OIG
California Rehabilitation Center Cycle 7 Medical Inspection Report
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Cycle 7, California Rehabilitation Center | iii
Contents
Illustrations iv
Introduction 1
Summary: Ratings and Scores 3
Medical Inspection Results 5
Deficiencies Identified During Case Review 5
Case Review Results 5
Compliance Testing Results 6
Institution-Specific Metrics 7
Population-Based Metrics 9
HEDIS Results 9
Recommendations 11
Indicators 14
Access to Care 14
Diagnostic Services 21
Emergency Services 26
Health Information Management 31
Health Care Environment 37
Transfers 43
Medication Management 49
Preventive Services 57
Nursing Performance 60
Provider Performance 65
Specialized Medical Housing 70
Specialty Services 75
Administrative Operations 81
Appendix A: Methodology 85
Case Reviews 86
Compliance Testing 89
Indicator Ratings and the Overall Medical Quality Rating 90
Appendix B: Case Review Data 91
Appendix C: Compliance Sampling Methodology 95
California Correctional Health Care Services’ Response 103
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | iv
Illustrations
Tables
1. CRC Summary Table: Case Review Ratings and Policy Compliance Scores 4
2. CRC Master Registry Data as of March 2023 7
3. CRC Health Care Staffing Resources as of March 2023 8
4. CRC Results Compared With State HEDIS Scores 10
5. Access to Care 18
6. Other Tests Related to Access to Care 19
7. Diagnostic Services 24
8. Health Information Management 34
9. Other Tests Related to Health Information Management 35
10. Health Care Environment 41
11. Transfers 46
12. Other Tests Related to Transfers 47
13. Medication Management 54
14. Other Tests Related to Specialized Services 55
15. Preventive Services 58
16. Specialized Medical Housing 73
17. Specialized Services 78
18. Other Tests Related to Specialized Services 79
19. Administrative Operations 82
A–1. Case Review Definitions 86
B–1. CRC Case Review Sample Sets 91
B–2. CRC Case Review Chronic Care Diagnoses 92
B–3. CRC Case Review Events by Program 93
B–4. CRC Case Review Sample Summary 93
Figures
A–1. Inspection Indicator Review Distribution for CRC 85
A–2. Case Review Testing 88
A–3. Compliance Sampling Methodology 89
Photographs
1. Triage and Treatment Area Waiting Room 37
2. Expired Medical Supplies Dated December 2022 38
3. Medical Supplies Stored in the Same Area as Cleaning Supplies 38
4. Clinic Floor Damaged and Unsanitary 39
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 1
Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the Inspector
General (the OIG) is responsible for periodically reviewing and reporting on the delivery
of the ongoing medical care provided to incarcerated people1 in the California
Department of Corrections and Rehabilitation (the department).2
In Cycle 7, the OIG continues to apply the same assessment methodologies used in
Cycle 6, including clinical case review and compliance testing. Together, these methods
assess the institution’s medical care on both individual and system levels by providing an
accurate assessment of how the institution’s health care systems function regarding
patients with the highest medical risk, who tend to access services at the highest rate.
Through these methods, the OIG evaluates the performance of the institution in
providing sustainable, adequate care. We continue to review institutional care using
15 indicators as in prior cycles.3
Using each of these indicators, our compliance inspectors collect data in answer to
compliance- and performance-related questions as established in the medical inspection
tool (MIT). In addition, our clinicians complete document reviews of individual cases and
also perform on-site inspections, which include interviews with staff. The OIG
determines a total compliance score for each applicable indicator and considers the MIT
scores in the overall conclusion of the institution’s compliance performance.
In conducting in-depth quality-focused reviews of randomized cases, our case review
clinicians examine whether health care staff used sound medical judgment in the course
of caring for a patient. In the event we find errors, we determine whether such errors
were clinically significant or led to a significantly increased risk of harm to the patient.
At the same time, our clinicians consider whether institutional medical processes led to
identifying and correcting individual or system errors, and we examine whether the
institution’s medical system mitigated the error. The OIG rates each applicable indicator
proficient, adequate, or inadequate, and considers each rating in the overall conclusion of
the institution’s health care performance.
In contrast to Cycle 6, the OIG will provide individual clinical case review ratings and
compliance testing scores in Cycle 7, rather than aggregate all findings into a single
overall institution rating. This change will clarify the distinctions between these differing
quality measures and the results of each assessment.
1 In this report, we use the terms patient and patients to refer to incarcerated people.
2 The OIG’s medical inspections are not designed to resolve questions about the constitutionality of care, and
the OIG explicitly makes no determination regarding the constitutionality of care that the department provides
to its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer selected Healthcare
Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 2
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
Rehabilitation Center, the institution had not 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 August 2022 to January 2023.4
4 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The case reviews
include emergency cardiopulmonary resuscitation (CPR) reviews in May 2022.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 3
Summary: Ratings and Scores
We completed the Cycle 7 inspection of CRC in June 2023. OIG inspectors monitored the
institution’s delivery of medical care that occurred between August 2022 and January 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 CRC adequate. quality at CRC inadequate.
OIG case review clinicians (a team of physicians and nurse consultants) reviewed
45 cases, which contained 881 patient-related events. They performed quality control
reviews; their subsequent collective deliberations ensured consistency, accuracy, and
thoroughness. Our OIG clinicians acknowledged institutional structures that catch and
resolve mistakes that may occur throughout the delivery of care. After examining the
medical records, our clinicians completed a follow-up on-site inspection in June 2023 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. Our physicians found no adverse deficiencies during this inspection.
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 358 patient records and 1,107 data points
and used the data to answer 89 policy questions. In addition, we observed CRC’s
processes during an on-site inspection in April 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 CRC.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 4
We list the individual indicators and ratings applicable for this institution in Table 1 below.
Table 1. CRC Summary Table: Case Review Ratings and Policy Compliance Scores
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
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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 CRC 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 CRC. Of these 10 indicators, OIG clinicians rated one proficient,
nine adequate, and zero inadequate. 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
rated adequate and two were rated inadequate. In the 881 events reviewed, we identified
179 deficiencies, 16 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 CRC:
• Staff performed well in retrieving and endorsing laboratory
diagnostic reports timely.
• Staff performed well in chronic care management of diabetes as the
providers and nursing staff collaborated with case management.
• Staff provided good access to providers and nurses for patients.
Our clinicians found the following weaknesses at CRC:
• Nurses did not consistently perform complete and relevant patient
assessments during outpatient and emergency care.
• Providers did not always endorse specialty reports timely and did not
create the patient notification letters with complete information.
• Staff encountered difficulties in providing continuity of medications
when patients were discharged from community hospitals.
6 For a further discussion of an adverse event, see Table A–1.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 6
Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable to CRC. Of these
10 indicators, our compliance inspectors rated one proficient, two adequate, and seven
inadequate. We tested policy compliance in Health Care Environment, Preventive
Services, and Administrative Operations as these indicators do not have a case review
component.
CRC showed a high rate of policy compliance in the following areas:
• Staff performed well in scanning, labeling, and entering community
hospital discharge reports, specialty service reports, and health care
service requests into patients’ electronic medical records within
required time frames.
• Nurses reviewed health care services request forms and conducted
face-to-face encounters within required time frames.
• Providers evaluated patients returning from outside community
hospitals within required time frames.
CRC showed a low rate of policy compliance in the following areas:
• Staff did not consistently provide radiology, routine, and STAT
laboratory services within the specified time frames.
• Providers often did not communicate results of diagnostic tests
timely. Most patient letters communicating these test results were
missing the date of the diagnostic service, the date of the results, and
whether the results were within normal limits.
• Staff frequently did not maintain medication continuity for chronic
care patients, patients discharged from the hospital, patients
admitted to the specialized medical housing unit, and patients who
had a temporary layover at CRC.
• Staff did not perform well in ensuring approved specialty services
were provided within specified time frames.
• Health care staff did not consistently follow universal hand hygiene
precautions during patient encounters.
• Nurses did not regularly inspect emergency response bags and
treatment carts.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 7
Institution-Specific Metrics
California Rehabilitation Center (CRC), located in the city of Norco in Riverside County,
is a medium Level II correctional facility, which houses more than 3,700 inmates. The
institution runs multiple clinics in which medical staff handle nonurgent requests for
health care services. CRC also treats patients requiring urgent or emergent care in its
triage and treatment area (TTA) and houses patients who need assistance with activities
of daily living in its outpatient housing unit (OHU). In addition, all patients who arrive at
or depart from the institution are screened in the prison’s receiving and release (R&R)
clinic. CRC has been designated by California Correctional Health Care Services
(CCHCS) as a basic care institution. Basic institutions are located in rural areas, away from
tertiary care centers and specialty care providers whose services would likely be used
frequently by higher-risk patients. Basic institutions have the capability to provide only
limited specialty medical services and consultations for a patient population that is
generally healthy. As of July 16, 2024, the department reports on its public tracker
that 67 percent of CRC’s incarcerated population is fully vaccinated for COVID-19 while
65 percent of CRC’s staff is fully vaccinated for COVID-19.7
In March 2023, the Health Care Services Master Registry showed that CRC had a total
population of 2,992. A breakdown of the medical risk level of the CRC population as
determined by the department is set forth in Table 2 below.8
Table 2. CRC Master Registry Data as of March 2023
Medical Risk Level Number of Patients Percentage*
High 1 36 1.2%
High 2 117 3.9%
Medium 1,375 46.0%
Low 1,464 48.9%
Total 2,992 100.0%
* Percentages may not total 100% due to rounding.
Source: Data for the population medical risk level were obtained from
the CCHCS Master Registry dated 3-24-23.
7 For more information, see the department’s statistics on its website page titled Population COVID‑19
Tracking.
8 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
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According to staffing data the OIG obtained from California Correctional Health Care
Services (CCHCS), as identified in Table 3 below, CRC had no vacant executive leadership
positions, 2.5 primary care provider vacancies, 0.2 nursing supervisor vacancies, and 6.0
nursing staff vacancies.
Table 3. CRC Health Care Staffing Resources as of March 2023
Executive Primary Care Nursing Nursing
Positions Leadership * Providers Supervisors Staff † Total
Authorized Positions 5.0 7.5 10.7 78.1 101.3
Filled by Civil Service 5.0 5.0 10.5 72.1 92.6
Vacant 0 2.5 0.2 6.0 8.7
Percentage Filled by Civil Service 100% 66.7% 98.1% 92.3% 91.4%
Filled by Telemedicine 0 0 0 0 0
Percentage Filled by Telemedicine 0 0 0 0 0
Filled by Registry 0 0.67 0 13.0 13.67
Percentage Filled by Registry 0 8.9% 0 16.6% 13.5%
Total Filled Positions 5.0 5.67 10.5 85.1 106.27
Total Percentage Filled 100% 75.6% 98.1% 109.0% 104.9%
Appointments in Last 12 Months 1.0 1.0 6.0 15.0 23.0
Redirected Staff 0 0 0 0 0
Staff on Extended Leave ‡ 0 1.0 0 7.0 8.0
Adjusted Total: Filled Positions 5.0 4.67 10.5 78.1 98.27
Adjusted Total: Percentage Filled 100% 62.3% 98.1% 100% 97.0%
* 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 February 1, 2023, from California Correctional
Health Care Services.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 9
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 CRC’s performance with population-based metrics to assess the
macroscopic view of the institution’s health care delivery. Currently, only one HEDIS
measure is available for review: poor HbA1c control, which measures the percentage of
diabetic patients who have poor blood sugar control. CRC’s results compared favorably
with those found in State health plans for this measure. 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)— CRC’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. CRC had a 61 percent influenza
immunization rate for adults 18 to 64 years old and an 83 percent influenza immunization
rate for adults 65 years of age and older.9 The pneumococcal vaccination rate was 67
percent.10
Cancer Screening
Statewide comparative data were not available for colorectal cancer screening; however,
we include these data for informational purposes. CRC had an 85 percent colorectal
cancer screening rate.
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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Cycle 7, California Rehabilitation Center | 10
Table 4. CRC Results Compared With State HEDIS Scores
CRC California California
Kaiser Kaiser
Cycle 7 California NorCal SoCal
HEDIS Measure Results * Medi-Cal † Medi-Cal † Medi-Cal †
HbA1c Screening 100% – – –
Poor HbA1c Control (> 9.0%) ‡,§ 6% 38% 28% 20%
HbA1c Control (< 8.0%) ‡ 84% – – –
Blood Pressure Control (< 140/90) ‡ 93% – – –
Eye Examinations 89% – – –
Influenza – Adults (18 – 64) 61% – – –
Influenza – Adults (65 +) 83% – – –
Pneumococcal – Adults (65 +) 67% – – –
Colorectal Cancer Screening 85% – – –
Notes and Sources
* Unless otherwise stated, data were collected in April 2023 by reviewing medical records from a sample of
CRC’s population of applicable patients. These random statistical sample sizes were based on a 95 percent
confidence level with a 15 percent maximum margin of error.
