OIG
California Correctional Institution Cycle 7 Medical Inspection Report
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Cycle 7, California Correctional Institution | iii
Contents
Illustrations iv
Introduction 1
Summary: Ratings and Scores 3
Medical Inspection Results 5
Deficiencies Identified During Case Review 5
Case Review Results 5
Compliance Testing Results 5
Institution-Specific Metrics 6
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 14
Access to Care 14
Diagnostic Services 20
Emergency Services 25
Health Information Management 30
Health Care Environment 36
Transfers 45
Medication Management 52
Preventive Services 60
Nursing Performance 63
Provider Performance 68
Specialized Medical Housing 74
Specialty Services 80
Administrative Operations 86
Appendix A: Methodology 89
Case Reviews 90
Compliance Testing 93
Indicator Ratings and the Overall Medical Quality Rating 94
Appendix B: Case Review Data 95
Appendix C: Compliance Sampling Methodology 99
California Correctional Health Care Services’ Response 107
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Illustrations
Tables
1. CCI Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. CCI Master Registry Data as of October 2023 7
3. CCI Health Care Staffing Resources as of October 2023 8
4. CCI Results Compared With State HEDIS Scores 10
5. Access to Care 17
6. Other Tests Related to Access to Care 18
7. Diagnostic Services 23
8. Health Information Management 33
9. Other Tests Related to Health Information Management 34
10. Health Care Environment 43
11. Transfers 49
12. Other Tests Related to Transfers 50
13. Medication Management 57
14. Other Tests Related to Medication Management 58
15. Preventive Services 61
16. Specialized Medical Housing 78
17. Specialty Services 83
18. Other Tests Related to Specialized Services 84
19. Administrative Operations 87
A–1. Case Review Definitions 90
B–1. CCI Case Review Sample Sets 95
B–2. CCI Case Review Chronic Care Diagnoses 96
B–3. CCI Case Review Events by Program 97
B–4. CCI Case Review Sample Summary 97
Figures
A–1. Inspection Indicator Review Distribution for CCI 89
A–2. Case Review Testing 92
A–3. Compliance Sampling Methodology 93
Photographs
1. Indoor Waiting Area 36
2. Expired Medical Supplies 37
3. Incomplete EMRB Glucometer Logs 38
4. Compromised EMRB Medical Supply 38
5. Expired Supplies in the Warehouse 39
6. Warehouse Supplies With Temperature Guidelines 39
7. Laboratory Equipment and Supplies Stored in the Soiled Utility Room
(photo 1 of 3) 40
8. Laboratory Equipment and Supplies Stored in the Soiled Utility Room
(photo 2 of 3) 41
9. Laboratory Equipment and Supplies Stored in the Soiled Utility Room
(photo 3 of 3) 41
10. Peeling Paint on the Clinic Ceiling 42
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Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector
General (the OIG) is responsible for periodically reviewing and reporting on the delivery
of the ongoing medical care provided to incarcerated people1 in the California
Department of Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in
Cycle 6, including clinical case review and compliance testing. Together, these methods
assess the institution’s medical care on both individual and system levels by providing an
accurate assessment of how the institution’s health care systems function regarding
patients with the highest medical risk, who tend to access services at the highest rate.
Through these methods, the OIG evaluates the performance of the institution in
providing sustainable, adequate care. We continue to review institutional care using
15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection
tool (MIT). In addition, our clinicians complete document reviews of individual cases and
also perform on-site inspections, which include interviews with staff. The OIG
determines a total compliance score for each applicable indicator and considers the MIT
scores in the overall conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course
of caring for a patient. In the event we find errors, we determine whether such errors
were clinically significant or led to a significantly increased risk of harm to the patient.
At the same time, our clinicians consider whether institutional medical processes led to
identifying and correcting individual or system errors, and we examine whether the
institution’s medical system mitigated the error. The OIG rates each applicable indicator
proficient, adequate, or inadequate, and considers each rating in the overall conclusion of
the institution’s health care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single
overall institution rating. This change will clarify the distinctions between these differing
quality measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and
the OIG explicitly makes no determination regarding the constitutionality of care that the department provides
to its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected Healthcare
Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
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As we did during Cycle 6, our office continues to inspect both those institutions
remaining under federal receivership and those delegated back to the department. There
is no difference in the standards used for assessing a delegated institution versus an
institution not yet delegated. At the time of the Cycle 7 inspection of California
Correctional Institution, the institution had been delegated back to the department by
the receiver.
We completed our seventh inspection of the institution, and this report presents our
assessment of the health care provided at this institution during the inspection period
from March 2023 to August 2023.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include death reviews between August 2022 and April 2023 and transfer reviews between March 2023 and June
2023.
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Summary: Ratings and Scores
We completed the Cycle 7 inspection of CCI in January 2024. OIG inspectors monitored the
institution’s delivery of medical care that occurred between March 2023 and August 2023.
The OIG rated the case review The OIG rated the compliance
component of the overall health care component of the overall health care
quality at CCI adequate. quality at CCI inadequate.
OIG case review clinicians (a team of physicians and nurse consultants) reviewed 45
cases, which contained 763 patient-related events. They performed quality control
reviews; their subsequent collective deliberations ensured consistency, accuracy, and
thoroughness. Our OIG clinicians acknowledged institutional structures that catch and
resolve mistakes, which may occur throughout the delivery of care. After examining
medical records, our clinicians completed a follow-up on-site inspection in January 2024
to verify their initial findings. The OIG physicians rated the quality of care for 20
comprehensive case reviews. Of these 20 cases, our physicians rated 18 adequate and two
inadequate.
To test the institution’s policy compliance, our compliance inspectors (a team of
registered nurses) monitored the institution’s compliance with its medical policies by
answering a standardized set of questions that measure specific elements of health care
delivery. Our compliance inspectors examined 344 patient records and 1,014 data points,
and we used the data to answer 90 policy questions. In addition, we observed CCI’s
processes during an on-site inspection in October 2023.
The OIG then considered the results from both case review and compliance testing, and
drew overall conclusions, which we report in 13 health care indicators.5
5 The indicators for Reception Center and Prenatal and Postpartum Care did not apply to CCI.
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We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. CCI Summary Table: Case Review Ratings and Policy Compliance Scores
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Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm. Deficiencies can be
minor or significant, depending on the severity of the deficiency. An adverse event occurs
when the deficiency caused harm to the patient. All major health care organizations
identify and track adverse events. We identify deficiencies and adverse events to
highlight concerns regarding the provision of care and for the benefit of the institution’s
quality improvement program to provide an impetus for improvement.6
The OIG found no adverse events at CCI during the Cycle 7 inspection.
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed 10 of the 13
indicators applicable to CCI. Of these 10 indicators, OIG clinicians rated one proficient
and nine adequate. The OIG physicians also rated the overall adequacy of care for each of
the 20 detailed case reviews they conducted. Of these 20 cases, 18 were adequate, and two
were inadequate. In the 763 events reviewed, we found 275 deficiencies, 21 of which the
OIG clinicians considered to be of such magnitude that, if left unaddressed, would likely
contribute to patient harm.
Our clinicians found the following strengths at CCI:
• Staff provided excellent access to nursing, provider, and specialty
appointments.
• Staff handled STAT laboratory tests appropriately.
• Clinic staff provided good continuity of care.
Our clinicians found the following weaknesses at CCI:
• Providers did not consistently communicate diagnostic test results to
patients with complete test result letters.
• Staff inconsistently retrieved or scanned specialty reports into patient
records timely.
Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable to CCI. Of these 10
indicators, our compliance inspectors rated one proficient, two adequate, and seven
inadequate. We tested policy compliance in Health Care Environment, Preventive
6 For a further discussion of an adverse event, see Table A–1.
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Services, and Administrative Operations as these indicators do not have a case review
component.
CCI showed a high rate of policy compliance in the following areas:
• Nursing staff often processed sick call request forms, performed face-to-face
evaluations, and completed nurse-to-provider referrals within required time
frames.
• Primary care providers usually evaluated their patients returning from
outside community hospitals or specialty service appointments within
specified time frames. Moreover, staff scheduled patients within required
time frames to see their providers upon arrival at the institution.
• Staff offered influenza vaccinations and provided colorectal cancer
screenings to patients timely.
CCI showed a low rate of policy compliance in the following areas:
• Staff frequently failed to maintain medication continuity for chronic care
patients, patients discharged from the hospital, and patients admitted to a
specialized medical housing unit. In addition, staff intermittently maintained
medication continuity for patients who transferred into the institution,
transferred within the institution, or had a temporary layover at CCI.
• Health care staff did not follow hand hygiene precautions before or after
patient encounters.
• CCI’s medical warehouse and clinical areas had multiple expired medical
supplies.
• Nurses did not regularly inspect emergency medical response bags.
• Providers sporadically communicated results of diagnostic services timely.
Most patient notification letters communicating these results were missing
the date of the diagnostic service, the date of the results, and whether the
results were within normal limits.
Institution-Specific Metrics
The California Correctional Institution (CCI) is located in Cummings Valley, west of the
city of Tehachapi in Kern County. CCI consists of five separate facilities, housing
incarcerated persons of varying security levels, from minimum to maximum security. The
institution operates three medical clinics where staff members handle nonurgent
requests for medical services. Each of the three facilities has a minor procedure room that
functions as a triage and treatment area (TTA). The TTA is used for urgent and
emergency care. CCI has been designated by California Correctional Health Care
Services (CCHCS) as a basic care institution. Basic care institutions are located in rural
areas, away from tertiary care centers and specialty care providers whose services would
likely be used frequently by high-risk patients. Basic care institutions are capable of
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providing limited specialty medical services and consultation for a generally healthy
patient population.7
As of July 18, 2024, the department reports on its public tracker that 78 percent of CCI’s
incarcerated population is fully vaccinated for COVID-19 while 55 percent of CCI’s staff
is fully vaccinated for COVID-19.
In October 2023, the Health Care Services Master Registry showed that CCI had a total
population of 1,718. A breakdown of the medical risk level of the CCI population as
determined by the department is set forth in Table 2 below.8
Table 2. CCI Master Registry Data as of October 2023
Medical Risk Level Number of Patients Percentage*
High 1 21 1.2%
High 2 87 5.1%
Medium 826 48.1%
Low 784 45.6%
Total 1,718 100.0%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk level were obtained from
the CCHCS Master Registry dated October 9, 2023.
7 For more information, see the department’s statistics on its website page titled Population COVID‑19
Tracking.
8 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
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According to staffing data the OIG obtained from California Correctional Health Care
Services (CCHCS), as identified in Table 3 below, CCI had 2.0 executive leadership
vacancies, 1.0 primary care provider vacancy, 0.7 nursing supervisor vacancy, and 2.0
nursing staff vacancies.
Table 3. CCI Health Care Staffing Resources as of October 2023
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 5.0 6.5 10.7 85.0 107.2
Filled by Civil Service 3.0 5.5 10.0 83.0 101.5
Vacant 2.0 1.0 0.7 2.0 5.7
Percentage Filled by Civil Service 60.0% 84.6% 93.5% 97.6% 94.7%
Filled by Telemedicine 0 0 0 0 0
Percentage Filled by Telemedicine 0 0 0 0 0
Filled by Registry 0 0 0 0 0
Percentage Filled by Registry 0 0 0 0 0
Total Filled Positions 3.0 5.5 10.0 83.0 101.5
Total Percentage Filled 60.0% 84.6% 93.5% 97.6% 94.7%
Appointments in Last 12 Months 0 0 1.0 4.0 5.0
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 0 0 3.0 3.0
Adjusted Total: Filled Positions 3.0 5.5 10.0 80.0 98.5
Adjusted Total: Percentage Filled 60.0% 84.6% 93.5% 94.1% 91.9%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes the classifications of Senior Psychiatric Technician and Psychiatric Technician.
‡ In Authorized Positions.
Notes: The OIG does not independently validate staffing data received from the department. Positions are based on
fractional time-base equivalents.
Source: Cycle 7 medical inspection preinspection questionnaire received on October 9, 2023, from California Correctional
Health Care Services.
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Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted above, the OIG
presents selected measures from the Healthcare Effectiveness Data and Information Set
(HEDIS) for comparison purposes. The HEDIS is a set of standardized quantitative
performance measures designed by the National Committee for Quality Assurance to
ensure that the public has the data it needs to compare the performance of health care
plans. Because the Veterans Administration no longer publishes its individual HEDIS
scores, we removed them from our comparison for Cycle 7. Likewise, Kaiser (commercial
plan) no longer publishes HEDIS scores. However, through the California Department of
Health Care Services’ Medi‑Cal Managed Care Technical Report, the OIG obtained
California Medi-Cal and Kaiser Medi-Cal HEDIS scores to use in conducting our
analysis, and we present them here for comparison.
HEDIS Results
We considered CCI’s performance with population-based metrics to assess the
macroscopic view of the institution’s health care delivery. Currently, only two HEDIS
measures are available for review: poor HbA1c control, which measures the percentage of
diabetic patients who have poor blood sugar control, and colorectal cancer screening
rates for patients ages 45 to 75. For poor HBA1c control, CCI’s results compared
favorably with those found in State health plans. We list the applicable HEDIS measures
in Table 4.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—CCI’s
percentage of patients with poor HbA1c control was significantly lower, indicating very
good performance on this measure.
Immunizations
Statewide comparative data were not available for immunization measures; however, we
include these data for informational purposes. CCI had a 38 percent influenza
immunization rate for adults 18 to 64 years old and a 55 percent influenza immunization
rate for adults 65 years of age and older.9 The pneumococcal vaccination rate was
95 percent.10
Cancer Screening
When compared with statewide Medi-Cal programs—California Medi-Cal, Kaiser
Northern California (Medi-Cal), and Kaiser Southern California (Medi-Cal)—CCI’s
9 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable result.
10 The pneumococcal vaccines administered are the 13, 15, and 20 valent pneumococcal vaccines (PCV13,
PCV15, and PCV20), or 23 valent pneumococcal vaccine (PPSV23), depending on the patient’s medical
conditions. For the adult population, the influenza or pneumococcal vaccine may have been administered at a
different institution other than where the patient was currently housed during the inspection period.
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colorectal cancer screening rate of 69% was only lower than Kaiser Southern California
(Medi-Cal).
Table 4. CCI Results Compared With State HEDIS Scores
CCI California California
Kaiser Kaiser
Cycle 7 California NorCal SoCal
HEDIS Measure Results * Medi-Cal † Medi-Cal † Medi-Cal †
HbA1c Screening 93% – – –
Poor HbA1c Control (> 9.0%) ‡,§ 7.4% 36% 31% 22%
HbA1c Control (< 8.0%) ‡ 88% – – –
Blood Pressure Control (< 140/90) ‡ 82% – – –
Eye Examinations 50% – – –
Influenza – Adults (18 – 64) 38% – – –
Influenza – Adults (65 +) 55% – – –
Pneumococcal – Adults (65 +) 95% – – –
Colorectal Cancer Screening 69% 37% 68% 70%
Notes and Sources
* Unless otherwise stated, data were collected in October 2023 by reviewing medical records from a sample
of SVSP’s population of applicable patients. These random statistical sample sizes were based on a 95 percent
confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services
publication Medi-Cal Managed Care External Quality Review Technical Report, dated July 1, 2022–
June 30, 2023 (published March - April 2024);
https://www.dhcs.ca.gov/dataandstats/reports/Documents/Medi-Cal-Managed-Care-Technical-Report-
Volume-1.pdf
‡ For this indicator, the entire applicable SVSP population was tested.
§ For this measure only, a lower score is better.
Source: Institution information provided by the California Department of Corrections and Rehabilitation.
Health care plan data were obtained from the CCHCS Master Registry.
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Recommendations
As a result of our assessment of CCI’s performance, we offer the following
recommendations to the department:
Diagnostic Services
• Medical leadership should ascertain causative factors related to the untimely
provision of laboratory services and implement remedial measures as
appropriate.
• The department should consider developing strategies, such as potentially an
electronic solution, to ensure providers create patient test result notification
letters when they endorse test results and ensure patient letters contain all
elements required by CCHCS policy.
Emergency Services
• Nursing leadership should determine the root cause of challenges that
prevent nurses from accurately documenting the time and sequence of events
during emergency responses and should implement remedial measures as
appropriate.
• Nursing and medical leadership should determine the challenges to
identifying all documentation and timeline deficiencies in the emergency
medical response clinical review process and should implement remedial
measures as appropriate.
