OIG
Calipatria State Prison Cycle 6 Medical Inspection Report
Read the report at CDCR ↗
Amarik K. Singh, Inspector General Neil Robertson, Chief Deputy Inspector General
OFFICE of the
OIG
INSPECTOR GENERAL
Independent Prison Oversight August 2022
Cycle 6
Medical Inspection
Report
Calipatria State
Prison
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please contact Shaun Spillane, Public Information Officer,
at 916-255-1131.
Cycle 6, Calipatria State Prison | iii
Contents
Introduction
1
Summary
3
Overall Rating: Adequate 3
Medical Inspection Results
7
Deficiencies Identified During Case Review 7
Case Review Results 7
Compliance Testing Results 8
Population-Based Metrics 9
HEDIS Results 9
Recommendations 12
Access to Care 15
Diagnostic Services 21
Emergency Services 26
Health Information Management 30
Health Care Environment 35
Transfers 43
Medication Management 50
Preventive Services 58
Nursing Performance 61
Provider Performance 68
Specialized Medical Housing 73
Specialty Services 79
Administrative Operations 85
Appendix A: Methodology 88
Case Reviews 89
Compliance Testing 92
Indicator Ratings and the Overall Medical Quality Rating 93
Appendix B: Case Review Data 94
Appendix C. Compliance Sampling Methodology 97
California Correctional Health Care Services’ Response 105
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Illustrations
Tables
1. CAL Summary Table 3
2. CAL Policy Compliance Scores 4
3. CAL Master Registry Data as of October 2021 5
4. CAL Health Care Staffing Resources as of April 2021 6
5. CAL Results Compared With State HEDIS Scores 11
6. Access to Care 18
7. Other Tests Related to Access to Care 19
8. Diagnostic Services 24
9. Health Information Management 32
10. Other Tests Related to Health Information Management 33
11. Health Care Environment 41
12. Transfers 47
13. Other Tests Related to Transfers 48
14. Medication Management 55
15. Other Tests Related to Medication Management 56
16. Preventive Services 59
17.Specialized Medical Housing 77
18. Specialty Services 82
19.Other Tests Related to Specialty Services 83
20. Administrative Operations 86
A–1. Case Review Definitions 89
B–1. CAL Case Review Sample Sets 94
B–2. CAL Case Review Chronic Care Diagnoses 95
B–3. CAL Case Review Events by Program 96
B–4. CAL Case Review Sample Summary 96
Figures
A-1. Inspection Indicator Review Distribution for CAL 88
A–2. Case Review Testing 91
A–3. Compliance Sampling Methodology 92
Photographs
1. Indoor Waiting Area in B Clinic 36
2. Patient Seen Sitting in B Clinic 36
3. Expired Medical Supplies Dated June 25, 2020 37
4. Expired Automated External Defibrillator in the OHU Dated December 14, 2018 37
5. Expired Medical Supply Dated November 2017 38
6. Medical Supplies Stored Directly on the Floor 38
7. Previously Sterilized Reusable Invasive Medical Equipment Missing Date Stamp and Initials 39
Cover: Rod of Asclepius courtesy of Thomas Shafee
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Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the
Inspector General (the OIG) is responsible for periodically reviewing and
reporting on the delivery of the ongoing medical care provided to incarcerated
persons1 in the California Department of Corrections and Rehabilitation (the
department).2
In Cycle 6, the OIG continues to apply the same assessment methodologies used
in Cycle 5, including clinical case review and compliance testing. These methods
provide 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. This information helps to assess the performance of
the institution in providing sustainable, adequate care.3
We continue to review institutional care using 15 indicators, as in prior cycles.
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).4 We determine a total compliance score for each applicable
indicator and consider the MIT scores in our overall assessment of the
institution’s performance. In addition, our clinicians complete document reviews
of individual cases and perform on-site inspections, which include interviews
with staff.
In reviewing cases, our clinicians examine whether providers 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.5 At the same time, our clinicians examine
whether the institution’s medical system mitigated the error. The OIG rates the
indicators as proficient, adequate, or inadequate.
1 In this report, we use the terms patient and patients to refer to incarcerated persons.
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, we continue to offer selected
Healthcare Effectiveness Data and Information Set (HEDIS) measures for comparison purposes.
4 The department regularly updates its policies. We update our policy-compliance testing to reflect
the department’s updates and changes.
5 If we learn a patient needs immediate care, we notify the institution’s chief
executive officer.
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The OIG has adjusted Cycle 6 reporting in two ways. First, commencing with
this reporting period, we interpret compliance and case review results together,
providing a more holistic assessment of the care; and second, we consider
whether institutional medical processes lead to identifying and correcting
provider or system errors. Our review assesses the institution’s medical care on
both system and provider levels.
As we did during Cycle 5, our office is continuing 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 our
Cycle 6 inspection Calipatria State Prison (CAL), the receiver had not delegated
this institution back to the department.
We completed our sixth inspection of CAL, and this report presents our
assessment of the health care provided at this institution during the inspection
period between April 2021 and September 2021.6 We completed our on-site
inspections during the coronavirus (COVID-19) pandemic and also obtained the
data used for our analysis during the period of the pandemic.7
Calipatria State Prison (CAL) is located in the city of Calipatria, in Imperial
County. The institution opened in 1992. The institution runs four main medical
clinics and treats patients needing urgent or emergent care in its triage and
treatment area (TTA). CAL also treats patients who require assistance with the
activities of daily living, but do not require a higher level of inpatient care: those
patients are treated in the institution’s outpatient housing unit (OHU).
CAL has been designated by 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 generally healthy patient population.
6 Samples are obtained per case review methodology shared with stakeholders in prior cycles. The
case reviews include death reviews between July 2020 and June 2021, emergency noncardiopulmonary
resuscitation (non-CPR) reviews between April 2021 and October 2021, CPR reviews between
December 2020 and January 2021, diabetes reviews between March 2021 and September 2021,
anticoagulation reviews between April 2021 and November 2021, high risk reviews between April
2021 and October 2021, hospitalization reviews between April 2021 and November 2021, specialty
reviews between April 2021 and October 2021, transfer reviews between March 2021 and July 2021,
and RN sick call reviews between March 2021 and August 2021.
7 As of May 13, 2022, the department reports on its public tracker that 82% of its incarcerated
population at CAL is fully vaccinated while 79% of CAL staff are fully vaccinated:
www.cdcr.ca.gov/covid19/population-status-tracking/.
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Summary
The OIG completed the Cycle 6 inspection of CAL in February 2022.
Our inspectors monitored the institution’s delivery of medical care
that occurred between April 2021 and September 2021.
We rated the overall quality of health care at CAL as adequate. We list
the individual indicators and ratings applicable for this institution in
Table 1 below.
Table 1. CAL Summary Table
Cycle 6 Cycle 6 Cycle 6 Change
Health Care Indicators Case Review Compliance Overall Since
Rating Rating Rating Cycle 5
Access to Care Adequate Adequate Adequate
Diagnostic Services Indequate Inadequate Inadequate
Emergency Services Adequate N/A Adequate
Health Information Management Adequate Inadequate Adequate
Health Care Environment N/A Inadequate Inadequate
Transfers Adequate Inadequate Inadequate
Medication Management Adequate Inadequate Inadequate
Prenatal and Postpartum Care N/A N/A N/A N/A
Preventive Services N/A Adequate Adequate
Nursing Performance Adequate N/A Adequate
Provider Performance Adequate N/A Adequate
Reception Center N/A N/A N/A N/A
Specialized Medical Housing Inadequate Adequate Inadequate
Specialty Services Adequate Adequate Adequate
Administrative Operations† N/A Inadequate Inadequate
* The symbols in this column correspond to changes that occurred in indicator ratings between the medical inspections
conducted during Cycle 5 and Cycle 6. The equals sign means there was no change in the rating. The single arrow means
the rating rose or fell one level, and the double arrow means the rating rose or fell two levels (green, from inadequate to
proficient; pink, from proficient to inadequate).
† Administrative Operations is a secondary indicator and is not considered when rating the institution’s overall medical
quality.
Source: The Office of the Inspector General medical inspection results.
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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 346
patient records and 1,013 data points and used the data to answer 89 policy
questions. In addition, we observed CAL processes during an on-site inspection
in November 2021. Table 2 below lists CAL average scores from Cycles 4, 5,
and 6.
Table 2. CAL Policy Compliance Scores
100%–85.0% 84.9%–75.0% 74.9%–0
Medical Cycle 4 Cycle 5 Cycle 6
Inspection Policy Compliance Category Average Average Average
Tool (MIT) Score Score Score
1 Access to Care 88.7% 73.6% 78.8%
2 Diagnostic Services 85.6% 78.1% 56.2%
4 Health Information Management 81.6% 89.6% 74.8%
5 Health Care Environment 80.9% 57.8% 48.5%
6 Transfers 80.7% 72.8% 70.6%
7 Medication Management 71.4% 58.4% 65.3%
8 Prenatal and Postpartum Care N/A N/A N/A
9 Preventive Services 63.2% 86.5% 80.9%
12 Reception Center N/A N/A N/A
13 Specialized Medical Housing 98.0% 93.3% 75.0%
14 Specialty Services 85.6% 89.1% 79.6%
15 Administrative Operations* 81.3% 84.8% 74.3%
* In Cycle 4, there were two secondary (administrative) indicators, and this score reflects the average
of those two scores. In Cycle 5 and moving forward, the two indicators were merged into one, with
only one score as the result.
Source: The Office of the Inspector General medical inspection results.
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The OIG clinicians (a team of physicians and nurse consultants) reviewed 47
cases, which contained 890 patient-related events. After examining the medical
records, our clinicians conducted a follow-up on-site inspection in February 2022
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 19 adequate
and one inadequate. Our physicians found one adverse event during this
inspection.
The OIG then considered the results from both case review and compliance
testing, and drew overall conclusions, which we report in the 13 health care
indicators.8 Multiple OIG physicians and nurses performed quality control
reviews; their subsequent collective deliberations ensured consistency, accuracy,
and thoroughness. Our OIG clinicians acknowledged institutional structures that
catch and resolve mistakes which may occur throughout the delivery of care. As
noted above, we listed the individual indicators and ratings applicable for this
institution in the CAL Summary Table.
In October 2021, the Health Care Services Master Registry showed that CAL had
a total population of 2,945. A breakdown of the medical risk level of the CAL
population as determined by the department is set forth in Table 3 below.9
Table 3. CAL Master Registry Data as of October 2021
Medical Risk Level Number of Patients Percentage
High 1 8 0.3%
High 2 40 1.4%
Medium 426 14.5%
Low 2,471 83.9%
Total 2,945 100.0%
Source: Data for the population medical risk level were obtained
from the CCHCS Master Registry dated 10-22-21.
8 The indicators for Reception Center and Prenatal Care did not apply to CAL.
9 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
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Based on staffing data the OIG obtained from California Correctional Health
Care Services (CCHCS), as shown in Table 4 below, CAL had zero executive
leadership vacancies, 0.5 primary care provider vacancies, 2.7 nursing supervisor
vacancies, and 1.2 nursing staff vacancies.
Table 4. CAL Health Care Staffing Resources as of April 2021
Executive Primary Care Nursing Nursing
Positions Leadership* Providers Supervisors Staff† Total
Authorized Positions 5.0 6.0 11.7 62.1 84.8
Filled by Civil Service 5.0 5.5 9.0 62.1 81.6
Vacant 0 0.5 2.7 1.2 4.4
Percentage Filled by Civil Service 100.0% 91.7% 76.9% 100.0% 96.2%
Filled by Telemedicine 0 0 0 0 0
Percentage Filled by Telemedicine 0% 0% 0% 0% 0%
Filled by Registry 0 1 0 8 9
Percentage Filled by Registry 0% 16.7% 0% 12.9% 10.6%
Total Filled Positions 5.0 6.5 9.0 70.1 90.6
Total Percentage Filled 100.0% 108.3% 76.9% 112.9% 106.8%
Appointments in Last 12 Months 1 0 1.0 14.0 16.0
Redirected Staff 0 0 0 0 7.0
Staff on Extended Leave‡ 0 0 3.0 1.0 4.0
Adjusted Total: Filled Positions 5.0 6.5 6.0 69.1 86.6
Adjusted Total: Percentage Filled 100% 108.3% 51.3% 111.3% 102.1%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes 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 6 medical inspection preinspection questionnaire received April 2021, from California Correctional
Health Care Services.
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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.10
The OIG identified one adverse event at CAL during the Cycle 6 inspection:
• In case 11, a provider reviewed a laboratory result of a hemoglobin
A1c level of 12.6 percent, consistent with the diagnosis of new onset
diabetes requiring timely treatment. The provider did not schedule a
follow-up visit, as the new onset diabetes was not addressed until
almost three months later. The delay placed the patient at risk for
diabetic complications, such as diabetic ketoacidosis.11
Case Review Results
OIG case reviewers (a team of physicians and nurse consultants) assessed 10 of
the 13 indicators applicable to CAL. Of these 10 indicators, OIG clinicians rated
eight adequate and two 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, 19 were adequate, and one was inadequate. In the 890 events reviewed,
there were 139 deficiencies, 24 of which our clinicians considered to be of such
magnitude that, if left unaddressed, would likely contribute to patient harm.
Our clinicians found the following strengths at CAL:
• The staff performed well with providing appointments with nurses
and specialized medical housing providers.
• The staff provided excellent specialty services for their patients. The
institution performed well in ensuring specialty appointments
occurred within the required time frames.
10 For a further discussion of an adverse event, see Table A-1.
11 Diabetic ketoacidosis is a diabetic complication in which the patient’s body produces excess blood
acids called ketones. This condition can be life-threatening and requires the patient to be hospitalized
for treatment.
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• The nurses delivered excellent care for patients returning from the
community hospital and from specialty services, as they provided
excellent assessments, interventions, and documentation.
Our clinicians found the following weaknesses at CAL:
• Staff performed poorly in completing and communicating laboratory
test results to their patients. The institution did not always retrieve
pathology reports.
• Specialized medical housing nurses did not always provide good
assessments or interventions for their patients. Specialized medical
staff also performed poorly in administering medications.
Compliance Testing Results
Our compliance inspectors assessed 10 of the 13 indicators applicable to CAL. Of
these 10 indicators, we rated four adequate and six inadequate. We tested only
policy compliance in the Health Care Environment, Preventive Services, and
Administrative Operations indicators, as these indicators do not have a case
review component.
CAL demonstrated a high rate of policy compliance in the following areas:
• The institution performed well in offering immunizations to their
patients and providing preventive services, such as influenza
vaccinations, annual screenings for tuberculosis (TB), and colorectal
cancer screenings.
• CAL did well in providing and administering TB medications to
patients.