† HEDIS Medi-Cal data were obtained from the California Department of Health Care Services publication
titled Medi-Cal Managed Care External Quality Review Technical Report, dated July 1, 2021 – June 30, 2022
(published April 2023); https://www.dhcs.ca.gov/dataandstats/reports/Documents/CA2021-22-MCMC-
EQR-TR-VOL1-F1.pdf.
‡ For this indicator, the entire applicable CRC 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.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 11
Recommendations
As a result of our assessment of CRC’s performance, we offer the following
recommendations to the department:
Access to Care
• Medical leadership should determine the cause of challenges in
timely providing chronic care follow-up appointments, follow-up
appointments for transfer-in patients, and follow-up specialty
appointments with providers. Leadership should implement
remedial measures as appropriate.
Diagnostic Services
• The department should consider developing strategies, such as
potentially an electronic solution, to ensure providers generate
letters communicating results to their patients, and that the letters
include all elements as required by policy.
• Medical leadership should ascertain causes related to the untimely
provision of radiology services, the root cause(s) of challenges in
reviewing and endorsing radiology reports timely and implement
remedial measures as appropriate.
• Medical leadership should determine the root cause of challenges
with collecting, receiving, and notifying STAT laboratory results and
implement remedial measures as appropriate.
Emergency Services
• Leadership should determine the root cause of challenges for
immediate activation of the 9-1-1 system for emergent patients
needing a higher level of care and implement remedial measures as
appropriate.
• Nursing leadership should determine the root cause of challenges
that prevent nurses from performing necessary reassessments as
clinically indicated for patients with urgent symptoms in the TTA
and implement remedial measures as appropriate.
Health Care Environment
• Medical leadership should determine the root cause for staff not
following all required universal hand hygiene precautions and take
necessary remedial measures.
• Nursing leadership should determine the root cause for staff not
ensuring clinic examination rooms contain essential core medical
equipment and verifying that staff follow equipment and medical
supply management protocols and take necessary remedial measures.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 12
• Executive leadership should determine the root cause for staff not
ensuring clean and sanitary clinics, medical storage rooms, and
medication rooms, and take necessary remedial measures.
• Nursing leadership should determine the root cause for staff not
ensuring the emergency medical response bags (EMRBs) are
regularly inventoried and sealed, as well as staff failing to properly
complete the monthly logs and take necessary remedial measures.
Medication Management
• Medical and nursing leadership should analyze the challenges in
ensuring that chronic care, hospital discharge, and en route patients
receive their medications timely and without interruption and
implement remedial measures as appropriate.
Preventive Services
• Nursing leadership should determine the challenges in ensuring
nursing staff properly document the monitoring of patients taking
TB medications and take remedial measures as appropriate.
• Medical leadership should analyze the challenges related to the
untimely provision of preventive vaccines to chronic care patients
and implement remedial measures as appropriate.
Nursing Performance
• Nursing leadership should determine the root cause of challenges
preventing nurses from performing complete assessments and
implement remedial measures as appropriate.
Provider Performance
• Medical leadership should analyze the challenges in provider
documentation for patient-related calls, emergency phone calls,
nurse co-consultations, provider orders, and management plans in
the EHRS and implement remedial measures as indicated.
Specialized Medical Housing
• Medical leadership should determine the challenges in providers
completing the OHU history and physical examination within the
time frame required by CCHCS policy, and implement remedial
measures as indicated.
Specialty Services
• Medical leadership should identify the cause of challenges in timely
completing follow-up specialty appointments and high-priority
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 13
specialty appointments and should continue to implement remedial
measures as appropriate.
• Medical leadership should determine the cause of challenges with
timely provider review of specialty consultation reports and should
implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 14
Access to Care
In this indicator, OIG inspectors evaluated the institution’s performance in providing
patients with timely clinical appointments. Our inspectors reviewed scheduling and
appointment timeliness for newly arrived patients, sick calls, and nurse follow-up
appointments. We examined referrals to primary care providers, provider follow-ups, and
specialists. Furthermore, we evaluated the follow-up appointments for patients who
received specialty care or returned from an off-site hospitalization.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Proficient Adequate (79.7%)
In this cycle, case review found CRC provided excellent access to care, improving from
Cycle 6. Staff almost always completed appointments timely, including appointments
with clinic providers, nurses, and specialty services. Staff also provided excellent provider
access for patients in OHU, and follow-up after hospitalizations, urgent or emergent
events, and transferring into CRC. Considering all factors, the OIG rated the case review
component of this indicator proficient.
Compliance testing showed CRC performed sufficiently in providing access to care. Staff
performed excellently with nurses’ reviews of patient sick call requests, completing face-
to-face nurse encounters, providing follow-up sick call appointments, and offering
provider follow-ups for patients returning from hospitalization. However, CRC scored
low for completing chronic care follow-up appointments with providers and provider
appointments for patients who transferred into the institution or returned from specialty
services. Factoring in all the information, the OIG rated the compliance testing
component of this indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 157 provider, nursing, TTA, specialty, and hospital events
requiring the institution to generate appointments. We identified three deficiencies
relating to Access to Care, two of which were significant.11
Access to Care Providers
Access to clinic providers is an integral part of patient care in health care delivery. CRC
did not perform well in providing chronic care follow-up appointments with clinic
providers. Compliance testing showed chronic care face-to-face follow-up appointments
occurred intermittently (MIT 1.001, 68.0%); however, nurse-to-provider follow-up
appointments occurred often (MIT 1.005, 87.5%), and sick call follow-up appointments
always occurred timely (MIT 1.006, 100%). Due to movement restrictions related to the
COVID-19 pandemic, OIG clinicians considered most cases of provider chart reviews for
11 Deficiencies occurred in cases 14, 21, and 45. Significant deficiencies occurred in cases 14 and 21.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 15
nonurgent, low-risk, or medium-risk chronic care appointments to be an acceptable
alternative to face-to-face or telephonic encounters. OIG clinicians reviewed 69 clinic
provider encounters and did not find any deficiencies.
Access to Specialized Medical Housing Providers
CRC had a mixed performance in providing access to OHU providers. Compliance
testing showed CRC performed poorly in completing written history and physical
examinations of patients admitted to the OHU within the required time frame (MIT
13.002, 30.0%). Our clinicians did not identify any deficiencies regarding patients’ access
to OHU providers.
Access to Clinic Nurses
CRC performed very well in access to nurse sick calls and provider-to-nurse referrals.
Compliance testing showed all nursing sick call requests were reviewed on the same day
they were received (MIT 1.003, 100%), and nurses often completed face-to-face visits
within one day after the sick call requests were reviewed (MIT 1.004, 90.0%). Our
clinicians reviewed 38 nursing sick call requests in 25 cases and identified only two
deficiencies related to clinic nurse access.12 The following is an example:
• In case 15, the nurse consulted with the provider and received orders
for the nurse to follow up with the patient within 14 days. However,
the nurse did not schedule the follow-up appointment, and as a
result, the intended nursing encounter did not occur.
Access to Specialty Services
CRC had a mixed performance in access to specialty services. Compliance testing showed
initial high-priority specialty appointments intermittently occurred within the required
time frame (MIT 14.001, 73.3%). However, initial medium-priority and routine-priority
specialty appointments often occurred timely (MIT 14.004, 80.0%, and MIT 14.007, 93.3%).
The institution’s more concerning results were with follow-up specialty appointments.
Compliance testing showed subsequent high-priority, medium-priority, and routine-
priority follow-up specialty appointments sometimes occurred within the required time
frame (MIT 14.003, 62.5%, MIT 14.006, 57.1%, and MIT 14.009, 62.5%). Our clinicians
assessed 58 specialty service events and identified three deficiencies.13 The following is an
example:
• In case 14, the provider assessed the patient after the patient saw the
ophthalmologist, who recommended the patient see the glaucoma
specialist within two weeks. However, the patient saw the glaucoma
eye specialist more than four weeks late.
We discuss access to specialty services further in the Specialty Services indicator.
12 Deficiencies occurred in case 15.
13 Deficiencies occurred in cases 14, 21, and 45, with two significant deficiencies occurring in cases 14 and 21.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 16
Follow-Up After Specialty Services
CRC needed improvement in ensuring patients see their providers within the required
time frame after specialty appointments. Compliance testing showed provider
appointments after specialty services sometimes occurred within the required time frame
(MIT 1.008, 59.3%). OIG clinicians identified one delayed appointment with the provider
after specialty services:
• In case 21, the provider ordered a high-priority referral to a lung
specialist to evaluate the patient for a lung nodule and abnormal lung
findings on X-rays. The provider follow-up appointment occurred
after five weeks instead of within five days.
Follow-Up After Hospitalization
CRC performed satisfactorily in ensuring patients see their providers within the required
time frames after hospitalizations. Compliance testing showed provider appointments
after hospitalization generally occurred within the required time frame (MIT 1.007,
83.3%). The OIG clinicians reviewed 11 hospital returns and did not identify any missed
or delayed appointments.
Follow-Up After Urgent or Emergent Care (TTA)
Providers always saw their patients following triage and treatment area (TTA) events as
medically indicated. OIG clinicians assessed eight TTA events and did not identify any
delayed or missed provider follow-up appointments.
Follow-Up After Transferring Into CRC
CRC had a mixed performance in access to care for patients who have recently
transferred into the institution. Compliance testing showed access for intake
appointments for newly arrived patients needed improvement (MIT 1.002, 62.5%). OIG
clinicians assessed nine transfer-in cases and did not find any deficiencies in this area.
Clinician On-Site Inspection
CRC has five main health care teams: two in the mobile clinic, two in Central Health, and
one in Facility D. CRC also has a triage and treatment area (TTA), receiving and release
(R&R), specialty clinic, and outpatient housing unit (OHU). In each care team, patients
are seen by various health care team members, consisting of a primary care provider
(PCP), registered nurse (RN), medical assistant (MA), and case manager (CM).
The OIG clinicians joined the health care team morning huddles and a provider meeting,
all of which were well attended. The scheduling supervisor reported scheduling 11 to 13
appointments for each provider per day in addition to co-consults from nursing staff. One
part-time provider from the registry supported a health care team and supplemented
coverage.
Our case review clinicians spoke with CRC’s executive leadership, medical and nursing
leadership, and scheduling supervisor regarding the institution’s access to care. They
reported scheduling of appointments during the review period was impacted by large-
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Cycle 7, California Rehabilitation Center | 17
scale COVID-19 quarantines due to the open-dormitory setting, a high volume of new
arrivals related to the reception center overflow, and receiving Chuckwalla Valley State
Prison transfers. The scheduling supervisor reported the main reason for the previous
appointment backlog was related to the large volume of new arrivals and not enough
providers to fulfill the appointment needs. The scheduling supervisor mentioned,
however, CRC had no current backlog and all appointments previously out of compliance
had been scheduled.
Compliance On-Site Inspection and Discussion
Four of six housing units randomly tested at the time of inspection had access to Health
Care Services Request Forms (CDCR 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.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 18
Compliance Testing 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 17 8 0 68.0%
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 15 9 1 62.5%
patient seen by the clinician within the required time frame? (1.002)
Clinical appointments: Did a registered nurse review the patient’s request
30 0 0 100%
for service the same day it was received? (1.003)
Clinical appointments: Did the registered nurse complete a face-to-face visit
27 3 0 90.0%
within one business day after the CDCR Form 7362 was reviewed? (1.004)
Clinical appointments: If the registered nurse determined a referral to a
primary care provider was necessary, was the patient seen within the
7 1 22 87.5%
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 2 0 28 100%
specified? (1.006)
Upon the patient’s discharge from the community hospital: Did the patient
20 4 0 83.3%
receive a follow-up appointment within the required time frame? (1.007)
Specialty service follow-up appointments: Did the clinician follow-up visits
16 11 18 59.3%
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): 79.7%
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, California Rehabilitation Center | 19
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
3 7 0 30.0%
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 11 4 0 73.3%
Service? (14.001)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 5 3 7 62.5%
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 12 3 0 80.0%
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? 4 3 8 57.1%
(14.006)
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician Request 14 1 0 93.3%
for Service? (14.007)
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care 5 3 7 62.5%
provider? (14.009)
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, California Rehabilitation Center | 20
Recommendations
• Medical leadership should determine the cause of challenges in
timely providing chronic care follow-up appointments, follow-up
appointments for transfer-in patients, and follow-up specialty
appointments with providers. Leadership should implement
remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 21
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 (59.8%)
Case review found CRC delivered overall good performance in diagnostic services. As in
Cycle 6, staff generally completed laboratory testing within appropriate time frames. Staff
retrieved and providers endorsed these results timely. However, case review found
providers need to improve with communicating with complete patient test result
notification letters. After reviewing all aspects, the OIG rated the case review component
of this indicator adequate.