Health Information Management
• The institution should identify the challenges to properly labeling and
scanning documents into the medical record and should implement remedial
measures as appropriate.
Health Care Environment
• Medical leadership should determine the root cause(s) for staff not following
all required universal hand hygiene precautions and should take necessary
remedial measures.
• Executive leadership should determine the root cause(s) for staff not ensuring
medical supply storage areas, located inside and outside the clinics, store
medical supplies adequately and should take necessary remedial measures.
• Nursing leadership should determine the root cause(s) for staff not ensuring
clinic examination rooms contain essential core medical equipment and
should take necessary remedial measures that include verifying staff follow
equipment and medical supply management protocols.
• Nursing leadership should determine the root cause(s) for staff not ensuring
the emergency medical response bags (EMRBs) are regularly inventoried and
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sealed, or staff failing to properly complete the monthly logs, and should take
necessary remedial measures.
Transfers
• Nursing leadership should determine the root cause of challenges
preventing nurses from thoroughly completing the initial health screening
process, including documenting a complete set of vital signs, answering all
questions, and documenting an explanation for all “Yes” answers before the
patient is transferred to the housing unit. Leadership should implement
remedial measures as appropriate.
• Nursing leadership should develop strategies to ensure newly arrived
patients receive medications without interruption. In addition, nursing
leadership should develop strategies to ensure nurses document reasons for
patient refusals on the MAR summaries in accordance with CCHCS policies
and procedures.
Medication Management
• The institution should develop and implement measures to ensure staff
timely make available and administer chronic care medications and
community hospital discharge medications. Measures should also ensure
timely administering medications to patients temporarily housed at the
institution, patients transferring within the institution, and patients
returning from off-site specialty appointments.
• Nursing leadership should develop and implement measures to ensure
nursing staff document administering medications, patient refusals, and no-
shows in the electronic health record, in accordance with CCHCS’s policies
and procedures.
Preventive Services
• Nursing leadership should develop and implement measures to ensure
nursing staff administer TB medications to patients as prescribed and
monitor the patients according to CCHCS policy.
• Medical leadership should determine the root cause(s) for challenges to
timely providing vaccinations to chronic care patients and should implement
appropriate remedial measures.
Nursing Performance
• Nursing leadership should determine the challenges preventing nurses from
performing complete assessments and documentation and should implement
remedial measures as appropriate.
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Specialized Medical Housing
• Medical leadership should determine the root cause of challenges to
providers completing thorough assessments and clear treatment plans for
specialized medical housing patients and should implement remedial
measures as appropriate.
• The institution should ascertain the causes related to the untimely
availability and administration of medications to specialized medical housing
patients and should implement remedial measures as appropriate.
Specialty Services
• Medical leadership should determine the root cause(s) of challenges to the
timely provision of specialty appointments for newly transferred patients and
should implement remedial measures as appropriate.
• Medical leadership should ascertain the challenges to the timely receipt and
provider review of specialty reports and should implement remedial
measures as appropriate.
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Indicators
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing
patients with timely clinical appointments. Our inspectors reviewed scheduling and
appointment timeliness for newly arrived patients, sick calls, and nurse follow-up
appointments. We examined referrals to primary care providers, provider follow-ups, and
specialists. Furthermore, we evaluated the follow-up appointments for patients who
received specialty care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Proficient Proficient (89.1%)
Compared with Cycle 6, case review found access to care at CCI had greatly improved. In
many respects, patients had excellent access to nurses, providers, and specialists. Follow-
up appointments after emergency care, hospital care, and specialty care were also timely
and appropriate. Overall, the OIG rated the case review component of this indicator
proficient.
Compliance testing showed CCI performed excellently in this indicator. Access to
providers was very good for newly transferred patients and for patients returning from
hospitalization and specialty service appointments. Nurses frequently reviewed patient
sick call requests and completed face-to-face encounters within required time frames.
However, staff needed improvement in providing chronic care appointments and in
maintaining an adequate system of replenishing health care request forms in housing
units. Based on the overall compliance score result, the OIG rated this indicator
proficient.
Case Review and Compliance Testing Results
OIG clinicians reviewed 187 provider, nursing, specialty, and hospital events requiring
the institution to generate appointments. We identified three deficiencies relating to
Access to Care, none of which were significant.11
Access to Clinic Providers
CCI’s performance was generally good in providing access to clinic providers. In
compliance testing, provider follow-up appointments frequently occurred when
requested by a nurse (MIT 1.005, 90.9%) and always occurred when ordered by a provider
(MIT 1.006, 100%). However, chronic care follow-up appointments only sometimes
occurred within required time frames (MIT 1.001, 72.0%). Case review found no
deficiencies related to outpatient provider access.
11 Deficiencies occurred in cases 8, 23, and 44.
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Access to Specialized Medical Housing Providers
Patients in specialized medical housing had excellent access to providers. Compliance
testing showed providers were generally prompt in completing history and physical
examinations within required time frames (MIT 13.002, 80.0%). Case review found
providers almost always evaluated patients upon arrival to the outpatient housing unit
(OHU) and rounded on patients appropriately. Providers also always assessed patients
after specialist appointments and hospital encounters. Case review identified only one
deficiency related to provider access in the OHU:
• In case 44, a provider completed an OHU admission history and physical one
day late.
Access to Clinic Nurses
CCI performed excellently in access to nurse sick calls and provider-to-nurse referrals.
Compliance testing showed nursing reviewed almost all sick call requests on the same
day they were received (MIT 1.003, 96.7%), and nurses completed nearly all face-to-face
encounters within one day after the sick call requests were reviewed (MIT 1.004, 93.1%).
OIG clinicians reviewed 33 nursing sick call requests in 20 cases and identified only two
minor deficiencies related to clinic nurse access.12 The following is an example:
• In case 8, a nurse triaged a health care request with a patient complaint of
constipation and a request for stool softener. However, the order for the
nursing evaluation appointment was scheduled incorrectly, resulting in the
patient not being timely seen.
Access to Specialty Services
CCI provided good access to specialists. Compliance testing showed outstanding
completion rates for high-priority (MIT 14.001, 93.3%), routine-priority (MIT 14.007,
100%) referrals, as well as for high-priority follow-up appointments (MIT 14.003, 100%).
However, medium-priority (MIT 14.004, 86.7%) referrals, and medium-priority (MIT
14.006, 60.0%) and routine-priority (MIT 14.009, 80.0%) follow-up appointments occurred
less timely. OIG clinicians reviewed 61 specialty events and identified no deficiencies
related to patient access for specialty referrals.
Follow-Up After Specialty Services
CCI also delivered good access to providers after specialty appointments. Compliance
testing showed patients were regularly seen within the expected time frames (MIT 1.008,
86.7%). Case review found no deficiencies related to scheduling a provider follow-up after
a specialty encounter.
Follow-Up After Hospitalization
CCI provided excellent follow-up for patients after a hospitalization. Compliance testing
showed all discharged patients were seen within the required time frame (MIT 1.007,
12 Nursing access deficiencies occurred in cases 8 and 9.
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100%). OIG clinicians reviewed 14 hospital events and did not identify any deficiencies
related to follow-up appointments after a hospitalization.
Follow-Up After Urgent or Emergent Care (TTA)
OIG clinicians reviewed 12 triage and treatment area (TTA) and emergency events with
no access deficiencies.
Follow-Up After Transferring Into CCI
Access to care for patients who had recently transferred into CCI was excellent.
Compliance testing showed providers consistently evaluated new patients within
required time frames (MIT 1.002, 95.7%). OIG clinicians reviewed six transfer-in events
and found no deficiencies related to provider access.
Clinician On-Site Inspection
CCI had three medical clinics at the time of our inspection: Facilities A, B, and C.
Facilities D and E had been closed in the prior year, but had offices used for
administrative purposes only. The providers worked a variety of schedules, including full-
time and part-time, two to five days per week. CCI also utilized telemedicine and registry
providers. Staff reported no backlog in any of the clinics at the time of our inspection.
Clinic supervisors stated evening clinics were occasionally held in Facility B if a
significant backlog developed, typically two to three times per month. Clinic staff
reported no custodial issues when patients are added to the clinic schedule or with
transporting patients.
Morning huddles were organized and collegial. Staff members attended either in-person
or through virtual conferencing. Office technicians participated in the huddles to ensure
timely scheduling of necessary appointments. Staff scheduled 10 to 12 appointments per
day for each provider with up to five additional nurse co-consultations. Clinic huddles
started at the beginning of the shift, with the huddle for OHU occurring approximately
one hour later to allow involved patient care team members to attend more than one
huddle if appropriate.
Compliance On-Site Inspection
Four of six housing units randomly tested at the time of inspection had access to Health
Care Services Request Forms (CDCR Form 7362) (MIT 1.101, 66.7%). In two housing units,
custody officers did not have a system in place for restocking the forms. The custody
officers reported reliance on medical staff to replenish the forms in the housing units.
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Cycle 7, California Correctional Institution | 17
Compliance Score Results
Table 5. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most recent chronic
care visit within the health care guideline’s maximum allowable interval or 18 7 0 72.0%
within the ordered time frame, whichever is shorter? (1.001)
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 22 1 2 95.7%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
29 1 0 96.7%
for service the same day it was received? (1.003)
Clinical appointments: Did the registered nurse complete a face-to-face visit
27 2 1 93.1%
within one business day after the CDCR Form 7362 was reviewed? (1.004)
Clinical appointments: If the registered nurse determined a referral to a
primary care provider was necessary, was the patient seen within the
10 1 19 90.9%
maximum allowable time or the ordered time frame, whichever is the
shorter? (1.005)
Sick call follow-up appointments: If the primary care provider ordered a
follow-up sick call appointment, did it take place within the time frame 1 0 29 100%
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
5 0 0 100%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
39 6 0 86.7%
occur within required time frames? (1.008) *
Clinical appointments: Do patients have a standardized process to obtain
4 2 0 66.7%
and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 89.1%
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Table 6. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the nurse
referred the patient to a provider, was the patient seen within the required N/A N/A N/A N/A
time frame? (12.003)
For patients received from a county jail: Did the patient receive a history
and physical by a primary care provider within seven calendar days (prior to N/A N/A N/A N/A
07/2022) or five working days (effective 07/2022)? (12.004)
Was a written history and physical examination completed within the
8 2 0 80.0%
required time frame? (13.002)
Did the patient receive the high-priority specialty service within 14 calendar
days of the primary care provider order or the Physician Request for 14 1 0 93.3%
Service? (14.001)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 7 0 8 100%
provider? (14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or the Physician Request 13 2 0 86.7%
for Service? (14.004)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 3 2 10 60.0%
(14.006)
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician Request 15 0 0 100%
for Service? (14.007)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care 4 1 10 80.0%
provider? (14.009)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Cycle 7, California Correctional Institution | 20
Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s performance in timely
completing radiology, laboratory, and pathology tests. Our inspectors determined
whether the institution properly retrieved the resultant reports and whether providers
reviewed the results correctly. In addition, in Cycle 7, we examined the institution’s
performance in timely completing and reviewing immediate (STAT) laboratory tests.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (63.6%)
As in Cycle 6, case review found CCI staff managed diagnostic services satisfactorily. The
timeliness of both test completion and results retrieval were exceptional. However,
providers performed poorly when creating patient test result notification letters. Despite
the large number of notification letter deficiencies, patient care was not significantly
affected. Considering all factors, the OIG rated the case review component of this
indicator adequate.
CCI’s compliance testing scored low for diagnostic services. Staff performed excellently
in completing radiology tests and retrieving pathology test results; however, staff
performed poorly in completing laboratory tests. Providers promptly endorsed diagnostic
results but only sporadically generated patient test result notification letters with all
required elements. Based on the overall compliance score result, the OIG rated this
indicator inadequate.
Case Review and Compliance Testing Results
The OIG clinicians reviewed 124 diagnostic events and identified 80 deficiencies.13 All 80
deficiencies related to health information management, two of which were significant.14
Test Completion
CCI performed well in completing diagnostic tests. Compliance testing showed CCI
completed all radiology tests within specified time frames (MIT 2.001, 100%) but
completed laboratory tests as specified only half the time (MIT 2.004, 50.0%).
Compliance testing did not have any STAT laboratory tests in their samples (MIT 2.007,
N/A).
Case review found no deficiencies in the completion of laboratory tests, EKGs, or on-site
radiology studies. Staff completed all tests within the requested time frames. OIG
13 Deficiencies occurred in cases 1, 2, 8, 11, 13–15, 17–24, 44, and 45.
14 Deficiencies occurred in cases 1, 2, 8, 11, 13–15, 17–24, 44, and 45. Significant deficiencies occurred in cases 17
and 44.
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Cycle 7, California Correctional Institution | 21
clinicians identified one STAT X-ray sample, which was completed within the required
time frame.15
Health Information Management
CCI’s performance in managing diagnostic test results was mixed between compliance
testing and case review. Compliance testing showed providers frequently reviewed and
endorsed radiology tests (MIT 2.002, 88.9%) and laboratory tests (MIT 2.005, 80.0%) within
required time frames. CCI staff performed perfectly in retrieving (MIT 2.010, 100%), and
satisfactorily in endorsing (MIT 2.011, 80.0%) pathology results. However, providers
performed poorly when communicating to patients with their test result letters, whether
for radiology (MIT 2.003, 33.3%), laboratory (MIT 2.006, 30.0%), or pathology (MIT 2.012,
10.0%) results.
Case review found no deficiencies related to retrieving diagnostic results. Providers
generally endorsed results promptly, although OIG clinicians identified two significantly
late endorsements.
• In case 17, a provider endorsed laboratory results six weeks late.
• In case 44, a provider endorsed laboratory results seven days late.
Case review found 71 of the 80 health information management deficiencies involved
patient notification letters.16 While the deficiencies were minor, their large number
revealed a widespread pattern. The following are examples:
• In case 1, a provider endorsed x-ray results but did not send the patient a
results notification letter.
• In case 2, a provider sent the patient a results notification letter but did not
include the date of the test or whether the results were normal.
• In case 19, a provider endorsed urine test results but did not send the patient
a test result notification letter.
• In case 21, a provider sent the patient a test result notification letter but did
not include whether the results were normal or whether a follow-up
appointment was necessary.
• In case 24, a provider endorsed ultrasound results but did not generate a test
result notification letter to the patient.
• In case 45, a provider endorsed laboratory results stating, “no suitable
specimen received.” However, the provider did not send the patient a test
result notification letter.
15 This event occurred in case 22.
16 Deficiencies occurred in cases 1, 2, 8, 11, 13–15, 17–24, 44, and 45.
Office of the Inspector General, State of California Inspection Period: March 2023 – August 2023 Report Issued: February 2025
Cycle 7, California Correctional Institution | 22
Clinician On-Site Inspection
We interviewed the diagnostic services supervisor and staff. A phlebotomist was assigned
to each of the three facilities at CCI for daily laboratory blood test collections. Facility C
housed the laboratory’s centralized office. Either a laboratory technician or a nurse
collected STAT laboratory tests at each facility. The ordering provider would access the
STAT laboratory results from a contracted vendor. Staff explained STAT laboratory tests
were not common, as most patients were transferred to the community hospital if they
required a STAT laboratory test.
Staff in Facility B conducted plain-film radiology services. CCI also offered ultrasound,
CT imaging, and MRI imaging, both on-site and off-site, depending on scheduling
needs.17
Staff reported no backlog for diagnostic services at the time of our inspection.
17 A CT scan is a computed, or computerized, tomography imaging scan. An MRI is a magnetic resonance
imaging scan.
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Compliance Score Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
10 0 0 100%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
8 1 1 88.9%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
3 6 1 33.3%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
5 5 0 50.0%
specified in the health care provider’s order? (2.004)
Laboratory: Did the health care provider review and endorse the laboratory
8 2 0 80.0%
report within specified time frames? (2.005)
Laboratory: Did the health care provider communicate the results of the
3 7 0 30.0%
laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and receive
N/A N/A N/A N/A
the results within the required time frames? (2.007)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frames? (2.008)
Laboratory: Did the health care provider endorse the STAT laboratory
N/A N/A N/A N/A
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report within the
10 0 0 100%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
8 2 0 80.0%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
1 9 0 10.0%
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 63.6%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should ascertain causative factors related to the untimely
provision of laboratory services and implement remedial measures as
appropriate.
