were
either not fully completed or not available at all. Further, the committee minutes did not
document discussion of all of the three required questions for the 12 incidents. As a result,
CAC received a score of zero on this test (MIT 15.007).
Emergency response drill packages for three medical emergency response drills conducted
in the prior quarter did not include required documentation; none of the three drill packages
contained a Medical Report of Injury or Unusual Occurrence (CDCR Form 7219) and one of
the drill packages did not list the CPR initiation time. As a result, CAC received a score of
zero on this test (MIT 15.101).
Inspectors reviewed six recent months’ Quality Management Committee (QMC) meeting
minutes and confirmed that the QMC evaluated program performance and took action when
the committee identified improvement opportunities. Three of the six meeting were
scheduled monthly (50 percent); due to scheduling conflicts, the other three meetings were
each scheduled one week late (MIT 15.003).
The institution scored in the proficient range with 100 percent scores on each of the following five
tests:
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The institution promptly processed all inmate medical appeals in each of the most recent 12
months (MIT 15.001). In addition, based on a sample of ten second-level medical appeals,
the institution’s responses addressed all of the patients’ appealed issues (MIT 15.102).
CAC took adequate steps to ensure the accuracy of its Dashboard data reporting
(MIT 15.004).
CAC reached targeted performance objectives for all of the three quality improvement
initiatives identified in its 2015 Performance Improvement Work Plan (MIT 15.005).
Medical staff promptly submitted the Initial Inmate Death Report (CDCR Form 7229A) to
CCHCS’s Death Review Unit for the one applicable death that occurred at CAC in the prior
12-month period (MIT 15.103).
Other Information Obtained from Non-Scored Areas
The OIG gathered non-scored data regarding the completion of death review reports.
CCHCS’s Death Review Committee timely completed its death review summary for the one
death that occurred during the testing period. For any inmate deaths that occurred prior to
November 1, 2015, the CCHCS Death Review Committee (DRC) was required to complete
a death review summary within 30 business days of the death and submit it to the
institution’s chief executive officer (CEO) five business days later. The DRC timely
completed both the death review summary and the subsequent CEO notification
(MIT 15.996).
Inspectors met with the institution’s CEO and chief support executive (CSE) to inquire
about CAC’s protocols for tracking appeals. The health care appeals coordinator provided
monthly appeals summary reports to the appropriate management staff. The reports
addressed statistics on appeal issues by subject area (medical, dental, mental health,
medication, and staff complaints) and the area the appeals were assigned. Management
discussed issues at the Quality Management Committee meetings, and evaluated trends and
any hotspot areas. In the six months preceding the OIG’s inspection, management did not
identify any critical problems through medical appeals (MIT 15.997).
Non-scored data regarding the institution’s practices for implementing local operating
procedures (LOPs) indicated that the institution had an effective process in place for revising
existing LOPs and developing new ones. When new or revised policies and procedures were
received from CCHCS, the health program specialist (HPS) distributed them to appropriate
subject matter experts (SME) assigned by management. The SME reviewed the new policy
and returned to the HPS for review by the respective sub-committee and Quality
Management committee. Once approved, training on the new or revised LOPs was provided
to impacted staff within 30 days. At the time of the OIG’s inspection in May 2016, CAC had
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implemented, or was developing, 25 of the 29 stakeholder-recommended LOPs (86 percent)
(MIT 15.998).
The OIG discusses the institution’s health care staffing resources in the About the Institution
section of this report (MIT 15.999).
Recommendations
No specific recommendations.
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JOB PERFORMANCE, TRAINING, LICENSING, AND CERTIFICATIONS
In this indicator, the OIG examines whether the institution
Case Review Rating:
adequately manages its health care staffing resources by evaluating
Not Applicable
whether job performance reviews are completed as required;
Compliance Score:
specified staff possess current, valid credentials and professional
Inadequate
licenses or certifications; nursing staff receive new employee (58.3%)
orientation training and annual competency testing; and clinical and
Overall Rating:
custody staff have current medical emergency response
Inadequate
certifications.
Compliance Testing Results
The institution received an inadequate compliance score of 58.3 percent in the Job Performance,
Training, Licensing, and Certifications indicator. The following four areas displayed opportunities
for improvement:
The OIG inspected records from March 2016 for five nurses, to determine if their nursing
supervisors properly completed monthly performance reviews. Inspectors identified the
following deficiencies for the five nurses’ monthly nursing reviews (MIT 16.101):
o The supervisor did not complete the required number of reviews for two nurses;
o The supervisor’s review did not summarize aspects that were well done for four
nurses;
o The documentation did not confirm that the supervising nurse discussed the findings
with two nurses.
None of the institution’s five providers who required a structured clinical performance
appraisal appropriately received one. One provider had not received a performance
evaluation since he was hired in 2013, and four received their last annual performance
appraisal from six months to almost four years late. Also, all five providers’ most recent
performance appraisal package lacked a Unit Health Record Clinical Appraisal, and four
applicable providers lacked both a 360-Degree Evaluation and a Core Competency-Based
Evaluation (MIT 16.103).
CAC hired seven nurses within the last 12 months, and not one of them received a timely
new employee orientation training. Six nurses received their orientation six to eight weeks
late and one nurse had still not received an orientation at the time of the inspection (over
eight months late) (MIT 16.107).
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The OIG tested provider, nursing, and custody staff records to determine if the institution
ensured that those staff members had current emergency response certifications. The
institution’s provider and nursing staff were all compliant, but custody managers were not.
While the California Penal Code exempts custody managers who primarily perform
managerial duties from medical emergency response certification training, CCHCS policy
does not allow for such an exemption. As a result, the institution received a score of
67 percent on this test (MIT 16.104).