Compliance testing showed mixed performance for CRC with diagnostic services. Staff
performed excellently in providing routine laboratory services and performed well in
reviewing and endorsing laboratory and pathology results. However, staff needed to
improve in completing radiology and STAT (immediate) laboratory services, along with
provider review and endorsement of radiology results. In addition, providers performed
poorly in generating patient letters with all required key elements. On balance, the OIG
rated the compliance testing component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 390 diagnostic events and found 65 deficiencies, three of which were
significant.14 Of these 65 deficiencies, we found 61 related to health information
management (HIM), three related to provider review of results, and one related to the
delayed completion of an ordered test.
For health information management, we consider test reports that were never retrieved
or reviewed to be as severe a problem as tests that were never performed. We discuss this
further in the Health Information Management indicator.
Test Completion
Compliance testing showed CRC needed improvement in completing radiology services
within required time frames (MIT 2.001, 60.0%), performed very well in completing
laboratory tests (MIT 2.004, 90.0%), and performed poorly in completing STAT laboratory
14 Deficiencies occurred in cases 2, 4, 6, 7–12, 14–21, and 23. Significant deficiencies occurred in cases 14, 16,
and 17.
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Cycle 7, California Rehabilitation Center | 22
tests within required time frames (MIT 2.007, 44.4%). OIG clinicians reviewed 22
radiology imaging studies and 367 laboratory tests and found one deficiency in test
completion within the required time frame. The following is an example:
• In case 23, the patient arrived at CRC, and the nurse ordered
COVID-19 testing to be performed in five days. However, the test
was performed one day late.
Clinicians had no STAT laboratory tests in their case review samples.
Health Information Management
CRC staff retrieved laboratory test results promptly and sent them to providers for
review. Compliance testing showed providers frequently endorsed laboratory results
timely (MIT 2.005, 90.0%). However, CRC needed improvement in providers endorsing
radiology test reports (MIT 2.002, 70.0%). Case reviewers also found instances of delayed
provider endorsements. The following are two examples:
• In case 14, the patient had a chest X-ray performed. The provider
endorsed the results 12 days after the X-ray results were available for
review.
• In case 16, the results of a lower back X-ray were available for review.
However, the provider endorsed the results two weeks later.
CRC performed poorly in relaying results to patients. Compliance scores for
communicating radiology results and laboratory results were poor (MIT 2.003, 20.0% and
MIT 2.006, 10.0%). Our clinicians also identified this as an area of underperformance.
OIG clinicians identified 61 HIM deficiencies, 60 of which were related to patient test
result notification letters. Of these 60 deficiencies, 48 deficiencies were due to missing
elements in the letters. The following is an example:
• In case 14, the provider endorsed the laboratory test results and
created a patient test result notification letter in EHRS. However, the
letter did not include either the date of the test or whether the results
are within normal limits.15
Compliance testing showed, while CRC staff always retrieved pathology reports timely
(MIT 2.010, 100%), and providers always endorsed pathology reports promptly (MIT 2.011,
100%), providers did not notify patients of their pathology results within the required
time frame (MIT 2.012, zero).
Clinician On-Site Inspection
At the on-site inspection, the OIG clinicians met with laboratory and radiology staff.
CRC provides on-site mobile CT, MRI, and ultrasound imaging services, as well as on-
15 EHRS is the Electronic Health Records System. The department’s electronic health record system is used for
storing the patient’s medical history. Health care staff use the system to communicate.
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Cycle 7, California Rehabilitation Center | 23
site general X-ray services.16 The senior radiologic technologist reported CRC imaging
services are provided by a part-time and a full-time radiologic technologist. The senior
laboratory assistant reported CRC provides clinical laboratory services supported by a
regional clinical laboratory specialist using frequent email communications and
telephonic support as needed. An external laboratory vendor provides laboratory and
pathology diagnostic services for the institution. After the vendor processes the
laboratory and pathology specimens, the vendor imports laboratory and pathology results
directly to the patients’ EHRS for the health care teams to review. The laboratory
technician reported any critical laboratory results are communicated through TTA staff
directly by the vendor by phone and a fax machine located in the office with 24-hour
access by nursing and laboratory staff.
16 A CT scan is a computed, or computerized, tomography imaging scan. An MRI is a magnetic resonance
imaging scan.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 24
Compliance Testing Results
Table 7. Diagnostic Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
6 4 0 60.0%
specified in the health care provider’s order? (2.001)
Radiology: Did the ordering health care provider review and endorse the
7 3 0 70.0%
radiology report within specified time frames? (2.002)
Radiology: Did the ordering health care provider communicate the results
2 8 0 20.0%
of the radiology study to the patient within specified time frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
9 1 0 90.0%
specified in the health care provider’s order? (2.004)
Laboratory: Did the health care provider review and endorse the laboratory
9 1 0 90.0%
report within specified time frames? (2.005)
Laboratory: Did the health care provider communicate the results of the
1 9 0 10.0%
laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and receive
4 5 0 44.4%
the results within the required time frames? (2.007)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
3 6 0 33.3%
staff notify the provider within the required time frames? (2.008)
Laboratory: Did the health care provider endorse the STAT laboratory
9 0 0 100%
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
10 0 0 100%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 10 0 0
pathology study to the patient within specified time frames? (2.012)
Overall percentage (MIT 2): 59.8%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, California Rehabilitation Center | 25
Recommendations
• The department should consider developing strategies, such as
potentially an electronic solution, to ensure providers generate
letters communicating results to their patients, and that the letters
include all elements as required by policy.
• Medical leadership should ascertain causes related to the untimely
provision of radiology services, the root cause(s) of challenges in
reviewing and endorsing radiology reports timely and implement
remedial measures as appropriate.
• Medical leadership should determine the root cause of challenges
with collecting, receiving, and notifying STAT laboratory results and
implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 26
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 mainly through case review.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Not Applicable
CRC generally provided sufficient emergency care. We found nursing staff responded
promptly to all emergent events and provided appropriate care. Frequently, nurses
performed good initial assessments and documented satisfactorily, which was an
improvement from Cycle 6. However, OIG clinicians observed a pattern of incomplete or
missing reassessments of patients with initial abnormal clinical presentations or vital
signs. Similar to Cycle 6, nursing and medical leadership did not always identify these
deficiencies in their clinical reviews. Taking all aspects into consideration, the OIG rated
this indicator adequate.
Case Review Results
The OIG clinicians reviewed 29 events, 17 of which were urgent or emergent events. We
found 19 deficiencies within various aspects of overall emergency care. Of these 19
deficiencies, four were significant.17
Emergency Medical Response
CRC custody and health care staff responded promptly to emergencies throughout the
institution. Generally, staff timely activated 9-1-1 emergency medical services. However,
the following example showed room for improvement:
• In case 3, staff activated a medical alarm for an unconscious patient
but did not contact 9-1-1 until 14 minutes later. This resulted in a
delay of transport to a higher level of care.
Cardiopulmonary Resuscitation Quality
In our CPR sample case, custody and medical staff worked collaboratively to provide care,
transported the patient to the TTA for additional interventions, and transferred the
17 Deficiencies occurred in cases 1–3 and 15–17. Significant deficiencies occurred in cases 3, 15, and 17.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 27
patient to a higher level of care. We identified a deficiency with AED documentation and
a deficiency with nursing reassessment. The following is an example:
• In case 3, the nurses responded to a medical alarm for an
unconscious patient. Staff performed CPR and when the patient had
a return of spontaneous circulation, nurses failed to reassess the
patient’s pulse, respirations, and oxygen saturation.18
Provider Performance
Providers performed well in urgent and emergent situations, and after-hours care.
Providers were available for consultation with nurses when necessary and were involved
in treatment decisions. They made accurate diagnoses and generally completed
documentation. However, on two occasions, the providers did not arrange for follow-up
appointments with patients when clinically indicated. The following is an example:
• In case 1, the patient had an abnormal electrocardiogram (EKG) and
intermittent chest pain but refused to be transported to the
community hospital. The provider did not arrange a follow-up
appointment to reassess the patient’s condition to determine if
further intervention was required.
Nursing Performance
Nurses also performed well during emergency events. They responded to emergencies
timely and generally provided good initial assessments; however, OIG clinicians
identified a pattern of nurses not reassessing initial abnormal patient presentations or
vital signs.19 The following are examples:
• In case 15, the patient requested a blood pressure check because he
had swelling in his fingers and toes, throbbing headache, and
dizziness. The nurses performed an EKG showing “Acute
MI/Ischemia,” administered nitroglycerin, and contacted emergency
medical services (EMS).20 However, the nurse did not reassess the
patient after each administration of nitroglycerin or obtain vital
signs every five minutes until EMS assumed care.
• In case 17, the patient complained of vomiting and had low blood
pressure. The nurse administered an anti-nausea medication but did
not reassess the low blood pressure.
18 Return of spontaneous circulation is the resumption of a sustained heart rhythm that perfuses the body after
cardiac arrest. Clinically, a health care staff will check and identify a central pulse.
19 Nursing reassessment deficiencies occurred in cases 2, 3, 15, 16, and 17.
20 Acute MI/Ischemia means either a heart attack or the heart muscle is not getting enough blood flow.
Nitroglycerin is a medication that dilates blood vessels to increase blood flow to the heart.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 28
Nursing Documentation
Nurses in the TTA usually performed thorough documentation for emergent events.
However, we identified documentation deficiencies. The following two are examples:
• In case 2, on two occasions, staff activated the medical alarm for a
patient for abdominal pain, and the patient was evaluated in the
TTA. However, nurses did not document the patient’s disposition or
actual time of discharge from the TTA.
• In case 3, the nurses did not document AED activity to include
whether shock was advised or delivered.
Emergency Medical Response Review Committee
The EMRRC met monthly and discussed emergency responses and unscheduled send
outs. However, the EMRRC did not review cases timely and rarely completed the required
checklists (MIT 15.003, zero). In addition, while the OIG clinicians found clinical reviews
were frequently performed, in four of the nine emergency events, the nursing and medical
leadership did not identify opportunities for improvement the OIG clinicians identified.21
Two examples are listed below:
• In case 2, nursing and medical leadership conducted a clinical review
of an emergent event for abdominal pain. They identified the delay in
activating 9-1-1. However, they did not identify the nursing staff did
not reassess the patient and the nursing staff did not obtain vital
signs for 22 minutes while waiting for EMS to arrive.
• In case 15, the clinical review labeled for this patient contained
contents for a different patient and event that occurred on the same
day.
Clinician On-Site Inspection
During the on-site inspection, we toured the TTA and spoke to nursing staff. The CRC
TTA contained two beds in independent bays, providing sufficient space for emergency
care. The TTA nurse explained they scheduled two RNs during each shift and assigned a
provider for TTA, who also covered the OHU. Nurses reported, if the assigned provider
was unavailable when needed, staff would contact the primary care provider. An assigned
provider was on call for the TTA after hours.
The TTA RN informed the OIG clinicians the AEDs were capable of recording activity
and the activity can be downloaded into the EHRS. Although AED activity can be
downloaded, the chief nurse executive (CNE) reported the nurses were also expected to
document emergency activity, to include whether a shock was advised or delivered.
The OIG clinicians also interviewed the TTA supervising registered nurse (SRN). The
SRN described his role in supporting the TTA RNs during emergencies and dual role as
supervisor of the OHU. Additionally, the SRN was designated as the EMRRC
21 Deficiencies occurred in cases 2, 3, 15, and 16. Significant deficiencies occurred in cases 3 and 15.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 29
Coordinator. The SRN reported an estimated 60 emergency transfers per month. The
supervisor reviewed each emergency prior to the end of each shift and addressed findings
with the staff in real time. In addition to shift reviews, the SRN reported mock drills and
tabletop reviews are conducted quarterly, in conjunction with custody staff.22 The SRN
stated these activities are to assist staff in identifying gaps and practicing skills, as well
as to offer additional education and guidance.
22 A tabletop review is a written emergency case scenario activity involving a team of responders discussing
necessary actions in the event of a real emergency.