• The department should consider developing strategies, such as potentially an
electronic solution, to ensure providers create patient test result notification
letters when they endorse test results and ensure patient letters contain all
elements required by CCHCS policy.
Office of the Inspector General, State of California Inspection Period: March 2023 – August 2023 Report Issued: February 2025
Cycle 7, California Correctional Institution | 25
Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency medical care. Our
clinicians reviewed emergency medical services by examining the timeliness and
appropriateness of clinical decisions made during medical emergencies. Our evaluation
included examining the emergency medical response, cardiopulmonary resuscitation
(CPR) quality, triage and treatment area (TTA) care, provider performance, and nursing
performance. Our clinicians also evaluated the Emergency Medical Response Review
Committee’s (EMRRC) performance in identifying problems with its emergency services.
The OIG assessed the institution’s emergency services through case review only and
performed no compliance testing for this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
CCI generally provided good emergency care. OIG clinicians found nursing staff
responded promptly to all emergent events and provided appropriate interventions.
Although OIG clinicians identified opportunities for improvement in patient
assessments, only one finding was clinically significant. As in Cycle 6, nurses continued
to struggle with documentation, which increased in frequency in Cycle 7. Moreover, the
EMRRC did not always identify these documentation discrepancies when conducting
clinical reviews of the emergency medical alarm activations and unscheduled transports
to a higher level of care. Compared with Cycle 6, in Cycle 7, OIG clinicians reviewed
more urgent and emergent events but found a similar number of emergency care
deficiencies. Taking this into consideration, the OIG rated this indicator adequate.
Case Review Results
OIG clinicians reviewed 54 events, 29 of which were urgent or emergent events. We
found 29 deficiencies in various aspects of overall emergency care, one of which was
significant.18
Emergency Medical Response
CCI custody and health care staff responded promptly to all emergencies throughout the
institution. Staff activated emergency medical services (EMS) when clinically indicated
and notified TTA staff in a timely manner.
Cardiopulmonary Resuscitation Quality
In our CPR sample case, custody and medical staff collaborated to provide care,
transport the patient to the TTA for additional interventions, and transfer the patient
18 Deficiencies occurred in cases 1–4, 7–9, 15, and 19–21. A significant deficiency occurred in case 2.
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Cycle 7, California Correctional Institution | 26
to a higher level of care. We identified a deficiency with the automatic external
defibrillator (AED) activation, described below:
• In case 4, custody staff activated an emergency medical alarm for this
unconscious patient. Upon the nurse’s arrival, custody was performing CPR.
The TTA RN documented a thready pulse and an irregular cardiac rhythm.
The TTA RN applied the AED pads to the patient. However, the nursing staff
did not activate the AED to assess for a shockable rhythm, although CPR
continued for five additional minutes. The significance of this deficiency was
mitigated by the nurse’s documentation of improvements to the patient’s
Glasgow Coma Scale (GCS) with each administration of nasal naloxone prior
to discontinuation of CPR.19
Provider Performance
CCI’s providers performed very well in urgent and emergent situations, and in after-
hours care. They made accurate diagnoses and completed documentation. Providers were
available for consultation with nurses when necessary and were involved in treatment
decisions. However, case review identified two deficiencies with provider performance.
Both are described below, with the latter considered significant:
• In case 1, a provider ordered the patient to be placed in a holding cell for
observation and to have vital signs taken every 30 minutes. However, the
provider did not enter the order, so the patient was not monitored as
intended.
• In case 2, a provider received a call from a TTA nurse for this patient who
fell, resulting in injuries. The right-handed patient had deformities of his
right fingers and a laceration. The provider did not examine the patient to
assess the possibility of an open fracture, the severity of the laceration, or the
risk of infection.20
Nursing Performance
CCI’s nurses performed well during emergency events. They responded to emergencies
timely, and frequently provided good interventions. Although we did not identify any
patterns or trends, OIG clinicians found opportunities for improvement in nursing
assessments. The following are examples:
• In case 2, the nurse evaluated the patient for a right-hand blunt-force trauma
related to a sustained fall. The nurse documented the patient’s fingers were
deformed with a laceration. However, the nurse did not assess the hand and
finger circulation, movement, and sensation (CMS) or advocate for a tetanus
shot.
19 The Glasgow Coma Scale is a clinical scale used to reliably measure a person’s level of consciousness and is
based on ability to perform eye movements, speak, and move the body. GCS is a vital assessment tool used
internationally and significantly affects the level of care needed for the patient.
20 An open fracture is a bone fracture with an open wound or break in the skin near the site of a broken bone.
Office of the Inspector General, State of California Inspection Period: March 2023 – August 2023 Report Issued: February 2025
Cycle 7, California Correctional Institution | 27
• In case 20, the patient was referred to the TTA for suspected cardiac chest
pain during a telemedicine encounter. The TTA nurse did not take the
patient’s pulse, listen to the patient’s heart or lungs, or describe the
presentation of the patient’s skin.
Nursing Documentation
Compared with Cycle 6, CCI had double the amount of documentation discrepancies in
the same number of cases in Cycle 7.21 The majority of deficiencies in emergency services
related to nursing documentation. Although documentation did not affect overall patient
care, the nurses did not always document the actual time of interventions provided,
resulting in the sequence of events being out of order or difficult to follow. The following
are examples:
• In case 7, staff activated an emergency medical alarm for an unconscious
patient suspected of an overdose. From the time of the TTA nurse’s arrival to
the scene, staff performed CPR for an additional nine minutes and
discontinued when the patient’s pulse was palpable. However, the TTA nurse
incorrectly documented the patient had palpable pulses with a heart rate of
78 at the time the nurse arrived at the scene, nine minutes before the pulse
was detected.
• In case 21, OHU staff directly referred the patient to the TTA for further
evaluation of brown vomit. Staff documented multiple conflicting times for
the initial TTA notification, patient departure and arrival to the TTA, and
the start and end times of nursing interventions.
• In case 21, on a separate occasion, OHU staff directly referred the patient to
the TTA. The nurses’ timeline documentation did not include the times of
transfer or arrival to the TTA. In addition, the TTA nurses did not document
the actual time of the initial evaluation. Furthermore, nurses documented
EMS activation 13 minutes prior to when EMS documentation showed they
received the initial dispatched call.
Emergency Medical Response Review Committee
The EMRRC met monthly and discussed emergency responses and unscheduled send
outs. However, compliance testing revealed incident packages were often deficient due to
cases not being reviewed within required time frames or being incomplete (MIT 15.003,
30.0%). Similarly, OIG clinicians found, in one case, the clinical review was not conducted
timely and was performed after the date of the OIG’s initial request. In addition, in a total
of five cases with unscheduled send outs, nursing and medical leadership did not identify
the same opportunities for improvement as OIG clinicians.22
• In case 1, an emergency event occurred on June 12, 2023, for which OIG
clinicians requested a clinical review on December 22, 2023. However, the
clinical review was not started until December 23, 2023.
21 Deficiencies in TTA nursing documentation occurred in cases 1–3, 7–9, 15, and 21.
22 Deficiencies occurred in cases 1, 2, 9, 20, and 21. None of the deficiencies in these cases were significant.
Office of the Inspector General, State of California Inspection Period: March 2023 – August 2023 Report Issued: February 2025
Cycle 7, California Correctional Institution | 28
• In cases 1, 9, and in two separate emergency events in case 21, the nursing
and medical leadership did not identify the same nursing documentation
deficiencies as the OIG.
Clinician On-Site Inspection
CCI had a vast layout with a considerable distance between the five separated facilities.
At the time of the inspection, CCI had three active facilities with patient populations.
Each facility maintained its own TTA. OIG clinicians toured the TTA areas at facilities A
and B. Facility B contained three independent emergency bays, while Facility A utilized a
single minor procedure room. All areas provided ample space for emergency care and
treatment. Facility B assigned two TTA RNs on second and third watch. In addition,
Facility B assigned one RN on first watch and assigned the receiving and release (R&R)
RN to report to the TTA to assist during emergencies. Facility A assigned one RN on
each shift. At both facilities, the primary care provider was designated as the point-of-
contact for emergencies. However, if a telemedicine provider was staffed during business
hours, a primary care provider available on-site from another yard would be contacted.
For after-hours emergencies, staff would coordinate the care with the on-call provider.
OIG clinicians inquired about community ambulance response times. The TTA RNs
reported that response times varied due to only having approximately two ambulances
available city-wide. A typical response time was estimated to be between 20 to 25
minutes. In addition, we asked about the assigned health care first responders. Nursing
staff reported all available staff respond to emergencies. OIG clinicians learned the
medication LVNs did not have an AED available to respond to medical emergencies and
were asked whether this presented any challenges. The LVN reported no challenges
because the TTA RN had an assigned radio on person and was responsible for responding
with the AED. In addition, the response times by both LVNs and the TTA RN were
within close proximity throughout the facility. OIG clinicians posed the same question to
nursing leadership, who reported this topic was already in discussion. Nursing leadership
further reported members of the nursing team on each shift were delegated an emergency
response task, such as scribing, CPR compression relief, airway management, or other
responsibilities.
Due to each facility having an assigned TTA RN, the nurses at both facilities A and B
reported regular attendance at the individual clinic huddles to report on recent events.
Upon further interview, the TTA RN at Facility A reported facilities A and C were unique
in that they did not have a designated R&R RN like Facility B. This, in turn, made the
TTA RNs responsible for processing patients who transferred in and out of the
institution. They did, however, report the Facility B R&R RN was available to assist for
large volume transfers on facilities A and C.
Office of the Inspector General, State of California Inspection Period: March 2023 – August 2023 Report Issued: February 2025
Cycle 7, California Correctional Institution | 29
Recommendations
• Nursing leadership should determine the root cause of challenges that
prevent nurses from accurately documenting the time and sequence of events
during emergency responses and should implement remedial measures as
appropriate.
• Nursing and medical leadership should determine the challenges to
identifying all documentation and timeline deficiencies in the emergency
medical response clinical review process and should implement remedial
measures as appropriate.
Office of the Inspector General, State of California Inspection Period: March 2023 – August 2023 Report Issued: February 2025
Cycle 7, California Correctional Institution | 30
Health Information Management
In this indicator, OIG inspectors evaluated the flow of health information, a crucial link
in high-quality medical care delivery. Our inspectors examined whether the institution
retrieved and scanned critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical record in a timely
manner. Our inspectors also tested whether clinicians adequately reviewed and endorsed
those reports. In addition, our inspectors checked whether staff labeled and organized
documents in the medical record correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (72.0%)
Similar to Cycle 6, case review found CCI sufficiently managed their health information.
Staff frequently retrieved and scanned hospital and emergency records timely. Although
staff sometimes scanned or endorsed some specialty reports late, these did not
significantly affect patient care. However, providers performed poorly in communicating
diagnostic results with test result notification letters to patients. After careful
consideration, the OIG rated the case review component of this indicator adequate.
CCI’s compliance testing performance was mixed. Staff always scanned patient health
care request forms. They also retrieved most hospital records and specialty reports within
required time frames. However, staff performed poorly in labeling medical documents.
Based on the overall compliance score result, the OIG rated the compliance component
of this indicator inadequate.
Case Review and Compliance Testing Results
The OIG clinicians reviewed 763 events and identified 99 deficiencies related to health
information management. Of these 99 deficiencies, four were significant.23
Hospital Discharge Reports
CCI staff often retrieved and scanned hospital discharge records timely. Compliance
testing showed staff generally scanned hospital discharge documents within required
time frames (MIT 4.003, 80.0%). All discharge documents contained key elements and
were endorsed by a provider within five days (MIT 4.005, 100%). OIG clinicians reviewed
14 off-site emergency department and hospital encounters. We identified only two
examples of a missing or late report as follows:
23 Deficiencies occurred in cases 1, 2, 8, 9, 11, 13–15, 17–24, 44, and 45.
Significant deficiencies occurred in cases 11, 17, 24, and 44.
Office of the Inspector General, State of California Inspection Period: March 2023 – August 2023 Report Issued: February 2025
Cycle 7, California Correctional Institution | 31
• In case 21, a biopsy report was pending at the time of the patient’s hospital
discharge. Staff never scanned the report into the electronic health record
system (EHRS).24
• In case 24, CCI staff retrieved and scanned the emergency room records late,
13 days after the patient’s evaluation.
• Also in case 24, staff never forwarded an emergency room report to a
provider for review.
Specialty Reports
CCI’s performance in handling specialty reports was scattered but poor overall.
Compliance testing showed staff scanned most specialty reports timely (MIT 4.002,
80.0%). Additionally, most high-priority specialty reports were retrieved and endorsed
timely (MIT 14.002, 80.0%). However, staff occasionally retrieved medium-priority (MIT
14.005, 40.0%), and sometimes retrieved routine-priority (MIT 14.008, 60.0%), specialty
reports within required time frames. Similarly, OIG clinicians reviewed 85 specialty
reports and identified 14 deficiencies.25 Although the deficiencies were generally not
significant, we identified a few patterns. For example, off-site specialty reports were
retrieved late or were missing in five of the 14 deficiencies.26 In addition, we found late
provider endorsements in seven of the 14 deficiencies.27 We also discuss these findings in
the Specialty Services indicator.
Diagnostic Reports
CCI had mixed performance in managing diagnostic reports. Compliance testing showed
CCI staff generally retrieved and endorsed results timely, but providers performed poorly
in communicating results with test result notification letters to patients. Case review
found similar results. OIG clinicians reviewed 124 diagnostic events and identified 80
health information management deficiencies.28 While only two were significant, 71 of the
80 deficiencies involved missing or incomplete patient test result notification letters.29
This pattern was observed in the previous cycle and remained an area to improve. Please
refer to the Diagnostics indicator for more details.
Urgent and Emergent Records
OIG clinicians reviewed 29 emergency care events and found CCI providers and nurses
recorded these events exceptionally well. We identified no deficiencies in this area. The
Emergency Services indicator provides additional information regarding emergency care
documentation.
24 EHRS is the Electronic Health Records System. The department’s electronic health record system is used for
storing the patient’s medical history and health care staff communication.
25 Deficiencies occurred in cases 19, 21, 22, 44, and 45.
26 Deficiencies occurred in cases 21, 22, and 44.
27 Deficiencies occurred in cases 21, 22, and 44.
28 Deficiencies occurred in cases 1, 2, 8, 11, 13–15, 17–24, 44, and 45.
29 Deficiencies occurred in cases 1, 2, 8, 11, 13–15, 17–24, 44, and 45. Significant deficiencies occurred in cases 17
and 44.
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Cycle 7, California Correctional Institution | 32
Scanning Performance
CCI performed variably in scanning. Compliance testing revealed no sampled documents
were scanned properly (MIT 4.004, zero). Yet, OIG clinicians reviewed 763 encounters
and identified only two mislabeled records. The following is an example:
• In case 9, staff mislabeled a urology specialty consultation report as a
hematology consultation report, and a neurology consultation report as a
surgical consultation report.
OIG clinicians found no misfiled or duplicated documents.
Clinician On-Site Inspection
We discussed health information management (HIM) processes with executive
leadership, the health information management supervisor, the utilization management
supervisor, specialty nursing managers, ancillary staff, and providers.
Utilization management and specialty services staff reported being vigilant about
tracking reports from off-site encounters. However, specialty services nurses erroneously
stated the time frame for retrieving specialty reports as 72 hours, instead of 48 hours as
required in the department’s Health Care Department Operations Manual (HCDOM).30
Utilization management supervisors expressed frustration in retrieving timely records
from one particular hospital. This challenge was echoed by multiple staff members.
Scanning of admission documents in the OHU was also problematic. Nursing staff used a
previous CTC form for admission. However, the health information management
supervisor explained the CTC inpatient forms could not be scanned into the record as
outpatient forms. Therefore, HIM staff did not scan these forms into the EHRS at all. The
OIG notes, as of the date of publishing this report, the HCDOM contains no record of
such a policy.
30 See HCDOM (3.1.11.c.4.k) at https://www.cdcr.ca.gov/hcdom/dom/chapter-3-health-care-operations/.
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Cycle 7, California Correctional Institution | 33
Compliance Score Results
Table 8. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s electronic
20 0 10 100%
health record within three calendar days of the encounter date? (4.001)
Are specialty documents scanned into the patient’s electronic health record
24 6 15 80.0%
within five calendar days of the encounter date? (4.002)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 4 1 0 80.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
0 24 0 0
and included in the correct patients’ files? (4.004)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 5 0 0 100%
review the report within five calendar days of discharge? (4.005)
Overall percentage (MIT 4): 72.0%
Source: The Office of the Inspector General medical inspection results.