The institution received a proficient score of 100 percent in the following four test areas:
All providers were current with their professional licenses, and nursing staff and the
pharmacist in charge were current with their professional licenses and certification
requirements (MIT 16.001, 16.105).
All ten nurses sampled were current with their clinical competency validations
(MIT 16.102).
The institution’s pharmacy and providers who prescribed controlled substances were current
with their Drug Enforcement Agency registrations (MIT 16.106).
Recommendations
No specific recommendations.
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POPULATION-BASED METRICS
The compliance testing and the case reviews give an accurate assessment of how the institution’s
health care systems are functioning with regard to the patients with the highest risk and utilization.
This information is vital to assess the capacity of the institution to provide sustainable, adequate
care. However, one significant limitation of the case review methodology is that it does not give a
clear assessment of how the institution performs for the entire population. For better insight into this
performance, the OIG has turned to population-based metrics. For comparative purposes, the OIG
has selected several Healthcare Effectiveness Data and Information Set (HEDIS) measures for
disease management to gauge the institution’s effectiveness in outpatient health care, especially
chronic disease management.
The Healthcare Effectiveness Data and Information Set is a set of standardized performance
measures developed by the National Committee for Quality Assurance with input from over 300
organizations representing every sector of the nation’s health care industry. It is used by over
90 percent of the nation’s health plans as well as many leading employers and regulators. It was
designed to ensure that the public (including employers, the Centers for Medicare and Medicaid
Services, and researchers) has the information it needs to accurately compare the performance of
health care plans. Healthcare Effectiveness Data and Information Set data is often used to produce
health plan report cards, analyze quality improvement activities, and create performance
benchmarks.
Methodology
For population-based metrics, the OIG used a subset of HEDIS measures applicable to the CDCR
inmate-patient population. Selection of the measures was based on the availability, reliability, and
feasibility of the data required for performing the measurement. The OIG collected data utilizing
various information sources, including the eUHR, the Master Registry (maintained by CCHCS), as
well as a random sample of patient records analyzed and abstracted by trained personnel. Data
obtained from the CCHCS Master Registry and Diabetic Registry was not independently validated
by the OIG and is presumed to be accurate. For some measures, the OIG used the entire population
rather than statistically random samples. While the OIG is not a certified HEDIS compliance
auditor, the OIG uses similar methods to ensure that measures are comparable to those published by
other organizations.
Comparison of Population-Based Metrics
For the California City Correctional Facility, seven of the nine HEDIS measures were applicable for
comparison and are listed in the following CAC Results Compared to State and National HEDIS
Scores table. Multiple health plans publish their HEDIS performance measures at the State and
national levels. The OIG has provided selected results for several health plans in both categories for
comparative purposes.
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Results of Population-Based Metric Comparison
Comprehensive Diabetes Care
For chronic care management, the OIG chose measures related to the management of diabetes.
Diabetes is the most complex common chronic disease requiring a high level of intervention on the
part of the health care system in order to produce optimal results. CAC performed well with its
management of diabetes.
When compared statewide, CAC significantly outperformed Medi-Cal in all five diabetic measures.
CAC also outperformed Kaiser Permanente in four of the five diabetic measures. However, CAC’s
scores were lower than Kaiser’s, both the North and South regions, for diabetic patients’ blood
pressure control by 6 and 7 percentage points, respectively.
When compared nationally, CAC significantly outperformed Medicaid, Medicare, and commercial
health plans (based on data obtained from health maintenance organizations) in all five of the
diabetic measures listed. In addition, CAC performed better than the U.S. Department of Veterans
Affairs (VA) in two of the four applicable measures, matched the VA for diabetic patients’ blood
pressure control, and scored only one percentage point lower for eye exams.
Immunizations
For influenza shots for younger adults, CAC scored much lower than all other entities reporting data
did in this measure (Kaiser, commercial plans, and the VA). However, the institution’s low score
was largely due to patient refusals. CAC offered the immunization to all sampled patients, but
55 percent of them refused the offers, which adversely affected the institution’s score. CAC had no
patients over the age of 65.
Cancer Screening
For colorectal cancer screenings, CAC scored the same as, or better than, all other entities that
reported data (Kaiser, commercial plans, Medicare, and the VA). Similar to influenza immunization
results, the institution offered cancer screenings to all patients sampled, but 18 percent of them
refused the offers, negatively affecting CAC’s scores.
Summary
The population-based metrics performance for CAC reflects an adequate chronic care program,
further corroborated by the institution’s adequate score in the Quality of Provider Performance and
Quality of Nursing Performance indicators, and its proficient score in the Access to Care and
Preventive Services indicators. For influenza immunizations, and cancer screening measures, CAC
has an opportunity to improve its scores by placing an emphasis on educating patients regarding
their refusal of these preventive services.
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CAC Results Compared to State and National HEDIS Scores
California National
HEDIS
Clinical Measures CAC Kaiser HEDIS HEDIS
HEDIS (No. Kaiser HEDIS Com- HEDIS VA
Cycle 4 Medi-Cal CA) (So.CA) Medicaid mercial Medicare Average
Results1 20152 20153 20153 20154 20154 20154 20145
Comprehensive Diabetes Care
HbA1c Testing (Monitoring) 100% 86% 95% 94% 86% 91% 93% 99%
Poor HbA1c Control (>9.0%)6, 7 3% 39% 18% 24% 44% 31% 25% 19%
HbA1c Control (<8.0%)6 92% 49% 70% 62% 47% 58% 65% -
Blood Pressure Control (<140/90)6 78% 63% 84% 85% 62% 65% 65% 78%
Eye Exams 89% 53% 69% 81% 54% 56% 69% 90%
Immunizations
Influenza Shots - Adults (18–64) 45% - 54% 55% - 50% - 58%
Influenza Shots - Adults (65+)8 - - - - - - 72% 76%
Immunizations: Pneumococcal8 - - - - - - 70% 93%
Cancer Screening
Colorectal Cancer Screening 82% - 80% 82% - 64% 67% 82%
1. Unless otherwise stated, data was collected in May 2016 by reviewing medical records from a sample of CAC’s
population of applicable inmate-patients. These random statistical sample sizes were based on a 95 percent confidence
level with a 15 percent maximum margin of error.
