OIG
California Correctional Institution Medical Inspection Report Cycle 4
Read the report at CDCR ↗
Robert A. Barton Office of the Inspector General
Inspector General
California Correctional Institution
Medical Inspection Results
Cycle 4
January 2016
Medical Inspection Unit Page 1
Office of the Inspector General State of California
Office of the Inspector General
CALIFORNIA CORRECTIONAL
INSTITUTION
Medical Inspection Results
Cycle 4
Robert A. Barton
Inspector General
Roy W. Wesley
Chief Deputy Inspector General
Shaun R. Spillane
Public Information Officer
January 2016
TABLE OF CONTENTS
Executive Summary ............................................................................................................................. i
Overall Assessment: Adequate .............................................................................................. iii
Clinical Case Review and OIG Clinician Inspection Results ............................................... iii
Compliance Testing Results.................................................................................................. iv
Population-Based Metrics ..................................................................................................... ix
Introduction ......................................................................................................................................... 1
About the Institution ........................................................................................................................... 1
Objectives, Scope, and Methodology.................................................................................................. 5
Case Reviews ................................................................................................................................... 6
Patient Selection for Retrospective Case Reviews .................................................................... 6
Benefits and Limitations of Targeted Subpopulation Review .................................................. 7
Case Reviews Sampled ............................................................................................................. 8
Compliance Testing ......................................................................................................................... 9
Sampling Methods for Conducting Compliance Testing .......................................................... 9
Scoring of Compliance Testing Results .................................................................................... 9
Dashboard Comparisons ......................................................................................................... 10
Overall Quality Indicator Rating for Case Reviews and Compliance Testing .............................. 11
Population-Based Metrics .............................................................................................................. 11
Medical Inspection Results ............................................................................................................... 12
Primary (Clinical) Quality Indicators of Health Care .................................................................... 12
Access to Care ......................................................................................................................... 13
Case Review Results ............................................................................................................ 13
Compliance Testing Results................................................................................................. 13
CCHCS Dashboard Comparative Data ................................................................................ 15
Recommendations ................................................................................................................ 15
Diagnostic Services ................................................................................................................. 16
Case Review Results ............................................................................................................ 16
Compliance Testing Results................................................................................................. 16
Recommendations ................................................................................................................ 17
Emergency Services................................................................................................................. 18
Case Review Results ............................................................................................................ 18
Recommendations ................................................................................................................ 21
Health Information Management (Medical Records) ............................................................. 22
Case Review Results ............................................................................................................ 22
Compliance Testing Results................................................................................................. 24
CCHCS Dashboard Comparative Data ................................................................................ 25
Recommendations ................................................................................................................ 26
Health Care Environment ....................................................................................................... 27
Compliance Testing Results................................................................................................. 27
Recommendations ................................................................................................................ 29
California Correctional Institution, Cycle 4 Medical Inspection Table of Contents
Office of the Inspector General State of California
Inter- and Intra-System Transfers ........................................................................................... 31
Case Review Results ............................................................................................................ 31
Compliance Testing Results................................................................................................. 32
Recommendations ................................................................................................................ 33
Pharmacy and Medication Management ................................................................................ 34
Case Review Results ............................................................................................................ 34
Compliance Testing Results................................................................................................. 35
CCHCS Dashboard Comparative Data ................................................................................ 37
Recommendations ................................................................................................................ 37
Preventive Services ................................................................................................................. 38
Compliance Testing Results................................................................................................. 38
CCHCS Dashboard Comparative Data ................................................................................ 39
Recommendations ................................................................................................................ 39
Quality of Nursing Performance ............................................................................................. 40
Case Review Results ............................................................................................................ 40
Recommendations ................................................................................................................ 41