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Cycle 7, California Rehabilitation Center | 30
Recommendations
• Leadership should determine the root cause of challenges for
immediate activation of the 9-1-1 system for emergent patients
needing a higher level of care and implement remedial measures as
appropriate.
• Nursing leadership should determine the root cause of challenges
that prevent nurses from performing necessary reassessments as
clinically indicated for patients with urgent symptoms in the TTA
and implement remedial measures as appropriate.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 31
Health Information Management
In this indicator, OIG inspectors evaluated the flow of health information, a crucial link
in high-quality medical care delivery. Our inspectors examined whether the institution
retrieved and scanned critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical record in a timely
manner. Our inspectors also tested whether clinicians adequately reviewed and endorsed
those reports. In addition, our inspectors checked whether staff labeled and organized
documents in the medical record correctly.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Proficient (93.0%)
Case review found CRC performed well in health information management. Staff
performed very well in retrieving and scanning hospital discharge records, specialty
reports, and urgent and emergent records. However, case review found opportunities for
improvement in providers communicating test results to patients with notification
letters. Taking all factors into consideration, the OIG rated the case review component of
this indicator adequate.
CRC performed exceptionally well overall in compliance testing. Staff always timely
scanned patient sick call requests, along with almost always timely retrieving and
scanning hospital records. Staff also performed well in properly scanning and labeling
medical records in the correct patient files, scanning specialty reports, and endorsing
hospital reports. Taking all results into consideration, the OIG rated the compliance
testing component of this indicator proficient.
Case Review and Compliance Testing Results
We reviewed 881 events and found 68 deficiencies related to health information
management, four of which were significant.23
Hospital Discharge Reports
Compliance testing showed staff performed well in timely retrieving and scanning
hospital discharge documents into patients’ electronic health records (MIT 4.003, 95.0%).
In addition, nearly all the hospital discharge reports contained physician discharge
summaries, and providers reviewed these reports timely (MIT 4.005, 91.7%). OIG
clinicians reviewed 11 off-site emergency department and hospital encounters and did
not identify any deficiencies.
23 Deficiencies occurred in cases 2, 4, 6–12, and 14–21. Deficiencies occurred in cases 14, 16, 17, and 20.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 32
Specialty Reports
For the most part, CRC performed well in retrieving and reviewing specialty reports.
Compliance testing showed most specialty reports were scanned into the electronic
health record system within required time frames (MIT 4.002, 86.7%). On the other hand,
staff needed improvement in retrieving and reviewing high-priority specialty service
consultant reports timely (MIT 14.002, 66.7%). CRC performed poorly in retrieving and
reviewing medium-priority and routine-priority specialty service consultation reports
timely (MIT 14.005, 46.2% and MIT 14.008, 53.3%). Our clinicians reviewed 54 specialty
reports and identified two deficiencies, neither of which was significant.24 The following
is an example:
• In case 14, the provider endorsed the specialist consultation report
two days late.
We also discuss these findings in the Specialty Services indicator.
Diagnostic Reports
CRC performed variably with diagnostic reports. Compliance testing showed providers
almost always endorsed laboratory reports within required time frames (MIT 2.005, 90.0%)
but only sometimes endorsed imaging reports within required time frames (MIT 2.002,
70.0%). Staff always received the final pathology study within the required time frames
(MIT 2.010, 100%). Providers always reviewed and endorsed pathology reports within
required time frames (MIT 2.011, 100%) but never communicated results of the pathology
study to patients within required time frames (MIT 2.012, zero). Our clinicians identified
65 deficiencies, three of which were significant.25 The following is an example:
• In case 14, the patient had a chest X-ray performed. However, the
provider endorsed the results 12 days after the results became
available.
Most deficiencies (46 out of 65 deficiencies) related to providers communicating test
results with incomplete test results letters. The following is an example:
• In case 6, the provider endorsed the laboratory test results and sent a
patient notification letter. However, the letter did not include either
the date of the test or whether the results were within normal limits.
Compliance testing showed CRC poorly managed the STAT test results. Specifically,
either the providers rarely acknowledged the STAT test results timely, or nursing staff
did not notify the provider timely (MIT 2.008, 33.3%). Clinical reviewers did not have any
STAT laboratory tests in the review samples.
The Diagnostic Services indicator provides more details on CRC’s diagnostic services
performance.
24 Deficiencies occurred in cases 12 and 14.
25 Significant deficiencies occurred in cases 16, 17, and 20.
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Cycle 7, California Rehabilitation Center | 33
Urgent and Emergent Records
OIG clinicians reviewed 29 emergency care events, 17 of which were urgent or emergent.
Providers recorded their emergency care sufficiently, including off-site telephone
encounters. OIG clinicians found four deficiencies in nursing and provider
documentation.26 Nursing deficiencies are discussed further in the Emergency Services
indicator. The following is an example of a provider documentation deficiency:
• In case 15, a TTA RN consulted the on-call provider for the patient
with high blood pressure and symptoms of headache and dizziness.
The provider ordered hydration, monitoring, EKG, and transfer to a
higher level of care. However, the provider did not document a
progress note in the EHRS.
Scanning Performance
Staff performed well with the scanning process. Compliance testing showed staff almost
always properly scanned and labeled patients’ medical files (MIT 4.004, 91.7%). OIG
clinicians identified one deficiency related to scanning medical documents:
• In case 21, the pulmonary specialist consultation report was scanned
into EHRS. However, it was mislabeled as “Pulmonary Function
Studies.”
Clinician On-Site Inspection
Our clinicians discussed health information management processes with the CRC health
records technician supervisor, office technicians, and providers. The health records
supervisor reported CRC implemented an improvement strategy for retrieval, scanning,
and endorsement of health records by tracking all community hospital emergency room
encounters, hospital admissions, off-site appointments, and telemedicine specialty
appointments and manually reviewing dates of scanning and provider endorsements
daily.
26 Deficiencies occurred in cases 2, 3, and 15.
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Cycle 7, California Rehabilitation Center | 34
Compliance Testing 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
26 4 15 86.7%
within five calendar days of the encounter date? (4.002)
Are community hospital discharge documents scanned into the patient’s
electronic health record within three calendar days of hospital discharge? 19 1 4 95.0%
(4.003)
During the inspection, were medical records properly scanned, labeled,
22 2 0 91.7%
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 22 2 0 91.7%
review the report within five calendar days of discharge? (4.005)
Overall percentage (MIT 4): 93.0%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, California Rehabilitation Center | 35
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
7 3 0 70.0%
radiology report within specified time frames? (2.002)
Laboratory: Did the health care provider review and endorse the laboratory
9 1 0 90.0%
report within specified time frames? (2.005)
Laboratory: Did the provider acknowledge the STAT results, OR did nursing
3 6 0 33.3%
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
10 0 0 100%
report within specified time frames? (2.011)
Pathology: Did the health care provider communicate the results of the
0 10 0 0
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 10 5 0 66.7%
frame? (14.002)
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required time 6 7 2 46.2%
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 8 7 0 53.3%
frame? (14.008)
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 36
Recommendations
The OIG offers no recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 37
Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting areas, infection
control, sanitation procedures, medical supplies, equipment management, and
examination rooms. Inspectors also tested clinics’ performance in maintaining auditory
and visual privacy for clinical encounters. Compliance inspectors asked the institution’s
health care administrators to comment on their facility’s infrastructure and its ability to
support health care operations. The OIG rated this indicator solely on the compliance
score. Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (56.4%)
In this cycle, multiple aspects of CRC’s health care environment needed improvement:
clinics’ medical supplies storage areas contained expired medical supplies, compromised
sterile medical supply packaging, unidentified medical supplies, or medical supplies
stored with cleaning materials. In addition, several examination and medication rooms
had damaged floors and were unsanitary while emergency medical response bag (EMRB)
logs were missing staff verification or inventory was not performed. Moreover, several
clinics did not meet the requirements for essential core medical equipment and supplies.
Lastly, staff sporadically washed their hands properly before examining patients or before
regloving. Taking all results into consideration, the OIG rated this indicator inadequate.
Compliance Testing Results
Outdoor Waiting Areas
The institution had no outdoor waiting areas for
patients.
Indoor Waiting Areas
We inspected CRC’s indoor waiting areas. Health
care and custody staff reported the existing indoor
waiting areas contained sufficient seating capacity
to provide patients protection from inclement
weather (see Photo 1). Custody staff also reported
they bring in a few patients at a time to prevent
overcrowding the indoor waiting areas. During our
inspection, we did not observe overcrowding in the
clinics’ waiting areas.
Photo 1. Triage and treatment area waiting room
(photographed on 4-10-23).
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 38
Clinic Environment
Nine of 10 clinic environments were sufficiently conducive for medical care. They
provided reasonable auditory privacy, appropriate waiting areas, wheelchair accessibility,
and nonexamination room workspace (MIT 5.109, 90.0%). In one clinic, we observed
laboratory staff providing services to multiple patients at the same time in the blood draw
stations, which hindered auditory privacy.
Six of the eight applicable clinics we observed contained appropriate space,
configuration, supplies, and equipment to allow their clinicians to perform proper
clinical examinations (MIT 5.110, 75.0%). In one clinic, the examination room had
unsecured confidential medical records. The remaining clinic examination room lacked
visual privacy for conducting clinical examinations.
Clinic Supplies
Five of the 10 clinics followed adequate
medical supply storage and management
protocols (MIT 5.107, 50.0%). We found
one or more of the following deficiencies
in five clinics: expired medical supplies
(see Photo 2), unidentified medical
supplies, and cleaning materials stored
with medical supplies (see Photo 3).
Photo 2. Expired medical supplies dated
December 2022 (photographed on 4-10-23).
Photo 3. Medical supplies stored in the same area as
cleaning supplies (photographed on 4-11-23).
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 39
Only two of the 10 clinics met requirements for essential core medical equipment and
supplies (MIT 5.108, 20.0%). The remaining eight clinics lacked medical supplies,
contained improperly calibrated equipment, or contained nonfunctional equipment. The
missing items included a tongue depressor and a nebulization unit. The staff had not
properly calibrated both an oto-ophthalmoscope and an automated vital signs machine.
We found a nonfunctional oto-ophthalmoscope. Staff did not properly log the results of
the defibrillator or an AED performance test within the last 30 days. In addition, several
clinics’ daily glucometer quality control logs were inaccurate, incomplete, or not logged
within the last 30 days.
We examined EMRBs stored in seven applicable locations to determine whether they
contained all essential items. We checked whether staff inspected the bags daily and
inventoried them monthly. None of the EMRBs passed our tests (MIT 5.111, zero). We
found one or more of the following deficiencies: staff did not ensure the EMRB’s
compartments were sealed and intact; staff had not inventoried the EMRBs when the seal
tags were replaced; and staff did not always log EMRB daily glucometer quality control
results.
Medical Supply Management
Staff always properly stored clinic medical supplies in the medical supply storage areas
outside the medical clinics (e.g., warehouse, Conex containers, etc.) (MIT 5.106, 100%).
According to the chief executive officer, CRC 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
with the existing system.
Infection Control and Sanitation
Staff appropriately, cleaned, sanitized,
and disinfected only two of 10 clinics
(MIT 5.101, 20.0%). In eight clinics, we
found one or more of the following
deficiencies: cleaning logs were not
maintained; biohazardous waste was
not emptied after each clinic day;
medical supply cabinet was unsanitary;
and several clinic floors were damaged
and unsanitary (see Photo 4).
Photo 4. Clinic floor damaged and
unsanitary (photographed on 4-10-23).
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 40
Staff in six of nine applicable clinics (MIT 5.102, 66.7%) properly sterilized or disinfected
medical equipment. In two clinics, we found several instances of previously sterilized
medical equipment with compromised packaging. In addition, staff did not routinely log
the receipt of used medical equipment requiring sterilization, and staff did not routinely
date stamp sterilized medical equipment packaging. In another clinic, staff did not
mention disinfecting the exam table as part of their daily start-up protocol.
We found operating sinks and hand hygiene supplies in the examination rooms in eight
of 10 clinics (MIT 5.103, 80.0%). In one clinic, the patient restrooms lacked antiseptic soap
and disposable hand towels. In another clinic, the patient restroom lacked disposable
hand towels.
We observed patient encounters in seven applicable clinics. In five clinics, clinicians did
not wash their hands before applying gloves or during subsequent regloving (MIT 5.104,
28.6%).
Health care staff in nine of 10 clinics followed proper protocols to mitigate exposure to
bloodborne pathogens and contaminated waste (MIT 5.105, 90.0%). In one clinic, we
discovered overfilled biohazard containers and found the designated storage area
unsecured.