2. HEDIS Medi-Cal data was obtained from the California Department of Health Care Services 2015 HEDIS Aggregate
Report for Medi-Cal Managed Care.
3. Data was obtained from Kaiser Permanente November 2015 reports for the Northern and Southern California regions.
4. National HEDIS data for Medicaid, commercial plans, and Medicare was obtained from the 2015 State of Health
Care Quality Report, available on the NCQA website: www.ncqa.org. The results for commercial plans were based on
data received from various health maintenance organizations.
5. The Department of Veterans Affairs (VA) data was obtained from the VA’s website, www.va.gov.
For the Immunizations: Pneumococcal measure only, the data was obtained from the VHA Facility Quality and Safety
Report - Fiscal Year 2012 Data.
6. For this indicator, the entire applicable CAC population was tested.
7. For this measure only, a lower score is better. For Kaiser, the OIG derived the Poor HbA1c Control indicator using
the reported data for the <9.0% HbA1c control indicator.
8. There were no patients over the age of 65 in the population at CAC; therefore, these measures were omitted from the
comparative analysis.
California City Correctional Facility, Cycle 4 Medical Inspection Page 56
Office of the Inspector General State of California
APPENDIX A — COMPLIANCE TEST RESULTS
California City Correctional Facility
Range of Summary Scores: 58.33% - 95.00%
Indicator Overall Score (Yes %)
Access to Care 87.90%
Diagnostic Services 77.28%
Emergency Services Not Applicable
Health Information Management (Medical Records) 87.20%
Health Care Environment 86.36%
Inter- and Intra-System Transfers 94.81%
Pharmacy and Medication Management 92.10%
Prenatal and Post-Delivery Services Not Applicable
Preventive Services 95.00%
Quality of Nursing Performance Not Applicable
Quality of Provider Performance Not Applicable
Reception Center Arrivals Not Applicable
Specialized Medical Housing (OHU, CTC, SNF, Hospice) Not Applicable
Specialty Services 88.57%
Internal Monitoring, Quality Improvement, and Administrative Operations 68.75%
Job Performance, Training, Licensing, and Certifications 58.33%
California City Correctional Facility, Cycle 4 Medical Inspection Page 57
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Access to Care
Number Yes No No Yes % N/A
1.001 Chronic care follow-up appointments: Was the inmate-patient’s most 25 5 30 83.33% 0
recent chronic care visit within the health care guideline’s maximum
allowable interval or within the ordered time frame, whichever is
shorter?
1.002 For endorsed inmate-patients received from another CDCR 3 4 7 42.86% 23
institution: If the nurse referred the inmate-patient to a provider during
the initial health screening, was the inmate-patient seen within the
required time frame?
1.003 Clinical appointments: Did a registered nurse review the 30 0 30 100.00% 0
inmate-patient’s request for service the same day it was received?
1.004 Clinical appointments: Did the registered nurse complete a 30 0 30 100.00% 0
face-to-face visit within one business day after the CDCR Form 7362
was reviewed?
1.005 Clinical appointments: If the registered nurse determined a referral to 6 1 7 85.71% 23
a primary care provider was necessary, was the inmate-patient seen
within the maximum allowable time or the ordered time frame,
whichever is the shorter?
1.006 Sick call follow-up appointments: If the primary care provider 6 0 6 100.00% 24
ordered a follow-up sick call appointment, did it take place within the
time frame specified?
1.007 Upon the inmate-patient’s discharge from the community hospital: 12 0 12 100.00% 0
Did the inmate-patient receive a follow-up appointment within the
required time frame?
1.008 Specialty service follow-up appointments: Do specialty service 19 5 24 79.17% 6
primary care physician follow-up visits occur within required time
frames?
1.101 Clinical appointments: Do inmate-patients have a standardized 6 0 6 100.00% 0
process to obtain and submit health care services request forms?
Overall Percentage: 87.90%
California City Correctional Facility, Cycle 4 Medical Inspection Page 58
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Diagnostic Services
Number Yes No No Yes % N/A
2.001 Radiology: Was the radiology service provided within the time frame 10 0 10 100.00% 0
specified in the provider’s order?
2.002 Radiology: Did the primary care provider review and initial the 8 2 10 80.00% 0
diagnostic report within specified time frames?
2.003 Radiology: Did the primary care provider communicate the results of 9 1 10 90.00% 0
the diagnostic study to the inmate-patient within specified time frames?
2.004 Laboratory: Was the laboratory service provided within the time 8 2 10 80.00% 0
frame specified in the provider’s order?
2.005 Laboratory: Did the primary care provider review and initial the 10 0 10 100.00% 0
diagnostic report within specified time frames?
2.006 Laboratory: Did the primary care provider communicate the results of 9 1 10 90.00% 0
the diagnostic study to the inmate-patient within specified time frames?
2.007 Pathology: Did the institution receive the final diagnostic report within 5 4 9 55.56% 0
the required time frames?
2.008 Pathology: Did the primary care provider review and initial the 6 1 7 85.71% 2
diagnostic report within specified time frames?