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Table 9. Other Tests Related to Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
8 1 1 88.9%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the laboratory
8 2 0 80.0%
report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
N/A N/A N/A N/A
staff notify the provider within the required time frame? (2.008)
Pathology: Did the institution receive the final pathology report within the
10 0 0 100%
required time frames? (2.010)
Pathology: Did the health care provider review and endorse the pathology
8 2 0 80.0%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
1 9 0 10.0%
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 12 3 0 80.0%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 6 9 0 40.0%
frame? (14.005)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 9 6 0 60.0%
frame? (14.008)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, California Correctional Institution | 35
Recommendations
• The institution should identify the challenges to properly labeling and
scanning documents into the medical record and should implement remedial
measures as appropriate.
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Cycle 7, California Correctional Institution | 36
Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting areas, infection
control, sanitation procedures, medical supplies, equipment management, and
examination rooms. Inspectors also tested clinics’ performance in maintaining auditory
and visual privacy for clinical encounters. Compliance inspectors asked the institution’s
health care administrators to comment on their facility’s infrastructure and its ability to
support health care operations. The OIG rated this indicator solely on the compliance
score. Case review does not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall compliance rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (51.9%)
Overall, CCI performed poorly with respect to its health care environment. In this cycle,
multiple aspects of CCI’s health care environment needed improvement: medical supply
storage areas in and outside of the clinics did not follow protocols for managing and
storing medical supplies; staff did not ensure medical equipment or health care areas
were properly disinfected; patient restrooms in the clinics were missing hand hygiene
supplies; several clinics did not meet the requirements for essential core medical
equipment and supplies; emergency medical response bag (EMRB) logs were missing
evidence of inventory or had compromised supplies; and staff did not properly sanitize
their hands throughout the patient encounters. Based on the overall compliance score
result, the OIG rated this indicator inadequate.
Compliance Testing Results
Patient Waiting Areas
We inspected only indoor waiting areas
as CCI had no outdoor waiting areas
(see Photo 1). Health care and custody
staff reported the existing waiting areas
contained sufficient seating capacity.
During our inspection, we did not
observe overcrowding in any of the
clinics’ indoor waiting areas.
Clinic Environment
All clinic environments were
sufficiently conducive for medical care;
they provided reasonable auditory Photo 1. Indoor waiting area (photographed on 10-26-23).
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Cycle 7, California Correctional Institution | 37
privacy, appropriate waiting areas, wheelchair accessibility, and nonexamination room
workspace (MIT 5.109, 100%).
Of the eight applicable clinics we observed, five contained appropriate space,
configuration, supplies, and equipment to allow their clinicians to provide proper
medical services (MIT 5.110, 62.5%). The remaining three clinics had one or more of the
following deficiencies: an examination table had a torn vinyl cover; examination room
furniture, ceiling, or soap dispenser were in disrepair; and an examination room had
unsecured confidential medical records.
Clinic Supplies
Four of the nine clinics followed adequate
medical supply storage and management
protocols (MIT 5.107, 44.4%). We found one
or more of the following deficiencies in the
remaining five clinics: expired medical
supplies (Photo 2); unidentified,
unorganized, or inaccurately labeled
supplies; cleaning materials stored with
medical supplies; and long-term storage of
staff’s food in a medical supply storage area.
Two of the nine clinics met requirements for
essential core medical equipment and
supplies (MIT 5.108, 22.2%). We found one
or more deficiencies in the remaining seven
clinics: improperly calibrated or
nonfunctional equipment; missing items
including examination table paper and oto-
ophthalmoscope; and incomplete or
inaccurate documentation of defibrillator or
AED performance tests within the last 30
days. Photo 2. Expired medical supplies
(photographed on 10-25-23).
We examined EMRBs to determine if they
contained all essential items. We checked
whether staff inspected the bags daily and
inventoried them monthly. Four of the seven applicable EMRBs passed our test (MIT
5.111, 57.1%). We found one or more of the following deficiencies with three EMRBs: staff
failed to inventory the EMRBs when seal tags were replaced; EMRB daily glucometer logs
were either inaccurate or incomplete; or EMRB contained compromised supplies (see
Photos 3 and 4, next page).
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Cycle 7, California Correctional Institution | 38
Photo 3. Incomplete EMRB glucometer
logs (photographed on 10-24-23).
Photo 4. Compromised EMRB medical supply
(photographed on 10-26-23).
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Cycle 7, California Correctional Institution | 39
Medical Supply Management
None of the medical supply storage
areas located outside the medical
clinics stored medical supplies
adequately (MIT 5.106, zero). In the
medical warehouse, we found expired
medical supplies (see Photo 5). In
addition, the warehouse manager
reported they did not maintain a
temperature log allowing them to
monitor the current temperature for
medical supplies with manufacturer
temperature guidelines stored in the
medical warehouse (see Photo 6).
Photo 5. Expired supplies in the warehouse
(photographed on 10-25-23).
According to the CEO, the institution did
not have any concerns about the medical
supply process. Health care managers and
medical warehouse managers expressed
no concerns about the medical supply
chain or their communication process.
Infection Control and Sanitation
Staff appropriately cleaned and
disinfected five of eight applicable clinics
(MIT 5.101, 62.5%). In three clinics, we
found one or more of the following
deficiencies: cleaning logs were not
maintained; a medical supply cabinet was
unsanitary; and a gurney was unsanitary.
Staff in five of nine clinics properly
sterilized or disinfected medical Photo 6. Warehouse supplies with temperature guidelines
equipment (MIT 5.102, 55.6%). In three (photographed on 10-25-23).
clinics, staff did not mention disinfecting
the examination table as part of their daily
start-up protocol. In the remaining clinic, we found compromised sterilized medical
equipment packaging.
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Cycle 7, California Correctional Institution | 40
We found operational sinks and hand hygiene supplies in the examination rooms in six of
nine clinics (MIT 5.103, 66.7%). The patient restrooms in three clinics lacked antiseptic
soap and disposable hand towels.
We observed patient encounters in seven clinics. In all clinics, none of the clinicians
properly washed or sanitized their hands before or after examining their patients, before
and after performing an invasive procedure, or during subsequent regloving (MIT 5.104,
zero).
Health care staff in all clinics followed proper protocols to mitigate exposure to blood-
borne pathogens and contaminated waste (MIT 5.105, 100%).
Physical Infrastructure
At the time of the compliance inspection, CCI did not have any ongoing Health Care
Facility Improvement Program projects. The institution’s health care management and
plant operations manager reported infrastructure in all clinical areas was in good
working order (MIT 5.999).
Compliance On-Site Inspection
In addition to the above findings,
our compliance inspectors
observed some notable findings in
clinics during their on-site
inspection. In one clinic,
laboratory supplies were being
stored in the soiled utility room
with biohazardous waste (Photos
7–9, this page and next page). In a
different clinic, we found peeling
paint on the ceiling (Photo 10,
page 42).
Photo 7. Laboratory equipment and
supplies stored in the soiled utility room
(photo 1 of 3, photographed on 10-24-23).
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Cycle 7, California Correctional Institution | 41
Photo 8. Laboratory equipment and supplies stored
in the soiled utility room (photo 2 of 3,
photographed on 10-24-23).
Photo 9. Laboratory equipment and supplies stored
in the soiled utility room (photo 3 of 3,
photographed on 10-24-23).
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Cycle 7, California Correctional Institution | 42
Photo 10. Peeling paint on the clinic ceiling (photographed on 10-25-23).
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Cycle 7, California Correctional Institution | 43
Compliance Score Results
Table 10. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately disinfected,
5 3 6 62.5%
cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable invasive
and noninvasive medical equipment is properly sterilized or disinfected as 5 4 5 55.6%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
6 3 5 66.7%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
0 7 7 0
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
9 0 5 100%
borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the medical
supply management process adequately support the needs of the medical 0 1 0 0
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
4 5 5 44.4%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
2 7 5 22.2%
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
9 0 5 100%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
5 3 6 62.5%
providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency crash
carts inspected and inventoried within required time frames, and do they 4 3 7 57.1%
contain essential items? (5.111)
Does the institution’s health care management believe that all clinical areas
This is a nonscored test. Please see the
have physical plant infrastructures that are sufficient to provide adequate
indicator for discussion of this test.
health care services? (5.999)
Overall percentage (MIT 5): 51.9%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, California Correctional Institution | 44
Recommendations
• Medical leadership should determine the root cause(s) for staff not following
all required universal hand hygiene precautions and should take necessary
remedial measures.
• Executive leadership should determine the root cause(s) for staff not ensuring
medical supply storage areas, located inside and outside the clinics, store
medical supplies adequately and should take necessary remedial measures.
• Nursing leadership should determine the root cause(s) for staff not ensuring
clinic examination rooms contain essential core medical equipment and
should take necessary remedial measures that include verifying staff follow
equipment and medical supply management protocols.
• Nursing leadership should determine the root cause(s) for staff not ensuring
the emergency medical response bags (EMRBs) are regularly inventoried and
sealed, or staff failing to properly complete the monthly logs, and should take
necessary remedial measures.
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Cycle 7, California Correctional Institution | 45
Transfers
In this indicator, OIG inspectors examined the transfer process for those patients who
transferred into the institution as well as for those who transferred to other institutions.
For newly arrived patients, our inspectors assessed the quality of health care screenings
and the continuity of provider appointments, specialist referrals, diagnostic tests, and
medications. For patients who transferred out of the institution, inspectors checked
whether staff reviewed patient medical records and determined the patient’s need for
medical holds. They also assessed whether staff transferred patients with their medical
equipment and gave correct medications before patients left. In addition, our inspectors
evaluated the performance of staff in communicating vital health transfer information,
such as preexisting health conditions, pending appointments, tests, and specialty
referrals; and inspectors confirmed whether staff sent complete medication transfer
packages to receiving institutions. For patients who returned from off-site hospitals or
emergency rooms, inspectors reviewed whether staff appropriately implemented
recommended treatment plans, administered necessary medications, and scheduled
appropriate follow-up appointments.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (67.1%)
Case Review found CCI performed overall sufficiently in the transfer indicator.
Compared with Cycle 6, case review identified a substantial improvement in the total
number of significant deficiencies, with only one deficiency related to the scanning and
endorsement of hospital discharge records. Although in Cycle 7, OIG clinicians reviewed
fewer events in fewer cases than in Cycle 6, we found a notable improvement in the
number of clinical-related deficiencies. OIG clinicians found a few deficiencies with
medication continuity upon patient arrival to and departure from the institution, as well
as with CCI notifying the receiving institution of pending specialty appointments for
patients transferring out of CCI. However, OIG clinicians also found minimal
deficiencies related to patient assessments upon arrival to the institution and upon return
from a community hospital or emergency department encounter. After reviewing all
aspects, the OIG rated the case review component of this indicator adequate.
Compared with Cycle 6, compliance testing similarly showed CCI’s overall performance
improved for this indicator. CCI performed excellently in completing the assessment and
disposition section of the screening process. However, CCI still needs substantial
improvement in completing initial health screening forms and ensuring medication
continuity for newly transferred patients. Based on the overall compliance score result,
the OIG rated the compliance component of this indicator inadequate.
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Cycle 7, California Correctional Institution | 46
Case Review and Compliance Testing Results
We reviewed 34 events in 16 cases in which patients transferred into or out of the
institution or returned from off-site hospitalizations or emergency room encounters. We
identified 13 deficiencies, one of which was significant.31
Transfers In
CCI had a mixed performance in the transfer-in process. Compliance testing showed that
R&R nurses performed poorly in completing the initial health screening form thoroughly
(MIT 6.001, 16.0%). However, nurses always completed the assessment and disposition
section of the form in its entirety (MIT 6.002, 100%). Compliance testing also found staff
sometimes ensured medication continuity occurred at the time of transfer (MIT 6.003,
52.4%) but performed poorly in medication continuity for patient layovers at the
institution (MIT 7.006, 50.0%). In addition, compliance testing showed newly arrived
patients were almost always seen by a provider within necessary time frames (MIT 1.002,
95.7%).
While compliance testing results varied, OIG clinicians found CCI’s transfer-in process
to be satisfactory. We reviewed six events in four cases in which patients transferred into
the facility from other institutions. We identified only two minor deficiencies.32 The
following is an example:
• In case 27, the nurse conducting the initial health screening for the newly
arrived patient did not obtain the patient’s vital signs.
The additional deficiency is addressed further in the Medication Management indicator.
Transfers Out
CCI also had a mixed performance in the transfer-out process. Compliance testing
showed patients who transferred out of the institution always had their medications,
durable medical equipment (DME), and required documents (MIT 6.101, 100%). In
contrast, OIG clinicians found only one medication deficiency. This is addressed further
in the Medication Management indicator.
OIG clinicians reviewed a total of seven transfer-out events in four cases in which
patients transferred out of the facility to other institutions. We identified four minor
deficiencies.33 In addition to the deficiency mentioned above, the following are examples:
• In cases 29 through 31, the nurses did not always document notifying the
receiving institutions of pending specialty consultations.
Hospitalizations
Patients returning from an off-site hospitalization or emergency room are at high risk for
lapses in care quality. These patients typically experienced severe illness or injury. They
31 Deficiencies occurred in cases 2, 9, 19–21, 24, 27, 29–31, and 44. A significant deficiency occurred in case 24.
32 Transfer in deficiencies occurred in cases 27 and 44.
33 Transfer out deficiencies occurred in cases 29–31.
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Cycle 7, California Correctional Institution | 47
require more care and place a strain on the institution’s resources. In addition, because
these patients have complex medical issues, successful health information transfer is
necessary for good quality care. Any transfer lapse can result in serious consequences for
these patients.
CCI had a mixed performance in the return process for hospitalizations and emergency
room encounters. Compliance testing showed follow-up appointments were always
completed within required time frames for patients returning from hospitalizations and
emergency room encounters (MIT 1.007, 100%). In most samples, staff scanned hospital
discharge documents into the patient’s electronic health record within three calendar
days of discharge (MIT 4.003, 80.0%). Compliance testing also found providers always
reviewed and endorsed documents in a timely manner (MIT 4.005, 100%).
In contrast to compliance testing, case review discovered opportunities for improvement.
We reviewed 21 hospitalization events in nine cases, 13 of which were community
hospital or emergency room encounter returns. We identified seven deficiencies, one of
which was significant.34 In one case, the follow-up appointment was not scheduled within
the time frame recommended by the hospital. We found a significant deficiency in which
staff did not scan the hospital record within 13 days after the patient was seen in the
emergency department and did not forward it to the provider for review. Additional
deficiencies related to hospital records are further addressed in the Health Information
Management indicator.
Case review did not find any significant patterns or trends. However, we identified some
clinical deficiencies. The following are examples:
• In case 2, the patient returned from the community emergency room with
elevated blood pressure. However, the nurse did not subjectively assess
whether the patient had taken their blood pressure medication that day.
• In case 21, the patient returned from a hospital admission for a
gastrointestinal bleed. Although the nurse documented the patient did not
complain of any symptoms, the nurse did not listen for bowel sounds and did
not describe the appearance of or palpate the abdomen.
Compliance testing showed CCI performed poorly in ensuring ordered medications were
administered, made available, or delivered to patients within the required time frames
(MIT 7.003, 20.0%). OIG clinicians also found two deficiencies related to continuity of
medication upon return from a hospitalization or emergency department encounter. This
is addressed further in the Medication Management indicator.
Clinician On-Site Inspection
OIG clinicians toured the R&R and TTA areas located in facilities A and B. We
interviewed the R&R nurse in Facility B. The nurse was knowledgeable and described
both the transfer-in and transfer-out processes. The nurse shared the R&R staffed one RN
on each shift, and all nurses were responsible for the transfer-in and transfer-out
processes. Although the R&R RN position was designated for Facility B, the TTA nurse
in Facility A reported the TTA RNs in facilities A and C perform the transfer processes
34 Hospital deficiencies occurred in cases 2, 19–21, and 24. A significant deficiency occurred in case 24.
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Cycle 7, California Correctional Institution | 48
for their respective facilities. The R&R nurse and TTA RN reported they received a list
from custody on a weekly basis that included the upcoming transfers, both incoming and
outgoing, for the subsequent week. Additionally, the nurses reported revisions to the list
were provided throughout the week. The R&R nurse in Facility B reported the average
number of patients transferring varied, with a weekly average of 25 to 30 patients
transferring in and an average of more than 40 patients transferring out.