Physical Infrastructure
At the time of our medical inspection, the institution’s administrative team reported no
ongoing health care facility improvement program construction projects. The
institution’s health care management and plant operations manager reported all clinical
area infrastructures were in good working order (MIT 5.999).
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 41
Compliance Testing Results
Table 10. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately disinfected,
2 8 1 20.0%
cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable invasive
and noninvasive medical equipment is properly sterilized or disinfected as 6 3 2 66.7%
warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks and
8 2 1 80.0%
sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal hand
2 5 4 28.6%
hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to blood-
9 1 1 90.0%
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 1 0 0 100%
health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for managing and
5 5 1 50.0%
storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have essential core
2 8 1 20.0%
medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas conducive
9 1 1 90.0%
to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms conducive to
6 2 3 75.0%
providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency crash
carts inspected and inventoried within required time frames, and do they 0 7 4 0
contain essential items? (5.111)
Does the institution’s health care management believe that all clinical areas
This is a nonscored test. Please see the
have physical plant infrastructures that are sufficient to provide adequate
indicator for discussion of this test.
health care services? (5.999)
Overall percentage (MIT 5): 56.4%
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 42
Recommendations
• Medical leadership should determine the root cause for staff not
following all required universal hand hygiene precautions and take
necessary remedial measures.
• Nursing leadership should determine the root cause for staff not
ensuring clinic examination rooms contain essential core medical
equipment and verifying that staff follow equipment and medical
supply management protocols and take necessary remedial measures.
• Executive leadership should determine the root cause for staff not
ensuring clean and sanitary clinics, medical storage rooms, and
medication rooms and take necessary remedial measures.
• Nursing leadership should determine the root cause 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 take necessary remedial measures.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 43
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 Adequate (83.2%)
Compared with Cycle 6, CRC’s transfer process showed similar performance. Although
case review found the transfer processes overall were satisfactory, OIG clinicians
identified areas for improvement in documenting a five-day supply of medication was
provided for patients transferring out. Considering all aspects of transfer-related care and
case review, the OIG rated the case review component of this indicator adequate.
Compared with Cycle 6, CRC’s overall compliance performance greatly improved for this
indicator. CRC still needs to improve in completing initial health screening forms.
However, the institution performed excellently in completing the assessment and
disposition section of the screening process and in ensuring medication continuity for
newly transferred patients. Consequently, the OIG rated the compliance testing
component of this indicator adequate.
Case Review and Compliance Testing Results
We reviewed 47 events in 19 cases in which patients transferred into or out of the
institution or returned from off-site hospitalizations or emergency room encounters. We
identified 17 deficiencies, three of which were significant.27
27 Deficiencies occurred in cases 2, 5, 14–17, 25, 27, and 43–45. Significant deficiencies occurred in cases 15, 16,
and 45.
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Cycle 7, California Rehabilitation Center | 44
Transfers In
CRC’s performance was mixed in the transfer-in process. Compliance testing showed
R&R nurses needed improvement in completing the initial health screening form
thoroughly (MIT 6.001, 72.0%.) However, the nurses almost always completed the
assessment and disposition section of the form (MIT 6.002, 95.8%). Compliance testing
also showed staff generally ensured medication continuity occurred at the time of
transfer for newly arrived patients (MIT 6.003, 81.8%) but needed improvement in
medication continuity for patient layovers at the institution (MIT 7.006, 57.1%). Moreover,
compliance testing revealed newly arrived patients were sometimes seen by a provider
within necessary time frames (MIT 1.002, 62.5%).
OIG clinicians reviewed 17 events in nine cases in which patients transferred into the
facility from other institutions. We identified only two minor deficiencies:28
• In case 5, the patient arrived at CRC and was scheduled to receive a
KOP blood pressure medication; however, the patient missed the
dose.29
• In case 45, the nurse performing the initial intake assessment did not
obtain or document the patient’s weight.
Transfers Out
CRC’S transfer-out process was satisfactory. OIG clinicians reviewed nine transfer-out
events, in a total of six cases, of which five events were unscheduled transfers. In these
instances, nurses received notice with limited time to prepare for the transfer. The nurses
did not always document notification of pending specialty consultations and did not
always document transferring the five-day supply of medications. The following are
examples:
• In cases 2, 25, and 45, the nurses did not document transferring the
five-day supply of medications with the patients.
• In cases 25 and 27, the patients transferred to another facility.
However, the nurses did not document notifying the receiving
institution of pending specialty consultations.
Hospitalizations
Patients returning from an off-site hospitalization or emergency room encounters are at
high risk for lapses in care quality. These patients have typically experienced severe
illness or injury. They require more care and place a strain on the institution’s resources.
In addition, because these patients have complex medical issues, successful health
information transfer is necessary for good quality care. Any transfer lapse can result in
serious consequences for these patients.
28 Deficiencies occurred in cases 5 and 45.
29 KOP means “keep on person” and refers to medications in which a patient can keep and self-administer
according to the directions provided.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 45
CRC staff performed sufficiently in the return process for hospitalizations and
emergency room encounters. In compliance testing, CRC staff often provided follow-up
appointments within required time frames to patients returning from hospitalizations
and emergency room encounters (MIT 1.007, 83.3%). However, OIG clinicians identified
significant deficiencies in medication continuity, which is addressed further in the
Medication Management section.
Clinician On-Site Inspection
OIG clinicians toured the R&R area and interviewed the RN on duty. The nurse reported
an RN was staffed on each shift, although after business hours, no custody or nursing
staff are present in the R&R area. Instead, after hours, the R&R RN reports to the TTA to
conduct their duties. The R&R RN reported on Wednesdays they receive the list of
incoming and outgoing transfers scheduled for the subsequent week. The nurse
estimated, prior to COVID-19, CRC averaged 65 new arrivals per week; however, as of
our on-site inspection, the average had increased to a range of 60 to over 100 new arrivals
per week. Additionally, the nurse reported an average of 10 to 20 patients transferring out
per week, with an increased number of patients paroling compared to the number in the
past. The R&R nurse explained a well-organized system for processing transfer patients
and shared a task list for other shifts to continue any additional work remaining.
Although, the nurse described the custody counterparts as being relatively new, they
were building a good working relationship.
While on-site, OIG clinicians also spoke with nursing leadership. Leadership indicated
their staff performed weekly audits for hospital returns and used their OIG metrics to
ensure nurses provide quality care as it relates to patient transfers. In addition, they
reported the daily care team huddles included dedicated time to discuss transfer-related
concerns.
Compliance On-site Inspection and Discussion
CRC had no transfer-out patients scheduled the week of the on-site inspection.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 46
Compliance Testing 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 18 7 0 72.0%
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 23 1 1 95.8%
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 9 2 14 81.8%
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 N/A N/A N/A N/A
required documents? (6.101)
Overall percentage (MIT 6): 83.2%
Source: The Office of the Inspector General medical inspection results.
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Cycle 7, California Rehabilitation Center | 47
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 15 9 1 62.5%
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 20 4 0 83.3%
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? 19 1 4 95.0%
(4.003)
For patients discharged from a community hospital: Did the preliminary or
final hospital discharge report include key elements and did a provider 22 2 0 91.7%
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 12 8 4 60.0%
within required time frames? (7.003)
Upon the patient’s transfer from one housing unit to another: Were
23 2 0 92.0%
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 4 3 0 57.1%
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
N/A N/A N/A N/A
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 Rehabilitation Center | 48
Recommendations
The OIG offers no recommendations for this indicator.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 49
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 (69.5%)
Case review found CRC’s performance in medication management was satisfactory. Staff
performed well with newly prescribed medications and chronic care medication
continuity. However, staff did not perform well with the hospital medication
reconciliation process. Taking all factors into account, the OIG rated the case review
component of this indicator adequate.
CRC had a mixed performance in compliance testing. Staff performed exceptionally well
in employing general security and storing medications in its main pharmacy, providing
newly prescribed medication orders, and providing medications for patients transferring
within the institution. However, staff needed improvement in timely providing chronic
care medications, hospital discharge medications, and medications for patients en route
who layover at CRC. Considering all testing results, the OIG rated the compliance testing
component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 117 events in 28 cases related to medications and found 14 medication
deficiencies, two of which were significant.30
New Medication Prescriptions
Staff performed excellently with timely administration and availability of new
prescription medications (MIT 7.002, 96.0%). OIG case review clinicians only found two
minor deficiencies related to new prescriptions. The following are examples:
• In cases 1 and 17, the patients received their KOP pain medications
one to two days late.
30 Deficiencies occurred in cases 1, 2, 4, 5, 7–27, and 43–45. Significant deficiencies occurred in cases 16 and 45.
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7, California Rehabilitation Center | 50
Chronic Medication Continuity
Compliance testing revealed patients rarely received their chronic care medications
within required time frames (MIT 7.001, 15.0%). In contrast, OIG case reviewers found
CRC performed well with chronic care medications. We identified only two examples in
which patients did not receive their medications timely:
• In cases 12 and 13, the patients did not receive their KOP cholesterol
medications in the month of January.
Hospital Discharge Medications
In compliance testing, CRC needed improvement in ensuring patients received their
medications on return from an off-site hospital or emergency room encounter (MIT 7.003,
60.0%). In four cases, our clinicians also found health care staff inaccurately reconciled
the hospital recommended medications, resulting in three medication errors:
• In case 16, the patient returned from a community hospital with
medication orders. However, CRC health care staff inaccurately
reconciled the prophylactic blood thinning medication order, and the
patient received double the amount of the recommended first dose.
Fortunately, the next morning, the pharmacist recognized the error
and corrected the dosage.
• In case 43, the patient returned from the community hospital after
sustaining a bleed in the brain. However, CRC health care staff
inaccurately reconciled the hospital medications, resulting in the
patient receiving aspirin, a medication that thins the blood, on two
consecutive days, although the hospital recommended the
medication be discontinued.
• In case 45, the patient returned from the community hospital after
knee surgery. However, CRC health care staff inaccurately reconciled
the hospital medications, resulting in the patient not receiving
prophylactic medications to reduce the risk of blood clots.
Specialized Medical Housing Medications
Staff performed well in ensuring patients received their needed medications during
admission in the OHU. OIG clinicians found OHU nurses often administered
medications timely. We identified the following deficiency:
• In case 43, the patient did not receive their cholesterol and blood
pressure medications for four days.
Transfer Medications
For transfer medications, staff performed well. Compliance testing showed CRC
performance was satisfactory with ensuring patients who transferred into the institution
received their medications timely (MIT 6.003, 81.8%). The staff also performed very well
with medication continuity for patients transferring from yard to yard (MIT 7.005, 92.0%).
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Cycle 7, California Rehabilitation Center | 51
However, patients who were on layover and temporarily housed at CRC sometimes
received their medications within required time frames (MIT 7.006, 57.1%). OIG
clinicians found a deficiency with continuity of KOP medication for a newly arrived
patient and three documentation deficiencies related to the amount of medication
transferred with patients. These are discussed further in the Transfers indicator.
Medication Administration
Compliance testing showed nurses frequently administered tuberculosis (TB)
medications within required time frames (MIT 9.001, 92.0%). However, the institution
performed poorly with monitoring patients taking TB medications, as required by policy
(MIT 9.002, 44.0%). Our clinicians did not have any case review samples with events
related to TB medications.
Case review clinicians found nurses often administered medications properly.
Clinician On-Site Inspection
During the on-site inspection, OIG clinicians interviewed the pharmacist in charge (PIC)
and nurses and toured the medication lines. The PIC reported a recent change to the
workflow, which allowed central pharmacy to be contacted 24 hours a day, seven days a
week. The Facility B medication line had three medication administration windows.
Nurses reported they had previously been staffed with two nurses but received a third
nurse when facility A closed. The Facility C medication line had two medication
administration windows, staffed with two nurses. Medication line nurses were
knowledgeable on the KOP process of documentation, administration, and medication
return time frames. Additionally, nurses reported good rapport with custody staff and
experienced minimal challenges with patients not reporting to the medication line. One
nurse shared a practice of assisting patients with obtaining new identification when their
identification was missing or damaged, to ensure they could receive medication timely.
During the well-coordinated nursing huddles, OIG clinicians observed health care staff
discussing expired medication orders, medication concerns, and plans for follow-up.
After the huddle, our clinicians met with the LVN care coordinators who reported they
were responsible for providing education on medication and vaccines related to chronic
care diagnoses.