2.009 Pathology: Did the primary care provider communicate the results of 1 6 7 14.29% 2
the diagnostic study to the inmate-patient within specified time frames?
Overall Percentage: 77.28%
California City Correctional Facility, Cycle 4 Medical Inspection Page 59
Office of the Inspector General State of California
Emergency Services
Scored Answers
Assesses reaction times and responses to emergency situations. The OIG RN
clinicians will use detailed information obtained from the institution’s incident Not Applicable
packages to perform focused case reviews.
Scored Answers
Health Information Management Yes
Reference +
(Medical Records)
Number Yes No No Yes % N/A
4.001 Are non-dictated progress notes, initial health screening forms, and 20 0 20 100.00% 0
health care services request forms scanned into the eUHR within three
calendar days of the inmate-patient encounter date?
4.002 Are dictated / transcribed documents scanned into the eUHR within
Not Applicable
five calendar days of the inmate-patient encounter date?
4.003 Are specialty documents scanned into the eUHR within the required 20 0 20 100.00% 0
time frame?
4.004 Are community hospital discharge documents scanned into the eUHR 11 0 11 100.00% 0
within three calendar days of the inmate-patient date of hospital
discharge?
4.005 Are medication administration records (MARs) scanned into the eUHR 20 0 20 100.00% 0
within the required time frames?
4.006 During the eUHR review, did the OIG find that documents were 9 3 12 75.00% 0
correctly labeled and included in the correct inmate-patient’s file?
4.007 Did clinical staff legibly sign health care records, when required? 14 18 32 43.75% 0
4.008 For inmate-patients discharged from a community hospital: Did 11 1 12 91.67% 0
the preliminary hospital discharge report include key elements and did
a PCP review the report within three calendar days of discharge?
Overall Percentage: 87.20%
California City Correctional Facility, Cycle 4 Medical Inspection Page 60
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Health Care Environment
Number Yes No No Yes % N/A
5.101 Infection Control: Are clinical health care areas appropriately 9 0 9 100.00% 0
disinfected, cleaned and sanitary?
5.102 Infection control: Do clinical health care areas ensure that reusable 8 1 9 88.89% 0
invasive and non-invasive medical equipment is properly sterilized or
disinfected as warranted?
5.103 Infection Control: Do clinical health care areas contain operable sinks 9 0 9 100.00% 0
and sufficient quantities of hygiene supplies?
5.104 Infection control: Does clinical health care staff adhere to universal 8 1 9 88.89% 0
hand hygiene precautions?
5.105 Infection control: Do clinical health care areas control exposure to 9 0 9 100.00% 0
blood-borne pathogens and contaminated waste?
5.106 Warehouse, Conex and other non-clinic storage areas: Does the 1 0 1 100.00% 0
medical supply management process adequately support the needs of
the medical health care program?
5.107 Clinical areas: Does each clinic follow adequate protocols for 9 0 9 100.00% 0
managing and storing bulk medical supplies?
5.108 Clinical areas: Do clinic common areas and exam rooms have 3 6 9 33.33% 0
essential core medical equipment and supplies?
5.109 Clinical areas: Do clinic common areas have an adequate environment 8 1 9 88.89% 0
conducive to providing medical services?
5.110 Clinical areas: Do clinic exam rooms have an adequate environment 6 3 9 66.67% 0
conducive to providing medical services?
5.111 Emergency response bags: Are TTA and clinic emergency medical 5 1 6 83.33% 3
response bags inspected daily and inventoried monthly, and do they
contain essential items?
5.999 For Information Purposes Only: Does the institution’s health care
management believe that all clinical areas have physical plant Information Only
infrastructures sufficient to provide adequate health care services?
Overall Percentage: 86.36%
California City Correctional Facility, Cycle 4 Medical Inspection Page 61
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Inter- and Intra-System Transfers
Number Yes No No Yes % N/A
6.001 For endorsed inmate-patients received from another CDCR 29 1 30 96.67% 0
institution or COCF: Did nursing staff complete the initial health
screening and answer all screening questions on the same day the
inmate-patient arrived at the institution?
6.002 For endorsed inmate-patients received from another CDCR 29 1 30 96.67% 0
institution or COCF: When required, did the RN complete the
assessment and disposition section of the health screening form; refer
the inmate-patient to the TTA, if TB signs and symptoms were present;
and sign and date the form on the same day staff completed the health
screening?
6.003 For endorsed inmate-patients received from another CDCR 6 1 7 85.71% 23
institution or COCF: If the inmate-patient had an existing medication
order upon arrival, were medications administered or delivered without
interruption?
6.004 For inmate-patients transferred out of the facility: Were scheduled 19 1 20 95.00% 0
specialty service appointments identified on the Health Care Transfer
Information Form 7371?
6.101 For inmate-patients transferred out of the facility: Do medication 1 0 1 100.00% 2
transfer packages include required medications along with the
corresponding Medication Administration Record (MAR) and
Medication Reconciliation?
Overall Percentage: 94.81%
California City Correctional Facility, Cycle 4 Medical Inspection Page 62
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Pharmacy and Medication Management
Number Yes No No Yes % N/A
7.001 Did the inmate-patient receive all chronic care medications 28 1 29 96.55% 1
within the required time frames or did the institution follow
departmental policy for refusals or no-shows?
7.002 Did health care staff administer or deliver new order prescription 30 0 30 100.00% 0
medications to the inmate-patient within the required time
frames?
7.003 Upon the inmate-patient’s discharge from a community 11 1 12 91.67% 0
hospital: Were all medications ordered by the institution’s
primary care provider administered or delivered to the
inmate-patient within one calendar day of return?