The R&R RN further described the processes in place to maintain continuity of care for
patients who transferred into CCI without their prescribed medications or with pending
specialty consultations. The process included having an assigned office technician (OT)
send a list to the primary care providers to notify them of patients who required
medication reconciliation. The R&R nurse was responsible for contacting the pharmacy
to ensure the pharmacist reconciled and dispensed the patient medications, notifying the
medication line LVNs to ensure they administered the next dose of medication, and
educating the patient to report to the medication line. For patients with pending
specialty consultations, the R&R RN notified the specialty nurse. To maintain continuity
during the transfer-out process, the R&R RN reported they manually reviewed and
counted KOP transfer medications to ensure patients had a current order for each
medication, the medication was within expiration dates, and patients had a five-day
supply of medications.35 Additionally, the R&R nurse reported they would call the
receiving institution and send a message in the electronic health record to notify of any
pending specialty consultations.
Compliance On-Site Inspection
R&R nursing staff always ensured patients transferring out of the institution had the
required medications, transfer documents, and assigned DME (MIT 6.101, 100%).
35 KOP means “keep on person” and refers to medications in which a patient can keep and self-administer
according to the directions provided.
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Compliance Score Results
Table 11. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Did nursing
staff complete the initial health screening and answer all screening 4 21 0 16.0%
questions within the required time frame? (6.001)
For endorsed patients received from another CDCR institution: When
required, did the RN complete the assessment and disposition section of
the initial health screening form; refer the patient to the TTA if TB signs and 25 0 0 100%
symptoms were present; and sign and date the form on the same day staff
completed the health screening? (6.002)
For endorsed patients received from another CDCR institution: If the patient
had an existing medication order upon arrival, were medications 11 10 4 52.4%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer packet 2 0 0 100%
required documents? (6.101)
Overall percentage (MIT 6): 67.1%
Source: The Office of the Inspector General medical inspection results.
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Table 12. Other Tests Related to Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 22 1 2 95.7%
patient seen by the clinician within the required time frame? (1.002)
Upon the patient’s discharge from the community hospital: Did the patient
receive a follow-up appointment with a primary care provider within the 5 0 0 100%
required time frame? (1.007)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 4 1 0 80.0%
(4.003)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 5 0 0 100%
review the report within five calendar days of discharge? (4.005)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient 1 4 0 20.0%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
18 7 0 72.0%
medications continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications 5 5 0 50.0%
administered or delivered without interruption? (7.006)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
2 3 0 40.0%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, California Correctional Institution | 51
Recommendations
• Nursing leadership should determine the root cause of challenges
preventing nurses from thoroughly completing the initial health screening
process, including documenting a complete set of vital signs, answering all
questions, and documenting an explanation for all “Yes” answers before the
patient is transferred to the housing unit. Leadership should implement
remedial measures as appropriate.
• Nursing leadership should develop strategies to ensure newly arrived
patients receive medications without interruption. In addition, nursing
leadership should develop strategies to ensure nurses document reasons for
patient refusals on the MAR summaries in accordance with CCHCS policies
and procedures.
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Medication Management
In this indicator, OIG inspectors evaluated the institution’s performance in
administering prescription medications on time and without interruption. The inspectors
examined this process from the time a provider prescribed medication until the nurse
administered the medication to the patient. When rating this indicator, the OIG strongly
considered the compliance test results, which tested medication processes to a much
greater degree than case review testing. In addition to examining medication
administration, our compliance inspectors also tested many other processes, including
medication handling, storage, error reporting, and other pharmacy processes.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (67.8%)
Case review found CCI performed well overall in medication management, with
improvement since Cycle 6. CCI improved in administering new medication
prescriptions and hospital discharge medications, with only one significant deficiency
identified. However, OIG clinicians found lapses in chronic care medication continuity
and a new challenge related to continuity of medication for patients attending off-site
specialty appointments. After reviewing all aspects, the OIG rated the case review
component of this indicator adequate.
Compliance testing showed CCI needed improvement in this indicator. CCI scored low
in providing patients with chronic care medications, community hospital discharge
medications, and medications for patients temporarily housed at the institution as well as
providing medication continuity for patients transferring within the institution. Based on
the overall compliance score result, the OIG rated the compliance component of this
indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 126 events in 25 cases related to medications and found 26 medication
deficiencies, one of which was significant.36
New Medication Prescriptions
Compliance testing showed CCI had opportunities for improvement in ensuring timely
administration and availability of new prescription medications (MIT 7.002, 76.0%).
Similarly, OIG clinicians found six deficiencies related to new prescriptions, one of
which was significant.37 The following are examples:
36 Deficiencies occurred in cases 11, 14, 15, 18–23, 31, and 44. A significant deficiency occurred in case 14.
37 New medication prescription deficiencies occurred in cases 11, 14, 18, and 19. A significant deficiency
occurred in case 14.
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• In case 14, the renewal orders for two glaucoma eye drop prescriptions were
designated as auto-refill. However, the prescription instructions stated,
“Request refill.” Consequently, the patient did not consistently receive the
medication used to decrease eye pressure, prevent optic nerve damage, and
preserve vision.
• In case 18, a provider ordered a new prescription for an antibiotic to start in
the evening; however, the patient did not receive it until the following day.
• In case 19, an order for an opioid use disorder treatment medication ended
prior to the patient’s morning medication administration. However, a
provider did not order a new prescription until two days later, to start on the
following day; this resulted in a four-day lapse in medication administration.
Chronic Medication Continuity
Compliance testing showed CCI needed improvement in chronic medication continuity.
Patients intermittently received their chronic care medications within required time
frames (MIT 7.001, 68.8%). Similarly, OIG clinicians also found 10 chronic care
deficiencies in which medications were not provided timely or were not received at all.38
The following are examples:
• In cases 11, 14, 15, and 23, patients did not receive their KOP chronic care
medications timely or at all.
• In case 19, 20, and 22, patients did not receive one or more doses of nurse
administered chronic care medication.
Hospital Discharge Medications
Compliance testing also showed CCI performed poorly in ensuring patients received
their medications upon return from an off-site hospital or emergency room encounter
(MIT 7.003, 20.0%). Similarly, OIG clinicians also found, in two cases, patients did not
receive the hospital recommended medications timely or at all.39 We identified the
following deficiencies:
• In case 19, the hospital recommended an iron supplement and constipation
medication to start the following day. However, the patient did not receive
the medications.
• In case 20, the hospital recommended a new hypertension medication.
However, the patient did not receive the medication until seven days after
returning to the institution.
Specialized Medical Housing Medications
OIG clinicians found CCI had opportunities for improvement in ensuring patients
received their needed medications while housed in the outpatient housing unit (OHU).
38 Patients did not receive chronic care medications timely or at all in cases 11, 14, 15, 19, 20, 22, and 23.
39 Patients did not receive hospital discharge medications timely or at all occurred in cases 19 and 20.
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Case review found OHU nurses generally administered medications timely; however, we
identified four medication deficiencies.40 The following are examples:
• In case 21, a prostate medication order ended prior to the morning
administration time. However, the provider did not order the prescription
until two days later, resulting in the patient not receiving two doses.
• In case 44, on two occasions, the patient did not receive an antibiotic topical
cream. Additionally, on one occasion, the patient did not receive a dose of a
medication to treat insomnia.
Transfer Medications
Compliance testing showed CCI needed improvement in transfer medications. Nurses
intermittently ensured patients who transferred into the institution received their
medications timely (MIT 6.003, 52.4%). In addition, CCI needed improvement in
medication continuity for patients transferring from yard to yard (MIT 7.005, 72.0%).
Moreover, CCI performed poorly with patients who were on layover and temporarily
housed at CCI, as they only occasionally received their medications within required time
frames (MIT 7.006, 50.0%). In contrast, OIG clinicians found only two minor medication
deficiencies within the transfer processes. The following are examples:
• In case 31, the transfer nurse documented the patient’s KOP prostate
prescription was missing for transport. However, the nurse did not
administer the medication to the patient prior to departure from the
institution.
• In case 44, the patient arrived to CCI with transfer medications. However,
the patient did not receive the first two doses of a topical antibiotic cream.
Medication Administration
Compliance found CCI nurses needed improvement in administering tuberculosis (TB)
medications within required time frames (MIT 9.001, 57.1%). For case review, OIG
clinicians did not have any case review samples with events related to TB medications.
OIG clinicians found CCI nurses generally administered medications properly. However,
in nine cases, we reviewed 30 events of patients returning from off-site specialty
consultations and found, on three occasions, nurses did not ensure the patient received
their scheduled medications prior to transfer from, or upon return to, the institution.41
The following are examples:
• In cases 20 and 21, the patients returned from prescheduled off-site specialty
procedures; however, they did not receive scheduled daily medications upon
return to the institution.
40 OHU medication deficiencies occurred in cases 21 and 44.
41 Deficiencies occurred in cases 20 and 21.
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Clinician On-Site Inspection
During the on-site inspection, OIG clinicians toured select medication areas to include
the Facility B medication room and the on-site pharmacy. We conducted interviews with
medication nurses. We also met with the pharmacist and nursing leadership to discuss
case review findings. In addition, the OIG clinicians attended huddles for all three
facilities, noting discussion of medication compliance, medication expiration, and other
care-related information.
The medication room on Facility B had three medication line windows, each of which
had their own separate automatic drug delivery system (ADDS). Facility B also had an
additional window connected to a private room for patients requiring injections. During
the tour, two nurses were present; however, they informed us three nurses are typically
assigned to this area. We found the nurses were knowledgeable about the medication
processes. We also observed the medication lines were distributed by patients’ last
names. However, the nurses explained they work as a team and would administer
medication to any patient reporting to their line.
Medication Practices and Storage Controls
CCI adequately stored and secured narcotic medications in all 10 applicable clinic and
medication line locations (MIT 7.101, 100%).
In contrast, CCI appropriately stored and secured nonnarcotic medications in only four
of 10 applicable clinic and medication line locations (MIT 7.102, 40.0%). In six locations,
we observed one or more of the following deficiencies: the medication storage cart was
unsanitary; the medication area either lacked a system in place to separate returned
medications (previously in possession by a patient) from other medications; the
medication area lacked a designated location for medications with expired pharmacy
labels that could potentially be restocked and reissued by the pharmacy; nurses did not
maintain unissued medication in its original labeled packaging; and daily security check
log entries for the treatment cart were incomplete.
Similarly, CCI staff kept medications protected from physical, chemical, and temperature
contamination in only one of the 10 applicable clinic and medication line locations (MIT
7.103, 10.0%). In nine locations, we found one or more of the following deficiencies: staff
did not consistently record the room or refrigerator temperatures; staff did not store
internal and external medications separately; and the medication refrigerator was
unsanitary. In addition, in one location, the provider refused to allow our inspectors
access to the staff supplies cabinet to conduct our inspection.
Staff successfully stored valid, unexpired medications in all 10 applicable medication line
locations (MIT 7.104, 100%).
Nurses exercised proper hand hygiene and contamination control protocols in only one of
six applicable locations (MIT 7.105, 16.7%). In the remaining locations, nurses neglected
to wash or sanitize their hands when required. These occurrences included before
preparing and administering medications and before each subsequent regloving. In
addition, some nurses did not resanitize their hands and change gloves when gloves were
compromised.
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Staff in four of six applicable medication preparation and administration areas
demonstrated appropriate administrative controls and protocols (MIT 7.106, 66.7%). In
two locations, medication nurses did not describe the process they followed when
reconciling a newly received medication and the medication administration record (MAR)
against the corresponding physician’s order.
Staff in only two of six applicable medication areas used appropriate administrative
controls and protocols when distributing medications to their patients (MIT 7.107,
33.3%). In four locations, we observed one or more of the following deficiencies:
medication nurses did not verbalize the medication error reporting process; medication
nurses did not reliably observe patients while they swallowed direct observation therapy
medications; medication nurses did not properly disinfect the insulin vial’s port prior to
withdrawing medication; and medication nurses did not follow CCHCS care guide when
administering Suboxone medication.
Pharmacy Protocols
CCI always followed general security, organization, and cleanliness management
protocols for nonrefrigerated and refrigerated medications stored in its pharmacy (MITs
7.108, 7.109, and 7.110, 100%).
The pharmacist-in-charge (PIC) correctly accounted for narcotic medications stored in
CCI’s pharmacy (MIT 7.111, 100%).
We examined 14 pharmacy-related medication error reports. The PIC timely and
correctly processed all reports (MIT 7.112, 100%).
Nonscored Tests
In addition to testing the institution’s self-reported medication errors, our inspectors
also follow up on any significant medication errors found during compliance testing. We
did not score this test; we provide these results for informational purposes only. At CCI,
the OIG did not find any applicable medication errors (MIT 7.998).
The OIG interviewed patients in restricted housing units to determine whether they had
immediate access to their prescribed asthma rescue inhalers or nitroglycerin
medications. Nine of 10 applicable patients interviewed indicated they had access to their
rescue medications. One patient reported he finished his medication one day prior and
had requested a refill. We promptly notified the CEO of this concern, and health care
management immediately reissued a replacement rescue inhaler to the patient (MIT
7.999).
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Compliance Score Results
Table 13. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required time frames
11 5 9 68.8%
or did the institution follow departmental policy for refusals or no‑shows? (7.001)
Did health care staff administer, make available, or deliver new order prescription
19 6 0 76.0%
medications to the patient within the required time frames? (7.002)
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient within 1 4 0 20.0%
required time frames? (7.003)
For patients received from a county jail: Were all medications ordered by the
institution’s reception center provider administered, made available, or delivered to N/A N/A N/A N/A
the patient within the required time frames? (7.004)
Upon the patient’s transfer from one housing unit to another: Were medications
18 7 0 72.0%
continued without interruption? (7.005)
For patients en route who lay over at the institution: If the temporarily housed patient
had an existing medication order, were medications administered or delivered 5 5 0 50.0%
without interruption? (7.006)
All clinical and medication line storage areas for narcotic medications: Does the
institution employ strong medication security controls over narcotic medications 10 0 6 100%
assigned to its storage areas? (7.101)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution properly secure and store nonnarcotic medications in the assigned 4 6 6 40.0%
storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution keep nonnarcotic medication storage locations free of contamination in 1 9 6 10.0%
the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution safely store nonnarcotic medications that have yet to expire in the 10 0 6 100%
assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ and follow
hand hygiene contamination control protocols during medication preparation and 1 5 10 16.7%
medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications for 4 2 10 66.7%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 2 4 10 33.3%
to patients? (7.107)
Pharmacy: Does the institution employ and follow general security, organization, and
1 0 0 100%
cleanliness management protocols in its main and remote pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
1 0 0 100%
medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
1 0 0 100%
medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
1 0 0 100%
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting protocols?
14 0 0 100%
(7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the OIG This is a nonscored test. Please see the indicator
find that medication errors were properly identified and reported by the institution?
for discussion of this test.
(7.998)
Pharmacy: For Information Purposes Only: Do patients in restricted housing units This is a nonscored test. Please see the indicator
have immediate access to their KOP prescribed rescue inhalers and nitroglycerin
for discussion of this test.
medications? (7.999)
Overall percentage (MIT 7): 67.8%
Source: The Office of the Inspector General medical inspection results.
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Table 14. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution: If the patient
had an existing medication order upon arrival, were medications 11 10 4 52.4%
administered or delivered without interruption? (6.003)
For patients transferred out of the facility: Do medication transfer packages
include required medications along with the corresponding transfer-packet 2 0 0 100%
required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
4 3 0 57.1%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 5 2 0 71.4%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 2 7 1 22.2%
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• The institution should develop and implement measures to ensure staff
timely make available and administer chronic care medications and
community hospital discharge medications. Measures should also ensure
timely administering medications to patients temporarily housed at the
institution, patients transferring within the institution, and patients
returning from offsite specialty appointments.
• Nursing leadership should develop and implement measures to ensure
nursing staff document administering medications, patient refusals, and no-
shows in the electronic health record, in accordance with CCHCS’s policies
and procedures.