Our clinicians also met with the TTA RN and discussed medication reconciliation for
patients returning to CRC from a hospitalization or off-site specialty appointment. The
TTA RN described challenges with medication reconciliation in EHRS as the system
prefills the wrong dates and defaults to KOP medication versus nurse administered.
Moreover, if completed, the order cannot be modified. Instead, the order must be
discontinued, and staff must enter a new order. Furthermore, the nurse reported not
being able to type in free text in the order entry, and the drop-down selection menu items
are limited.
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Cycle 7, California Rehabilitation Center | 52
Compliance Testing Results
Medication Practices and Storage Controls
Staff adequately stored and secured narcotic medications in eight of nine clinic and
medication line locations (MIT 7.101, 88.9%). In one location, staff did not properly and
securely store narcotic medications as required by CCHCS policy.
Staff adequately stored and secured nonnarcotic medications in four of nine clinic and
medication line locations (MIT 7.102, 44.4%). In five locations, we observed one or more
of the following deficiencies: nurses did not maintain unissued medication in its original
labeled packaging; treatment cart log was missing daily security check entries; and the
medication area lacked a clearly labeled designated area for refrigerated medications to
be returned to the pharmacy.
Staff properly protected medications from physical, chemical, and temperature
contamination in only four of the nine clinic and medication line locations (MIT 7.103,
44.4%). In five locations, we found one or more of the following deficiencies: staff did not
consistently record the room and refrigerator temperatures; staff did not store internal
and external medications separately; and the medication refrigerator was unsanitary.
Staff always adequately stored valid, unexpired medications in all medication line
locations (MIT 7.104, 100%).
Nurses did not perform proper hand hygiene and contamination control protocols in all
six applicable locations (MIT 7.105, zero). In six locations, some nurses neglected to wash
or sanitize their hands before each subsequent re-gloving.
Staff in four of six applicable medication preparation and administration areas
intermittently had appropriate administrative controls and protocols (MIT 7.106, 66.7%).
In two locations, medication nurses did not describe the process they followed when
reconciling newly received medication and the medication administration record (MAR)
against the corresponding physician’s order.
Staff in only one of six applicable medication areas used appropriate administrative
controls and protocols when distributing medications to patients (MIT 7.107, 16.7%). In
five locations, we observed one or more of the following deficiencies: medication nurses
did not distribute medications to patients within the required time frame; medication
nurses did not always verify patient’s identification using a secondary identifier;
medication nurses did not reliably observe patients while they swallowed direct
observation therapy medications; and medication nurses did not follow CCHCS care
guide when administering Suboxone medication because the nurses did not provide
counseling for 30 seconds to ensure the Suboxone medication adhered to the patient’s
mouth.
Pharmacy Protocols
Staff 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%).
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Cycle 7, California Rehabilitation Center | 53
The PIC correctly accounted for narcotic medications stored in CRC’s pharmacy (MIT
7.111, 100%).
We reviewed eight 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 followed 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
CRC, the OIG did not find any applicable medication errors (MIT 7.998).
At the time of our inspection, CRC did not have a dedicated restrictive housing unit (MIT
7.999).
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Cycle 7, California Rehabilitation Center | 54
Compliance Testing 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
3 17 5 15.0%
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
24 1 0 96.0%
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 12 8 4 60.0%
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
23 2 0 92.0%
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 4 3 0 57.1%
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 8 1 3 88.9%
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 5 3 44.4%
storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications: Does the
institution keep nonnarcotic medication storage locations free of contamination in 4 5 3 44.4%
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 9 0 3 100%
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 0 6 6 0
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 6 66.7%
patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering medications 1 5 6 16.7%
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?
8 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?
(7.998) for discussion of this test.
Pharmacy: For Information Purposes Only: Do patients in restricted housing units This is a nonscored test. Please see the indicator
have immediate access to their KOP prescribed rescue inhalers and nitroglycerin
medications? (7.999) for discussion of this test.
Overall percentage (MIT 7): 69.5%
Source: The Office of the Inspector General medical inspection results.
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Table 14. Other Tests Related to Specialized Services
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 9 2 14 81.8%
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 N/A N/A N/A N/A
required documents? (6.101)
Patients prescribed TB medication: Did the institution administer the
23 2 0 92.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 11 14 0 44.0%
medication? (9.002)
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 5 5 0 50.0%
within required time frames? (13.003)
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical and nursing leadership should analyze the challenges in
ensuring that chronic care, hospital discharge, and en route patients
receive their medications timely and without interruption and
implement remedial measures as appropriate.
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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
patients out quickly. The OIG rated this indicator solely according to the compliance
score. Our case review clinicians do not rate this indicator.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (74.6%)
CRC had a mixed performance in preventive services. Staff performed well in
administering TB medications, screening patients annually for TB, offering patients an
influenza vaccine for the most recent influenza season, and offering colorectal cancer
screening for patients from ages 45 through 75. However, CRC performed poorly in
monitoring patients taking prescribed TB medications and in offering required
immunizations for chronic care patients. The OIG rated this indicator inadequate.
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Compliance Testing Results
Table 15. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
23 2 0 92.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the patient
per policy for the most recent three months he or she was on the 11 14 0 44.0%
medication? (9.002)
Annual TB screening: Was the patient screened for TB within the last year?
25 0 0 100%
(9.003)
Were all patients offered an influenza vaccination for the most recent
24 1 0 96.0%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the patient
25 0 0 100%
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 11 12 15.4%
Are patients at the highest risk of coccidioidomycosis (Valley Fever)
N/A N/A N/A N/A
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 74.6%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should determine the challenges in ensuring
nursing staff properly document the monitoring of patients taking
TB medications and take remedial measures as appropriate.
• Medical leadership should analyze the challenges related to the
untimely provision of preventive vaccines to chronic care patients
and implement remedial measures as appropriate.
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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
CRC’s overall nursing care was sufficient. Compared with Cycle 6, OIG clinicians found
more nursing deficiencies in fewer nursing encounters. While the majority of these
deficiencies were minor and did not place patients at significant risk of harm, our
clinicians identified opportunities for improvement in several areas, such as nursing
assessments, as detailed below. Considering all these factors, the OIG rated this indicator
adequate.
Case Review Results
We reviewed 157 nursing encounters in 42 cases. Of the nursing encounters we reviewed,
76 occurred in the outpatient setting, and 38 were nursing sick call requests. We
identified 57 overall nursing performance deficiencies, five of which were significant.31
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 frequently provided timely and appropriate care. OIG clinicians identified 26
outpatient nursing deficiencies, which included a pattern of incomplete clinically
31 Deficiencies occurred in cases 1–3, 10–17, 22, 25, 27–34, and 41–45. Significant deficiencies occurred in cases 14, 15, 17,
and 43.
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relevant assessments. Of those, one was considered significant.32 The following are
examples of both the significant deficiencies and deficiency patterns we identified:
• In case 14, the sick call nurse evaluated a patient with swelling
around the eyes, as well as redness, tearing, and a sluggish right eye
pupil reaction. However, rather than conduct a co-consult or notify
the provider, the nurse requested a provider follow-up in 14 days
instead.
• In case 28, the patient complained of a very strong, worsening pain
in the abdomen. The nurse did not assess for abdominal tenderness,
listen to bowel sounds, or inquire about the last bowel movement.
• In case 32, the diabetic patient complained of bilateral foot pain and
requested orthopedic shoes. However, the nurse did not inquire
about the date of onset of the pain and did not assess foot pulses or
sensation.
• In case 41, the patient complained of intermittent right earache and
decreased hearing for two months. Although the nurse documented
the tympanic membranes were intact, the nurse did not describe the
appearance.33 Additionally, the nurse did not obtain complete vital
signs.
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. Nurses often documented their assessment findings and interventions
satisfactorily. However, the following are examples of outpatient documentation
deficiencies:
• In cases 2, 12, 13, and 16, nurses did not document descriptions of
patient gait, although the assessments were clinically relevant.
• In case 32, the nurse evaluated the patient for a new infected scab on
the back, which the nurse described as an “illegal tattoo.” However,
the nurse did not document the localization of the infection on the
lower back and did not document the measurement or size of the
infected scab.
Emergency Services
OIG clinicians reviewed 17 urgent or emergent events and found nine nursing
deficiencies. Nurses responded promptly to emergent events. However, nurses showed
32 Outpatient nursing deficiencies occurred in cases 1–2, 10–16, 28–34, and 41–42. A significant nursing
deficiency occurred in case 14.
33 The tympanic membrane is also known as the eardrum, a thin tissue layer which separates from the middle
ear from the external ear.
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opportunities for improvement with assessments. Please refer to the Emergency Services
indicator for further details.
Hospital Returns
OIG clinicians reviewed 12 nursing events involving returns from off-site hospitals or
emergency rooms. OIG clinicians identified five nursing deficiencies, one of which was
significant.34 The nurses mostly performed sufficient nursing assessments; however,
there were opportunities for improvement with reconciliation of hospital recommended
medications. Please refer to the Medication Management indicator for further details.
Transfers
OIG clinicians reviewed 13 cases involving transfer-in and transfer-out processes. OIG
clinicians did not find any patterns of deficiencies for the transfer-in process. However,
in the transfer-out process, OIG clinicians found nurses did not always document the
number or type of medications transferred out with the patient or document notifying the
receiving institution of pending specialty consultations. Please refer to the Transfers
indicator for further details.
Specialized Medical Housing
OIG clinicians reviewed four cases with a total of 55 events, 20 of which were nursing
encounters. In the OHU, OIG clinicians found nurses generally provided good care.
Please refer to the Specialized Medical Housing indicator.
Specialty Services
OIG clinicians reviewed five cases with a total of 83 events, 18 of which included nurse
evaluations prior to a procedure or upon their return from an off-site specialist
appointment. OIG clinicians identified five nursing deficiencies related to specialty
services. Although OIG clinicians did not find any deficiency patterns, in one case, on
two separate occasions, the nurse assessments were not thorough. Please refer to the
Specialty Services indicator for additional details. The following is an example:
• In case 14, this patient had two appointments with an off-site
ophthalmologist. However, upon return, the nurses did not complete
an objective eye assessment to include the appearance of the eyes or
indicate if there were any problems.
Medication Management
OIG clinicians reviewed 117 events involving medication management. Nurses generally
administered medications as ordered; however, they had challenges with medication
reconciliation for patients returning from off-site hospitalizations. In addition, OIG
clinicians found deficiencies with gaps or timeliness of delivery as it relates to
medication administration. We discuss this further in the Medication Management
indicator.
34 Deficiencies occurred in cases 2, 15, 17, and 43. A significant deficiency occurred in case 15.
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Clinician On-Site Inspection
Our clinicians spoke with nurses and managers in the TTA, OHU, R&R, specialty clinics,
outpatient clinics, and medication areas. We observed several well-attended, organized
huddles with good staff participation. We found clinic staff knowledgeable and familiar
with their patients. Clinic nurses reported varying numbers of patients scheduled each
day, related to new patients arriving to the institution. The clinic nurses reported sick
call requests ranged from 12 to 22 per day. The staff reported the biggest challenge was
the volume of appointments. Nursing staff also acknowledged new leadership, and most
nurses reported generally good morale; although, some nurses indicated morale could
still improve.
We interviewed two LVN care coordinators. They reported CRC had four LVN care
coordinators who were responsible for screenings, tracking dashboard measures, patient
education, vaccinations, preparing documentation for review by the providers prior to
chronic care appointments, offering medications, and reporting information in the
nursing huddles.
We discussed some of our case findings with nursing leadership and they informed us
they had already self-identified some areas for improvement. The CNE provided various
audit tools for the sick call process, the OHU, wound care, and return from higher level
of care and reported utilizing their “OIG monthly metrics” as guidance. In addition, the
CNE reported implementing a staff survey to assist in identifying areas of need and
promoting consistent staff engagement. Our clinicians reviewed staff training files and
recent education and trainings, which included nursing documentation, full assessments,
protocol competencies, and annual nursing skills.
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Recommendations
• Nursing leadership should determine the root cause of challenges
preventing nurses from performing complete assessments and
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
As in Cycle 6, CRC providers delivered acceptable care. Providers generally made
appropriate evaluations and correctly diagnosed medical conditions. They worked with
case management teams to manage chronic conditions and referred patients
appropriately to specialists for a higher level of care when needed. The OIG rated this
indicator adequate.
Case Review Results
OIG clinicians reviewed 88 medical provider encounters and identified 29 deficiencies,
one of which was significant.35 In addition, our clinicians examined the quality of care in
19 comprehensive case reviews. Of these 19 cases, we found 18 cases were adequate and
one was inadequate.