• Nursing staff at CAL reviewed health care services request forms and
conducted face-to-face encounters within the required time frames.
CAL demonstrated a low rate of policy compliance in the following areas:
• Providers frequently did not communicate results of diagnostic
services timely. Most patient letters communicating these results
were missing the date of the diagnostic service, the date of the
results, and an indication of whether the results were within normal
limits.
• CAL staff frequently failed to maintain medication continuity for
chronic care patients, for patients discharged from the hospital, and
for patients admitted to a specialized medical housing unit. There
was also poor medication continuity for patients who transferred
into the institution and for patients who had a temporary layover at
CAL.
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• The institution did not always ensure approved specialty services
were provided timely to patients upon their arrival at CAL.
• Clinical staff did not consistently follow universal hand hygiene
precautions before or after patient encounters.
• Nursing staff did not regularly inspect and replenish medical
supplies, emergency response bags, and treatment carts.
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 6. 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
Kaiser Medi-Cal HEDIS scores for three of five diabetic measures to use in
conducting our analysis, and we present them here for comparison.
HEDIS Results
We considered CAL’s performance with population-based metrics to assess the
macroscopic view of the institution’s health care delivery. CAL’s results
compared favorably with those found in State health plans for diabetic care
measures. We list the applicable HEDIS measures in Table 5.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California Medi-Cal,
Kaiser Northern California (Medi-Cal), and Kaiser Southern California
(Medi-Cal)—CAL performed better in two of the three diabetic measures that
have statewide comparative data: HbA1c screening and poor HbA1c control.
Kaiser SoCal outperformed CAL in blood pressure control.
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Immunizations
Statewide comparative data were also not available for immunization measures;
however, we include this data for informational purposes. CAL had a 54 percent
influenza immunization rate for adults 18 to 64 years old.12
Cancer Screening
Statewide comparative data were not available for colorectal cancer screening;
however, we include these data for informational purposes. CAL had a 72 percent
colorectal cancer screening rate.
12 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a reportable
result.
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Table 5. CAL Results Compared With State HEDIS Scores
California California
CAL Kaiser Kaiser
California NorCal SoCal
Cycle 6 Medi-Cal Medi-Cal Medi-Cal
HEDIS Measure Results* 2018† 2018† 2018†
HbA1c Screening 97% 90% 94% 96%
Poor HbA1c Control (> 9.0%) ‡, § 8% 34% 25% 18%
HbA1c Control (< 8.0%) ‡ 77% – – –
Blood Pressure Control (< 140/90) ‡ 82% 65% 78% 84%
Eye Examinations 70% – – –
Influenza – Adults (18–64) 54% – – –
Influenza – Adults (65+)| N/A – – –
Pneumococcal – Adults (65+)| N/A – – –
Colorectal Cancer Screening 72% – – –
Notes and Sources
* Unless otherwise stated, data were collected in November 2021 by reviewing medical records from a sample
of CAL’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, 2019–June 30, 2020
(published April 2021). www.dhcs.ca.gov/documents/MCQMD/CA2019-20-EQR-Technical-Report-Vol3-F2.pdf
‡
For this indicator, the entire applicable CAL population was tested.
§
For this measure only, a lower score is better.
| For this indicator, the scoring was nonapplicable due to the sample yielding a total population of less than 10
patients.
Source: Institution information provided by the California Department of Corrections and Rehabilitation. Health
care plan data were obtained from the CCHCS Master Registry.
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Recommendations
As a result of our assessment of CAL’s performance, we offer the following
recommendations to the department:
Diagnostic Services
• Medical leadership should ensure time-sensitive laboratory tests are
completed within the specified time frames.
• The department should consider developing an electronic solution to
ensure providers create patient letters at the time of endorsement
and the patient results letter automatically populates accurately with
all elements required by CCHCS policy.
Emergency Services
• Nursing leadership should consider providing additional training to
staff to ensure thorough documentation of emergent events includes
all appropriate times.
• Nursing leadership should ensure supervising registered nurses
(SRNs) complete thorough audits of emergent events in which
patients transfer to a higher level of care.
Health Information Management
• Medical leadership should ensure pathology results are retrieved
within the required time frames.
• Medical leadership should remind staff to properly scan and file
medical records.
Health Care Environment
• Medical leadership should remind staff to follow universal hand
hygiene precautions. Implementing random spot checks could
improve compliance.
• Executive and nursing leadership should consider performing
random spot checks to ensure medical supplies are adequately stored
in medical supply storage areas located in and outside the clinic.
• Nursing leadership should consider directing each clinic nurse
supervisor to review the monthly emergency medical response bag
(EMRB) logs to ensure the EMRBs are regularly inventoried and
sealed.
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Transfers
• Nursing leadership should consider reminding nursing staff to
thoroughly complete the initial health screening, including
answering all questions and documenting an explanation for each
“yes” answer.
• Nursing leadership should ensure nursing staff administer
medications to patients without interruption.
Medication Management
• Medical and nursing leadership should ensure that patients with
chronic care conditions, patients returning from hospital admission,
and layover patients receive their medications timely and without
interruption.
Preventive Services
• Nursing leadership and the public health nurse should consider
educating their nursing staff in accurately monitoring patients
taking TB medications.
Nursing Performance
• Nursing leadership should ensure nurses perform more detailed
assessments and interventions during outpatient encounters and
should consider implementing audits.
Specialized Medical Housing
• Nursing leadership should ensure nurses initiate and document care
plans in the electronic health record system (EHRS).
• Nursing leadership should remind outpatient housing unit (OHU)
nurses to adhere to PICC line local operating procedures.13
• Nursing leadership should remind nurses to complete the OHU
admission assessment within the required time frame, as stated in
CCHCS policy.
• Nursing leadership should ensure that patients admitted to the OHU
receive their medications upon admission timely and without
interruption.
13 A PICC is a peripherally inserted central catheter, which is used to provide intravenous access and
administer fluids and medication.
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Specialty Services
• Medical leadership should ascertain the challenges to providers’
receiving specialty reports within the required time frames, as well
as challenges to providers’ timely reviewing those reports, and
leadership should implement remedial measures as appropriate.
• Medical leadership should ensure patients receive preapproved
specialty services within the specified time frames.
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Access to Care
Overall
Rating
In this indicator, OIG inspectors evaluated the institution’s performance in Adequate
providing patients with timely clinical appointments. Our inspectors reviewed
the scheduling and appointment timeliness for newly arrived patients, sick call, Case Review
and nurse follow-up appointments. We examined referrals to primary care Rating
providers, provider follow-ups, and specialists. Furthermore, we evaluated the Adequate
follow-up appointments for patients who received specialty care or returned from
an off-site hospitalization. Compliance
Score
Adequate
Results Overview
(78.8%)
CAL provided good access to care. The OIG clinicians found that the institution
performed adequately in clinic provider appointments, and most other
appointments were also completed in a timely manner, including nursing
appointments, specialized medical housing provider appointments, and specialist
appointments. Compliance testing showed similar results. CAL’s performances
in both compliance testing and case review rating contributed to the OIG’s rating
this indicator adequate.
Case Review and Compliance Testing Results
Our clinicians reviewed 403 provider, nursing, urgent or emergent care (TTA),
specialty, and hospital events that required the institution to generate
appointments. We found seven deficiencies related to access to care; two were
significant.14
Access to Clinic Providers
CAL performed adequately in ensuring provider appointments occurred within
the required time frames. Although compliance testing found poor completion of
chronic care follow-up appointments (MIT 1.001, 48.0%), the institution
performed well in both nurse-to-provider referred appointments and provider-
ordered sick call follow-up appointments (MIT 1.005, 84.6%; MIT 1.006, 100%).
The OIG clinicians reviewed 81 clinic provider appointments and identified two
deficiencies.15 An example follows:
• In case 6, a nurse evaluated the patient for headache and vomiting,
and documented that the patient would follow up with a provider
appointment in 14 days. However, the nurse did not initiate the
appointment.
14 Deficiencies occurred once in cases 3, 6, 17, 19, and 30, and twice in case 18. Cases 6 and 18 had
significant deficiencies.
15 Deficiencies occurred in cases 6 and 18.
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Access to Specialized Medical Housing Providers
CAL performed well in access to care in its specialized medical housing, the
outpatient housing unit (OHU). When staff admitted patients to the OHU,
providers examined patients in a timely manner. Providers evaluated patients and
completed progress notes within the appropriate time frames. Compliance
testing found that 80.0 percent of the OHU admission history and physical
examinations occurred within the required time frame (MIT 13.002). The OIG
clinicians assessed 25 provider encounters and did not identify any deficiency
related to a late or missed admission history and physical examinations or follow-
up appointments.
Access to Clinic Nurses
CAL performed well with access to nurse sick calls and provider-to-nurse
referrals. Compliance testing found that almost all nurse sick call requests were
reviewed on the day they were received (MIT 1.003, 96.7%). Moreover, the nurses
evaluated 96.6 percent of their patients within the required one business day
(MIT 1.004). OIG clinicians identified four deficiencies related to clinic nurse
access.16 One example follows:
• In case 18, the patient complained of pain from an infection;
however, the sick call nurse did not evaluate the patient until 13 days
later.
Access to Specialty Services
OIG compliance testing found that 86.7 percent of the initial high-priority
specialty appointments (MIT 14.001), 80.0 percent of the initial medium-priority
specialty appointments (MIT 14.004), and 100 percent of the initial routine
specialty appointments (MIT 14.007) occurred within the required time frames.
The institution also performed well in follow-up specialty appointments (MIT
14.003, 100%; MIT 14.006, 88.9%; and MIT 14.009, 100%). OIG clinicians reviewed
68 specialty events and did not identify any deficiencies.
Follow-up After Specialty Service
CAL performed adequately in ensuring patients saw their providers after
specialty appointments. Compliance testing revealed that 82.4 percent of
provider appointments after specialty services occurred within the required time
frames (MIT 1.008). The OIG clinicians did not identify missed or delayed
provider appointments.
16 Deficiencies occurred in cases 3, 18, 19, and 30.
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Follow-up After Hospitalization
CAL performed well in ensuring that patients see their providers within the
required time frames after hospitalizations. Compliance testing found that 83.3
percent of provider appointments occurred within the required time frames (MIT
1.007). OIG clinicians reviewed 13 hospital returns and did not identify missed or
delayed provider appointments.
Follow-up After Urgent or Emergent Care (TTA)
CAL providers generally saw their patients following a triage and treatment area
(TTA) event as requested. The OIG clinicians assessed 29 TTA events and
identified one deficiency related to a missed provider appointment after a TTA
event:
• In case 17, the TTA nurse provided emergency care for the patient
with inflammatory bowel disease and consulted a provider; however,
the nurse did not enter the order for the follow-up provider
appointment as recommended by the provider.
Follow-up After Transferring Into the Institution
Compliance testing found that 68.0 percent of provider appointments for newly
arrived patients occurred within the required time frames (MIT 1.002). Our
clinicians evaluated seven transfer-in events and did not identify any missed or
delayed provider appointments.
Clinician On-Site Inspection
CAL has four main clinics: Clinics A, B, C and D. Each clinic had an assigned
provider and an office technician who attended the morning huddles and ensured
that provider appointments were met. Each provider saw about 10 to 15 patients
per day. At the time of the clinician on-site inspection, there were five
appointments in the backlog for the four provider clinics. Our clinicians discussed
the missed provider or nursing appointments with the scheduler supervisor and
the chief nursing executive (CNE). They explained that the missed appointments
were due to human errors, as the nurses did not enter the order for the
appointments; the medical leadership would provide further training.
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Table 6. 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
12 13 0 48.0%
allowable interval or 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
17 8 0 68.0%
screening, was the patient seen by the clinician within the required
time frame? (1.002) *
Clinical appointments: Did a registered nurse review the patient’s
29 1 0 96.7%
request for service the same day it was received? (1.003) *
Clinical appointments: Did the registered nurse complete a face-to-
face visit within one business day after the CDCR Form 7362 was 28 1 1 96.6%
reviewed? (1.004) *
Clinical appointments: If the registered nurse determined a
referral to a primary care provider was necessary, was the patient seen
11 2 17 84.6%
within the 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 1 0 29 100%
time frame specified? (1.006) *
Upon the patient’s discharge from the community hospital: Did the
patient receive a follow-up appointment within the required time 5 1 2 83.3%
frame? (1.007) *
Specialty service follow-up appointments: Did the clinician follow-
up visits occur within required time frames? (1.008) *
,† 14 3 28 82.4%
Clinical appointments: Do patients have a standardized process to
3 3 0 50.0%
obtain and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 78.8%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician
follow-up visits following specialty services. As a result, we tested MIT 1.008 only for high-priority specialty
services or when staff ordered follow-ups. The OIG continued to test the clinical appropriateness of
specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Table 7. Other Tests Related to Access to Care
Compliance Questions
Scored Answer
Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the N/A N/A N/A N/A
required time frame? (12.003) *
For patients received from a county jail: Did the patient receive a
history and physical by a primary care provider within seven calendar N/A N/A N/A N/A
days? (12.004) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time 8 2 0 80.0%
frame? (13.002) *
For or OHU, CTC, SNF, and Hospice (applicable only for samples prior to
4/2019): Did the primary care provider complete the Subjective, Objective,
Assessment, and Plan notes on the patient at the minimum intervals 0 0 10 N/A
required for the type of facility where the patient was treated? (13.003)*
*
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 13 2 0 86.7%
Request for Service? (14.001) *
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 11 0 4 100%
(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 12 3 0 80.0%
Request 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 8 1 6 88.9%
provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 15 0 0 100%
Request 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 provider? 8 0 7 100%
(14.009) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still had state-
mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of provider
follow-ups within specialized medical housing units through case reviews.
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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Diagnostic Services
Overall
Rating
In this indicator, OIG inspectors evaluated the institution’s performance in
Inadequate
timely completing radiology, laboratory, and pathology tests. Our inspectors
determined whether the institution properly retrieved the resultant reports and Case Review
whether providers reviewed the results correctly. In addition, in Cycle 6, we
Rating
examined the institution’s performance in timely completing and reviewing
Inadequate
immediate (STAT) laboratory tests.
Compliance
Score
Results Overview
Inadequate
(56.2%)
CAL delivered a poor performance in diagnostic services. Although CAL
performed well in completing radiology tests, the institution needed
improvement in completing laboratory tests and in communicating test results to
patients. Furthermore, the institution did not always retrieve pathology reports
or communicate the pathology results to patients. Considering the inadequate
case review rating and the low overall compliance score, the OIG rated this
indicator inadequate.
Case Review and Compliance Testing Results
Our clinicians reviewed 241 diagnostic events and identified 23 deficiencies, four
of which were significant.17 The deficiencies were related to laboratory tests not
completed timely, a pathology report not retrieved, and poor communication of
test results to the patients.