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Preventive Services
In this indicator, OIG compliance inspectors tested whether the institution offered or
provided cancer screenings, tuberculosis (TB) screenings, influenza vaccines, and other
immunizations. If the department designated the institution as being at high risk for
coccidioidomycosis (Valley Fever), we tested the institution’s performance in transferring
out patients quickly. The OIG rated this indicator solely according to the compliance
score. Case review does not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Adequate (75.0%)
CCI had a mixed performance in preventive services. Staff performed very well in
screening patients annually for TB, offering patients an influenza vaccine for the most
recent influenza season, and offering colorectal cancer screening for patients from ages
45 through 75. The institution transferred out patients who had the highest risk of
contracting coccidioidomycosis (Valley Fever) within the required time frames. However,
staff only sometimes administered TB medications as prescribed, intermittently
monitored patients taking prescribed TB medications, and sporadically offered required
immunizations to chronic care patients. These findings are set forth in the table on the
next page. Based on the overall compliance score result, the OIG rated this indicator
adequate.
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Compliance Score Results
Table 15. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
4 3 0 57.1%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 5 2 0 71.4%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
23 2 0 92.0%
(9.003)
Were all patients offered an influenza vaccination for the most recent
22 2 1 91.7%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the patient
22 3 0 88.0%
offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the patient
N/A N/A N/A N/A
offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was patient
N/A N/A N/A N/A
offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients? (9.008) 2 6 17 25.0%
Are patients at the highest risk of coccidioidomycosis (Valley Fever)
5 0 0 100%
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 75.0%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should develop and implement measures to ensure
nursing staff administer TB medications to patients as prescribed and
monitor the patients according to CCHCS policy.
• Medical leadership should determine the root cause(s) for challenges to
timely providing vaccinations to chronic care patients and should implement
appropriate remedial measures.
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Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care delivered by the
institution’s nurses, including registered nurses (RN), licensed vocational nurses (LVN),
psychiatric technicians (PT), certified nursing assistants (CNA), and medical assistants
(MA). Our clinicians evaluated nurses’ performance in making timely and appropriate
assessments and interventions. We also evaluated the institution’s nurses’ documentation
for accuracy and thoroughness. Clinicians reviewed nursing performance across many
clinical settings and processes, including sick call, outpatient care, care coordination and
management, emergency services, specialized medical housing, hospitalizations,
transfers, specialty services, and medication management. The OIG assessed nursing care
through case review only and performed no compliance testing for this indicator.
When summarizing nursing performance, our clinicians understand that nurses perform
numerous aspects of medical care. As such, specific nursing quality issues are discussed
in other indicators, such as Emergency Services, Specialty Services, and Specialized
Medical Housing.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
Case Review found a significant improvement in nursing performance from Cycle 6 to
Cycle 7, with a notable decrease in the number of overall nursing deficiencies as well as
significant deficiencies. However, our clinicians still identified opportunities for
improvement in nursing assessment and documentation. Considering all factors, the OIG
rated this indicator adequate.
Case Review Results
We reviewed 184 nursing encounters in 44 cases. Of the nursing encounters we reviewed,
76 occurred in the outpatient setting, and 33 were nursing sick call requests. We
identified 75 nursing performance deficiencies, none of which were significant.42
Outpatient Nursing Assessment and Interventions
A critical component of nursing care is the quality of nursing assessment, which includes
both subjective (patient interviews) and objective (observation and examination)
elements. A comprehensive assessment allows nurses to gather essential information
about their patients and develop appropriate interventions.
Nurses generally provided timely and appropriate care. OIG clinicians identified 27
outpatient nursing deficiencies, none of which were significant.43 Although, we identified
42 Deficiencies occurred in cases 1–4, 7–9, 15–23, 27, 29–32, 34, 38, and 40–45.
43 Outpatient nursing deficiencies occurred in cases 1, 2, 8, 9, 15–20, 23, 32, 34, 38, 40–43, and 45.
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no particular trends or patterns of deficiencies, nurses had opportunities for
improvement in performing thorough patient assessments and carrying out appropriate
nursing interventions. The following are examples:
• In case 9, a nurse triaged a health care request for a patient with complaint of
“bad” toenails and medication not working. The nurse requested a follow-up
with the provider within 14 days without performing a face-to-face
assessment of the patient’s toes.
• In case 20, the patient diagnosed with asthma, sleep apnea, and diabetes
complained of excessive sleepiness, no energy, and the inability to stay
awake. The nurse did not listen to the patient’s lungs and did not palpate
pulses and check capillary refill to ensure proper circulation. Additionally,
the nurse did not inquire about the patient’s knowledge and use of a
prescribed CPAP machine, asthma-related incidences, or inhaler use. In
addition, the nurse did not perform peak flows, obtain a blood sugar reading,
or inquire about the patient’s eating habits or daily activity participation.
Furthermore, the nurse did not refer the patient to the primary care provider
for evaluation. However, the severity of this deficiency was mitigated due to
mental health staff also monitoring the patient for the same complaints.
• In case 40, the patient complained of right eye pain with redness and
irritation for three days. The nurse documented right eyelid swelling.
However, the nurse did not inquire about the activity at onset or cause of the
swelling, conduct a visual acuity exam, or describe the appearance of the eye
and cornea (e.g., white, redness, foreign body, injury, or drainage).
Additionally, the nurse did not educate the patient.
Outpatient Nursing Documentation
Complete and accurate nursing documentation is an essential component of patient
care. Without proper documentation, health care staff can overlook changes in
patients’ conditions. Although nurses often documented their assessment findings
and interventions satisfactorily, emergency services showed opportunities for
improvement. This is discussed further in the Emergency Services indicator. The
following are examples of outpatient documentation deficiencies:
• In case 15, the nurse documented the patient ambulated to the clinic after an altercation,
and the nurse completed an injury report. However, the nurse did not document the
assessment findings or whether the patient sustained any injuries in the electronic health
record.
• In cases 2 and 19, the nurses documented the patients refused their
medications; however, both patients were not at the institution and were off-
site at a community emergency room.
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Case Management
OIG clinicians reviewed eight cases in which patients met with a care coordinator.44 Care
coordinators are LVNs who perform duties such as chronic care education. We did not
identify any deficiencies in scheduling or evaluating patients for care management
appointments.
Wound Care
OIG clinicians reviewed five cases involving wound care, dressing changes, PICC line
care, or drain care.45 We identified three cases in which care was not performed as
ordered or in accordance with community standards. These concerns are discussed
further in the Specialized Medical Housing indicator.
Emergency Services
OIG clinicians reviewed 29 urgent or emergent events. Nurses responded promptly to
emergent events and frequently provided good interventions. Although no patterns or
trends were identified, OIG clinicians found opportunities for improvement in nursing
assessment and documentation, which we detail further in the Emergency Services
indicator.
Hospital Returns
OIG clinicians reviewed 13 nursing events in which patients returned from a community
hospital or emergency room. OIG clinicians identified two nursing deficiencies, neither
of which was significant.46 The nurses generally performed good nursing assessments,
which we detail further in the Transfers indicator.
Transfers
OIG clinicians reviewed eight cases that involved transfer-in and transfer-out processes.
Nurses evaluated patients appropriately and initiated provider appointments within
appropriate time frames. However, nurses did not always document pertinent
information when patients transferred out of the institution. Please refer to the Transfers
indicator for further details.
Specialized Medical Housing
OIG clinicians reviewed four cases with a total of 84 events, 28 of which were nursing
encounters. In the OHU, OIG clinicians found nurses generally provided good care.
Please refer to the Specialized Medical Housing indicator for further details.
Specialty Services
OIG clinicians reviewed 19 cases with a total of 113 events, 30 of which included nurse
evaluations of patients prior to a procedure or upon return from an off-site specialist
44 Care coordinator encounters occurred in cases 11-14, 16, 17, 19, and 20.
45 Wound care, dressing changes, PICC line, or renal drain care occurred in cases 2, 19, 21, 23 and 24.
46 Deficiencies occurred in cases 2 and 21.
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appointment. OIG clinicians identified seven minor nursing deficiencies related to
specialty services. Please refer to the Specialty Services indicator for additional details.
Medication Management
OIG clinicians reviewed 126 events involving medication management and
administration. We identified 26 deficiencies, one of which was significant. Nurses
generally administered medications timely and as ordered; however, on three occasions,
medication was not administered to patients prior to or upon return from off-site
specialty appointments. Further details are provided in the Medication Management
indicator.
Clinician On-Site Inspection
Our clinicians toured each facility, which included TTAs, R&R, OHU, medical clinics,
and select medication administration areas. OIG clinicians also conducted interviews
with staff and supervisors. We learned nursing leadership had been in their respective
roles for over two years. Both the chief nurse executive (CNE) and supervising registered
nurse (SRN) III had started with the institution in various nursing roles and had
promoted into their current positions. The CNE reported challenges with morale due to
increased overdose incidents and the recent closures of two of the institution’s facilities
as well as the closure of a nearby prison. The closures resulted in staff transfers and
resignations. She mentioned, although they had lost good talent, she was proud of the
staff, and recently the institution had been highlighted by CCHCS headquarters for
reducing the specialty appointment backlogs. Although the CNE described morale as
poor, interviews with nursing staff and supervisors reflected differently. Nurses in
various roles reported the working environment was “decent” and “great,” and they felt
they had established good rapport with custody staff. Nurses interviewed also felt
supported by their leadership.
The CNE additionally discussed many CCHCS headquarters initiatives, such as offering
COVID-19 vaccines to patients who had previously refused and then reoffering
vaccination to those over the age of 65. In addition, while touring Facility B, our
clinicians observed an in-progress initiative: nurses issuing nasal naloxone and educating
patients regarding the medication’s use for overdoses. OIG clinicians inquired whether
patients had been using the naloxone for the intended purpose. Interviews with
medication line nurses indicated, while they did not have direct knowledge of the patient
actual use, they had not experienced an increase in requests for refills in housing units
for those who had already had them issued in previous months. The nurses indicated this
may be because the patients are using naloxone as intended; however, patients may also
be hesitant to request refills to avoid investigation into the medication’s use. However,
the CNE reported the program had resulted in fewer staff-administered naloxone
medications.
In addition to staff interviews, our clinicians also attended the facility huddles and the
OHU huddle. The huddles were offered remotely and were well attended by staff from
various disciplines. The huddles were organized, and teams discussed patient needs and
were familiar with their patient panels. Our OIG clinicians further had the opportunity to
attend the Facility B Population Management meeting, which was well structured and
provided valuable information regarding specific patient needs.
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Recommendations
• Nursing leadership should determine the challenges preventing nurses from
performing complete assessments and documentation and should implement
remedial measures as appropriate.
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Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of care delivered by the
institution’s providers: physicians, physician assistants, and nurse practitioners. Our
clinicians assessed the institution’s providers’ performance in evaluating, diagnosing,
and managing their patients properly. We examined provider performance across several
clinical settings and programs, including sick call, emergency services, outpatient care,
chronic care, specialty services, intake, transfers, hospitalizations, and specialized
medical housing. We assessed provider care through case review only and performed no
compliance testing for this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
CCI providers delivered acceptable medical care; an improvement compared with Cycle
6. Providers mostly performed well with chronic conditions and emergency clinical
settings, while providing continuity for patients. Providers usually reviewed medical
records carefully and ordered appropriate specialty referrals. However, we found
providers needed improvement with outpatient assessments, caring for OHU patients,
following up with specialists, thoroughly documenting, and sending complete patient
test result notification letters. The majority of the deficiencies did not significantly affect
patient care. After carefully considering all aspects of provider care, the OIG rated this
indicator adequate.
Case Review Results
OIG clinicians reviewed 113 provider encounters and identified 60 deficiencies, 16 of
which were significant.47 In addition, our clinicians examined the quality of care in 20
comprehensive case reviews. Of these 20 cases, we found 18 adequate and two inadequate.
Outpatient Assessment and Decision-Making
Providers generally made appropriate assessments and sound decisions. Most providers
obtained thorough histories, performed pertinent examinations, and developed
reasonable differential diagnoses. Providers typically ordered necessary tests and
specialty referrals. However, case review identified 25 deficiencies related to outpatient
provider assessments, six of which were significant.48 Half of the six deficiencies involved
a patient with poorly controlled diabetes, who was not appropriately managed.49 The
following are three additional examples of poor assessment or decision-making:
47 Deficiencies occurred in cases 1, 2, 8, 13, 15–25, 44, and 45. Significant deficiencies occurred in cases 2, 8, 13,
19, 21, 23, and 44.
48 Deficiencies occurred in cases 1, 8, 13, 15–20, 22, 23, and 25. Significant deficiencies occurred in cases 8, 13,
19, and 23.
49 Deficiencies occurred in case 13.
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• In case 8, the patient complained of neck pain. However, the provider did not
document a detailed history of the pain or perform a neck examination. The
provider also failed to give a clear rationale for diagnosing this patient’s neck
pain as “nerve pain.”
• In case 19, a provider evaluated the patient after hospitalization for a kidney
infection. The hospital staff recommended weekly blood tests; however, the
provider did not order the blood tests and gave no rationale.
• In case 23, the patient had high blood pressure and a thyroid disorder.
Although the patient admitted he had stopped taking his medications, a
provider continued to order the medications for months. The provider also
failed to order follow-up blood pressure checks or thyroid laboratory testing
to reassess whether the medications were still medically indicated.
Outpatient Review of Records
Providers generally reviewed medical records carefully. Case review identified only two
minor deficiencies related to record review as follows:
• In case 1, a provider ordered a lower dose of Suboxone for the patient.50
However, the provider did not review the patient’s medication record to
verify when the last dose was given. As a result, the patient received two
doses of Suboxone on the day of the medication change.
• In case 2, a provider evaluated the patient after a finger laceration. However,
the provider did not document the patient’s tetanus immunization status. As
a result, the patient did not receive a tetanus vaccine booster after his injury.
Emergency Care
TTA providers delivered good patient care. Most providers triaged patients appropriately
and were available for phone consultations with nurses. Case review identified only two
deficiencies, one of which was significant.51 We discuss both deficiencies in the
Emergency Services indicator.
Chronic Care
In most instances, providers appropriately managed patients with chronic health
conditions. In addition to the assessment deficiencies mentioned above, we identified
three deficiencies in which providers did not address all the patient’s chronic conditions
or document them properly in their progress notes.52
50 Suboxone is a medication containing buprenorphine and naloxone. Suboxone is used to treat opioid
dependence and addiction.
51 Deficiencies occurred in cases 1 and 2. A significant deficiency occurred in case 2.
52 Deficiencies occurred in cases 15, 16, and 22.
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Specialized Medical Housing
Providers delivered suboptimal care for OHU patients. Providers completed admission
and discharge documents thoroughly and generally timely. In addition, providers often
evaluated patients after specialty and hospital encounters. However, the primary OHU
provider did not always address specialists’ recommendations and often poorly
documented physical examinations and treatment plans, which lacked thoroughness.53
The providers also tended to focus on the patients’ acute conditions, while deferring their
chronic conditions. Although most of the identified deficiencies were not significant,
they showed a worrisome pattern involving complex patients. We discussed the
deficiencies further in the Specialized Medical Housing indicator.
Specialty Services
CCI providers generally referred and consulted appropriately with off-site and
telemedicine specialists, as well as with eConsult providers.54 However, case review
identified nine deficiencies related to the provider responses to specialty reports, six of
which were significant.55 Provider endorsements of eConsult responses were late or
missing, as in the following two examples:
• In case 13, one provider reviewed the recommendations from an eConsult
endocrinologist over a month after the response was available.
• Also in case 13, another provider received a message about the
endocrinologist’s recommendations but did not respond to the message or
acknowledge the recommendations at the patient’s next appointment.
We also found providers endorsed specialists’ reports but did not follow or address the
recommendations.
• In case 2, the patient had multiple right hand finger fractures. The
orthopedic surgeon recommended orthopedic follow-up in six weeks and
physical therapy. However, a provider did not order physical therapy and did
not order orthopedic specialty follow-up until 14 weeks later.
• In case 13, the patient with diabetes was prescribed diabetic medications. An
endocrinologist had recommended stopping one of the medications as it
could cause low blood sugar. However, a provider continued to refill this
medication.
• In case 23, the patient had surgery for a ruptured Achilles tendon. The
podiatrist recommended the patient use a wheelchair for optimal healing and
not bear weight on his foot or use crutches. However, even after multiple
patient encounters and nurse notifications, the provider did not order a
wheelchair.
53 Deficiencies occurred in cases 21, 44, and 45.
54 eConsult is an electronic specialty consulting service whereby providers can inquire of specialists about
medical questions and receive advice and recommendations for patient care.