Outpatient Assessment and Decision-Making
Providers generally made appropriate assessments and sound medical decisions for their
patients. Most of the time, providers diagnosed medical conditions correctly, ordered
appropriate tests, and referred their patients to specialists when needed. However, our
clinicians identified 16 deficiencies related to poor medical assessment and decision-
making, one of which was significant.36 The following is an example:
• In case 14, the provider assessed the patient who complained of loss
of appetite for one month and weight loss. The provider did not
evaluate for significant weight loss of 18.6 pounds within a span of a
month, did not perform a physical examination, and did not order
35 Deficiencies occurred in cases 1, 4–9, 13–19, 21, 43, and 45. A significant deficiency occurred in case 14.
36 Deficiencies occurred in cases 4, 8, 13, 14, and 16–19. A significant deficiency occurred in case 14.
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laboratory tests. Instead, the provider ordered high calorie lipid-
based nutrient supplement for the patient who was prediabetic.37
Specialized Medical Housing
Providers generally delivered good care in the OHU. However, we identified four
deficiencies related to provider care in the OHU. The following is an example:
• In case 45, the nurse co-consulted the provider on call for a patient in
OHU, who had watery diarrhea three times a day for two days while
taking multiple oral antibiotics, doxycycline and cefdinir. The
provider prescribed anti-motility medication, Imodium AD. Having
diarrhea while being on multiple antibiotics may indicate an
infection with a highly contagious bacteria, Clostridium difficile.
The provider should have considered placing the patient with
suspected Clostridium difficile infection on contact precautions
pending further diagnostic evaluation.
We further discuss specialized medical housing provider performance in the Specialized
Medical Housing indicator.
Review of Records
Providers performed well in reviewing medical records and addressing discharge
recommendations for patients returning from hospitalizations. We identified two
deficiencies.38 The following is an example:
• In case 14, the provider evaluated the patient following a
hospitalization for dehydration, an abnormal pancreas, and multiple
significant laboratory abnormalities. The provider endorsed the
hospital discharge report, which recommended to discontinue
diuretic medication, refer to a gastroenterologist, and order CT
imaging of the abdomen. However, the provider did not refer to a
gastroenterology specialist, order the CT of abdomen, or document
the rationale.
Providers also generally performed well in reviewing patients’ MARs and renewing
patients’ medications timely. We found one deficiency related to a provider’s incomplete
review of the MAR for a patient who returned from the hospital as described below:
• In case 45, the provider assessed the patient for OHU admission
history and physical examination after the patient had a knee
surgery. The provider documented the patient was on prophylactic
blood thinner to prevent postoperative leg clots. However, the
provider did not thoroughly review the MAR Summary, which
documented the patient was not taking any blood thinners.
37 The high calorie lipid-based nutrient supplement can have a significant amount of carbohydrates, increasing
sugar levels.
38 Deficiencies occurred in cases 14 and 45.
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Emergency Care
Providers usually managed patients in the TTA with urgent or emergent conditions
appropriately. In addition, providers were available for consultation with TTA staff. We
identified three deficiencies related to emergency care, none of which were significant.39
The following is an example:
• In case 16, a patient who had underlying anemia was assessed by the
provider in the TTA for shortness of breath and having black stools
for the last two to three weeks. The provider ordered a fecal
immunochemical test and blood count to assess for possible
bleeding. However, the provider did not stop the medication, aspirin,
which may increase the risk of bleeding.
We discussed further in the Emergency Services indicator.
Chronic Care
In most instances, providers appropriately managed patients’ chronic health conditions,
such as hypertension, diabetes, asthma, hepatitis C infection, and cardiovascular disease.
CRC has an effective case management team approach to managing patients with
diabetes. Nursing staff collaborated with providers as a team, focusing their care of
diabetes by monitoring sugars, adjusting medications including insulin to reach glycemic
goals, and educating patients. However, we identified two deficiencies related to the
management of diabetes.40 The following is an example:
• In case 6, the provider assessed a patient with uncontrolled blood
sugar levels. The patient refused medications but agreed to further
education with diabetic classes and dietician consultations.
However, the provider requested dietician services to occur in three
months instead of an earlier referral for the patient’s uncontrolled
diabetes.
Specialty Services
Providers appropriately referred patients for specialty consultation when needed. When
specialists made recommendations, providers usually followed the recommendations
appropriately and reviewed specialty reports timely. We identified two deficiencies
related to the provider not following specialists’ recommendations timely.41 The
following is an example:
• In case 4, the cardiologist evaluated the patient and recommended
obtaining an echocardiogram and to follow up within four weeks.
However, the provider ordered a follow-up referral more than seven
weeks later and did not document a rationale for the delay.
39 Deficiencies occurred in cases 1, and 15–17.
40 Deficiencies occurred in cases 6 and 7.
41 Deficiencies occurred in cases 4 and 9.
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We discuss providers’ specialty performance further in the Specialty Services indicator.
Documentation Quality
Providers generally documented outpatient encounters on the same day of the encounter.
Documentation is important because it shows the provider’s thought process during
clinical decision-making. When contacted by nurses, providers did not always document
the interactions. Our clinicians found three undocumented interactions.42 The following
is an example:
• In case 17, a nurse co-consulted with the provider for the patient
who presented with swelling of the left forearm, two skin abscesses,
and chest pain. The provider recommended an oral antibiotic and to
follow up with a nurse in three days. However, the provider did not
document this in the progress note.
Provider Continuity
CRC offered good provider continuity. Providers were assigned to specific clinics taking
care of assigned patients.
Patient Notification Letter
We found providers performed poorly in communicating diagnostic results to their
patients with complete patient test result notification letters. These deficiencies are
discussed in the Diagnostic Services indicator.
Clinician On-Site Inspection
At the on-site inspection, OIG clinicians attended meetings and spoke with medical
leadership and providers. We attended the weekly provider meeting, with good
participation by medical leadership and clinic providers. The physician on call reported
on significant overnight events including TTA evaluations and required follow-up cases.
We also observed morning huddles, which were well attended. Staff reported on TTA
events, return from higher level of care, off-site specialty appointments, significant
laboratory results, expiring prescriptions, missed medications, medication concerns,
policy alerts, status of COVID-19 tests, durable medical equipment (DME) requests, and
any hunger strikes. Staff assigned providers to specified clinics to ensure patients’
continuity of care. Each provider was scheduled to see seven to 13 patients during the
inspection. The providers expressed they were well supported from medical leadership.
42 Deficiencies occurred in cases 15 and 17.
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Recommendations
• Medical leadership should analyze the challenges in provider
documentation for patient-related calls, emergency phone calls,
nurse co-consultations, provider orders, and management plans in
the EHRS and implement remedial measures as indicated.
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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. Our clinicians also interpreted relevant compliance results and incorporated them
into this indicator. At the time of our inspection, CRC’s specialized medical housing
consisted of an outpatient housing unit (OHU).
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Adequate Inadequate (67.5%)
As in Cycle 6, CRC performed satisfactorily in case review for this indicator. While
providers and nurses provided good care, we identified opportunities for improvement
related to provider evaluations, nursing assessments, and medication management. After
reviewing all aspects, the OIG rated the case review component of this indicator
adequate.
Compared with Cycle 6, compliance testing showed CRC performed poorly overall in this
indicator. Nurses performed excellently in completing initial assessments within the
required time frame. In contrast, CTC showed poor medication continuity for newly
admitted patients to the OHU and a poor provider completion rate for history and
physical examinations within the required time frame. Considering all testing results, the
OIG rated the compliance testing component of this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 55 OHU events that included 15 provider encounters and 20 nursing
encounters. Due to the frequency of nursing and provider contacts in the specialized
medical housing, the OIG bundles up to two weeks of patient care into a single event. We
identified 14 deficiencies, none of which were considered significant.43
Provider Performance
Providers generally delivered satisfactory care. Compliance testing showed providers
occasionally completed admission history and physicals without delay (MIT 13.002,
30.0%). Our clinicians found providers often made appropriate assessments and decisions,
reviewed medical records thoroughly, and addressed specialists’ recommendations
43 Deficiencies occurred in cases 43–45.
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timely. We identified four deficiencies, none of which were significant.44 The following
are examples:
• In case 43, the patient returned from the community hospital with
recommendations to increase the dose of cholesterol medication;
however, the provider did not increase the dose or document the
rationale for not following the recommendation.
• In case 45, the patient complained of frequent diarrhea over an
extended period of time. The initial test for the infectious cause of
the diarrhea was negative. Following infectious disease specialist
recommendations, the providers conducted additional testing for an
infectious toxin as the possible cause; however, the providers did not
consider ordering contact precautions when nurses reported the
patient’s roommates also developed diarrhea.
Nursing Performance
Compliance testing showed OHU nurses frequently performed timely admission
assessments (MIT 13.001, 90.0%). Case reviewers also found nurses completed timely
admission assessments. In addition, OHU nurses conducted regular rounds and generally
provided good care. However, our clinicians found opportunities for improvement in
admission nursing assessments and documentation, as follows:
• In case 45, the nurse did not complete a thorough OHU admission
assessment for the patient who was discharged from the community
hospital. The nurse did not assess for swelling at the surgical site,
listen to the lungs, or check capillary refill.45
• In case 43, on multiple occasions during OHU rounds, the nurses
documented the patient’s skin was intact with no abnormalities;
however, the patient had facial sutures and scattered abrasions.
Medication Administration
OHU staff had a mixed performance in medication administration. Compliance testing
showed half the newly admitted patients received their medications within required time
frames (MIT 13.003, 50.0%). Our clinicians identified three deficiencies related to
medication management.46 This is discussed further in the Medication Management
indicator.
Clinician On-Site Inspection
At the onsite inspection, OIG clinicians toured CRC’s OHU and interviewed OHU staff
and nurses. The OHU contained 10 medical beds, seven of which were occupied at the
44 Deficiencies occurred in cases 43 and 45.
45 Capillary refill is a test that measures changes in blood flow to the tissue. Pressure is applied to the fingernail
bed until white. Then pressure is removed. Return of blood is indicated by the nail turning back to the pink
tissue color. A prolonged duration for the blood to return to the tissue can indicate a medical condition.
46 Deficiencies occurred in cases 43–45.
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time of our inspection. Nurses stated the OHU was staffed with RNs, LVNs, and one
provider. Our clinicians attended a well-organized huddle led by the OHU RN, with input
from the provider and SRN. In further discussions with the OHU nurse, OIG clinicians
were informed this nurse was not the usual assigned OHU nurse; however, this nurse was
knowledgeable and well-versed in the OHU processes. In addition, the nurse shared a
desktop manual that delineated the required shift responsibilities, tasks, and
documentation to be completed each shift.
Compliance On-Site Inspection and Discussion
At the time of the on-site inspection, the OHU had a functional call light communication
system (MIT 13.101, 100%).
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Compliance Testing 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
3 7 0 30.0%
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 5 5 0 50.0%
within required time frames? (13.003)
For specialized health care housing (CTC, SNF, hospice, OHU): Do
specialized health care housing maintain an operational call 1 0 0 100%
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 0 1 N/A
operating procedure or within the required time frames? (13.102)
Overall percentage (MIT 13): 67.5%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should determine the challenges in providers
completing the OHU history and physical examination within the
time frame required by CCHCS policy, and implement remedial
measures as indicated.
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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 (70.5%)
Case review found CRC generally provided satisfactory specialty services for patients.
Providers made appropriate referrals and offered follow-up care after specialty services.
Specialty nurses reviewed specialty service requests and appropriately scheduled patients
for specialty appointments. Although TTA nurses performed acceptable assessments of
patients returning from specialty appointments, case review found opportunities for
improvement with providers’ reviews of specialists’ recommendations. Considering all
factors, the OIG rated the case review component of this indicator adequate.
Compared with Cycle 6, compliance testing showed CRC’s overall performance worsened
in this indicator. CRC’s performance was satisfactory for providing medium- and
routine-priority specialty services and in communicating denials of requests for specialty
services. However, CRC scored low in providing high-priority specialty services and
subsequent follow-up appointments for high-, medium-, and routine-priority specialty
services, as well as in retrieving and endorsing specialty reports. Factoring in all testing
results, the OIG rated the compliance testing component of this indicator inadequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 69 events related to Specialty Services, which included 50
specialty consultations and procedures, one wound care provider specialty encounter, and
18 nursing encounters. We identified 17 deficiencies in this category, three of which were
considered significant.47
Access to Specialty Services
Compliance testing showed patients almost always received specialty services with
routine-priority referrals timely (MIT 14.007 93.3%). Patients often received specialty
services with medium-priority referrals timely (MIT 14.004, 80.0%) but inconsistently
received specialty services with high-priority referrals within the required time frame
(MIT 14.001, 73.3%). CRC did not perform well in providing patients with subsequent
follow-up, routine-priority, medium-priority, and high-priority specialty service
47 Deficiencies occurred in cases 4, 7, 9, 14–16, 19–21, 43, and 45. Significant deficiencies occurred in cases 14,
20, and 43.