Test Completion
CAL performed very well in completing radiology tests. Compliance testing
showed the institution completed 100 percent of radiology tests within the
required time frames (MIT 2.001). The OIG clinicians reviewed 22 radiology tests
and found all tests completed as requested.
However, CAL performed poorly in completing laboratory tests. Compliance
testing showed 50.0 percent of laboratory tests were completed within the
requested time frames (MIT 2.004). Our clinicians reviewed 206 laboratory tests
and identified five deficiencies related to late laboratory completion, one of
which was significant:18
• In case 8, a provider ordered a urine toxicology to be completed on
the same day; however, the test was not done until three weeks later.
17 Deficiencies occurred once in cases 9, 13, 16, 17, 19, and 20; twice in cases 6, 15, and 21; three times
in case 7; and four times in cases 8 and 14. Significant deficiencies occurred in cases 8, 14, 15, and 19.
18 Deficiencies occurred once in cases 9, 13, and 14, and twice in case 8. A significant deficiency
occurred in case 8.
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The OIG did not review any STAT laboratory tests during the review period.
Health Information Management
Compliance testing showed providers endorsed most radiology and laboratory
reports timely (MIT 2.002, 100%, and MIT 2.005, 90.0%). Our clinicians identified
two deficiencies related to late endorsement of a diagnostic test.19
Compliance testing also showed providers did not thoroughly communicate the
results of radiology studies or laboratory tests to the patients (MIT 2.003, 30.0%,
and MIT 2.006, 10.0%). Our clinicians found on 11 occasions, providers did not
thoroughly communicate the radiology or laboratory results to their patients, and
on one occasion, the provider did not communicate a radiology result to the
patient.20 Examples follow:
• In case 6, the provider did not send a results letter informing the
patient of the ultrasound result.
• In case 14, the provider sent a laboratory results letter but did not
include all the required elements, such as the test date.
Compliance testing revealed that CAL retrieved 40.0 percent of pathology reports
within the required time frames (MIT 2.010). Providers endorsed the pathology
reports within the required time frames (MIT 2.011, 85.7%); however, the
providers did not send pathology results letters to their patients within the
required time frames (MIT 2.012, zero) Our clinicians reviewed two events
associated with pathology reports and found two deficiencies:
• In case 14, the patient had a gastric biopsy, but the institution did
not retrieve the pathology report.
• In case 21, the provider did not send a letter informing the patient of
a pathology result.
Clinician On-Site Inspection
During the time of our on-site inspection, CAL had one part-time and two full-
time phlebotomists. The OIG clinicians discussed the delays in completing
laboratory tests. The supervisor attributed the delays to being short of staff
during the OIG review period.
During business hours, CAL had on-site radiology technicians to perform X-ray
examinations; after hours, on weekends, and on holidays, the institution
transferred patients to a community hospital for urgent imaging tests. The
19 Deficiencies occurred in cases 8 and 15.
20 Deficiencies occurred once in cases 8, 15, 17, 20, and 21; twice in cases 6 and 14; and three times in
case 7.
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institution also had a mobile imaging vendor who performed on-site CT scans,
MRIs, and ultrasound studies during business hours.
Our clinicians discussed the lack of thorough communication of test results to
patients with the chief physician and surgeon (CP&S). The CP&S attributed to
human error the providers’ not including all the required elements in the
patients’ letters and said would notify providers of the error.
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Table 8. Diagnostic Services
Scored Answer
Compliance Questions
Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
10 0 0 100%
specified in the health care provider’s order? (2.001) *
Radiology: Did the ordering health care provider review and endorse
10 0 0 100%
the radiology report within specified time frames? (2.002) *
Radiology: Did the ordering health care provider communicate the
results of the radiology study to the patient within specified time 3 7 0 30.0%
frames? (2.003)
Laboratory: Was the laboratory service provided within the time
5 5 0 50.0%
frame specified in the health care provider’s order? (2.004) *
Laboratory: Did the health care provider review and endorse the
9 1 0 90.0%
laboratory report within specified time frames? (2.005) *
Laboratory: Did the health care provider communicate the results
of the laboratory test to the patient within specified time frames? 1 9 0 10.0%
(2.006)
Laboratory: Did the institution collect the STAT laboratory test and
N/A N/A N/A N/A
receive the results within the required time frames? (2.007) *
Laboratory: Did the provider acknowledge the STAT results, OR did
nursing staff notify the provider within the required time frames? N/A N/A N/A N/A
(2.008) *
Laboratory: Did the health care provider endorse the STAT laboratory
N/A N/A N/A N/A
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report
4 6 0 40.0%
within the required time frames? (2.010) *
Pathology: Did the health care provider review and endorse the
6 1 3 85.7%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results
of the pathology study to the patient within specified time frames? 0 7 3 0
(2.012)
Overall percentage (MIT 2): 56.2%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should ensure time-sensitive laboratory tests are
completed within the specified time frames.
• The department should consider developing an electronic solution to
ensure providers create patient letters at the time of endorsement
and the patient results letter automatically populates accurately with
all elements required by CCHCS policy.
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Emergency Services
Overall
Rating
In this indicator, OIG clinicians evaluated the quality of emergency medical care.
Our clinicians reviewed emergency medical services by examining the timeliness Adequate
and appropriateness of clinical decisions made during medical emergencies. Our
evaluation included examining the emergency medical response, cardio- Case Review
pulmonary resuscitation (CPR) quality, triage and treatment area (TTA) care,
Rating
provider performance, and nursing performance. Our clinicians also evaluated
Adequate
the Emergency Medical Response Review Committee’s (EMRRC) performance in
identifying problems with its emergency services. The OIG assessed the Compliance
institution’s emergency services mainly through case review. Score
(N/A)
Results Overview
CAL delivered adequate emergency care. We reviewed approximately the same
number of events we reviewed in Cycle 5, and we identified fewer deficiencies.
Providers performed well in urgent and emergent situations. Nursing staff
provided timely and appropriate care but did not always document thoroughly.
We identified a pattern of deficiencies in the documenting assessment timelines
and intervention timelines. We identified another area for improvement in the
emergency medical response (EMR) audits related to transferring patients to a
higher level of care. Although audits were completed timely, the auditing
committee did not identify areas of performance improvement in approximately
half of the reviewed cases. Taking into account all aspects of emergency services,
we rated this indicator adequate.
Case Review Results
We reviewed 29 urgent or emergent events in 15 cases.21 We identified 15
emergency care deficiencies, of which none were significant.22
Emergency Medical Response
CAL staff responded promptly to medical emergencies throughout the
institution. Medical and custody staff worked cohesively to initiate care, activate
emergency medical services (EMS), and transfer patients to a higher level of care
when applicable. Our clinicians did not identify any significant deficiencies in
CAL’s emergency response.
21 We reviewed emergency events in cases 1–8, 13, and 15–20.
22 Deficiencies occurred twice in cases 3, 18, and 19, and three times in cases 5, 15, and 17.
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Cardiopulmonary Resuscitation Quality
During the review period, we reviewed two cases in which cardiopulmonary
resuscitation (CPR) was initiated.23 We found that staff initiated CPR timely,
activated the 9-1-1 system appropriately, and promptly transferred the patient to
the TTA for further interventions.
Provider Performance
Providers performed well in urgent and emergent events. Providers were
available to the TTA staff for consultation. The providers generally made
appropriate decisions, ordered transfers to a higher level of care when necessary,
and documented these events thoroughly.
Nursing Performance
Nurses performed well in emergency events. The nurses responded promptly to
emergency events and provided appropriate assessments and interventions.
Patients were monitored appropriately. We identified no patterns of deficiencies
in assessments and interventions.
Nursing Documentation
Nursing documentation was adequate. Nurses generally documented the
timelines of the emergency events appropriately. However, we identified a
pattern of timeline discrepancies related to the sequence of events when patients
are transferred to the community hospital.24 Although documentation
deficiencies were commonly identified during urgent and emergent events, these
deficiencies are considered minor and did not significantly increase the risk of
harm to patients. Examples follow:
• In cases 3 and 5, there were timeline documentation discrepancies in
nursing assessments after the patients departed to the community
hospital.
• In case 18, there was a timeline discrepancy in documenting nursing
intervention, as the TTA nurse documented that the patient received
medication and intravenous (IV) fluid after the patient had already
departed the TTA to a community hospital. Furthermore, the nurse
did not document the size of the IV needle.
• In case 19, there was a timeline discrepancy in documenting an
emergent event, as the TTA nurse documented administering IV
fluid prior to the patient’s arrival at the TTA. Furthermore, the nurse
23 We reviewed CPR in cases 2 and 5.
24 Documentation deficiencies occurred once in cases 3, 5, 17, and 19, and twice in cases 15 and 18.
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documented that the EKG was completed, but did not document the
EKG result.
Emergency Medical Response Review Committee
Emergency Medical Response Review Committee (EMRRC) meetings occurred
monthly, during which the committee discussed pertinent findings obtained from
the EMR audits. Our compliance team found one incomplete checklist and
identified that one checklist was missing, supervisory documentation of the
committee’s clinical review was missing, and entries were missing (MIT 15.003,
25.0%). In case review, we found documentation deficiencies were not identified
in the EMRRC or in the supervisory clinical review.25
Clinician On-Site Inspection
Our clinicians toured the TTA, which had three bays to provide emergency care.
Staffing for the TTA included two RNs for all shifts. During normal business
hours, CAL had a designated provider for the TTA. After hours, on weekends,
and on holidays, CAL used on-call providers.
The new EMR training was implemented January 2021. In emergency events, the
TTA staff respond to the emergency with the medical emergency response
vehicle (MERV).
The TTA supervising registered nurse (SRN) reported that audits are performed
by spot-checking the documentation and assessment of all care provided in the
TTA. The yard SRN is responsible for completing the EMR checklist if an
emergency response occurs in the SRN’s assigned yard. The TTA SRN reported
that the yard SRN would address any documentation or assessment issues at the
time of the review, when possible.
The TTA staff morale at the time of our visit was low; the staff were often
overworked due to a staff shortage resulting from COVID-19 exposure. Staff
reported that the TTA SRN was very supportive of the TTA staff and assisted
them as needed.
25 Deficiencies in EMR audits were identified in cases 3, 5, 15, 17, and 19.
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Recommendations
• Nursing leadership should consider providing additional training to
staff to ensure thorough documentation of emergent events includes
all appropriate times.
• Nursing leadership should ensure supervising registered nurses
(SRNs) complete thorough audits of emergent events in which
patients transfer to a higher level of care.
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Health Information Management
Overall
Rating
In this indicator, OIG inspectors evaluated the flow of health information, a Adequate
crucial link in high-quality medical care delivery. Our inspectors examined
whether the institution retrieved and scanned critical health information
Case Review
(progress notes, diagnostic reports, specialist reports, and hospital discharge
Rating
reports) into the medical record in a timely manner. Our inspectors also tested
Adequate
whether clinicians adequately reviewed and endorsed those reports. In addition,
our inspectors checked whether staff labeled and organized documents in the
Compliance
medical record correctly.
Score
Inadequate
(74.8%)
Results Overview
CAL had a mixed performance in this indicator. CAL performed well in
retrieving and scanning hospital records, specialty reports, and diagnostic tests.
Nurses and providers recorded urgent and emergent events thoroughly. However,
the institution did not always retrieve pathology reports within the required time
frames. After considering all factors of health information management, the OIG
rated this indicator adequate.
Case Review and Compliance Results
During the review period, our clinicians found 24 deficiencies related to health
information management, five of which were significant.26
Hospital Discharge Reports
CAL performed very well in retrieving and scanning hospital records.
Compliance testing found that CAL staff retrieved and scanned all hospital
discharge records within the required time frames (MIT 4.003, 100%). Most
discharge records included the important physician discharge summary, and
providers endorsed the reports within five days (MIT 4.005, 87.5%). Our clinicians
reviewed 13 hospital events and did not identify any deficiencies.
Specialty Reports
CAL performed well in retrieving and reviewing specialty reports. Compliance
testing showed that 86.7 percent of specialty reports were scanned within the
required time frame (MIT 4.002). Staff received or reviewed most high-priority,
medium-priority, and routine specialty reports within the required time frames
(MIT 14.002, 78.6%; MIT 14.005, 80.0%; and MIT 14.008, 66.7%).
26 Deficiencies occurred once in cases 3 and 16; twice in cases 6, 17, 19, and 21; and three times in
cases 7, 14, 15, and 20. Significant deficiencies occurred in cases 3, 14, 15, 19, and 20.
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Our clinicians reviewed 67 specialty reports and identified two specialty reports
received late and three specialty reports reviewed late.27 These deficiencies are
discussed in the Specialty Services indicator.
Diagnostic Reports
CAL proficiently retrieved and endorsed diagnostic reports. Compliance testing
showed providers endorsed radiology and laboratory reports within the required
time frames (MIT 2.002, 100%, and MIT 2.005, 90.0%).
However, CAL performed poorly in retrieving pathology reports, as compliance
testing found staff retrieved 40.0 percent of pathology reports within the required
time frames (MIT 2.010). Providers often endorsed the pathology reports within
the specified time frames (MIT 2.011, 85.7%). Our clinicians found that one of two
pathology reports was not retrieved; the missing pathology report is discussed in
the Diagnostic Services indicator.28
Urgent and Emergent Records
Our clinicians reviewed 29 emergency care events and found that the nurses and
providers recorded these events sufficiently. Our clinicians did not identify any
deficiencies.
Scanning Performance
Compliance testing found CAL performed poorly with the scanning process: the
institution did not scan, label, or name medical files accurately (MIT 4.004, zero).
Our clinicians identified one mislabeled document:
• In case 16, an EKG was mislabeled as a parole medication receipt.
Clinician On-Site Inspection
Medical staff at CAL’s central medical record office scanned records as they
received them. Most patients returning from a community hospital had their
hospital records with them. Triage and treatment area (TTA) nurses were
instructed to contact the hospital directly for any missing hospital records.
For on-site specialty reports, the on-site specialty nurses reported that they
scanned the reports on the same day the visit occurred. For off-site specialty
reports, the medical record staff scanned the hand-written reports on the day the
visit occurred and scanned the formal specialty reports as they received them.
The specialty nurses also contacted the specialists directly for any missing
specialty reports.
27 Two specialty reports were retrieved late occurred in case 20. Three specialty reports were reviewed
late occurred in cases 3, 15, and 17.