55 Deficiencies occurred in cases 2, 8, 13, 19, and 23. Significant deficiencies occurred in cases 2, 8, 13, and 23.
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Potentially dangerous situations can arise when medical staff do not make an effort to
clarify specialists’ recommendations that either are not communicated or are unclear. A
significant example follows:
• In case 8, a neurologist evaluated a patient with seizures. The neurologist
recommended medication changes, instructing the patient’s medical staff to
taper one medication off and to start a second medication. However, the
neurologist did not specify the parameters for tapering the first medication
or starting the second medication. The provider did not clarify the
recommendations with the neurologist but instead ordered a lower dose of
the first medication for one week and a follow-up with the primary provider
in two weeks. As a result, the first medication expired abruptly, rather than
being tapered off.
Documentation Quality
Providers were generally careful to document their patient encounters and nurse
interactions. Case review did not find any evidence of missing progress notes from on-
call providers or of providers cloning past progress notes. However, we identified three
deficiencies related to other missing documentation.
• In case 13, the patient refused a change in medication, but the provider did
not complete an informed refusal form.
• In case 22, a provider evaluated the patient after two specialty appointments.
However, the provider did not include vital signs, a physical examination,
current diagnoses, or treatment plans in their progress note.
• In case 24, a provider canceled a request for services (RFS) for an
ophthalmology specialist.56 However, the provider did not document
discussions with ophthalmology specialist, nurses, or the patient to explain
why the provider canceled the appointment.
Patient Notification Letters
Providers often did not send patient test result notification letters to patients. When they
did, the letters only sometimes contained the four elements required by policy. Please
refer to the Diagnostic Services indicator for details.
Provider Continuity
Provider continuity at CCI was excellent. OIG clinicians did not identify any deficiencies
related to the lack of provider continuity.
Clinician On-Site Inspection
The medical provider staff at CCI was unique at the time of our inspection. The chief
physician and surgeon (CP&S) position was vacant. The CCI providers included on-site
providers (physician and advanced practitioners), one telemedicine physician, and one
56 The request for service (RFS) is a referral order for a specialty consultation.
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registry physician. Even with provider vacancies, morale was positive and united.
Although several providers had been assigned to one yard for a long period, provider
schedules often created the need for cross-coverage. No clinics had a backlog of
appointments, and all eligible providers, including the CME, assisted with the overnight
on-call duties. Staff reported two effects on hiring: another local institution had recently
closed, and two of the five yards at CCI had also closed due to the decreased patient
population. Thus, providers felt uncertain about job security. In addition, CCI’s remote
location may also have contributed to recruitment challenges.
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Recommendations
The OIG offers no recommendations for this indicator.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the specialized medical
housing units. We evaluated the performance of the medical staff in assessing,
monitoring, and intervening for medically complex patients requiring close medical
supervision. Our inspectors also evaluated the timeliness and quality of provider and
nursing intake assessments and care plans. We assessed staff members’ performance in
responding promptly when patients’ conditions deteriorated and looked for good
communication when staff consulted with one another while providing continuity of
care. At the time of our inspection, CCI’s specialized medical housing consisted of an
Outpatient Housing Unit (OHU).
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (48.1%)
In Cycle 7, the OHU was reopened after being temporarily closed in Cycle 6. During
Cycle 7, CCI performed sufficiently in the care of OHU patients. However, both
providers and nurses had opportunities for improvement in performing thorough and
focused physical assessments, implementing relevant interventions, and documenting the
care planned or provided. After reviewing all aspects, the OIG rated the case review
component of this indicator adequate.
Compliance testing showed mixed performance in this indicator. Although staff often
timely completed admission assessments and history with physical examinations, staff
needed improvement in medication administration. The nursing staff also needed to
complete documentation when conducting rounds in the OHU due to a nonfunctional
call light system. Based on the overall compliance score result, the OIG rated the
compliance component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 84 OHU events, which included 34 provider encounters and 28 nursing
encounters. Due to the frequency of nursing and provider contacts in specialized medical
housing, the OIG bundles up to two weeks of patient care into a single event. We
identified 41 deficiencies, three of which were significant.57
Provider Performance
Providers needed improvement in delivering medical care for OHU patients. Compliance
testing showed providers generally completed admission history and physicals without
delay (MIT 13.002, 80.0%). Case review also found providers completed these timely, along
with conducting prompt patient rounds and follow-ups after off-site encounters.
However, we found providers only sometimes completed thorough physical exams,
57 Deficiencies occurred in cases 19, 21, 44, and 45. Significant deficiencies occurred in cases 21 and 44.
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documented clear treatment plans, and addressed specialists’ recommendations. We
identified 16 provider deficiencies, three of which were significant.58 The following are
examples:
• In case 21, the patient initially had an abnormal blood test; subsequently, the
provider referred the patient for a bone marrow biopsy, a painful and invasive
procedure. However, the repeat blood test was normal. In addition, the blood
specialist recommended a face-to-face appointment before the biopsy.
Nevertheless, the bone marrow biopsy was performed with normal results,
indicating the procedure was unnecessary.
• In case 44, the patient had rectal cancer and finished radiation therapy,
resulting in rectal burns. A provider evaluated this patient five times in the
following month but never examined the affected area, even when the patient
complained of rectal pain.
• Also in case 44, after the patient’s final radiation treatment, the radiation
specialist recommended follow-up with the patient’s medical oncologist and
rectal surgeon. A provider endorsed the radiation specialist’s report timely
but did not order either of the follow-up appointments until the provider
received a message from a nurse one month later.
• In case 45, during multiple patient encounters over a two-month period, the
provider conducted patient rounds but failed to document clear treatment
plans.
Nursing Performance
Compliance testing and case review found OHU nurses almost always performed timely
admission assessments (MIT 13.001, 90.0%). OIG clinicians also found OHU nurses
conducted regular rounds and generally provided good care. However, our clinicians
found opportunities for improvement in nursing assessments, interventions, and
documentation. We identified 18 nursing deficiencies, none of which were significant.59
The following are examples:
• In case 19, the patient was admitted to the OHU with a PICC line and renal
drain.60 The OHU nurse did not measure the length of the PICC line,
document the presence of the renal drain and its contents, or describe the
condition of the surrounding dressings.61 Furthermore the nurse inaccurately
documented the location of the renal abscess.
58 Provider deficiencies occurred in cases 21, 44, and 45. Significant deficiencies occurred in cases 21 and 44.
59 Nursing deficiencies occurred in cases 19, 21, 44, and 45.
60 A peripherally inserted central catheter (PICC) provides intravenous access to administer fluids and
medication. A renal drain is a flexible tube that drains urine from the kidney into a bag outside the body.
61 The PICC line is measured to ensure proper placement or determine if it has been dislodged prior to
medication or fluid administration.
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• In case 21, the patient was housed in the OHU after surgical repair of a left
inguinal hernia.62 However, nurses did not perform wound care consistently,
as ordered.
• In case 23, the patient had an order for daily dressing changes for 14 days.
However, due to errors in order entry, the patient’s dressing changes did not
occur at the frequency specified.
• In case 44, on multiple occasions throughout the patient’s OHU admission,
certified nursing assistants (CNAs) documented abnormal vital signs;
however, they did not document if the patient was asymptomatic, recheck the
vital signs, or notify the RN or provider on duty.
Medication Administration
Compliance testing revealed CCI performed poorly in ensuring patients admitted to the
OHU received their medications within required time frames (MIT 13.003, 22.2%). OIG
clinicians identified four deficiencies related to medication management, none of which
were significant.63 These are addressed further in the Medication Management
indicator.
Clinician On-Site Inspection
The OIG clinicians toured CCI’s OHU, attended the huddle, and interviewed the OHU
staff. The huddle was well organized and detailed, with great multidisciplinary staff
participation. Nursing staff reported the OHU had 14 medical beds and two designated
rooms for mental health observation. The institution had no negative pressure rooms. At
the time of the inspection, all 14 medical beds were occupied. The RN reported full
occupancy was typical, with most beds occupied by chronic care patients or patients
returning from the hospital.
The OHU had 24-hour nursing staff with one RN assigned to second watch and one LVN
assigned to first and third watches. All watches also had two assigned CNAs, although on
the day of the tour, only one CNA was present. According to the RN, an additional LVN
assisted on second watch when available. Staff reported having designated providers for
coverage, with after-hours coverage handled by the on-call provider.
During the tour, we observed a call light system; however, it was not functional. Nursing
staff reported they conducted 30-minute rounds since the call light had been inoperable
for quite some time. In addition, staff reported a team approach during daily nursing
rounds, with the CNA and the LVN or RN conducting patient encounters together. The
staff also reported providers conducted rounds daily during weekdays.
The OHU staff reported challenges on first watch with custody staff being unable to open
patient doors without first receiving permission from the watch commander. The staff
reported this could result in a delay of care in an emergent situation. In addition,
62 Inguinal hernia is a protrusion of the abdominal cavity in groin area due to a defect or opening on abdominal
wall.
63 Medication administration deficiencies occurred in cases 21 and 44.
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although staff reported morale was good, they also reported the OHU RN post is not
desirable due to the full census, workload, and limited staffing.
Compliance On-Site Inspection
At the time of the compliance on-site inspection, the OHU did not have a functioning
call light communication system in place (MIT 13.101, N/A). Although the institution had
a local operating procedure (LOP) in an event a call light system was unavailable,
compliance testing revealed the OHU nurse did not perform safety checks as indicated in
the LOP for all patients admitted to the OHU (MIT 13.102, zero).
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Compliance Score Results
Table 16. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Did the registered nurse complete an initial
9 1 0 90.0%
assessment of the patient on the day of admission? (13.001)
Was a written history and physical examination completed within the
8 2 0 80.0%
required time frame? (13.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 2 7 1 22.2%
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call 0 0 1 N/A
system? (13.101)
For specialized health care housing (CTC, SNF, hospice, OHU): Do health
care staff perform patient safety checks according to institution’s local 0 1 0 0
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): 48.1%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the root cause of challenges to
providers completing thorough assessments and clear treatment plans for
specialized medical housing patients and should implement remedial
measures as appropriate.
• The institution should ascertain the causes related to the untimely
availability and administration of medications to specialized medical housing
patients and should implement remedial measures as appropriate.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty services. The OIG
clinicians focused on the institution’s performance in providing needed specialty care.
Our clinicians also examined specialty appointment scheduling, providers’ specialty
referrals, and medical staff’s retrieval, review, and implementation of any specialty
recommendations.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (74.6%)
Case review found patients received good specialty care at CCI. Providers appropriately
ordered specialty and procedure referrals, while nurses usually made sound assessments.
Staff scheduled provider follow-up appointments within requested time frames and
generally addressed recommendations promptly. Although we identified some late
provider endorsements of specialty reports, they did not significantly increase medical
risks for the patients. Considering all factors, the OIG rated the case review component
of this indicator adequate.
Compared with Cycle 6, compliance testing showed CCI generally improved overall in
this indicator. Access to specialists ranged from excellent to poor, depending on the
appointment priority. Preapproved specialty referrals for newly arrived patients
sporadically occurred within recommended time frames. In addition, retrieval of
medium-priority and routine-priority specialty reports and prompt provider
endorsements both needed improvements. Based on the overall compliance score result,
the OIG rated this indicator inadequate.
Case Review and Compliance Testing Results
Our clinicians reviewed 85 events related to specialty services, which included 30 nursing
encounters and 50 specialty consultations or procedures. We identified 22 deficiencies in
this category, only one of which was significant.64
Access to Specialty Services
Compliance testing showed the timeliness of specialty referrals was variable. Although
specialty access for new transfers to CCI was low (MIT 14.010, 40.0%), access for
established patients was outstanding. CCI patients with high-priority (MIT 14.001,
93.3%), medium-priority (MIT 14.004, 86.7%), and routine-priority (MIT 14.007, 100%)
specialty referrals were typically seen within required time frames. Even follow-up
appointments with specialists were always timely for high-priority (MIT 14.003, 100%),
and often timely for routine-priority (MIT 14.009, 80.0%), patients. However, the
64 Deficiencies occurred in cases 2, 11, 19, 21, 22, 44, and 45. A significant deficiency occurred in case 11.
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timeliness of follow-up appointments for medium-priority patients was insufficient (MIT
14.006, 60.0%). Case review found no deficiencies with specialty access.
Nursing Performance
CCI nurses performed sufficiently in assessing patients who returned to the facility from
off-site specialty appointments. OIG clinicians identified seven minor deficiencies
related to specialty services. The following are examples:
• In case 19, the RN performed a COVID-19 symptom screening for the patient
returning from an off-site specialty appointment. The nurse documented the
patient had a nonproductive cough but did not perform a COVID-19 test or
refer the patient for testing as a precaution.
• In case 21, the RN documented the patient’s blood pressure was elevated
upon return from an off-site specialty appointment; however, the nurse did
not obtain vital signs to recheck the elevated blood pressure.
• In case 22, the RN evaluated the patient upon return from a high-priority off-
site specialty consultation. The nurse scheduled the patient for a 14-day
provider follow-up appointment, rather than an appointment within five days
as required.
Provider Performance
CCI providers ordered appropriate specialty consultations and time frames. However,
providers did not always implement specialty recommendations or order the requested
follow-up consultations. We discuss specific examples in the Provider Performance
indicator.
Health Information Management
CCI staff experienced challenges in managing specialty records. As shown in our
compliance testing, staff often retrieved and reviewed high-priority reports timely (MIT
14.002, 80.0%), but staff did not manage medium-priority (MIT 14.005, 40.0%) and routine-
priority (MIT 14.008, 60.0%) reports as well. Case review also found mixed performance.
We found only one missing specialty report and one report that was retrieved but not sent
to a provider for review.65 However, we commonly found late provider endorsements of
specialty reports. Our clinicians identified seven cases involving a late endorsement, one
of which was significant.66 The following are examples:
• In case 11, a provider endorsed an endocrinology eConsult report 22 days
after the report was available.
• In case 22, a provider endorsed an orthopedic report eight days late.
• In case 44, a provider endorsed an off-site radiology report seven days late.
65 Deficiencies occurred in cases 19 and 44.
66 Deficiencies occurred in cases 11, 19, 21, 22, and 44. A significant deficiency occurred in case 11.
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Clinician On-Site Inspection
OIG clinicians discussed the specialty services process with CCI medical and nursing
leadership, specialty nurses, utilization management nurses, and providers. They
reported CCI provided on-site specialty services for optometry, orthotics, and physical
therapy. Some radiology services were also available on-site. Off-site specialists were
generally accessible and flexible in scheduling appointments. Gastroenterology
specialists, in particular, agreed to bundle appointments for procedures to accommodate
multiple CCI patients in a single day. Neurosurgery specialty appointments posed an
occasional challenge due to the more distant location of this specialty. Case review found
RFS denials were relatively common, with providers being asked to use eConsult as an
option. However, providers were not entirely familiar with this resource and its benefits
to the patient and the institution.
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Compliance Score Results
Table 17. Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive the high-priority specialty service within 14 calendar
days of the primary care provider order or the Physician Request for 14 1 0 93.3%
Service? (14.001)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 12 3 0 80.0%
frame? (14.002)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 7 0 8 100%
(14.003)
Did the patient receive the medium-priority specialty service within 15-45
calendar days of the primary care provider order or Physician Request for 13 2 0 86.7%
Service? (14.004)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 6 9 0 40.0%
frame? (14.005)
Did the patient receive the subsequent follow-up to the medium-priority
specialty service appointment as ordered by the primary care provider? 3 2 10 60.0%
(14.006)
Did the patient receive the routine-priority specialty service within 90
calendar days of the primary care provider order or Physician Request for 15 0 0 100%
Service? (14.007)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 9 6 0 60.0%
frame? (14.008)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 4 1 10 80.0%
(14.009)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
2 3 0 40.0%
institution, was the appointment scheduled at the receiving institution
within the required time frames? (14.010)
Did the institution deny the primary care provider’s request for specialty
19 1 0 95.0%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
12 8 0 60.0%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 74.6%
Source: The Office of the Inspector General medical inspection results.
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Table 18. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up visits
39 6 0 86.7%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
24 6 15 80.0%
within five calendar days of the encounter date? (4.002)
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the root cause(s) of challenges to the
timely provision of specialty appointments for newly transferred patients and
should implement remedial measures as appropriate.