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appointments as ordered by the provider (MIT 14.009, 62.5%, MIT 14.006, 57.1% and MIT
14.003, 62.5%). OIG clinicians identified two deficiencies related to specialty
appointments.48 The following is an example:
• In case 45, the provider ordered an infectious disease specialty
referral with a high-priority time frame. However, the specialist
consultation appointment occurred two days late.
Provider Performance
Providers generally ordered appropriate specialty consultations and followed specialty
recommendations. However, compliance testing showed follow-up appointments with
providers after specialty consultations intermittently occurred within required time
frames (MIT 1.008, 59.3%). OIG clinicians identified three deficiencies in which providers
did not endorse specialist reports timely, and four deficiencies in which providers did not
implement specialty recommendations, none of which were significant.49 The following
are examples:
• In case 7, the provider reviewed and endorsed the specialist
consultation report one day late.
• In case 9, the provider endorsed the specialist consultation report.
However, the provider did not follow the specialist’s
recommendations to order a three-month follow-up appointment
and laboratory tests. The provider did not document the rationale for
not following the recommendations.
Nursing Performance
The specialty nurses often reviewed specialty service requests and appropriately
scheduled patients for specialty appointments. TTA nurses generally performed
thorough assessments of patients returning from specialty appointments, reviewed
specialist recommendations, and communicated the recommendations to the
providers. OIG clinicians reviewed 18 nursing encounters related to specialty services
and identified five nursing deficiencies.50 The following is an example:
• In case 16, the patient returned from an off-site specialty cardiology
consultation. The off-site specialist canceled the scheduled
procedure and performed an alternative procedure. However, the
receiving nurse and specialty nurse did not notify the provider of the
procedure change.
This is discussed further in the Nursing Performance indicator.
48 Deficiencies occurred in cases 14 and 45.
49 Late endorsement deficiencies occurred in cases 7 and 14. Providers did not implement specialists’
recommendations in case 4, 9, 19, and 45.
50 Deficiencies occurred in cases 14–16.
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Health Information Management
Compliance testing showed that CRC performed well in scanning specialty reports
within required time frames (MIT 4.002, 86.7%). However, the providers needed
improvement in reviewing specialty reports timely for routine-priority (MIT 14.008,
53.3%), medium-priority (MIT 14.005, 46.2%), and high-priority (MIT 14.002, 66.7%). Our
clinicians identified two deficiencies related to scanning, retrieving, or reviewing
specialty reports, one of which was significant as described below:51
• In case 20, the provider ordered a high-priority specialty referral for
an interventional radiologist. This specialist performed an
ultrasound-guided biopsy of the patient’s bilateral thyroid nodules to
evaluate for cancer. The procedure report was scanned into EHRS;
however, the report was not forwarded to the provider for review.
Clinician On-Site Inspection
We discussed the specialty referral management process with medical and nursing
leadership, providers, specialty nurses, and the utilization management nurse. CRC offers
on-site specialty services including hearing aid evaluations, physical therapy, respiratory
therapy, sleep studies, orthotics, optometry, and ophthalmology.
Specialty staff reported that specialty nurses reviewed referral requests, contacted
specialists for available appointments, and scheduled the appointments. They described
the process of obtaining off-site specialty appointments as a team process. Specifically,
the utilization management nurse notified the off-site specialty nurse of approved
Requests for Services (RFS), and the off-site specialty nurse processed the related
documentation. The off-site specialty nurse utilized a filing cabinet tracking system
organized by month and separated appointments as pending, scheduled, and completed.
The off-site specialty nurse reported three nurses were cross trained in the position, and
directions for using the tracking system were available. In addition, medical records staff
were tasked with obtaining any consultation reports that did not accompany patients
upon their return. The CRC specialty team reported challenges with obtaining high-
priority appointments within compliance dates, due to off-site specialty clinic
availability.
We discussed the process for ensuring specialty recommendations. Nursing leadership
indicated that, as a result of the clinicians’ identification in the case reviews of
deficiencies this cycle with high-priority RFS follow-up appointments, leadership
immediately implemented a change in their process. In the new process, the nurse who
assessed the patient after a high-priority specialty referral would be the responsible
person to schedule the follow-up provider appointment to occur within five calendar
days. The patient care team would schedule the follow-up provider appointment for
medium- and low-priority specialty referrals.
51 Deficiencies occurred in cases 20 and 21. A significant deficiency occurred in case 21.
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Compliance Testing Results
Table 17. Specialized 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 11 4 0 73.3%
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 10 5 0 66.7%
frame? (14.002)
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 5 3 7 62.5%
(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 12 3 0 80.0%
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 7 2 46.2%
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? 4 3 8 57.1%
(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 14 1 0 93.3%
Service? (14.007)
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required time 8 7 0 53.3%
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? 5 3 7 62.5%
(14.009)
For endorsed patients received from another CDCR institution: If the patient
was approved for a specialty services appointment at the sending
N/A N/A N/A N/A
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
20 0 0 100%
services within required time frames? (14.011)
Following the denial of a request for specialty services, was the patient
16 4 0 80.0%
informed of the denial within the required time frame? (14.012)
Overall percentage (MIT 14): 70.5%
Source: The Office of the Inspector General medical inspection results.
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Table 18. Other Tests Related to Specialized Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up visits
16 11 18 59.3%
occur within required time frames? (1.008) *
Are specialty documents scanned into the patient’s electronic health record
26 4 15 86.7%
within five calendar days of the encounter date? (4.002)
* CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician follow-up visits
following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty services or when staff ordered
follow-ups. The OIG continued to test the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should identify the cause of challenges in timely
completing follow-up specialty appointments and high-priority
specialty appointments and should continue to implement remedial
measures as appropriate.
• Medical leadership should determine the cause of challenges with timely
provider review of specialty consultation 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. Our case review clinicians do not rate this indicator.
Because none of the tests in this indicator directly affected clinical patient care (it is a
secondary indicator), the OIG did not consider this indicator’s rating when determining
the institution’s overall quality rating.
Ratings and Results Overview
Case Review Rating Compliance Rating and Score
Not Applicable Inadequate (64.2%)
CRC’s performance was mixed in this indicator as the institution scored well in some
applicable tests yet needed to improve in several areas. The EMRRC did not review cases
timely and only occasionally completed the required checklists. In addition, the
institution conducted medical emergency response drills with inconsistent
documentation and only occasionally completed drill forms timely. Lastly, physician
managers did not complete annual appraisals in a timely manner while nurse managers
did not ensure newly hired nurses received the required onboarding training. These
findings are set forth in the table on the next page. Overall, the OIG rated this indicator
inadequate.
Compliance Testing Results
Nonscored Results
At CRC, the OIG did not find any applicable adverse sentinel events requiring root cause
analysis during our inspection period (MIT 15.001).
The institution did not have any reported deaths during our inspection period
(MIT 15.998).
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Compliance Testing 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 monthly?
5 1 0 83.3%
(15.002)
For Emergency Medical Response Review Committee (EMRRC) reviewed
cases: Did the EMRRC review the cases timely, and did the incident
0 12 0 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 1 2 0 33.3%
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
0 0 0 N/A
CCHCS Mortality Case Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
9 1 0 90.0%
administer medications? (15.104)
Did physician managers complete provider clinical performance appraisals
0 4 1 0
timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 7 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR), Basic Life
Support (BLS), and Advanced Cardiac Life Support (ACLS) certifications? 2 0 1 100%
(15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy maintain a 5 0 2 100%
valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
Agency (DEA) registration certificates, and did the pharmacy maintain valid 1 0 0 100%
Automated Drug Delivery System (ADDS) licenses? (15.109)
Did nurse managers ensure their newly hired nurses received the required
0 1 0 0
onboarding and clinical competency training? (15.110)
Did the CCHCS Death Review Committee process death review reports
This is a nonscored test. Please refer to the
timely? Effective 05/2022: Did the Headquarters Mortality Case Review
discussion in this indicator.
process mortality review reports timely? (15.998)
What was the institution’s health care staffing at the time of the OIG medical This is a nonscored test. Please refer to Table 3
inspection? (15.999) for CCHCS-provided staffing information.
Overall percentage (MIT 15): 64.2%
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 CRC
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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. CRC Case Review Sample Sets
Sample Set Total
Anticoagulation 2
CTC/OHU 3
Diabetes 3
Emergency Services – CPR 1
Emergency Services – Non-CPR 2
High Risk 6
Hospitalization 4
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 15
Specialty Services 3
45
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Table B–2. CRC Case Review Chronic Care Diagnoses
Sample Set Total
Anemia 2
Anticoagulation 5
Arthritis/Degenerative Joint Disease 6
Asthma 5
Cardiovascular Disease 4
Chronic Kidney Disease 3
Chronic Pain 13
Cirrhosis/End-Stage Liver Disease 1
COPD 3
COVID-19 7
Deep Venous Thrombosis/Pulmonary Embolism 3
Diabetes 10
Gastroesophageal Reflux Disease 4
Hepatitis C 7
Hyperlipidemia 21
Hypertension 15
Mental Health 22
Migraine Headaches 1
Seizure Disorder 1
Sleep Apnea 3
Substance Abuse 16
Thyroid Disease 2
154
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Table B–3. CRC Case Review Events by Program
Diagnosis Total
Diagnostic Services 392
Emergency Care 29
Hospitalization 21
Intrasystem Transfers In 17
Intrasystem Transfers Out 9
Outpatient Care 279
Specialized Medical Housing 55
Specialty Services 79
881
Table B–4. CRC Case Review Sample Summary
Sample Set Total
MD Reviews Detailed 20
MD Reviews Focused 3
RN Reviews Detailed 12
RN Reviews Focused 28
Total Reviews 63
Total Unique Cases 45
Overlapping Reviews (MD & RN) 18
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Appendix C: Compliance Sampling Methodology
California Rehabilitation Center
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 24 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 or CMPs only)
• Randomize
• Abnormal
MITs 2.007 – 009 Laboratory STAT 9 Quest • Appt. date (90 days – 9 months)
• Order name (CBC 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 24 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 24 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 11 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 0 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 24 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 7 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 8 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication error
reports (recent 12 months)
MIT 7.999 Restricted Unit N/A at this On-site active • KOP rescue inhalers & nitroglycerin
KOP Medications
Institution
medication listing medications for IPs housed in
restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001 – 007 Recent Deliveries N/A at this OB Roster • Delivery date (2 – 12 months)
institution • Most recent deliveries (within date
range)
Pregnant Arrivals N/A at this OB Roster • Arrival date (2 – 12 months)
institution • Earliest arrivals (within date range)
Preventive Services
MITs 9.001 – 002 TB Medications 25 Maxor • Dispense date (past 9 months)
• Time period on TB meds (3 months
or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior to
Annual Screening inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior to
Vaccinations inspection)
• Randomize
• Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior to
Screening inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. prior to
institution inspection)
• Date of birth (age 52 – 74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs. prior to
institution inspection)
• Date of birth (age 24 – 53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP — any risk level)
• Randomize
• Condition must require vaccination(s)
MIT 9.009 Valley Fever N/A at this Cocci transfer • Reports from past 2 – 8 months
institution status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
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Cycle 7, California Rehabilitation Center | 99
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, and radiology 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, and radiology 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, and radiology services
• Randomize
MIT 14.010 Specialty Services 0 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3 – 9 months)
• Randomize
MITs 14.011 – 012 Denials 20 InterQual • Review date (3 – 9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events events report (2 – 8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC 12 EMRRC meeting • Monthly meeting minutes
minutes (6 months)
MIT 15.004 LGB N/A at this LGB meeting • Quarterly meeting minutes
institution minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
MIT 15.103 Death Reports 0 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations (continued)
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 5 On-site provider • All required performance evaluation
Evaluation Packets evaluation files documents
MIT 15.106 Provider Licenses 7 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 0 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
Office of the Inspector General, State of California Inspection Period: August 2022 – January 2023 Report Issued: September 2024
Cycle 7
Medical Inspection Report
for
California Rehabilitation Center
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Neil Robertson
Chief Deputy Inspector General
STATE of CALIFORNIA
September 2024
OIG