Quality of Provider Performance ............................................................................................ 42
Case Review Results ............................................................................................................ 42
Recommendations ................................................................................................................ 46
Specialized Medical Housing (OHU, CTC, SNF, Hospice) .................................................... 48
Case Review Results ............................................................................................................ 48
Compliance Testing Results................................................................................................. 50
Recommendations ................................................................................................................ 50
Specialty Services .................................................................................................................... 51
Case Review Results ............................................................................................................ 51
Compliance Testing Results................................................................................................. 52
Recommendations ................................................................................................................ 53
Secondary (Administrative) Quality Indicators of Health Care..................................................... 54
Internal Monitoring, Quality Improvement, and Administrative Operations ......................... 55
Compliance Testing Results................................................................................................. 55
CHCS Dashboard Comparative Data ................................................................................... 57
Recommendations ................................................................................................................ 57
Job Performance, Training, Licensing, and Certifications ..................................................... 58
Compliance Testing Results................................................................................................. 58
Recommendations ................................................................................................................ 59
Population-Based Metrics .............................................................................................................. 60
Appendix A — Compliance Test Results ......................................................................................... 64
Appendix B — Clinical Data ............................................................................................................ 77
Appendix C — Compliance Sampling Methodology ....................................................................... 80
California Correctional Health Care Services’ Response ................................................................. 85
California Correctional Institution, Cycle 4 Medical Inspection Table of Contents
Office of the Inspector General State of California
LIST OF TABLES AND FIGURES
Health Care Quality Indicators ........................................................................................................... ii
CCI Executive Summary Table ....................................................................................................... viii
CCI Health Care Staffing Resources — July 2015 .............................................................................. 2
CCI Master Registry Data as of June 8, 2015 ...................................................................................... 3
Commonly Used Abbreviations .......................................................................................................... 4
Access to Care — CCI Dashboard and OIG Compliance Results..................................................... 15
Health Information Management — CCI Dashboard and OIG Compliance Results ........................ 25
Pharmacy and Medication Management — CCI Dashboard and OIG Compliance Results ............ 37
Preventive Services — CCI Dashboard and OIG Compliance Results ............................................. 39
Internal Monitoring, Quality Improvement, and Administrative Operations —
CCI Dashboard and OIG Compliance Results ............................................................................ 57
CCI Results Compared to State and National HEDIS Scores ........................................................... 63
California Correctional Institution, Cycle 4 Medical Inspection List of Tables and Figures
Office of the Inspector General State of California
EXECUTIVE SUMMARY
Under the authority of California Penal Code Section 6126, which assigns the Office of the
Inspector General (OIG) responsibility for oversight of the California Department of Corrections
and Rehabilitation (CDCR), the OIG conducts a comprehensive inspection program to evaluate the
delivery of medical care at each of CDCR’s 35 adult prisons. The OIG explicitly makes no
determination regarding the constitutionality of care in the prison setting. That determination is left
to the Receiver and the federal court. The assessment of care by the OIG is just one factor in the
court’s determination whether care in the prisons meets constitutional standards. The court may find
that an institution that the OIG found to be providing adequate care still does not meet constitutional
standards, depending on the analysis of the underlying data provided by the OIG. Likewise, an
institution that has been rated inadequate by the OIG could still be found to pass constitutional
muster with the implementation of remedial measures if the underlying data were to reveal easily
mitigated deficiencies.
The OIG’s inspections are mandated by the Penal Code and not aimed at specifically resolving the
court’s questions on constitutional care. To the degree that they provide another factor for the court
to consider, the OIG is pleased to provide added value to the taxpayers of California.
For this fourth cycle of inspections, the OIG added a clinical case review component and
significantly enhanced the compliance portion of the inspection process from that used in prior
cycles. In addition, the OIG added a population-based metric comparison of selected Healthcare
Effectiveness Data Information Set (HEDIS) measures from other State and national health care
organizations and compared that data to similar results for the California Correctional Institution
(CCI).
The OIG performed its Cycle 4 medical inspection at CCI from July to September 2015. The
inspection included in-depth reviews of 63 inmate-patient files conducted by clinicians, as well as
reviews of documents from 415 inmate-patient files, covering 93 objectively scored tests of
compliance with policies and procedures applicable to the delivery of medical care. The OIG
assessed the case review and compliance results at CCI using 14 health care quality indicators
applicable to the institution, made up of 12 primary clinical indicators and two secondary
administrative indicators. To conduct clinical case reviews, the OIG employs a clinician team
consisting of a physician and a registered nurse consultant, while compliance testing is done by a
team of deputy inspectors general trained in monitoring medical compliance. Of the 12 primary
indicators, seven were rated by both case review clinicians and compliance inspectors, three were
rated by case review clinicians only, and two were rated by compliance inspectors only; both
secondary indicators were rated by compliance inspectors only. See the Health Care Quality
Indicators table on page ii. Based on that analysis, OIG experts made a considered and measured
overall opinion that the quality of health care at CCI was adequate.