7.004 For inmate-patients received from a county jail: Were all
medications ordered by the institution’s reception center provider
Not Applicable
administered or delivered to the inmate-patient within the
required time frames?
7.005 Upon the inmate-patient’s transfer from one housing unit to 21 0 21 100.00% 0
another: Were medications continued without interruption?
7.006 For inmate-patients en route who lay over at the institution:
If the temporarily housed inmate-patient had an existing
Not Applicable
medication order, were medications administered or delivered
without interruption?
7.101 All clinical and medication line storage areas for narcotic 5 1 6 83.33% 7
medications: Does the institution employ strong medication
security controls over narcotic medications assigned to its clinical
areas?
7.102 All clinical and medication line storage areas for non-narcotic 8 2 10 80.00% 3
medications: Does the institution properly store non-narcotic
medications that do not require refrigeration in assigned clinical
areas?
7.103 All clinical and medication line storage areas for non-narcotic 6 2 8 75.00% 5
medications: Does the institution properly store non-narcotic
medications that require refrigeration in assigned clinical areas?
7.104 Medication preparation and administration areas: Do nursing 3 1 4 75.00% 9
staff employ and follow hand hygiene contamination control
protocols during medication preparation and medication
administration processes?
7.105 Medication preparation and administration areas: Does the 4 0 4 100.00% 9
institution employ appropriate administrative controls and
protocols when preparing medications for inmate-patients?
7.106 Medication preparation and administration areas: Does the 4 1 5 80.00% 8
institution employ appropriate administrative controls and
protocols when distributing medications to inmate-patients?
California City Correctional Facility, Cycle 4 Medical Inspection Page 63
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Pharmacy and Medication Management
Number Yes No No Yes % N/A
7.107 Pharmacy: Does the institution employ and follow general 1 0 1 100.00% 0
security, organization, and cleanliness management protocols in
its main and satellite pharmacies?
7.108 Pharmacy: Does the institution’s pharmacy properly store 1 0 1 100.00% 0
non-refrigerated medications?
7.109 Pharmacy: Does the institution’s pharmacy properly store refrigerated 1 0 1 100.00% 0
or frozen medications?
7.110 Pharmacy: Does the institution’s pharmacy properly account for 1 0 1 100.00% 0
narcotic medications?
7.111 Pharmacy: Does the institution follow key medication error reporting 26 0 26 100.00% 4
protocols?
7.998 For Information Purposes Only: During eUHR compliance testing and
case reviews, did the OIG find that medication errors were properly Information Only
identified and reported by the institution?
7.999 For Information Purposes Only: Do inmate-patients in isolation
housing units have immediate access to their KOP prescribed rescue Information Only
inhalers and nitroglycerin medications?
Overall Percentage: 92.10%
California City Correctional Facility, Cycle 4 Medical Inspection Page 64
Office of the Inspector General State of California
Prenatal and Post-Delivery Services
Scored Answers
This indicator is not applicable to this institution. Not Applicable
Scored Answers
Yes
Reference +
Preventive Services
Number Yes No No Yes % N/A
9.001 Inmate-patients prescribed TB medications: Did the institution 4 0 4 100.00% 0
administer the medication to the inmate-patient as prescribed?
9.002 Inmate-patients prescribed TB medications: Did the institution 3 1 4 75.00% 0
monitor the inmate-patient monthly for the most recent three months he
or she was on the medication?
9.003 Annual TB Screening: Was the inmate-patient screened for TB within 27 3 30 90.00% 0
the last year?
9.004 Were all inmate-patients offered an influenza vaccination for the most 30 0 30 100.00% 0
recent influenza season?
9.005 All inmate-patients from the age of 50 through the age of 75: Was 30 0 30 100.00% 0
the inmate-patient offered colorectal cancer screening?
9.006 Female inmate-patients from the age of 50 through the age of 74:
Was the inmate-patient offered a mammogram in compliance with Not Applicable
policy?
9.007 Female inmate-patients from the age of 21 through the age of 65:
Not Applicable
Was the inmate-patient offered a pap smear in compliance with policy?
9.008 Are required immunizations being offered for chronic care 8 0 8 100.00% 22
inmate-patients?
9.009 Are inmate-patients at the highest risk of coccidioidomycosis (valley 5 0 5 100.00% 0
fever) infection transferred out of the facility in a timely manner?
Overall Percentage: 95.00%
California City Correctional Facility, Cycle 4 Medical Inspection Page 65
Office of the Inspector General State of California
Quality of Nursing Performance
Scored Answers
The quality of nursing performance will be assessed during case reviews, conducted
by OIG clinicians, and is not applicable for the compliance portion of the medical
inspection. The methodologies OIG clinicians use to evaluate the quality of nursing Not Applicable
performance are presented in a separate inspection document entitled OIG MIU
Retrospective Case Review Methodology.
Quality of Provider Performance
Scored Answers
The quality of provider performance will be assessed during case reviews,
conducted by OIG clinicians, and is not applicable for the compliance portion of the
medical inspection. The methodologies OIG clinicians use to evaluate the quality of Not Applicable
provider performance are presented in a separate inspection document entitled OIG
MIU Retrospective Case Review Methodology.
Reception Center Arrivals
Scored Answers
This indicator is not applicable to this institution. Not Applicable
Specialized Medical Housing
(OHU, CTC, SNF, Hospice)
Scored Answers
This indicator is not applicable to this institution. Not Applicable
California City Correctional Facility, Cycle 4 Medical Inspection Page 66
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Specialty Services
Number Yes No No Yes % N/A
14.001 Did the inmate-patient receive the high-priority specialty service within 13 2 15 86.67% 0
14 calendar days of the PCP order?