28 The missing pathology report occurred in case 14.
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Table 9. Health Information Management
Scored Answer
Compliance Questions
Yes No N/A Yes %
Are health care service request forms scanned into the patient’s
electronic health record within three calendar days of the encounter 20 0 10 100%
date? (4.001)
Are specialty documents scanned into the patient’s electronic
26 4 15 86.7%
health record 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 8 0 0 100%
hospital discharge? (4.003) *
During the inspection, were medical records properly scanned,
0 24 0 0
labeled, 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
7 1 0 87.5%
and did a provider review the report within five calendar days of
discharge? (4.005) *
Overall percentage (MIT 4): 74.8%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 10. 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
10 0 0 100%
endorse the radiology report within specified time frames? (2.002) *
Laboratory: Did the health care provider review and endorse the
9 1 0 90.0%
laboratory report within specified time frames? (2.005) *
Laboratory: Did the provider acknowledge the STAT results, OR did
nursing staff notify the provider within the required time frame? N/A N/A N/A N/A
(2.008) *
Pathology: Did the institution receive the final pathology report within
4 6 0 40.0%
the required time frames? (2.010) *
Pathology: Did the health care provider review and endorse the
6 1 3 85.7%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results of
0 7 3 0
the 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 11 3 1 78.6%
frame? (14.002) *
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required 12 3 0 80.0%
time frame? (14.005) *
Did the institution receive and did the primary care provider review
the routine-priority specialty service consultant report within the 10 5 0 66.7%
required time frame? (14.008) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should ensure pathology results are retrieved
within the required time frames.
• Medical leadership should remind staff to properly scan and file
medical records.
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Health Care Environment
Overall
Rating
In this indicator, OIG compliance inspectors tested clinics’ waiting areas,
Inadequate
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 Case Review
inspectors asked the institution’s health care administrators to comment on their Rating
facility’s infrastructure and its ability to support health care operations. The OIG (N/A)
rated this indicator solely on the compliance score, using the same scoring
thresholds used in the Cycle 4 and Cycle 5 medical inspections. Our case review Compliance
clinicians do not rate this indicator. Score
Inadequate
(48.5%)
Results Overview
Multiple aspects of CAL’s health care environment needed improvement:
multiple clinics and the medical warehouse contained expired medical supplies;
multiple clinics contained noncalibrated or nonfunctional equipment;
Emergency Medical Response Bags (EMRB) had nonfunctional oxygen tanks or a
defective oxygen pressure gauge; EMRB logs were missing staff verification, or
EMRB inventory was not performed; and staff did not regularly sanitize their
hands before or after examining patients. These factors resulted in
an inadequate rating for this indicator.
Compliance Testing Results
Outdoor Waiting Areas
The institution had no waiting areas that required patients to be outdoors.
Indoor Waiting Areas
We inspected indoor waiting areas. Health care and custody staff reported
existing waiting areas contained sufficient seating capacity. However, during our
inspection, we observed overcrowding or noncompliance with social distancing
requirements in a majority of the clinics’ indoor waiting areas. For example,
custody staff reported the indoor holding area for A Clinic had a maximum
capacity of eight patients at a time, but we observed the holding area did not
have enough space to comply with the social distancing requirement once it
reach its maximum capacity. In addition, custody staff in B Clinic, which was
located in a temporary location, reported they avoided overcrowding by only
calling patients to the clinic close to the patient’s appointment time, but we
observed overcrowding and noncompliance with social distancing requirements
(see Photo 1, next page).
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Photo 1. Indoor waiting area in B Clinic showed overcrowding and noncompliance
with social distancing requirement (photographed on November 16, 2021).
Clinic Environment
All clinic environments were sufficiently conducive to medical care: they
provided reasonable auditory privacy, wheelchair accessibility, and
nonexamination room workspace (MIT 5.109, 100%).
Of the nine clinics we observed,
three contained appropriate space,
configuration, supplies, and
equipment to allow their clinicians
to perform proper clinical
examinations (MIT 5.110, 33.3%). The
remaining six clinics had one or
more of the following deficiencies:
examination rooms lacked visual or
auditory privacy (see Photo 2);
examination rooms lacked adequate
space (less than 100 square feet);
there was a torn clinician chair vinyl
cover; and examination table
placement prevented patients from
fully lying down. Photo 2. Patient seen sitting B Clinic’s examination room doorway;
patient encounter did not provide a reasonable level of auditory
privacy (photographed on November 16, 2021).
Clinic Supplies
Three of the 10 clinics followed adequate medical supply storage and management
protocols (MIT 5.107, 30.0%). We found one or more of the following deficiencies in
six clinics: expired medical supplies (see Photo 3, next page); unidentified or
inaccurately labeled medical supplies; compromised original medical supply
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packaging; medical supplies stored
directly on the floor; staff members’
personal food items stored in the
medical supply storage room
location; and cleaning materials
stored with medical supplies.
Four of the 10 clinics met
requirements for essential core
medical equipment and supplies
(MIT 5.108, 40.0%). The remaining six
clinics lacked medical supplies or
contained improperly calibrated or
nonfunctional equipment. The
missing items included examination
table disposable paper and a Snellen
chart. The staff had not properly
calibrated a nebulizer and vital sign
equipment. We found a
nonfunctional oto-ophthalmoscope
and expired automated external
defibrillator (AED) pads (see Photo 4,
below).
Photo 3. Expired medical supplies dated June 25, 2020
(photographed on November 16, 2021).
We examined emergency medical response
bags (EMRBs) to determine whether they
contained all essential items. We checked
whether staff inspected the bags daily and
inventoried them monthly. None of the
eight EMRBs passed our test (MIT 5.111,
zero). We found one or more of the
following deficiencies with all the EMRBs:
staff failed to ensure that EMRB
compartments were sealed and intact; staff
had not inventoried the EMRBs when seal
tags were replaced or had not inventoried
the EMRBs in the previous 30 days; several
EMRBs lacked medium- or large-sized
gloves; EMRBs contained compromised
nonrebreather mask or Ambu bag
packaging; and EMRBs had nonfunctional
oxygen gauges. In addition, we found that
the treatment carts in the TTA did not meet
the minimum inventory level.
Photo 4. Expired automated external defibrillator (AED)
in the OHU dated December 14, 2018 (photographed
on November 16, 2021).
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In addition to the above findings, our compliance inspectors observed the
following in the clinics or examination rooms when they conducted their on-site
inspection:
• We observed B clinic staff respond to housing unit B-3 for an
emergency. Staff reported they were unable to use the EMRB’s
oxygen due to the installed nonfunctional oxygen gauge. Staff
reported they needed to wait for the institution’s emergency medical
response vehicle (EMRV) to arrive at the housing unit to use the
oxygen tank and administer oxygen to the patient.
Medical Supply Management
None of the medical supply storage areas
located outside the medical clinics stored
medical supplies adequately (MIT 5.106,
zero). We found expired medical supplies
and medical supplies stored directly on the
floor (see Photos 5 and 6). The warehouse
manager reported that he and his staff do
not monitor and maintain a temperature
log where medical supplies were stored.
Photo 5. Expired medical supply dated November 2017
(photographed on November 18, 2021).
According to the chief executive
officer (CEO), the institution did not
have any concerns about the medical
supplies process. Health care
managers and medical warehouse
managers expressed no concerns
about the medical supply chain or
their communication process with
the existing system.
In addition to the above findings, our
compliance inspectors observed the
following in the medical warehouse
or Conex box when they conducted
their on-site inspection:
Photo 6. Medical supplies stored directly on the floor
(photographed on November 18, 2021).
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• The medical warehouse stored
reusable medical equipment
without date stamps that
specified when the equipment
was processed in the autoclave
and without the nurse’s initials
(see Photo 7).
Infection Control and Sanitation
Staff appropriately disinfected, cleaned,
and sanitized eight of 10 clinics (MIT
5.101, 80.0%). In one clinic, cleaning logs
were not maintained, and the cabinet
under the sink was unsanitary. In
another clinic, biohazardous waste was
not emptied after each clinic day.
Staff in six of 10 clinics (MIT 5.102,
60.0%) properly sterilized or disinfected
medical equipment. In four clinics, we
found one or more of the following
deficiencies: staff did not mention
Photo 7. Previously sterilized reusable invasive medical
disinfecting the examination table as
equipment was missing a date stamp and nurse’s initials
part of their daily start-up protocol; staff
(photographed on November 18, 2021).
did not remove and replace the
examination table disposable paper after
each patient encounter; and staff stored previously sterilized medical equipment
beyond the documented shelf life.
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 restroom lacked
antiseptic soap. In another clinic, the patient restroom lacked disposable hand
towels, and the clinic examination room lacked an alcohol-based hand sanitizer
or antiseptic soap and disposable hand towels.
We observed patient encounters in five clinics. In four clinics, clinicians did not
wash their hands before or after examining their patients, before regloving, or
after performing physical therapy services (MIT 5.104, 20.0%).
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%).
One clinic lacked medical gowns as part of their personal protective equipment
(PPE).
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Physical Infrastructure
CAL’s health care management and plant operations manager reported that all
clinical area infrastructures were in good working order and did not hinder
health care services.
At the time of our medical inspection, the institution reported several health care
facility improvement program (HCFIP) projects were started between July 2018
and June 2021, including renovating Clinics B, C, D, and the central health
facility’s primary clinics. The construction slowed and halted due to the COVID-
19 pandemic. The institution estimated the projects would be restarted on
February 2022 and be completed between March 2022 and August 2023 (MIT
5.999).
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Table 11. Health Care Environment
Scored Answer
Compliance Questions Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately
8 2 0 80.0%
disinfected, cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable
invasive and noninvasive medical equipment is properly sterilized or 6 4 0 60.0%
disinfected as warranted? (5.102)
Infection control: Do clinical health care areas contain operable
8 2 0 80.0%
sinks and sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal
1 4 5 20.0%
hand hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to
9 1 0 90.0%
blood-borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the
medical supply management process adequately supports the needs 0 1 0 0
of the medical health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for
3 7 0 30.0%
managing and storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have
4 6 0 40.0%
essential core medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas
10 0 0 100%
conducive to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms
3 6 1 33.3%
conducive to providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency
crash carts inspected and inventoried within required time frames, 0 8 2 0
and do they contain essential items? (5.111)
Does the institution’s health care management believe that all clinical This is a nonscored test. Please
areas have physical plant infrastructures that are sufficient to provide see the indicator for discussion of
adequate health care services? (5.999) this test.
Overall percentage (MIT 5): 48.5%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical leadership should remind staff to follow universal hand
hygiene precautions. Implementing random spot checks could
improve compliance.
• Executive and nursing leadership should consider performing
random spot checks to ensure medical supplies are adequately stored
in medical supply storage areas located in and outside the clinic.
• Nursing leadership should consider directing each clinic nurse
supervisor to review the monthly emergency medical response bag
(EMRB) logs to ensure the EMRBs are regularly inventoried and
sealed.
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Transfers
Overall
Rating
In this indicator, OIG inspectors examined the transfer process for those patients
Inadequate
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 screenings and the continuity of provider appointments, specialist Case Review
referrals, diagnostic tests, and medications. For patients who transferred out of Rating
the institutions, inspectors checked whether staff reviewed patient medical Adequate
records and determined the patient’s need for medical holds. They also assessed
whether staff transferred patients with their medical equipment and gave correct Compliance
medications before patients left. In addition, our inspectors evaluated the Score
performance of staff in communicating vital health transfer information, such as Inadequate
preexisting health conditions, pending appointments, tests, and specialty (70.6%)
referrals; and inspectors confirmed whether staff sent complete medication
transfer packages to the receiving institution. For patients who returned from
off-site hospitals or emergency rooms, inspectors reviewed whether staff
appropriately implemented the recommended treatment plans, administered
necessary medications, and scheduled appropriate follow-up appointments.
Results Overview
CAL delivered a mixed performance in this indicator. Our clinicians reviewed a
similar number of events for inter- and intrasystem transfers as we did in in
Cycle 5. However, in this cycle, the clinicians identified multiple deficiencies
related to medication continuity for patients returning from the hospital. Our
compliance team also found delays in medication continuity for patients
returning to the institution from the hospital as well as for patients transferring
into CAL from another institution. In addition, the compliance team found
nurses performed poorly in completing the initial health screening when the
patients transferred into the institution. Considering both case review and
compliance results, the OIG rated this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 36 events in 20 cases in which patients transferred into or out of the
institution or returned from an off-site hospital or emergency room. We
identified nine deficiencies, three of which were significant.29
Transfers In
CAL’s performance in transferring patients into the institution was poor. The
receiving and release (R&R) nurses did not complete the initial health screening
form thoroughly (MIT 6.001, 28.0%). Analysis of the compliance data showed that
the nurses did not complete the initial health screening within the required time
frames, address the symptom of fatigue in the TB screening, or obtain the
29 Deficiencies occurred in cases 4, 15, 17, 22, 25, 26, and 46. Significant deficiencies occurred in case
4, 15, and 17.
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patient’s weight. In addition, the nursing staff did not document an explanation
to the “Yes” answers to questions regarding medical appointments, mental illness
treatment, and cocci risk factors.
OIG clinicians reviewed 14 events in seven cases in which patients transferred
into the facility from other institutions. We identified three deficiencies, none of
which were significant.30 Examples follow:
• In case 4, the nurse assessed the newly arrived patient with a history
of hypertension. The nurse obtained an elevated blood pressure
reading but did not auscultate heart sounds, assess for leg
edema, reassess the blood pressure, or inquire about compliance with
blood pressure medications. In addition, the nurse documented an
RN follow-up in 30 days but did not order the RN follow-up
appointment on the arrival day. Instead, a nurse ordered the
appointment 28 days later.
• In case 22, a patient arrived at CAL, but the nurse did not obtain vital
signs and weight. In addition, daily COVID-19 quarantine rounds
were not consistently conducted, as ordered.
The compliance team found that medication continuity for newly arrived patients
was poor (MIT 6.003, 54.6%). The compliance team found that keep-on-person
(KOP) medications were not provided timely. However, CAL performed well in
medication continuity for patients who transferred within the institution (MIT
7.005, 92.0%). Our case reviewers did not find deficiencies related to medication
continuity for patients arriving to the institution.
Compliance testing found that patients endorsed from another institution were
seen by the clinician within the required time frame; however, the RN did not
address the patient’s chronic care conditions, such as asthma, hypertension, and
pain (MIT 1.002, 68.0%). Our clinicians did not identify any missed or delayed
clinician appointments.
Compliance testing found that 25.0 percent of the preapproved specialty
appointments occurred timely for patients transferring into CAL (MIT 14.010).
Our clinicians did not identify any missed or delayed preapproved specialty
appointments.
Transfers Out
Compliance testing found that patients who transferred out of the institution
consistently had their medications and required documents (MIT 6.101, 100%).
Our clinicians reviewed three transfer-out cases and identified two deficiencies
30 We reviewed the following transfer-in cases 4, 8, 20, 22, 23, 24, and 26. Deficiencies occurred
in cases 4, 22, and 46.