California Correctional Institution, Cycle 4 Medical Inspection Page i
Office of the Inspector General State of California
Health Care Quality Indicators
All Institutions–
Fourteen Primary Indicators (Clinical) CCI Applicability
Applicability
Both case review
1–Access to Care All institutions
and compliance
Both case review
2–Diagnostic Services All institutions
and compliance
3–Emergency Services All institutions Case review only
4–Health Information Management Both case review
All institutions
(Medical Records) and compliance
5–Health Care Environment All institutions Compliance only
Both case review
6–Inter- and Intra-System Transfers All institutions
and compliance
Both case review
7–Pharmacy and Medication Management All institutions
and compliance
Female institutions
8–Prenatal and Post-Delivery Services Not Applicable
only
9–Preventive Services All institutions Compliance only
10–Quality of Nursing Performance All institutions Case review only
11–Quality of Provider Performance All institutions Case review only
Institutions with
12–Reception Center Arrivals Not Applicable
reception centers
All institutions with
13–Specialized Medical Housing Both case review
an OHU, CTC, SNF,
(OHU, CTC, SNF, Hospice) and compliance
or Hospice
Both case review
14–Specialty Services All institutions
and compliance
Two Secondary Indicators All Institutions–
CCI Applicability
(Administrative) Applicability
15–Internal Monitoring, Quality
Improvement, and Administrative All institutions Compliance only
Operations
16–Job Performance, Training, Licensing,
All institutions Compliance only
and Certifications
California Correctional Institution, Cycle 4 Medical Inspection Page ii
Office of the Inspector General State of California
Overall Assessment: Adequate
Based on the clinical case reviews and compliance testing, the
OIG’s overall assessment rating for CCI was adequate. For the
Overall Assessment
12 primary (clinical) quality indicators applicable to CCI, the OIG
Rating:
found two proficient, nine adequate, and one inadequate. For the
two secondary (administrative) quality indicators, the OIG found
Adequate
one proficient and one inadequate. To determine the overall
assessment for CCI, the OIG considered individual clinical ratings
and individual compliance question scores within each of the
indicator categories, putting emphasis on the primary indicators. Based on that analysis, OIG
experts made a considered and measured overall opinion about the quality of health care observed at
CCI.
Clinical Case Review and OIG Clinician Inspection Results
The clinicians’ case reviews sampled patients with high medical needs and included a review of
1,075 patient care events.1 For the 12 primary indicators applicable to CCI, clinicians evaluated ten
by case review; two were proficient, seven were adequate, and one was inadequate. When
determining the overall adequacy of care, the OIG paid particular attention to the clinical nursing
and provider quality indicators, as adequate health care staff can sometimes overcome suboptimal
processes and programs. However, the opposite is not true; inadequate health care staff cannot
provide adequate care, even though the established processes and programs onsite may be adequate.
The OIG clinicians identify inadequate medical care based on the risk of significant harm to the
patient, not the actual outcome.
While the clinicians rated most indicators proficient or adequate for the case reviews, they had
significant concerns with the quality of both nursing and provider care, with both of these indicators
actually performing only marginally adequately.
Program Strengths — Case Review
Generally, CCI provided excellent access to primary care services.
CCI provided excellent diagnostic services, with diagnostic tests being performed, results
being reviewed by providers, and patients being notified of results in a timely manner.
The institution’s providers mitigated some of the deficiencies identified in this report,
especially with regard to nursing performance.
1 Each OIG clinician team includes a board certified physician and a registered nurse consultant with experience in both
correctional and community medical settings.
California Correctional Institution, Cycle 4 Medical Inspection Page iii
Office of the Inspector General State of California
Program Weaknesses — Case Review
Emergency services were inadequate. Specifically, nurses routinely failed to provide
thorough and appropriate “chest pain” care, and there were problems with the management
of respiratory distress.
Several indicators revealed a pattern of incomplete patient assessment and incomplete
documentation of health care records by nursing staff.
Multiple providers utilized legacy (“cloned”) notes during the period reviewed, which
resulted in deficient patient care.