14.002 Did the PCP review the high priority specialty service consultant report 13 0 13 100.00% 2
within the required time frame?
14.003 Did the inmate-patient receive the routine specialty service within 90 15 0 15 100.00% 0
calendar days of the PCP order?
14.004 Did the PCP review the routine specialty service consultant report 15 0 15 100.00% 0
within the required time frame?
14.005 For endorsed inmate-patients received from another CDCR 2 4 6 33.33% 0
institution: If the inmate-patient was approved for a specialty services
appointment at the sending institution, was the appointment scheduled
at the receiving institution within the required time frames?
14.006 Did the institution deny the primary care provider request for specialty 12 0 12 100.00% 0
services within required time frames?
14.007 Following the denial of a request for specialty services, was the 12 0 12 100.00% 0
inmate-patient informed of the denial within the required time frame?
Overall Percentage: 88.57%
California City Correctional Facility, Cycle 4 Medical Inspection Page 67
Office of the Inspector General State of California
Scored Answers
Internal Monitoring, Quality Improvement, and Yes
Reference +
Administrative Operations
Number Yes No No Yes % N/A
15.001 Did the institution promptly process inmate medical appeals during the 12 0 12 100.00% 0
most recent 12 months?
15.002 Does the institution follow adverse/sentinel event reporting
Not Applicable
requirements?
15.003 Did the institution Quality Management Committee (QMC) meet at 3 3 6 50.00% 0
least monthly to evaluate program performance, and did the QMC take
action when improvement opportunities were identified?
15.004 Did the institution’s Quality Management Committee (QMC) or other 1 0 1 100.00% 0
forum take steps to ensure the accuracy of its Dashboard data
reporting?
15.005 For each initiative in the Performance Improvement Work Plan 3 0 3 100.00% 1
(PIWP), has the institution performance improved or reached the
targeted performance objective(s)?
15.006 For institutions with licensed care facilities: Does the Local
Governing Body (LGB), or its equivalent, meet quarterly and exercise
Not Applicable
its overall responsibilities for the quality management of patient health
care?
15.007 Does the Emergency Medical Response Review Committee perform 0 12 12 0.00% 0
timely incident package reviews that include the use of required review
documents?
15.101 Did the institution complete a medical emergency response drill for 0 3 3 0.00% 0
each watch and include participation of health care and custody staff
during the most recent full quarter?
15.102 Did the institution’s second level medical appeal response address all 10 0 10 100.00% 0
of the inmate-patient’s appealed issues?
15.103 Did the institution’s medical staff review and submit the initial inmate 1 0 1 100.00% 0
death report to the Death Review Unit in a timely manner?
15.996 For Information Purposes Only: Did the CCHCS Death Review
Committee submit its inmate death review summary to the institution Information Only
timely?
15.997 For Information Purposes Only: Identify the institution’s protocols
Information Only
for tracking medical appeals.
15.998 For Information Purposes Only: Identify the institution’s protocols
Information Only
for implementing health care local operating procedures.
15.999 For Information Purposes Only: Identify the institution’s health care
Information Only
staffing resources.
Overall Percentage: 68.75%
California City Correctional Facility, Cycle 4 Medical Inspection Page 68
Office of the Inspector General State of California
Scored Answers
Job Performance, Training, Licensing, and Yes
Reference +
Certifications
Number Yes No No Yes % N/A
16.001 Do all providers maintain a current medical license? 7 0 7 100.00% 0
16.101 Does the institution’s Supervising Registered Nurse conduct periodic 0 5 5 0.00% 0
reviews of nursing staff?
16.102 Are nursing staff who administer medications current on their clinical 10 0 10 100.00% 0
competency validation?
16.103 Are structured clinical performance appraisals completed timely? 0 5 5 0.00% 2
16.104 Are staff current with required medical emergency response 2 1 3 66.67% 0
certifications?
16.105 Are nursing staff and the Pharmacist-in-Charge current with their 5 0 5 100.00% 1
professional licenses and certifications?
16.106 Do the institution’s pharmacy and authorized providers who prescribe 1 0 1 100.00% 0
controlled substances maintain current Drug Enforcement Agency
(DEA) registrations?