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related to incomplete interfacility transfer forms and one deficiency related to a
lapse in medication continuity.31 An example is listed below:
• In case 26, the nurse did not complete the interfacility transfer
information, such as the medical clearance, history and physical
exam, and patient’s medical summary. Furthermore, the patient did
not receive a five-day supply of aspirin.
Hospitalizations
Compliance testing showed that CAL performed poorly in medication continuity
for patients who returned to the institution after discharge from the hospital
(MIT 7.003, 50.0%). Our clinicians identified three deficiencies related to
medication continuity; all three were considered significant:
• In case 4, the patient returned from a community hospital with a
diagnosis of a stroke, and the patient received his blood pressure
medications and aspirin two days late.
• In case 15, the patient with history of diabetes returned from the
hospital, and the patient received his diabetic medication two days
late and his chest pain medication 14 days late.
• In case 17, the patient returned from the hospital with a diagnosis of
an acute inflammatory bowel disease, and the patient did not receive
his morning doses of antibiotic, blood pressure medication, and
nonsteroidal anti-inflammatory medications.
CAL performed well in ensuring that provider follow-up appointments occurred
within the required time frame for patients returning from the hospital or
emergency room visits (MIT 1.007, 83.3%). Our clinicians did not identify missed
or delayed provider appointments.
Compliance testing found that staff retrieved and scanned all hospital discharge
records within the required time frames (MIT 4.003, 100%). Most discharge
records included the important physician discharge summary, and the providers
endorsed the reports within five days (MIT 4.005, 87.5%). Our clinicians did not
identify any deficiency related to hospital discharge records.
Clinician On-Site Inspection
The R&R staff were knowledgeable about the transfer process, including
medication availability, provider appointment timelines, completion of screening
questions, and specialty appointment continuity. For patients transferring into
the institution, the R&R nurses reviewed the patients’ charts to identify any
special needs to ensure the transfer is appropriate for the institution. The R&R
nurses also use Omnicell (the automated medication dispensing machine) in the
31 Deficiencies occurred once in case 25 and twice in case 26.
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TTA to obtain medications for newly arrived patients without their chronic care
medications.
For patients transferring out of the institution, the R&R nurses prescreened the
chart and messaged the provider for clearance. The nurses also performed either
a COVID-19 polymerase chain reaction (PCR) or a rapid antigen test, verified the
patient’s possession of durable medical equipment and KOP medications, and
obtained a five-day supply of medications. The resource RN coordinated all the
care for patients on Suboxone upon arrival and discharge.32 Paroling patients
received a 30-day supply of Suboxone and information from the resource RN
regarding where they would follow up in the community for further care.
32 Suboxone is a medication used to treat opioid dependence and addiction.
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Table 12. Transfers
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
7 18 0 28.0%
COCF: Did nursing staff complete the initial health screening and
answer all screening questions within the required time frame?
(6.001) *
For endorsed patients received from another CDCR institution or
COCF: When required, did the RN complete the assessment and
25 0 0 100%
disposition section of the initial health screening form; refer the
patient to the TTA if TB signs and symptoms were present; and
sign and date the form on the same day staff completed the health
screening? (6.002)
For endorsed patients received from another CDCR institution or
6 5 14 54.6%
COCF: If the patient had an existing medication order upon arrival,
were medications administered or delivered without interruption?
(6.003) *
For patients transferred out of the facility: Do medication transfer
2 0 0 100%
packages include required medications along with the
corresponding transfer packet required documents? (6.101) *
Overall percentage (MIT 6): 70.6%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 13. 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 17 8 0 68.0%
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 5 1 2 83.3%
within the required time frame? (1.007) *
Are community hospital discharge documents scanned into the
patient’s electronic health record within three calendar days of hospital 8 0 0 100%
discharge? (4.003) *
For patients discharged from a community hospital: Did the preliminary
or final hospital discharge report include key elements and did a
7 1 0 87.5%
provider 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 4 4 0 50.0%
patient 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 3 2 0 60.0%
administered or delivered without interruption? (7.006) *
For endorsed patients received from another CDCR institution: If
the patient was approved for a specialty services appointment at the
5 15 0 25.0%
sending institution, was the appointment scheduled at the receiving
institution within the required time frames? (14.010) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should consider reminding nursing staff to
thoroughly complete the initial health screening, including
answering all questions and documenting an explanation for each
“yes” answer.
• Nursing leadership should ensure nursing staff administer
medications to patients without interruption.
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Medication Management
Overall
Rating
In this indicator, OIG inspectors evaluated the institution’s performance in
Inadequate
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 Case Review
indicator, the OIG particularly considered the compliance test results, which Rating
tested medication processes to a much greater degree than case review testing. In Adequate
addition to examining medication administration, our compliance inspectors also
tested many other processes, including medication handling, storage, error Compliance
reporting, and other pharmacy processes. Score
Inadequate
(65.3%)
Results Overview
CAL performed variably in this indicator. In Cycle 5, both case review and
compliance testing demonstrated that the institution administered medications
without interruption. However, in this cycle, both case review and compliance
testing showed delays in medication continuity with chronic care, hospital
discharge, specialized medical housing, and transfer medications. Our
compliance team found a pattern of patients’ not receiving their 30-day supply of
chronic care KOP medications within the required time frames. Our case review
clinicians found significant deficiencies related to delays in medication
continuity for patients returning from the hospital and for patients admitted to
the specialized medical housing unit. Considering both case review and
compliance testing results, we rated this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 113 events in 26 cases related to medication management and found
21 medication deficiencies, six of which were significant.33
New Medication Prescriptions
CAL performed well in delivering newly prescribed medications. Compliance
testing showed that most newly prescribed medication deliveries were completed
within the required time frames (MIT 7.002, 92.0%), and case review also showed
most patients received their newly prescribed medications timely. We identified
five delays in patients’ receiving newly prescribed medications.34 An example
follows:
• In case 28, the patient received newly prescribed pain-relieving
medication one day late.
33 Deficiencies occurred once in cases 1, 4, 12–14, 18, 26, 28, and 47; twice in cases 7 and 46; and four
times in cases 15 and 17. Significant deficiencies occurred in cases 4, 7, 13, 15, 17, and 46.
34 Delayed receiving of newly prescribed medication occurred in cases 1, 7, 15, 18, and 28.
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Chronic Medication Continuity
Compliance testing found most patients did not receive their chronic care
medications within the required time frames (MIT 7.001, 13.3%). Analysis of the
compliance data further showed KOP medications were not made available one
business day prior to supply exhaustion or were refused by patients, and when
medication was refused, the reason for the refusal was not documented. In
contrast, our clinicians found most patients received their chronic care
medications within the required time frames; however, there were two significant
deficiencies related to chronic medication continuity:
• In case 7, the patient received his blood thinner medication four days
late.
• In case 13, the patient received his blood pressure medication one
month late.
Hospital Discharge Medications
CAL frequently did not ensure patients received their medications when they
returned from an off-site hospital or emergency room. The compliance team
found that 50.0 percent of patients did not receive their medications within the
required time frame (MIT 7.003). Our clinicians reviewed 13 hospital returns and
identified three medication management deficiencies, all of which were
significant.35 These deficiencies are discussed further in the Transfers indicator.
Specialized Medical Housing Medications
Medication management in the specialized medical housing was poor. In
compliance testing, patients who were admitted to the outpatient housing unit
(OHU) were not always given their medications timely (MIT 13.004, 70.0%). Our
case review clinicians identified five deficiencies related to medication
management; one was considered significant.36 These deficiencies are discussed
further in the Specialized Medical Housing indicator.
Transfer Medications
In compliance testing, CAL frequently did not ensure that patients who
transferred into the institution received their medication timely (MIT 6.003,
54.6%). Patients who were temporarily housed at the facility generally did not
receive their medications within the required time frames (MIT 7.006, 60.0%).
However, compliance testing found proficient medication continuity for patients
transferring from yard to yard (MIT 7.005, 92.0%). Our case review clinicians did
35 Significant deficiencies in medication management for patients returning from the hospital
occurred in cases 4, 15, and 17.
36 Medication management deficiencies in specialized medical housing occurred once in cases 7, 18,
and 47, and twice in case 46. A significant deficiency occurred in case 46.
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not find any deficiencies related to medication continuity for patients who
transferred into the institution.
Both case review and compliance testing found that CAL performed well in
ensuring patients who transferred out of the institution received their five-day
supply of medications (MIT 6.101, 100%). Our clinicians found one deficiency
related to medication management for a patient transferring out of the
institution.37 Additional information is discussed in the Transfers indicator.
Medication Administration
Compliance testing showed nurses administered tuberculosis (TB) medications
within the required time frames (MIT 9.001, 88.2%). However, the institution did
not thoroughly monitor patients taking TB medications, as required by policy
(MIT 9.002, 29.4%). Our case review clinicians did not identify any deficiencies
related to TB medications.
Clinician On-Site Inspection
Our clinicians attended huddles in the OHU, in A Clinic, and in C Clinic. During
the huddles, care teams discussed medication compliance, including medication
nonadherence, and discussed medication continuity for patients transferring into
the institution, arriving from another yard, or returning from the hospital.
Our clinicians interviewed the medication nurses and found them to be
knowledgeable about the medication administration process. The medication
nurses attended clinic huddles and notified providers of expiring medications.
Medication rooms were clean and organized, and there were no backlogs of KOP
medications.
Our clinicians met with the pharmacist and with nursing leadership to review the
on-site questions concerning delays in medication continuity for patients
returning from the hospital. Nursing leadership recognized there should be more
oversight of the medication reconciliation process. The chief medical executive
(CME) also agreed the existing medication reconciliation process was not
followed in one reviewed case that we discussed.38
The pharmacist-in-charge (PIC) had recently joined CAL and acknowledged that
more training would be provided to his pharmacy technicians, in reviewing
orders and scanning medications, to prevent delays in medication continuity.
Nursing leadership confirmed that most of the medications can be obtained from
the Omnicell in the TTA if the nurses need the medication for delivery.39
37 A deficiency in medication management for patients transferring out of the institution occurred
once in case 26.
38 We discussed case 4.
39 An Omnicell is an automated medication dispensing machine.
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Compliance Testing Results
The institution adequately stored and secured narcotic medications in seven of
eight clinic and medication line locations (MIT 7.101, 87.5%). In one location,
nurses did not describe the appropriate narcotic medication discrepancy
reporting process.
CAL appropriately stored and secured nonnarcotic medications in all clinic and
medication line locations (MIT 7.102, 100%).
Staff kept medications protected from physical, chemical, and temperature
contamination in four of the 10 clinic and medication line locations (MIT 7.103,
40.0%). In six locations, we found one or more of the following deficiencies: staff
did not consistently record room and refrigerator temperatures, and staff did not
store oral and topical medications separately.
Staff successfully stored valid, unexpired medications in nine of the 10 applicable
medication line locations (MIT 7.104, 90.0%). In one location, nurses did not label
the multiuse medication, as required by CCHCS policy.
Nurses exercised proper hand hygiene and contamination control protocols in
three of six locations (MIT 7.105, 50.0%). In three locations, some nurses
neglected to wash or sanitize their hands before each subsequent regloving.
Staff in three of six medication preparation and administration areas
demonstrated appropriate administrative controls and protocols (MIT 7.106,
50.0%). In three locations, we observed one or both of the following deficiencies:
medication nurses did not maintain unissued medication in its original labeled
packaging, or 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 two of six medication areas used appropriate administrative controls and
protocols when distributing medications to their patients (MIT 7.107, 33.3%). In
four locations, we observed one or more of the following deficiencies: medication
nurses did not distribute medications to patients within the time frame of one
hour before or one hour after the normal distribution time; medication nurses did
not consistently verify patients’ identification prior to administering
medications; medication nurses did not reliably observe patients while they
swallowed direct observation therapy medications; and nurses did not follow
insulin protocols properly. We observed during insulin administration that some
medication nurses did not properly disinfect the vial’s port prior to withdrawing
medication.
Pharmacy Protocols
CAL 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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The pharmacist-in-charge (PIC) did not correctly review monthly inventories of
controlled substances in the institution’s clinic and medication storage locations.
Specifically, the pharmacists and nurses present at the time of the medication-
area inspection did not correctly complete several medication-area inspection
checklists (CDCR Form 7477). These errors resulted in a score of zero in this test
(MIT 7.111).
We examined 25 medication error reports. The PIC timely or correctly processed
only 13 of these 25 reports (MIT 7.112, 52.0%). In 11 reports, the PIC did not
document one or more of the following: an explanation for not notifying the
provider and/or patient, the contributing cause of the error, where in the error
occurred within the pharmacy process, and recommended changes to correct the
medication error. For the remaining one report, the prior PIC completed a
Medication Error Follow-up form that was not free of discrepancy. Specifically,
the form was completed prior to the notification date of the error sent to the
previous PIC.
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 CAL, we did not find any applicable medication
errors (MIT 7.998).
We interviewed patients in restricted housing units to determine whether they
had immediate access to their prescribed asthma rescue inhalers or nitroglycerin
medications. Six of eight applicable patients interviewed indicated they had
access to their rescue medications. Two patients reported they did not have their
prescribed rescue inhalers: one patient stated he does not need the inhaler, while
the other patient stated the medication just run out at the time of our inspection.
We promptly notified the CEO of this concern, and health care management
obtained new refusal documentation for one patient and immediately issued a
replacement rescue inhaler to the other patient (MIT 7.999).
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Table 14. Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required
time frames or did the institution follow departmental policy for refusals 2 13 10 13.3%
or no-shows? (7.001) *
Did health care staff administer, make available, or deliver new order
23 2 0 92.0%
prescription 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 4 4 0 50.0%
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 N/A N/A N/A N/A
delivered to the patient within the required time frames? (7.004) *
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 administered or 3 2 0 60.0%
delivered without interruption? (7.006) *
All clinical and medication line storage areas for narcotic medications:
Does the institution employ strong medication security controls over 7 1 2 87.5%
narcotic medications 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 10 0 0 100%
assigned storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications:
Does the institution keep nonnarcotic medication storage locations free 4 6 0 40.0%
of contamination in 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 9 1 0 90.0%
the assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ
and follow hand hygiene contamination control protocols during medication 3 3 4 50.0%
preparation and medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications 3 3 4 50.0%
for patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering 2 4 4 33.3%
medications to patients? (7.107)
Pharmacy: Does the institution employ and follow general security,
organization, and cleanliness management protocols in its main and remote 1 0 0 100%
pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store
1 0 0 100%
nonrefrigerated medications? (7.109)
Pharmacy: Does the institution’s pharmacy properly store refrigerated or
1 0 0 100%
frozen medications? (7.110)
Pharmacy: Does the institution’s pharmacy properly account for narcotic
0 1 0 0
medications? (7.111)
Pharmacy: Does the institution follow key medication error reporting
13 12 0 52.0%
protocols? (7.112)
Pharmacy: For Information Purposes Only: During compliance testing, did the This is a nonscored test. Please
OIG find that medication errors were properly identified and reported by the see the indicator for discussion of this
institution? (7.998) test.