The internal audits performed at CCI were inadequate. Nursing audits failed to detect
patterns of inadequate care and documentation. The inconsistent process for emergency
medical response review failed to identify deficiencies.
Compliance Testing Results
Of the 14 total indicators of health care applicable to CCI, 11 were evaluated by compliance
inspectors.2 There were 93 individual compliance questions within those 11 indicators, generating
1,221 data points, that tested CCI’s compliance with California Correctional Health Care Services
(CCHCS) policies and procedures.3 Those 93 questions are detailed in Appendix A — Compliance
Test Results. The institution’s inspection scores for the 11 applicable indicators ranged from
71.7 percent to 100 percent, with the secondary (administrative) indicator Internal Monitoring,
Quality Improvement, and Administrative Operations receiving the lowest score, and the primary
(clinical) indicator Specialized Medical Housing (OHU, CTC, SNF, Hospice) receiving the highest.
For the nine primary indicators applicable to compliance testing, the OIG rated four proficient and
five adequate. For the two secondary indicators, which involve administrative health care functions,
one was rated proficient and one inadequate.
Program Strengths — Compliance Testing
As the CCI Executive Summary Table on page viii indicates, the institution’s compliance scores
were in the proficient range for the following five indicators: Pharmacy and Medication
Management (93.2 percent), Preventive Services (88.8 percent), Specialized Medical Housing
(OHU, CTC, SNF, Hospice) (100 percent), Specialty Services (85.7 percent), and Job Performance,
Training, Licensing, and Certifications (95.8 percent). The following are some of CCI’s strengths
based on its compliance scores on individual questions within all primary health care indicators:
2 The OIG’s compliance inspectors are trained deputy inspectors general with expertise in CDCR policies regarding
medical staff and processes.
3 The OIG used its own clinicians to provide clinical expert guidance for testing compliance in certain areas where
CCHCS policies and procedures did not specifically address an issue.
California Correctional Institution, Cycle 4 Medical Inspection Page iv
Office of the Inspector General State of California
Inmate-patients had a standardized process to obtain and submit health care service request
forms, and nursing staff timely reviewed patients’ requests.
Providers conducted timely follow-up appointments with patients who were discharged from
a community hospital.
The institution ensured that patients timely received their radiology and laboratory
diagnostic services.
Health information management staff timely scanned non-dictated progress notes, initial
health screening forms, health care service request forms, and medication administration
records into patients’ health records.
All of the institution’s clinics were appropriately disinfected, cleaned, and sanitized; all
applicable clinics had operable sinks and sufficient quantities of hygiene supplies.
Health care staff employed strong medication security controls over narcotic medications in
the clinics and medication line locations that stored them.
Nursing staff followed proper protocols when preparing medications and administering them
to patients.
In its main pharmacy, the institution followed general security, organization, and cleanliness
management protocols; properly stored non-refrigerated and refrigerated medications;
maintained adequate controls and properly accounted for narcotic medications; and followed
key medication error reporting protocols.
CCI provided all sampled patients with annual tuberculosis screenings, and timely provided
or offered all sampled patients influenza vaccinations and annual colorectal cancer
screenings, when required.
For all patients sampled who were admitted to the OHU, nursing staff and providers
conducted initial assessments, evaluations, and history and physical examinations within
required time frames.
Patients received their routine specialty services timely, and providers timely reviewed
high-priority specialists’ reports. When the institution denied specialty service requests, it
processed them timely and providers timely communicated the denial status to patients.
The following are some of the strengths identified within the two secondary administrative
indicators:
CCI promptly processed all inmate medical appeals timely in each of the most recent 12
months reviewed.
California Correctional Institution, Cycle 4 Medical Inspection Page v
Office of the Inspector General State of California
The Quality Management Committee met monthly, evaluated program performance and
took action when improvement opportunities were identified, and took adequate steps to
ensure the accuracy of its Dashboard data reporting.
All providers were current with their professional licenses; nursing staff and the
pharmacist-in-charge were current with their professional licenses and certification
requirements; and the institution’s pharmacy and providers who prescribed controlled
substances were current with their Drug Enforcement Agency registrations.