16.107 Are nursing staff current with required new employee orientation? 0 1 1 0.00% 0
Overall Percentage: 58.33%
California City Correctional Facility, Cycle 4 Medical Inspection Page 69
Office of the Inspector General State of California
APPENDIX B — CLINICAL DATA
Table B-1: CAC Sample Sets
Sample Set Total
Death Review/Sentinel Events 1
Diabetes 3
Emergency Services — Non-CPR 5
High Risk 11
Hospitalization 5
Intra-System Transfers In 3
Intra-System Transfers Out 3
RN Sick Call 15
Specialty Services 5
51
California City Correctional Facility, Cycle 4 Medical Inspection Page 70
Office of the Inspector General State of California
Table B-2: CAC Chronic Care Diagnoses
Diagnosis Total
Anemia 2
Arthritis/Degenerative Joint Disease 5
Asthma 5
Cardiovascular Disease 3
Chronic Pain 10
Cirrhosis/End-Stage Liver Disease 1
Diabetes 11
Diagnosis 19
Gastroesophageal Reflux Disease 10
Gastrointestinal Bleed 1
Hepatitis C 14
Hyperlipidemia 11
Hypertension 20
Mental Health 1
Seizure Disorder 1
114
California City Correctional Facility, Cycle 4 Medical Inspection Page 71
Office of the Inspector General State of California
Table B-3: CAC Event — Program
Program Total
Diagnostic Services 105
Emergency Care 28
Hospitalization 26
Intra-System Transfers In 12
Intra-System Transfers Out 11
Outpatient Care 567
Specialized Medical Housing 0
Specialty Services 111
860
Table B-4: CAC Case Review Sample Summary
Total
MD Reviews, Detailed 30
MD Reviews, Focused 1
RN Reviews, Detailed 17
RN Reviews, Focused 25
Total Reviews 73
Total Unique Cases 51
Overlapping Reviews (MD & RN) 22
California City Correctional Facility, Cycle 4 Medical Inspection Page 72
Office of the Inspector General State of California
APPENDIX C — COMPLIANCE SAMPLING METHODOLOGY
California City Correctional Facility
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Access to Care
MIT 1.001 Chronic Care Patients Master Registry Chronic care conditions (at least one condition per
inmate-patient—any risk level)
(30) Randomize
MIT 1.002 Nursing Referrals OIG Q: 6.001 See Intra-system Transfers
(30)
MITs 1.003-006 Nursing Sick Call MedSATS Clinic (each clinic tested)
(5 per clinic) Appointment date (2–9 months)
30 Randomize
MIT 1.007 Returns from OIG Q: 4.008 See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(12)
MIT 1.008 Specialty Services OIG Q: 14.001 & See Specialty Services
Follow-up 14.003
(30)
MIT 1.101 Availability of Health OIG onsite Randomly select one housing unit from each yard
Care Services review
Request Forms
(6)
Diagnostic Services
MITs 2.001–003 Radiology Radiology Logs Appointment date (90 days–9 months)
Randomize
(10) Abnormal
MITs 2.004–006 Laboratory Quest Appt. date (90 days–9 months)
Order name (CBC or CMPs only)
Randomize
(10) Abnormal
MITs 2.007–009 Pathology InterQual Appt. date (90 days–9 months)
Service (pathology related)
(9) Randomize
California City Correctional Facility, Cycle 4 Medical Inspection Page 73
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Timely Scanning OIG Qs: 1.001, Non-dictated documents
(20) 1.002, & 1.004 1st 10 IPs MIT 1.001, 1st 5 IPs MITs 1.002, 1.004
MIT 4.002 OIG Q: 1.001 Dictated documents
(0) First 20 IPs selected
MIT 4.003 OIG Qs: 14.002 Specialty documents
(20) & 14.004 First 10 IPs for each question
MIT 4.004 OIG Q: 4.008 Community hospital discharge documents
(11) First 20 IPs selected
MIT 4.005 OIG Q: 7.001 MARs
(20) First 20 IPs selected
MIT 4.006 Documents for Any misfiled or mislabeled document identified
(12) any tested inmate during OIG compliance review (12 or more = No)
MIT 4.007 Legible Signatures & OIG Qs: 4.008, First 8 IPs sampled
Review 6.001, 6.002, One source document per IP
7.001, 12.001,
(32) 12.002 & 14.002
MIT 4.008 Returns From Inpatient claims Date (2–8 months)
Community Hospital data Most recent 6 months provided (within date range)
Rx count
Discharge date
Randomize (each month individually)
First 5 inmate-patients from each of the 6 months
(if not 5 in a month, supplement from another, as
(12)
needed)
Health Care Environment
MIT 5.101-105 Clinical Areas OIG inspector Identify and inspect all onsite clinical areas.
MIT 5.107–111 (9) onsite review
Inter- and Intra-System Transfers
MIT 6.001-003 Intra-System SOMS Arrival date (3–9 months)
Transfers Arrived from (another CDCR facility)
Rx count
Randomize
(30)
MIT 6.004 Specialty Services MedSATS Date of transfer (3–9 months)
Send-Outs Randomize
(20)
MIT 6.101 Transfers Out OIG inspector R&R IP transfers with medication
(3) onsite review
California City Correctional Facility, Cycle 4 Medical Inspection Page 74
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care OIG Q: 1.001 See Access to Care
Medication At least one condition per inmate-patient—any risk
level
(30) Randomize
MIT 7.002 New Medication Master Registry Rx count
Orders Randomize
(30) Ensure no duplication of IPs tested in MIT 7.001
MIT 7.003 Returns from OIG Q: 4.008 See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(12)
MIT 7.004 RC Arrivals – OIG Q: 12.001 See Reception Center Arrivals
Medication Orders
N/A at this institution
MIT 7.005 Intra-Facility Moves 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)
(21)
Randomize
MIT 7.006 En Route SOMS Date of transfer (2–8 months)
Sending institution (another CDCR facility)
Randomize
(0) NA/DOT meds
MITs 7.101-103 Medication Storage OIG inspector Identify and inspect clinical & med line areas that
Areas onsite review store medications
(varies by test)
MITs 7.104–106 Medication OIG inspector Identify and inspect onsite clinical areas that
Preparation and onsite review prepare and administer medications
Administration Areas
(13)
MITs 7.107-110 Pharmacy OIG inspector Identify & inspect all onsite pharmacies
(1) onsite review
MIT 7.111 Medication Error Monthly All monthly statistic reports with Level 4 or higher
Reporting medication error Select a total of 5 months
(30) reports
MIT 7.999 Isolation Unit KOP Onsite active KOP rescue inhalers & nitroglycerin medications
Medications medication for IPs housed in isolation units
(1) listing
Prenatal and Post-Delivery Services
MIT 8.001-007 Recent Deliveries OB Roster Delivery date (2–12 months)
N/A at this institution Most recent deliveries (within date range)
Pregnant Arrivals OB Roster Arrival date (2–12 months)
N/A at this institution Earliest arrivals (within date range)
California City Correctional Facility, Cycle 4 Medical Inspection Page 75
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Preventive Services
MITs 9.001–002 TB Medications Maxor Dispense date (past 9 months)
Time period on TB meds (3 months or 12 weeks)
(4) Randomize
MIT 9.003 TB Code 22, Annual SOMS Arrival date (at least 1 year prior to inspection)
TST TB Code (22)
(15) Randomize
TB Code 34, Annual SOMS Arrival date (at least 1 year prior to inspection)
Screening TB Code (34)
(15) Randomize
MIT 9.004 Influenza SOMS Arrival date (at least 1 year prior to inspection)
Vaccinations Randomize
(30) Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer SOMS Arrival date (at least 1 year prior to inspection)
Screening Date of birth (51 or older)
(30) Randomize
MIT 9.006 Mammogram SOMS Arrival date (at least 2 yrs prior to inspection)
Date of birth (age 52–74)
N/A at this institution Randomize
MIT 9.007 Pap Smear SOMS Arrival date (at least three yrs prior to inspection)
Date of birth (age 24–53)
N/A at this institution Randomize
MIT 9.008 Chronic Care OIG Q: 1.001 Chronic care conditions (at least 1 condition per
Vaccinations IP—any risk level)
Randomize
(30) Condition must require vaccination(s)
MIT 9.009 Valley Fever Cocci transfer Reports from past 2–8 months
(number will vary) status report Institution
Ineligibility date (60 days prior to inspection date)
(5)
All
California City Correctional Facility, Cycle 4 Medical Inspection Page 76
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Reception Center Arrivals
MITs 12.001–008 RC SOMS Arrival date (2–8 months)
Arrived from (county jail, return from parole, etc.)