Pharmacy: For Information Purposes Only: Do patients in restricted This is a nonscored test. Please
housing units have immediate access to their KOP prescribed rescue see the indicator for discussion of this
inhalers and nitroglycerin medications? (7.999) test.
Overall percentage (MIT 7): 65.3%
* The OIG clinicians considered these compliance tests along with their case review findings when determining the
quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 15. Other Tests Related to Medication Management
Scored Answer
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
6 5 14 54.6%
were medications administered or delivered without interruption?
(6.003) *
For patients transferred out of the facility: Do medication transfer
packages include required medications along with the 2 0 0 100%
corresponding transfer-packet required documents? (6.101) *
Patients prescribed TB medication: Did the institution administer the
15 2 0 88.2%
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 5 12 0 29.4%
on the medication? (9.002) *
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 7 3 0 70.0%
within required time frames? (13.004) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Medical and nursing leadership should ensure that patients with
chronic care conditions, patients returning from hospital admission,
and layover patients receive their medications timely and without
interruption.
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Preventive Services
Overall
In this indicator, OIG compliance inspectors tested whether the institution Rating
offered or provided cancer screenings, tuberculosis (TB) screenings, influenza Adequate
vaccines, and other immunizations. If the department designated the institution
as high risk for coccidioidomycosis (valley fever), we tested the institution’s
Case Review
performance in transferring out patients quickly. The OIG rated this indicator
Rating
solely according to the compliance score, using the same scoring thresholds used
(N/A)
in the Cycle 4 and Cycle 5 medical inspections. Our case review clinicians do not
rate this indicator.
Compliance
Score
Results Overview Adequate
(80.9%)
CAL staff performed well in administering TB medications as prescribed,
screening patients annually for TB, offering patients an influenza vaccine for the
most recent influenza season, offering colorectal cancer screening for all patients
ages 45 through 75, and offering required immunizations to chronic care
patients. The institution faltered in monitoring patients who were taking
prescribed TB medications. These findings are set forth in the table on the next
page. Overall, we rated this indicator adequate.
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Table 16. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
15 2 0 88.2%
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 5 12 0 29.4%
the medication? (9.002) †
Annual TB screening: Was the patient screened for TB within the
25 0 0 100%
last year? (9.003)
Were all patients offered an influenza vaccination for the most recent
21 4 0 84.0%
influenza season? (9.004)
All patients from the age of 45 through the age of 75: Was the
24 1 0 96.0%
patient offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the
N/A N/A N/A N/A
patient offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was
N/A N/A N/A N/A
patient offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients?
14 2 9 87.5%
(9.008)
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): 80.9%
* The OIG clinicians considered these compliance tests along with their case review findings when determining the
quality rating for this indicator.
† In April 2020, after our review but before this report was published, CCHCS reported adding the symptom of fatigue
into the electronic health record system (EHRS) PowerForm for tuberculosis (TB)-symptom monitoring.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership and the public health nurse should consider
educating their nursing staff in accurately monitoring patients
taking TB medications.
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Nursing Performance
Overall
In this indicator, the OIG clinicians evaluated the quality of care delivered by the Rating
institution’s nurses, including registered nurses (RNs), licensed vocational nurses Adequate
(LVNs), psychiatric technicians (PTs), and certified nursing assistants (CNAs).
Our clinicians evaluated nurses’ performance in making timely and appropriate
Case Review
assessments and interventions. We also evaluated the institution’s nurses’
Rating
performance in many clinical settings and processes, including sick call,
Adequate
outpatient care, care coordinating and management, emergency services,
specialized medical housing, hospitalizations, transfers, specialty services, and Compliance
medication management. The OIG assessed nursing care through case review
Score
only and performed no compliance testing for this indicator. (N/A)
When summarizing overall 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.
Results Overview
CAL generally delivered acceptable nursing care. Compared to their performance
in Cycle 5, CAL nurses improved in assessment, intervention, and documentation
in outpatient clinics, care management, emergency services, hospital returns, and
specialty services. In this cycle, CAL nursing performance was very good in
hospitalizations and in specialty services. However, nurses had opportunities for
improvement in assessments, documentation, and interventions, especially in the
OHU and in interfacility transfers. We rated this indicator adequate.
Case Review Results
Our clinicians reviewed 184 nursing encounters in 46 cases, of which 97 were
outpatient nursing encounters. We identified 66 deficiencies, seven of which
were significant.40 Of the 97 outpatient nursing encounters, we identified 37
deficiencies, two of which were significant.41
Nursing Assessment and Intervention
A critical component of nursing care is the quality of nursing assessment, which
includes both subjective (patient interview) and objective (observation and
examination) elements. CAL nurses generally provided adequate nursing
assessments and interventions. Most deficiencies related to the quality of nursing
care were due to incomplete or inadequate nursing assessments. We identified a
pattern of incomplete COVID-19 isolation or quarantine rounds, incomplete vital
40 Nursing performance deficiencies occurred in cases 1–7, 12-13, 15-19, 22, 25, 26, 30, 31, 33, 34, 36,
39, 40, and 42–47. Significant deficiencies occurred in cases 6, 18, 33, and 46.
41 Outpatient nursing performance deficiencies occurred in cases 1–4, 6, 12–19, 30, 31, 33, 34, 36, 39,
40, and 42–45. Significant deficiencies occurred in cases 6 and 33.
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signs, especially the weight, and incomplete assessments of medication
compliance.
• In cases 1, 2, 15, 16, 17, 18, 19, and 22, nurses did not perform
COVID-19 quarantine rounds, as ordered.
• In cases 7, 13, 15, 17, 18, 22, 33, 42, 46, and 47, nurses either did not
fully complete vital signs or did not complete vital signs at all.
• In cases 15, 33, and 39, nurses did not assess medication compliance.
• In case 2, nurses completed COVID-19 isolation rounds twice a day.
However, nurses did not consistently obtain a full set of vital signs
that included the respiratory rate.
• In case 6, the LVN consulted with the RN for a patient who reported
symptoms of vomiting, fever, and the inability to hold down water.
However, the RN instructed the LVN to advise the patient to submit
a sick call request instead of evaluating the patient the same day for
possible COVID-19 symptoms and dehydration.
• In case 15, the diabetic patient complained of lightheadedness,
dizziness, and vomiting blood. The patient was transported to the
hospital. The nurse did not obtain orthostatic vital signs or a blood
sugar level, document the times EMS arrived and departed from the
TTA, nor assess the patient’s condition upon transfer.
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. Some examples of incomplete documentation
include timeline discrepancies in emergency events, missing documentation on
the medication administration record, missing discharge documentation from
patients discharged from the OHU, missing refusals forms, and missing
documentation of communication for pending specialty appointments for
patients transferring out of the institution. However, CAL nurses performed well
in documentation for outpatient clinics, specialty services, transfers, and
hospitalizations.
Nursing Sick Call
The nursing sick call process involves reviewing each sick call request and
determining whether the patient’s medical symptoms warrant an urgent or
routine evaluation. Our clinicians reviewed 49 nursing sick call requests and
identified 21 deficiencies, one of which was significant.42 CAL nurses reviewed
42 Deficiencies in face-to-face assessments for sick call requests occurred in cases 3, 13, 15, 17, 18, 30,
31, 33, 36, 39, 40, 42, 43, 44, and 45. One significant deficiency occurred in case 33.
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symptomatic sick call requests appropriately and generally saw patients timely.
The examples below demonstrate room for improvement:
• In case 3, the sick call nurse evaluated the patient for leg swelling
after starting a new blood pressure medication. However, the nurse
did not weigh the patient. In addition, instead of consulting with the
provider that day for a further plan of care, the nurse referred the
patient for a provider appointment in 14 days.
• In case 15, the patient complained of not being able to keep
food down and reported daily vomiting. The sick call nurse did not
obtain a weight nor assess abdominal tenderness, flatness, or
distention.
• In case 33, the patient with a history of asthma complained of
food allergies, difficulty breathing, diarrhea, and drug withdrawal
symptoms. The sick call nurse did not assess lung sounds, bowel
sounds, or abdominal tenderness; did not indicate whether the
abdomen was flat, distended, or rounded; did not assess medication
compliance since the patient was prescribed an inhaler; and did not
obtain a weight.
• In case 44, the patient was evaluated for hearing loss and tenderness
to the right ear. However, the sick call nurse did not inspect the
inside of the right ear. In addition, the nurse documented on the ear
drop medication order that the medication was to be placed in the
wrong ear.
Care Management
OIG clinicians reviewed seven cases in which patients were evaluated by a care
manager or coordinator.43 Our clinicians found nurses generally performed
appropriate assessments and interventions for patients with chronic conditions.
The RNs evaluated the patients’ need for chronic care appointments upon their
transfer into the institution and for follow-up visits ordered by the provider. The
LVNs serve as care coordinators in addition to their other duties, such as
performing TB screening, blood pressure checks, blood glucose checks, wound
care, patient education, COVID-19 testing, vaccinations, and EKGs, as well as
distributing durable medical equipment.
Wound Care
We reviewed one case in which wound care was provided.44 We identified no
deficiencies for wound care.
43 Patients were evaluated by the care manager in cases 2, 4, 9, 11, 13, 15, and 16.
44 Wound care was performed in case 16.
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Emergency Services
Staff performed well when responding to urgent and emergent patients. Nurses
generally provided appropriate assessments, interventions, and documentation.
However, we identified a pattern of inconsistent timelines related to the
sequence of events for patients transferring to the community hospital.45 We also
found room for improvement in the accuracy of the emergency response reviews
completed as part of the EMRRC audits.46 We discuss this further in the
Emergency Services indicator.
Hospital Returns
We reviewed 11 events in eight cases involving patients who returned from a
community hospital or emergency room.47 Nurses performed well in providing
complete assessments, interventions, and documentation. However, we did
identify deficiencies related to medication continuity. We discuss this further in
the Transfers indicator.
Transfers
We reviewed 10 cases that involved transfer-in or transfer-out processes at
CAL.48 Nurses generally performed well in the transfer-in process. However,
there was room for improvement in the transfer-out process, due to incomplete
screenings and missing documentation or communication of pending specialty
appointments. Please refer to the Transfers indicator for further details.
Specialized Medical Housing
We reviewed five cases with a total of 22 nursing events, and we identified 16
deficiencies, five of which were significant.49 Nursing assessment,
documentation, and care plans had room for improvement in the outpatient
housing unit (OHU). We discuss this further in the Specialized Medical Housing
indicator.
45 Emergency services documentation deficiencies occurred in cases 3, 5, 15, 17, 18, and 19.
46 Deficiencies in EMR audits were occurred in cases 3, 5, 15, 17, and 19.
47 Patients returning from an off-site hospitalization or emergency room visit occurred in cases 3, 4, 7,
15, 16, 17, 18, and 19.
48 Transfer cases included cases 4, 8, 20, 22, 23, 24, 25, 26, 27, and 46.
49 SMH nursing deficiencies occurred in cases 7, 18, 46, and 47. Significant deficiencies occurred twice
in case 18 and three times in case 46.
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Specialty Services
We reviewed 68 events in 16 cases in which patients received specialty services;
there were no nursing performance deficiencies.50 When patients returned to the
institution from a specialty appointment, CAL nurses performed very well.
Nurses appropriately assessed patients, reviewed off-site documents for
recommendations, and communicated information to providers.
Medication Management
Our clinicians examined 113 events in 26 cases related to medications. We found
21 medication deficiencies, six of which were significant.51 Both compliance
inspectors and case reviewers identified lapses in medication continuity. In
addition, we found incomplete medication reconciliation for patients returning
from the hospital and lapses in medication administration in the OHU. Please
refer to the Medication Management indicator for further details.
Clinician On-Site Inspection
Our clinicians interviewed nurses and nurse managers in the triage and
treatment area (TTA), the outpatient housing unit, and the receiving and release
(R&R) area, as well as in the specialty services clinics, public health clinics,
outpatient clinics, and medication areas. Clinics B, C, and D were under
construction, so the staff was working out of temporary facilities. Clinic A
construction was completed six months prior to our on-site visit. We attended
two outpatient clinic huddles and one OHU huddle. The huddles were well
attended by the care teams, and pertinent information was discussed. Nursing
staff were familiar with the patient population.
Clinic staff reported no backlog for the RN line at the time of our visit. The RN
clinic line ranged from 15 to 23 patients per day, and the LVN care coordinator
line ranged from 20 to 30 patients per day. The LVN staff served as care
coordinators, and their duties consisted of performing blood pressure checks,
performing TB screenings, offering vaccines, patient education, and dispensing
durable medical equipment. The two outpatient clinics we visited were short-
staffed, and the LVN care coordinators were out due to illness.
We also met with the chief executive officer (CEO), the chief medical executive
(CME), chief nursing executive (CNE), the supervising registered nurse III (SRN
III), the chief physician and surgeon (CP&S), the public health nurse (PHN), and
the infection control nurse, and were told that the institution was on a modified
program due to the COVID-19 outbreak at the institution. At the time of our
visit, the team reported that 81 percent of patients were COVID-19 vaccinated
and 77 percent of staff were COVID-19 vaccinated.
50 Specialty services occurred in cases 3, 4, 7, 9, 10, 11, 12, 13, 14, 15, 17, 18, 20, 21, 46, and 47.
51 Deficiencies in medication management occurred once in cases 1, 4, 12, 13, 14, 18, 26, 28, and 47;
twice in cases 7 and 46; and four times in cases 15 and 17. Significant deficiencies occurred in cases 4,
7, 13, 15, 17, and 46.
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The CEO reported the goal was to offer the patients the COVID-19 booster
vaccines by March 2022.
At our on-site visit, the leadership informed us that they had 30 patients who had
tested positive for COVID-19 and approximately 70 staff who either tested
positive for COVID-19 or were in isolation or quarantine due to COVID-19
exposure. Five buildings were under COVID-19 quarantine. Patients in the
quarantined buildings were released in cohorts, according to their building, for
medications and appointments. The patients in COVID-19 isolation were
medicated at the cell front, and if they had any medical concerns, they were
evaluated in the building, which had a clinic space with adequate vital sign
equipment. In addition, we were informed the CME had written standing orders
for cough drops, Pedialyte, and Tylenol to limit patient movement for patients
with COVID-19 symptoms.
The leadership addressed our findings and acknowledged several opportunities
for quality improvement. Nursing leadership expressed its belief that the team
had experienced challenges with staffing due to a 66-percent vacancy rate along
with multiple staff who had been out sick due to COVID-19, but acknowledged
the great work the team had performed in providing patient care, despite the
current staffing constraints.