• Medical leadership should ascertain the challenges to the timely receipt and
provider review of specialty reports and should implement remedial
measures as appropriate.
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Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care administrative
processes. Our inspectors examined the timeliness of the medical grievance process and
checked whether the institution followed reporting requirements for adverse or sentinel
events and patient deaths. Inspectors checked whether the Emergency Medical Response
Review Committee (EMRRC) met and reviewed incident packages. We investigated and
determined whether the institution conducted required emergency response drills.
Inspectors also assessed whether the Quality Management Committee (QMC) met
regularly and addressed program performance adequately. In addition, our inspectors
determined whether the institution provided training and job performance reviews for its
employees. We checked whether staff possessed current, valid professional licenses,
certifications, and credentials. The OIG rated this indicator solely based on the
compliance score. Case review does not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Adequate (80.3%)
CCI’s overall performance was satisfactory in administrative operations. Although CCI
scored excellently in most applicable tests, it needed improvement in several areas. The
Emergency Medical Response Review Committee (EMRRC) only sporadically completed
the required checklists and reviewed the cases within required time frames. In addition,
staff conducted all medical emergency response drills with incomplete or inconsistent
documentation. Lastly, physician managers only occasionally completed annual
performance appraisals in a timely manner. These findings are set forth in the table on
the next page. Based on the overall compliance score result, the OIG rated this indicator
adequate.
Compliance Testing Results
Nonscored Results
At CCI, the OIG did not have any applicable adverse sentinel events requiring root cause
analysis during our inspection period (MIT 15.001).
We obtained CCHCS Mortality Case Review reporting data. In our inspection, for four
patients, we found no evidence in the submitted documentation the preliminary mortality
reports had been completed. These reports were overdue at the time of the OIG’s
inspection. (MIT 15.998).
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Compliance Score Results
Table 19. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the This is a nonscored test. Please refer to the
institution meet RCA reporting requirements? (15.001) discussion in this indicator.
Did the institution’s Quality Management Committee (QMC) meet
6 0 0 100%
monthly? (15.002)
For Emergency Medical Response Review Committee (EMRRC) reviewed
cases: Did the EMRRC review the cases timely, and did the incident
3 7 0 30.0%
packages the committee reviewed include the required documents?
(15.003)
For institutions with licensed care facilities: Did the Local Governing Body
(LGB) or its equivalent meet quarterly and discuss local operating N/A N/A N/A N/A
procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during each
watch of the most recent quarter, and did health care and custody staff 0 3 0 0
participate in those drills? (15.101)
Did the responses to medical grievances address all of the patients’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial patient death reports to the
4 0 0 100%
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
10 0 0 100%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
2 4 0 33.3%
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 10 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR), Basic Life
Support (BLS), and Advanced Cardiac Life Support (ACLS) certifications? 2 0 1 100%
(15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy maintain a 6 0 1 100%
valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
Agency (DEA) registration certificates, and did the pharmacy maintain valid 1 0 0 100%
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
1 0 0 100%
onboarding and clinical competency training? (15.110)
Did the CCHCS Death Review Committee process death review reports
This is a nonscored test. Please refer to the
timely? Effective 05/2022: Did the Headquarters Mortality Case Review
discussion in this indicator.
process mortality review reports timely? (15.998)
What was the institution’s health care staffing at the time of the OIG This is a nonscored test. Please refer to Table 3
medical inspection? (15.999) for CCHCS-provided staffing information.
Overall percentage (MIT 15): 80.3%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no recommendations for this indicator.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with stakeholders to review
CCHCS policies and procedures, relevant court orders, and guidance developed by the
American Correctional Association. We also reviewed professional literature on
correctional medical care; reviewed standardized performance measures used by the
health care industry; consulted with clinical experts; and met with stakeholders from the
court, the receiver’s office, the department, the Office of the Attorney General, and the
Prison Law Office to discuss the nature and scope of our inspection program. With input
from these stakeholders, the OIG developed a medical inspection program that evaluates
the delivery of medical care by combining clinical case reviews of patient files, objective
tests of compliance with policies and procedures, and an analysis of outcomes for certain
population-based metrics.
We rate each of the quality indicators applicable to the institution under inspection based
on case reviews conducted by our clinicians or compliance tests conducted by our
registered nurses. Figure A–1 below depicts the intersection of case review and
compliance.
Figure A–1. Inspection Indicator Review Distribution for CCI
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Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the recommendation of
its stakeholders, which continues in the Cycle 7 medical inspections. Below, Table A–1
provides important definitions that describe this process.
Table A–1. Case Review Definitions
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The OIG eliminates case review selection bias by sampling using a rigid methodology.
No case reviewer selects the samples he or she reviews. Because the case reviewers are
excluded from sample selection, there is no possibility of selection bias. Instead,
nonclinical analysts use a standardized sampling methodology to select most of the case
review samples. A randomizer is used when applicable.
For most basic institutions, the OIG samples 20 comprehensive physician review cases.
For institutions with larger high-risk populations, 25 cases are sampled. For the
California Health Care Facility, 30 cases are sampled.
Case Review Sampling Methodology
We obtain a substantial amount of health care data from the inspected institution and
from CCHCS. Our analysts then apply filters to identify clinically complex patients with
the highest need for medical services. These filters include patients classified by CCHCS
with high medical risk, patients requiring hospitalization or emergency medical services,
patients arriving from a county jail, patients transferring to and from other departmental
institutions, patients with uncontrolled diabetes or uncontrolled anticoagulation levels,
patients requiring specialty services or who died or experienced a sentinel event
(unexpected occurrences resulting in high risk of, or actual, death or serious injury),
patients requiring specialized medical housing placement, patients requesting medical
care through the sick call process, and patients requiring prenatal or postpartum care.
After applying filters, analysts follow a predetermined protocol and select samples for
clinicians to review. Our physician and nurse reviewers test the samples by performing
comprehensive or focused case reviews.
Case Review Testing Methodology
An OIG physician, a nurse consultant, or both review each case. As the clinicians review
medical records, they record pertinent interactions between the patient and the health
care system. We refer to these interactions as case review events. Our clinicians also
record medical errors, which we refer to as case review deficiencies.
Deficiencies can be minor or significant, depending on the severity of the deficiency. If a
deficiency caused serious patient harm, we classify the error as an adverse event. On the
next page, Figure A–2 depicts the possibilities that can lead to these different events.
After the clinician inspectors review all the cases, they analyze the deficiencies, then
summarize their findings in one or more of the health care indicators in this report.
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Figure A–2. Case Review Testing
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Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and compliance
inspectors. Analysts follow a detailed selection methodology. For most compliance
questions, we use sample sizes of approximately 25 to 30. Figure A–3 below depicts the
relationships and activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT) questions to
determine the institution’s compliance with CCHCS policies and procedures. Our nurse
inspectors assign a Yes or a No answer to each scored question.
OIG headquarters nurse inspectors review medical records to obtain information,
allowing them to answer most of the MIT questions. Our regional nurses visit and
inspect each institution. They interview health care staff, observe medical processes, test
the facilities and clinics, review employee records, logs, medical grievances, death
reports, and other documents, and obtain information regarding plant infrastructure and
local operating procedures.
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Scoring Methodology
Our compliance team calculates the percentage of all Yes answers for each of the
questions applicable to a particular indicator, then averages the scores. The OIG
continues to rate these indicators based on the average compliance score using the
following descriptors: proficient (85.0 percent or greater), adequate (between 84.9 percent
and 75.0 percent), or inadequate (less than 75.0 percent).
Indicator Ratings and the Overall Medical
Quality Rating
The OIG medical inspection unit individually examines all the case review and
compliance inspection findings under each specific methodology. We analyze the case
review and compliance testing results for each indicator and determine separate overall
indicator ratings. After considering all the findings of each of the relevant indicators, our
medical inspectors individually determine the institution’s overall case review and
compliance ratings.
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Appendix B: Case Review Data
Table B–1. CCI Case Review Sample Sets
Sample Set Total
CTC/OHU 2
Death Review/Sentinel Events 2
Diabetes 4
Emergency Services – CPR 5
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 4
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 12
Specialty Services 4
45
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Table B–2. CCI Case Review Chronic Care Diagnoses
Sample Set Total
Anemia 1
Anticoagulation 2
Arthritis/Degenerative Joint Disease 1
Asthma 3
COPD 1
Cancer 3
Cardiovascular Disease 1
Chronic Kidney Disease 1
Chronic Pain 5
Cirrhosis/End Stage Liver Disease 4
Deep Vein Thrombosis/Pulmonary Embolism 1
Diabetes 10
Gastroesophageal Reflux Disease 7
Hepatitis C 19
Hyperlipidemia 8
Hypertension 16
Mental Health 25
Migraine Headaches 1
Seizure Disorder 2
Substance Abuse 22
Thyroid Disease 2
135
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Table B–3. CCI Case Review Events by Program
Diagnosis Total
Diagnostic Services 157
Emergency Care 54
Hospitalization 21
Intrasystem Transfers In 6
Intrasystem Transfers Out 7
Outpatient Care 319
Specialized Medical Housing 84
Specialty Services 115
763
Table B–4. CCI Case Review Sample Summary
Sample Set Total
MD Reviews Detailed 20
MD Reviews Focused 2
RN Reviews Detailed 12
RN Reviews Focused 25
Total Reviews 59
Total Unique Cases 45
Overlapping Reviews (MD & RN) 14
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Appendix C: Compliance Sampling Methodology
California Correctional Institution
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least one
Patients condition per patient — any risk level)
• Randomize
MIT 1.002 Nursing Referrals 25 OIG Q: 6.001 • See Transfers
MITs 1.003 – 006 Nursing Sick Call 30 Clinic • Clinic (each clinic tested)
(6 per clinic) Appointment List • Appointment date (2 – 9 months)
• Randomize
MIT 1.007 Returns From 5 OIG Q: 4.005 • See Health Information Management
Community (Medical Records) (returns from
Hospital community hospital)
MIT 1.008 Specialty Services 45 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 6 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001 – 003 Radiology 10 Radiology Logs • Appointment date
(90 days – 9 months)
• Randomize
• Abnormal
MITs 2.004 – 006 Laboratory 10 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 0 Quest • Appt. date (90 days – 9 months)
• Order name (CBC, BMP, or CMPs only)
• Randomize
• Abnormal
MITs 2.010 – 012 Pathology 10 InterQual • Appt. date (90 days – 9 months)
• Service (pathology-related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 30 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 IPs for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 IPs for each question
MIT 4.003 Hospital Discharge 5 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 IPs selected
MIT 4.004 Scanning Accuracy 24 Documents for • Any misfiled or mislabeled document
any tested identified during
incarcerated OIG compliance review
person (24 or more = No)
MIT 4.005 Returns From 5 CADDIS off-site • Date (2 – 8 months)
Community Hospital admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101 – 105 Clinical Areas 14 OIG inspector • Identify and inspect all on-site clinical
MITs 5.107 – 111 on-site review areas
Transfers
MITs 6.001 – 003 Intrasystem Transfers 25 SOMS • Arrival date (3 – 9 months)
• Arrived from (another departmental
facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 2 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 • See Access to Care
Medication • At least one condition per patient —
any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of IPs tested in
MIT 7.001
MIT 7.003 Returns From 5 OIG Q: 4.005 • See Health Information Management
Community Hospital (Medical Records) (returns from
community hospital)
MIT 7.004 RC Arrivals — N/A at this OIG Q: 12.001 • See Reception Center
Medication Orders institution
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2 – 8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 10 SOMS • Date of transfer (2– 8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101 – 103 Medication Storage Varies OIG inspector • Identify and inspect clinical & med
Areas by test on-site review line areas that store medications
MITs 7.104 – 107 Medication Varies OIG inspector • Identify and inspect on-site clinical
Preparation and by test on-site review areas that prepare and administer
Administration Areas medications
MITs 7.108 – 111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 14 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication error
reports (recent 12 months)
MIT 7.999 Restricted Unit 10 On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications medication listing medications for IPs housed in
restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001 – 007 Recent Deliveries N/A at this OB Roster • Delivery date (2 – 12 months)
institution • Most recent deliveries (within date
range)
Pregnant Arrivals N/A at this OB Roster • Arrival date (2 – 12 months)
institution • Earliest arrivals (within date range)
Preventive Services
MITs 9.001 – 002 TB Medications 7 Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months
or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior to
Annual Screening inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior to
Vaccinations inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior to
Screening inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior to
institution inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs. prior to
institution inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require vaccination(s)
MIT 9.009 Valley Fever 5 Cocci transfer • Reports from past 2 – 8 months
status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001 – 007 RC N/A at this SOMS • Arrival date (2 – 8 months)
institution • Arrived from (county jail, return from
parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001 – 003 Specialized Health 10 CADDIS • Admit date (2 – 8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of 5 days)
• Rx count
• Randomize
MITs 13.101 – 102 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001 – 003 High-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care / addiction
medication, narcotic treatment
program, and transgender services
• Randomize
MITs 14.004 – 006 Medium-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care/addiction
medication, narcotic treatment
program, and transgender services
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Specialty Services (continued)
MITs 14.007 – 009 Routine-Priority 15 Specialty Services • Approval date (3 – 9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C, HIV,
orthotics, gynecology, consult to
public health/Specialty RN, dialysis,
ECG 12-Lead (EKG), mammogram,
occupational therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, radiology,
follow-up wound care/addiction
medication, narcotic treatment
program, and transgender services
• Randomize
MIT 14.010 Specialty Services 5 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – 012 Denials 20 InterQual • Review date (3 – 9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events events report (2 – 8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC 10 EMRRC meeting • Monthly meeting minutes
minutes (6 months)
MIT 15.004 LGB N/A at this LGB meeting • Quarterly meeting minutes
institution minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
MIT 15.103 Death Reports 4 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
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Quality Sample Category No. of Data Source Filters
Indicator Samples
Administrative Operations (continued)
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 6 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 10 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site certification • All staff
Response tracking logs • Providers (ACLS)
Certifications • Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
MIT 15.109 Pharmacy and All On-site listing of • All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
document
MIT 15.110 Nursing Staff New All Nursing staff • New employees (hired within last
Employee training logs 12 months)
Orientations
MIT 15.998 CCHCS Mortality 4 OIG summary log: • Between 35 business days &
Case Review deaths 12 months prior
• California Correctional Health Care
Services mortality reviews
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California Correctional Health Care Services’
Response
February 3, 2025
Amarik Singh, Inspector General
Office of the Inspector General
10111 Old Placerville Road, Suite 110
Sacramento, CA 95827
Dear Ms. Singh:
California Correctional Health Care Services has reviewed the draft Medical Inspection Report
for California Correctional Institution conducted by the Office of the Inspector General from
March 2023 to August 2023. Thank you for preparing the report. While CCHCS disagrees with the
findings for the compliance portion of the OIG Inspection for California Correctional Institution,
we understand that the OIG is forming a workgroup to revise the Medical Inspection Tool to
reduce or eliminate subjectivity and complex, compound questions that make it difficult for
CCHCS to determine areas of policy non-compliance. CCHCS looks forwardto participating in
such efforts and urges the OIG to begin the process as soon as possible.
If you have any questions or concerns, please contact me at (916) 691-3747.
Sincerely,
DeAnna Gouldy
Deputy Director
Policy and Risk Management Services
California Correctional Health Care Services
cc: Diana Toche, D.D.S., Undersecretary, Health Care Services, CDCR
Clark Kelso, Receiver
Jeff Macomber, Secretary, CDCR
Directors, CCHCS
Roscoe Barrow, Chief Counsel, CCHCS Office of Legal Affairs
Renee Kanan, M.D., Deputy Director, Medical Services, CCHCS
Barbara Barney-Knox, R.N., Deputy Director, Nursing Services, CCHCS
Annette Lambert, Deputy Director, Quality Management, CCHCS
Robin Hart, Associate Director, Risk Management Branch, CCHCS
Regional Executives, Region IV, CCHCS
Chief Executive Officer, CCI
Heather Pool, Chief Assistant Inspector General, OIG
Doreen Pagaran, R.N., Nurse Consultant Program Review, OIG
Amanda Elhardt, Report Coordinator, OIG
P.O. Box 588500
Elk Grove, CA 95758
Office of the Inspector General, State of California Inspection Period: March 2023 – August 2023 Report Issued: February 2025
Cycle 7
Medical Inspection Report
for
California Correctional Institution
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
STATE of CALIFORNIA
February 2025
OIG