N/A at this institution Randomize
Specialized Medical Housing
MITs 13.001–004 CTC CADDIS Admit date (1–6 months)
Type of stay (no MH beds)
Length of stay (minimum of 5 days)
N/A at this institution
Randomize
MIT 13.101 Call Buttons OIG inspector Review by location
CTC onsite review
N/A at this institution
Specialty Services Access
MITs 14.001–002 High-Priority MedSATS Approval date (3–9 months)
(15) Randomize
MITs 14.003–004 Routine MedSATS Approval date (3–9 months)
(15) Remove optometry, physical therapy or podiatry
Randomize
MIT 14.005 Specialty Services MedSATS Arrived from (other CDCR institution)
Arrivals Date of transfer (3–9 months)
(6) Randomize
MIT 14.006-007 Denials InterQual Review date (3–9 months)
(2) Randomize
IUMC/MAR Meeting date (9 months)
Meeting Minutes Denial upheld
(10) Randomize
California City Correctional Facility, Cycle 4 Medical Inspection Page 77
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Internal Monitoring, Quality Improvement, & Administrative Operations
MIT 15.001 Medical Appeals Monthly medical Medical appeals (12 months)
(all) appeals reports
MIT 15.002 Adverse/Sentinel Adverse/sentinel Adverse/sentinel events (2–8 months)
Events events report
(0)
MITs 15.003–004 QMC Meetings Quality Meeting minutes (12 months)
Management
Committee
(6) meeting minutes
MIT 15.005 Performance Institution PIWP PIWP with updates (12 months)
Improvement Work Medical initiatives
Plans (PIWP)
(4)
MIT 15.006 LGB LGB meeting Quarterly meeting minutes (12 months)
N/A at this minutes
institution
MIT 15.007 EMRRC EMRRC meeting Monthly meeting minutes (6 months)
(12) minutes
MIT 15.101 Medical Emergency Onsite summary Most recent full quarter
Response Drills reports & Each watch
documentation
(3) for ER drills
MIT 15.102 2nd Level Medical Onsite list of Medical appeals denied (6 months)
Appeals appeals/closed
(10) appeals files
MIT 15.103 Death Reports Institution-list of Most recent 10 deaths
deaths in prior Initial death reports
(1) 12 months
MIT 15.996 Death Review OIG summary Between 35 business days & 12 months prior
Committee log - deaths CCHCS death reviews
(1)
MIT 15.998 Local Operating Institution LOPs All LOPs
Procedures (LOPs)
(all)
California City Correctional Facility, Cycle 4 Medical Inspection Page 78
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Job Performance, Training, Licensing, and Certifications
MIT 16.001 Provider licenses Current provider Review all
listing (at start of
(7) inspection)
MIT 16.101 RN Review Onsite RNs who worked in clinic or emergency setting
Evaluations supervisor six or more days in sampled month
periodic RN Randomize
(5) reviews
MIT 16.102 Nursing Staff Onsite nursing On duty one or more years
Validations education files Nurse administers medications
(10) Randomize
MIT 16.103 Provider Annual OIG Q:16.001 All required performance evaluation documents
Evaluation Packets
(7)
MIT 16.104 Medical Emergency Onsite All staff
Response certification o Providers (ACLS)
Certifications tracking logs o Nursing (BLS/CPR)
(all) o Custody (CPR/BLS)
MIT 16.105 Nursing staff and Onsite tracking All required licenses and certifications
Pharmacist in system, logs, or
Charge Professional employee files
Licenses and
Certifications
(all)
MIT 16.106 Pharmacy and Onsite listing of All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
(all) document
MIT 16.107 Nursing Staff New Nursing staff New employees (hired within last 12 months)
Employee training logs
Orientations
(all)
California City Correctional Facility, Cycle 4 Medical Inspection Page 79
Office of the Inspector General State of California
C C
ALIFORNIA ORRECTIONAL
H C S ’
EALTH ARE ERVICES
R
ESPONSE
California City Correctional Facility, Cycle 4 Medical Inspection Page 80
Office of the Inspector General State of California