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Recommendations
• Nursing leadership should ensure nurses perform more detailed
assessments and interventions during outpatient patient encounters
and should consider implementing audits.
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Provider Performance
Overall
In this indicator, OIG case review clinicians evaluated the quality of care Rating
delivered by the institution’s providers: physicians, physician assistants, and Adequate
nurse practitioners. Our clinicians assessed the institution’s providers’
performance in evaluating, diagnosing, and managing their patients properly. We
Case Review
examined provider performance across several clinical settings and programs,
Rating
including sick call, emergency services, outpatient care, chronic care, specialty
Adequate
services, intake, transfers, hospitalizations, and specialized medical housing. We
assessed provider care through case review only and performed no compliance
Compliance
testing for this indicator.
Score
(N/A)
Results Overview
CAL providers delivered good patient care in this cycle. They generally made
appropriate assessments and decisions, managed chronic medical conditions
effectively, reviewed medical records thoroughly, and addressed specialists’
recommendations adequately. The OIG rated this indicator adequate.
Case Review Results
In our inspection, we found a total of nine deficiencies, of which two were
considered significant.52 OIG physicians also rated the overall adequacy of care
for each of the 20 detailed case reviews they conducted. Of these 20 cases, 19
were adequate and one was inadequate.
Assessment and Decision-Making
CAL providers generally made appropriate assessments and sound medical plans
for their patients. They diagnosed medical conditions correctly, ordered
appropriate tests, and coordinated effective treatment plans for their patients.
Our clinicians identified four deficiencies related to poor medical decisions.53 An
example follows:
• In case 46, the patient complained of an ingrown toenail. The
provider noted that the patient had an ingrown toenail on the left
foot, but did not document which toe or assess for signs of infection
that may have required treatment and an antibiotic.
52 Deficiencies occurred in cases 5, 6, 8, 9, 11, 15, 16, 17, and 48. Significant deficiencies occurred in
cases 6 and 11.
53 Deficiencies occurred in cases 8, 16, 17, and 46.
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Review of Records
For patients who returned from hospitalizations, CAL providers performed well
in reviewing medical records and addressing the hospitalists’ recommendations.
Providers also performed well in reviewing the medication administration record
(MAR) and reconciling the patient’s medications.
Emergency Care
CAL providers made appropriate triage decisions when the patients arrived at
the triage and treatment area (TTA) for emergency treatment. In addition,
providers were available for consultation with the TTA nursing staff. We did not
identify any deficiencies related to emergency care.
Chronic Care
CAL providers delivered good care in managing chronic medical conditions such
as hypertension, diabetes, asthma, hepatitis C infection, and cardiovascular
disease. For patient with diabetes, the providers regularly monitored the patients’
blood glucose levels and adjusted diabetic medications as needed. However, our
clinicians identified two deficiencies related to diabetic care, of which one was
considered significant.54 An example follows:
• In case 11, the provider reviewed an elevated hemoglobin A1c
consistent with the diagnosis of new onset diabetes.55 However,
the provider did not address the new onset diabetes until almost
three months later.
For patients requiring anticoagulation, providers prescribed appropriate doses of
oral anticoagulants and monitored INR levels when indicated.56 However, there
was one significant deficiency related to poor anticoagulation management:
• In case 6, the patient had an acute deep vein thrombosis, and the
provider prescribed an oral anticoagulant at half of the
recommended dose to treat an acute deep vein thrombosis.
54 Deficiencies occurred in cases 9 and 11. A significant deficiency occurred in case 11.
55 Hemoglobin A1c is a blood test that measures the average plasma glucose over the previous 12
weeks.
56 The INR is a lab test to measure the body’s blood clotting. This test is used to monitor the effectiveness of blood thinning medications
such as warfarin.
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Specialty Services
CAL providers appropriately referred patients to specialists and reviewed
specialty reports in a timely manner; providers also adequately addressed
specialists’ recommendations. Our clinicians did not identify any provider
deficiencies related to specialty services.
Documentation Quality
CAL providers generally documented outpatient and TTA encounters on the day
of the encounter. Our clinicians identified two deficiencies related to a provider’s
lack of documentation.57 An example follows:
• In case 5, the patient presented to the TTA without a pulse, and a
provider was notified; however, the provider did not document a
progress note for this TTA event.
Provider Continuity
CAL assigned providers to specified clinics to ensure continuity of care. Our
clinicians did not identify any issues related to provider continuity.
Clinician On-Site Inspection
Medical leadership reported that CAL had 6.5 provider positions and no
vacancies. Providers were enthusiastic about their work and generally satisfied
with nursing, diagnostic, and specialty services. Provider meetings occur every
Wednesday, and population health management meetings occur one to two
times per months for each main clinic. Our clinicians attended morning huddles,
where the clinic team discussed patients returning from hospitalization or
specialty appointments with recommendations. The nurses informed the
providers of the scheduled appointments, expiring medications, and new arrivals
from other institutions.
CAL providers routinely screened patients for possible opioid abuse and referred
them to the substance use disorder treatment program. Our clinicians discussed
with the chief physician and surgeon (CP&S) and chief medical executive (CME)
possible Suboxone diversion.58 Our clinicians discussed a case where the patient
stated that he injected Suboxone under his clavicle, and subsequently the patient
developed soft tissue infection and osteomyelitis.59 The CME acknowledged the
possible Suboxone diversion and stated that the institution followed the CCHCS
guidelines for Suboxone administration. The CME also consulted with CCHCS
57 Deficiencies occurred cases 5 and 15.
58 Suboxone is a medication containing buprenorphine and naloxone. Suboxone is used to treat opioid
dependence and addiction.
59 Osteomyelitis is an infection of the bone.
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medical leadership, who instructed the institution to continue with the use of
Suboxone, as the benefits outweigh the risks of harm.
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Recommendations
The OIG offers no recommendations for this indicator.
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Specialized Medical Housing
Overall
Rating
In this indicator, OIG inspectors evaluated the quality of care in the specialized
Inadequate
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 Case Review
quality of provider and nursing intake assessments and care plans. We assessed Rating
staff members’ performance in responding promptly when patients’ conditions Inadequate
deteriorated, and we looked for good communication when staff consulted with
Compliance
one another while providing continuity of care. Our clinicians also interpreted
Score
relevant compliance results and incorporated them into this indicator. At the
Adequate
time of our inspection, CAL’s specialized medical housing consisted of an
(75.0%)
outpatient housing unit (OHU).
Results Overview
Overall, CAL delivered poor care in the OHU. We found poor nursing
assessments and interventions. We also found problems with medication
continuity. However, provider performance was adequate. After considering case
review results and compliance testing, we rated this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed five OHU cases, which included 25 provider events and 22 nursing
events.60 Because of the care volume that occurred in the specialized medical
housing unit, each provider event represented up to one month of provider care,
and each nursing event represented up to two weeks of nursing care. We
identified 22 deficiencies, six of which were significant.61
Provider Performance
The providers generally delivered good care in the OHU. Compliance inspectors
found that providers generally performed timely admission history and physical
exams (MIT 13.002, 80.0%). Our clinicians reported similar findings: providers
performed rounds on their patients within appropriate intervals and completed
thorough discharge summaries. Our clinicians found one provider deficiency;
this deficiency is discussed in the Provider Performance indicator.62
60 OHU events occurred in cases 7, 8, 18, 46, and 47.
61 OHU deficiencies occurred three times in case 47, four times in case 7, six times in case 18, and
nine times in case 46. Significant deficiencies occurred twice in case 18 and four times in case 46.
62 The deficiency occurred in case 46.
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Nursing Performance
Compliance testing found that patients admitted into the OHU frequently did
not receive a timely initial nursing health assessment (MIT 13.001, 50.0%). Our
clinicians did not identify any missed or delayed initial nursing health
assessments. However, we found incomplete nursing assessments, missed care
plans, and poor documentation. Our clinicians concluded that of the 22
deficiencies in specialized medical housing, 16 were directly related to quality of
nursing care, five of which were significant. Examples of deficiencies follow:
• In cases 7, 18, 46, and 47, the nurses did not establish appropriate
patient care plans.
• In cases 7 and 18, the nurses did not consistently assess the PICC
line site at least daily for the patients requiring intravenous (IV)
antibiotic therapy.63 Furthermore, in these two cases, the nurses did
not consistently obtain vital signs twice a day, as ordered.
• In case 18, on several occasions, the certified nursing assistant (CNA)
obtained vital signs showing low pulses but did not notify the RN for
further evaluation. In addition, an RN did not obtain an antibiotic
trough level, as ordered.64
• In case 46, the patient with end stage liver disease was admitted to
the OHU, but the admitting nurse did not assess lung and bowel
sounds, did not palpate the abdomen for tenderness, and did not
assess abdominal appearance. The nurse also did not obtain an
admission weight. In addition, on a few occasions the patient’s
oxygen saturation was low while the patient was on room air;
however, the nurses did not assess lung sounds, respiratory rate, skin
color, or reassess the oxygen saturation timely.
• In case 47, the patient returned from a hospitalization for a joint
infection and was readmitted to the OHU. The nurse did not obtain
the patient’s weight upon his readmission and did not establish a
care plan to address the infection. In addition, the nurses did not
consistently complete a full set of vital signs to include temperature,
respiration rate, pulse, blood pressure, and oxygen saturation at least
daily for a patient with an infection requiring antibiotic therapy.
63 A PICC is a peripherally inserted central catheter, which is used to provide intravenous access and
administer fluids and medication.
64 The trough is the lowest level of the drug while in the therapeutic range. Trough levels are used in
medication monitoring.
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Medication Administration
OHU staff performed poorly in medication administration. Compliance testing
showed 70.0 percent of patients newly admitted to the OHU received their
medications within the required time frames (MIT 13.004). Our clinicians
identified five deficiencies related to medication management; one was
considered significant.65 The following are examples:
• In case 18, the patient received the newly prescribed antibiotic one
day late.
• In case 46, the patient was transferred to CAL and admitted to the
OHU; however, the patient did not receive four doses of his blood
pressure medication.
• In case 47, the patient received the newly prescribed blood pressure
medication four days late.
Clinician On-Site Inspection
Our clinicians interviewed the OHU RN and the provider, who reported having a
good working relationship with medical leadership and nursing staff. The OHU
nurse reported the TTA or R&R RN provided care to the patient after hours, and
that care could include admissions, discharges, emergencies, or changes of
condition. When asked whether care plans were initiated in OHU, the OHU
nurse reported that OHU nurses do not create care plans, and if there were an
order to “Review Care Plans,” that order meant they were to review the chart, not
the actual care plan. The OHU nurse reported that sick call requests were
collected and addressed the same day.
Our clinicians attended the well-organized OHU morning huddle, which was
conducted daily. The provider, the RN, the utilization management nurse, the
office technician, the infection control nurse, the supervising RN, and custody
staff were present. The discussion included admissions, discharges, emergencies,
medication renewals and refusals, specialty appointments, and patients on
antibiotics through the PICC line.
The institution’s OHU had 18 beds, including two negative-pressure rooms for
respiratory isolation. At the time of our on-site inspection, 13 beds were
occupied, and two were vacant due to alarm issues and a water leak. Nursing
staff reported that patients who were at risk of falling were provided portable call
lights in addition to their room call lights to help prevent injury.
Nurses provided 24-hour care, with an RN and CNA in the morning and one LVN
on the evening and graveyard shifts. When there was no RN on duty in the OHU,
65 Deficiencies occurred once in case 7, 18, and 47, and twice in case 46. A significant deficiency
occurred once in case 46.
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the LVNs were instructed to notify the treatment and triage area (TTA) RN if
they had any patient concerns. The supervising RN was recently assigned to the
OHU, approximately one month prior to our on-site visit, and was still learning
the responsibilities in the OHU.
In the OHU, the provider generally saw the patient once a month, or more
frequently as needed. The nurse reported rounds were performed on every shift
and documented in a communication book. These rounds consisted of making
sure the patient was stable and addressing any patient concerns. If a patient
reported any changes of conditions or had any abnormal findings, the LVN or
CNA notifies the RN for further evaluation and documents the conditions or
findings, as well as the RN notification, in the electronic health record. The OHU
RN generally performed rounds on the patient daily.
When our clinicians met with nursing leadership to review on-site questions
regarding poor assessments or documentation, the nursing leadership reported
that in the future more oversight would be implemented. Nursing leadership
reported they had a PICC line group that created the PICC local operating
procedures. The CNE reported the PICC line group will help monitor staff
compliance and charting, to ensure that antibiotics were administered and the
PICC policy was followed. Nursing leadership was not aware that OHU nurses
were not initiating care plans but confirmed that OHU nurses should be
initiating care plans for patients in OHU, and that training would be provided.
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Table 17. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Prior to 4/2019: Did the registered
nurse complete an initial assessment of the patient on the day of
admission, or within eight hours of admission to CMF’s Hospice? 5 5 0 50.0%
Effective 4/2019: Did the registered nurse complete an initial
assessment of the patient at the time of admission? (13.001) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time 8 2 0 80.0%
frame? (13.002) *
For OHU, CTC, SNF, and Hospice (applicable only for samples prior
to 4/2019): Did the primary care provider complete the
Subjective, Objective, Assessment, and Plan notes on the patient 0 0 10 N/A
at the minimum intervals required for the type of facility where the
patient was treated? (13.003) *,†
Upon the patient’s admission to specialized medical housing: Were
all medications ordered, made available, and administered to the 7 3 0 70.0%
patient within required time frames? (13.004) *
For OHU and CTC only: Do inpatient areas either have properly
working call systems in its OHU & CTC or are 30-minute patient
1 0 0 100%
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter patient’s cells? (13.101) *
For specialized health care housing (CTC, SNF, Hospice, OHU):
Do health care staff perform patient safety checks according to
0 0 1 N/A
institution’s local operating procedure or within the required time
frames? (13.102) *
Overall percentage (MIT 13): 75.0%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still have
state-mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of
provider follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
• Nursing leadership should ensure nurses initiate and document care
plans in the electronic health record system (EHRS).
• Nursing leadership should remind outpatient housing unit (OHU)
nurses to adhere to PICC line local operating procedures.
• Nursing leadership should remind nurses to complete the OHU
admission assessment within the required time frame, as stated in
CCHCS policy.
• Nursing leadership should ensure that patients admitted to the OHU
receive their medications upon admission timely and without
interruption.
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Specialty Services
Overall
Rating
In this indicator, OIG inspectors evaluated the quality of specialty services. The
Adequate
OIG clinicians focused on the institution’s performance in providing needed
specialty care. Our clinicians also examined specialty appointment scheduling,
Case Review
providers’ specialty referrals, and medical staff’s retrieval, review, and
Rating
implementation of any specialty recommendations.
Adequate
Compliance
Results Overview
Score
Adequate
CAL provided good specialty services for their patients. The institution
(79.6%)
performed well in ensuring that specialty appointments occurred within the
required time frames. However, the institution did not always ensure that
preapproved specialty appointments occurred timely for patients transferred into
the institution. Medical staff generally retrieved specialty reports timely. Nurses
appropriately assessed patients’ returns from specialty appointments and
informed the providers about any specialists’ urgent recommendations. We rated
this indicator adequate.
Case Review and Compliance Testing Results
Our clinicians reviewed 81 events related to specialty services, including 68
specialty consultations and procedures, and found six deficiencies, two of which
were significant.66 The institution performed well in completing specialty
appointments and scanning specialty reports. However, two specialty reports
were not retrieved timely, and three reports were not endorsed within the
required time frames.
Access to Specialty Services
Compliance testing showed that CAL completed the initial high-priority,
medium-priority, and routine specialty appointments within the required time
frames (MIT 14.001, 86.7%; MIT 14.004; 80.0%, and MIT 14.007, 100%). The
institution also performed well in completing high-priority, medium-priority, and
routine follow-up specialty appointments (MIT 14.003, 100%; MIT 14.006, 88.9%;
and MIT 14.009, 100%). Our clinicians did not identify any missed or delayed
specialty appointments.
For patients transferring into CAL, preapproved specialty appointments often
occurred untimely (MIT 14.010, 25.0%). Our clinicians reviewed seven transfer-in
events and did not identify any missed or delayed preapproved specialty
appointments.
66 Deficiencies occurred once in cases 15 and 17, and twice in cases 3 and 20. Significant deficiencies
occurred in cases 3 and 20.
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Provider Performance
Providers generally referred patients appropriately, reviewed specialty reports
within the recommended time frames, and addressed the specialists’
recommendations. We did not identify any deficiencies related to provider
performance.
Nursing Performance
Specialty nurses reviewed requests for specialty services and appropriately
arranged for specialty appointments. The nurses performed excellent nursing
assessments when patient returned from their specialty appointments. They
reviewed the specialists’ findings and recommendations and communicated those
results to the providers. The nurses also obtained orders and requested provider
follow-up appointments. We reviewed 13 nursing encounters related to specialty
services and did not identify any deficiencies.
Health Information Management
Compliance testing showed that 86.7 percent of specialty reports were scanned
within the required time frames (MIT 4.002). However, the institution did not
always receive or review the high-priority, medium-priority, and routine specialty
reports within the required time frames (MIT 14.002, 78.6%; MIT 14.005, 80.0%;
and MIT 14.008, 66.7%). Our clinicians identified two specialty reports retrieved
late.67 One example follows:
• In case 20, the orthopedic surgeon evaluated the patient; however,
the report was not retrieved until 20 days after this encounter.
Our clinicians also identified one specialty report not endorsed by a provider and
two reports endorsed late.68
Patient Care Environment
The telemedicine staff generally maintained the video, audio, and remote medical
equipment, such as the stethoscope and the otoscope, so specialists could
effectively assess their patients. However, there was a deficiency related to
remoted medical equipment that was not available or broken:
• In case 3, the telemedicine cardiologist saw the patient twice, and in
each appointment, the remote stethoscope was either not available
or broken.
67 Late retrieval of a specialty reports occurred twice case 20.
68 An unendorsed specialty report occurred in case 17, and two late endorsed reports occurred in cases
3 and 15.
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Clinician On-Site Inspection
The institution employed multiple nurses for on-site, off-site, and telemedicine
specialty services. The nurses reviewed specialty requests, contacted the
specialist for available appointments, and scheduled the appointments. The
specialty nurses also assembled the diagnostic tests requested by the specialists
and forwarded these tests to the specialists on the days of their appointments.
CAL medical record staff acknowledged the missing specialty reports and had
informed the program specialist. CAL medical records staff also informed our
clinicians that the specialists occasionally did not forward their reports to CAL
within the required time frames.
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Table 18. Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive the high-priority specialty service within
14 calendar days of the primary care provider order or the Physician 13 2 0 86.7%
Request for Service? (14.001) *
Did the institution receive and did the primary care provider review
the high-priority specialty service consultant report within the 11 3 1 78.6%
required time frame? (14.002) *
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 11 0 4 100%
provider? (14.003) *
Did the patient receive the medium-priority specialty service
within 15-45 calendar days of the primary care provider order or 12 3 0 80.0%
Physician Request for Service? (14.004) *
Did the institution receive and did the primary care provider review
the medium-priority specialty service consultant report within the 12 3 0 80.0%
required time frame? (14.005) *
Did the patient receive the subsequent follow-up to the medium-
priority specialty service appointment as ordered by the primary 8 1 6 88.9%
care provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 15 0 0 100%
Request for Service? (14.007) *
Did the institution receive and did the primary care provider review
the routine-priority specialty service consultant report within the 10 5 0 66.7%
required time frame? (14.008) *
Did the patient receive the subsequent follow-up to the routine-
priority specialty service appointment as ordered by the primary 8 0 7 100%
care provider? (14.009) *
For endorsed patients received from another CDCR institution: If
the patient was approved for a specialty services appointment at the
5 15 0 25.0%
sending 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
1 1 1 50.0%
specialty services within required time frames? (14.011)
Following the denial of a request for specialty services, was the
patient informed of the denial within the required time frame? 3 0 0 100%
(14.012)
Overall percentage (MIT 14): 79.6%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 19. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up
14 3 28 82.4%
visits occur within required time frames? (1.008) *, †
Are specialty documents scanned into the patient’s electronic health
26 4 15 86.7%
record within five calendar days of the encounter date? (4.002) *
* The OIG clinicians considered these compliance tests along with their own case review findings when
determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care physician
follow-up visits following most specialty services. As a result, we test 1.008 only for high-priority specialty
services or when the staff orders PCP or PC RN follow-ups. The OIG continues 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 ascertain the challenges to provider’s
receiving specialty reports within the required time frames, as well
as challenges to providers’ timely reviewing those reports, and
leadership should implement remedial measures as appropriate.
• Medical leadership should ensure patients receive preapproved
specialty services within the specified time frames.
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Administrative Operations
Overall
Rating
In this indicator, OIG compliance inspectors evaluated health care
Inadequate
administrative processes. Our inspectors examined the timeliness of the medical
grievance process and checked whether the institution followed reporting
Case Review
requirements for adverse or sentinel events and patient deaths. Inspectors
checked whether the Emergency Medical Response Review Committee (EMRRC) Rating
met and reviewed incident packages. We investigated and determined whether (N/A)
the institution conducted the required emergency response drills. Inspectors also
Compliance
assessed whether the Quality Management Committee (QMC) met regularly and
Score
addressed program performance adequately. In addition, our inspectors
Inadequate
determined whether the institution provided training and job performance
(74.3%)
reviews for its employees. We checked whether staff possessed current, valid
professional licenses, certifications, and credentials. The OIG rated this indicator
solely according to the compliance score, using the same scoring thresholds used
in the Cycle 4 and Cycle 5 medical inspections. Our case review clinicians do not
rate this indicator.
Because none of the tests in this indicator affected clinical patient care directly
(it is a secondary indicator), we did not consider this indicator’s rating when
determining the institution’s overall quality rating.
Results Overview
CAL’s performance was mixed in this indicator, as the institution scored well in
some applicable tests but faltered in others. The Emergency Medical Response
Review Committee (EMRRC) did not always complete the required checklists. In
addition, the institution conducted medical emergency response drills with
incomplete documentation. Physician managers did not always complete annual
performance appraisals in a timely manner. These findings are set forth in the
table on the next page. Overall, we rated this indicator inadequate.
Nonscored Results
At CAL, the OIG did not have any applicable adverse sentinel events requiring
root cause analysis during our inspection period (MIT 15.001).
We obtained CCHCS Death Review Committee (DRC) reporting data. Two
unexpected (Level 1) deaths and one expected (Level 2) death occurred during our
review period. In our inspection, we found the DRC did not complete any death
review reports promptly. The DRC finished all three reports 43 to 99 days late
and submitted the reports to the institution’s CEO 36 to 92 days late (MIT 15.998).
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Table 20. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the
N/A N/A N/A N/A
institution meet RCA reporting requirements? (15.001) *
Did the institution’s Quality Management Committee (QMC) meet
6 0 0 100%
monthly? (15.002)
For Emergency Medical Response Review Committee (EMRRC)
reviewed cases: Did the EMRRC review the cases timely, and did
3 9 0 25.0%
the incident 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 N/A N/A N/A N/A
operating 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 0 3 0 0
custody staff participate in those drills? (15.101)
Did the responses to medical grievances address all of the inmates’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial inmate death reports
2 1 0 66.7%
to the CCHCS Death Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
10 0 0 100%
administer medications? (15.104)
Did physician managers complete provider clinical performance
0 6 0 0
appraisals timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 10 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR),
Basic Life Support (BLS), and Advanced Cardiac Life Support (ACLS) 2 0 1 100%
certifications? (15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy 6 0 1 100%
maintain a valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
1 0 0 100%
Agency (DEA) registration certificates? (15.109)
Did nurse managers ensure their newly hired nurses received the
1 0 0 100%
required onboarding and clinical competency training? (15.110)
This is a nonscored test. Please
Did the CCHCS Death Review Committee process death review
refer to the discussion in this
reports timely? (15.998)
indicator.
This is a nonscored test. Please
What was the institution’s health care staffing at the time of the OIG
refer to Table 4 for CCHCS-
medical inspection? (15.999)
provided staffing information.
Overall percentage (MIT 15): 74.3%
* Effective March 2021, this test was for informational purposes only.
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 CAL
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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 6 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 our
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
To reach an overall quality rating, our inspectors collaborate and examine all the
inspection findings. We consider the case review and the compliance testing
results for each indicator. After considering all the findings, our inspectors reach
consensus on an overall rating for the institution.
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Appendix B: Case Review Data
Table B–1. CAL Case Review Sample Sets
Sample Set Total
Anticoagulation 3
CTC/OHU 2
Death Review/Sentinel Events 2
Diabetes 3
Emergency Services – CPR 1
Emergency Services – Non-CPR 2
High Risk 4
Hospitalization 4
Intrasystem Transfers In 3
Intrasystem Transfers Out 3
RN Sick Call 18
Specialty Services 2
Total 47
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Table B–2. CAL Case Review Chronic Care Diagnoses
Diagnosis Total
Anemia 5
Anticoagulation 3
Arthritis/Degenerative Joint Disease 3
Asthma 5
COPD 1
COVID-19 4
Cancer 1
Cardiovascular Disease 2
Chronic Pain 13
Cirrhosis/End-Stage Liver Disease 3
Coccidioidomycosis 1
Deep Venous Thrombosis / Pulmonary Embolism 3
Diabetes 7
Gastroesophageal Reflux Disease 5
Gastrointestinal Bleed 1
Hepatitis C 15
Hyperlipidemia 10
Hypertension 14
Mental Health 5
Migraine Headaches 1
Seizure Disorder 1
Sleep Apnea 1
Substance Abuse 18
Total 122
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Table B–3. CAL Case Review Events by Program
Diagnosis Total
Diagnostic Services 251
Emergency Care 45
Hospitalization 28
Intra-system Transfers In 14
Intra-system Transfers Out 3
Outpatient Care 340
Specialized Medical Housing 75
Specialty Services 134
Total 890
Table B–4. CAL Case Review Sample Summary
Total
MD Reviews Detailed 20
MD Reviews Focused 0
RN Reviews Detailed 12
RN Reviews Focused 27
Total Reviews 59
Total Unique Cases 47
Overlapping Reviews (MD & RN) 12
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Appendix C. Compliance Sampling Methodology
Calipatria State Prison
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least
Patients one 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 Appointment • Clinic (each clinic tested)
(6 per clinic) List • Appointment date (2–9 months)
• Randomize
MIT 1.007 Returns From 8 OIG Q: 4.005 • See Health Information
Community Management (Medical Records)
Hospital (returns from 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 0 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 8 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 Ips selected
MIT 4.004 Scanning Accuracy 24 Documents for any • Any misfiled or mislabeled
tested inmate document identified during
OIG compliance review (24 or
more = No)
MIT 4.005 Returns From 8 CADDIS Off-site • Date (2–8 months)
Community Hospital Admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101–105 Clinical Areas 10 OIG inspector • Identify and inspect all on-site
MITs 5.107–111 on-site review clinical areas.
Transfers
MITs 6.001–003 Intrasystem Transfers 25 SOMS • Arrival date (3–9 months)
• Arrived from (another
departmental facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 2 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 See Access to Care
Medication • At least one condition per
patient—any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of Ips
tested in MIT 7.001
MIT 7.003 Returns From 8 OIG Q: 4.005 • See Health Information
Community Hospital Management (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 5 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
Areas by test on-site review & med line areas that store
medications
MITs 7.104–107 Medication Varies OIG inspector • Identify and inspect on-site
Preparation and by test on-site review clinical areas that prepare and
Administration Areas administer medications
MITs 7.108–111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 25 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 8 On-site active • KOP rescue inhalers &
KOP Medications medication listing nitroglycerin 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 17 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
Annual Screening to inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior
Vaccinations to inspection)
• Randomize
• Filter out Ips tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior
Screening to inspection)
• Date of birth (45 or older)
• Randomize
MIT 9.006 Mammogram N/A at this SOMS • Arrival date (at least 2 yrs. Prior
institution to inspection)
• Date of birth (age 52–74)
• Randomize
MIT 9.007 Pap Smear N/A at this SOMS • Arrival date (at least three yrs.
institution Prior to 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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Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001–008 Reception Center N/A at this SOMS • Arrival date (2–8 months)
institution • Arrived from (county jail, return
from parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001–004 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
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
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• Randomize
MIT 14.010 Specialty Services 20 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3–9 months)
• Randomize
MITs 14.011–012 Denials 3 InterQual • Review date (3–9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events (ASE) 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 3 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 6 On-site • All required performance
Evaluation Packets provider evaluation documents
evaluation files
MIT 15.106 Provider Licenses 10 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site • All staff
◦ Providers (ACLS)
Response certification
Certifications tracking logs ◦ 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
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.109 Pharmacy and All On-site listing • All DEA registrations
Providers’ Drug of 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 Death Review 3 OIG summary log: • Between 35 business days &
Committee deaths 12 months prior
• California Correctional
Health Care Services death
reviews
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California Correctional Health Care Services’
Response
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Cycle 6
Medical Inspection Report
for
Calipatria State Prison
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Neil Robertson
Chief Deputy Inspector General
STATE of CALIFORNIA
August 2022
OIG