The institution met all performance review requirements for its providers. Also, nursing
supervisors completed required nursing reviews, nursing staff who administered medications
possessed current clinical competency validations, and nursing staff hired within the last
year timely received new employee orientation training.
Program Weaknesses — Compliance Testing
The only indicator that received a compliance score in the inadequate range was the secondary
administrative indicator Internal Monitoring, Quality Improvement, and Administrative Operations
(71.6 percent). However, the following are some of the weaknesses identified by CCI’s compliance
scores on individual questions within the primary health care indicators:
When patients transferred into CCI from another institution and nursing staff referred them
to a primary care provider (PCP), many did not receive their PCP appointment timely. Also,
PCPs frequently failed to conduct timely appointments with patients who suffered from
chronic care conditions.
Health information management staff often failed to scan documents timely into
inmate-patients’ electronic health records, and did not always appropriately label them.
Clinicians’ signatures on health care records were often illegible.
In several clinics, sterilized medical equipment was not appropriately stored, or essential
medical equipment showed no evidence of current calibration.
Nursing staff did not always obtain all required information during initial health screenings
of patients who transferred into CCI from another CDCR institution.
Providers often failed to timely review consultant reports for patients’ routine specialty
services.
The institution frequently failed to provide timely specialty service appointments to
inmate-patients who transferred into CCI with previously approved or scheduled specialty
appointments at the sending institution.
California Correctional Institution, Cycle 4 Medical Inspection Page vi
Office of the Inspector General State of California
The following are some of the weaknesses identified within the two secondary administrative
indicators:
The Emergency Medical Response Review Committee minutes did not include all required
documents for incidents discussed at meetings, and the warden and chief executive officer
did not sign the meeting minutes as required by policy.
Medical emergency response drill packets did not include all required documentation.
Custody managers did not have current emergency response certifications as required by
CCHCS policy.
The CCI Executive Summary Table on the following page lists the quality indicators the OIG
inspected and assessed during the clinical case reviews and objective compliance tests, and provides
the institution’s rating in each area. The overall indicator ratings were based on a consensus
decision by the OIG’s clinicians and non-clinical inspectors.
California Correctional Institution, Cycle 4 Medical Inspection Page vii
Office of the Inspector General State of California
CCI Executive Summary Table
Case
Compliance Overall Indicator
Primary Indicators (Clinical) Review
Score Rating
Rating
Access to Care Proficient 81.1% Adequate
Diagnostic Services Proficient 84.4% Proficient
Emergency Services Inadequate Not Applicable Inadequate
Health Information Management
Adequate 78.2% Adequate
(Medical Records)
Health Care Environment Not Applicable 84.4% Adequate
Inter- and Intra-System Transfers Adequate 84.1% Adequate
Pharmacy and Medication Management Adequate 93.2% Adequate
Preventive Services Not Applicable 88.8% Proficient
Quality of Nursing Performance Adequate Not Applicable Adequate
Quality of Provider Performance Adequate Not Applicable Adequate
Specialized Medical Housing (OHU, CTC,
Adequate 100.0% Adequate
SNF, Hospice)
Specialty Services Adequate 85.7% Adequate
Note: The Prenatal and Post-Delivery Services and Reception Center Arrivals indicators did not apply to this
institution.
Case
Compliance Overall Indicator
Secondary Indicators (Administrative) Review
Score Rating
Rating
Internal Monitoring, Quality Improvement,
Not Applicable 71.7% Inadequate
and Administrative Operations
Job Performance, Training, Licensing, and
Not Applicable 95.8% Proficient
Certifications
Compliance ratings for quality indicators are proficient (greater than 85.0 percent), adequate
(75.0 percent to 85.0 percent), or inadequate (below 75.0 percent).
California Correctional Institution, Cycle 4 Medical Inspection Page viii
Office of the Inspector General State of California
Population-Based Metrics
In general, CCI performed well for population-based metrics. In three of the five comprehensive
diabetes care measures, CCI outperformed other State and national organizations. This included
Medi-Cal as well as Kaiser Permanente, typically one of the highest-scoring health organizations in
California; and Medicaid, Medicare, national commercial health plans (based on data obtained from
health maintenance organizations), and the U.S. Department of Veterans Affairs (VA). For the two
remaining diabetes care measures, the institution’s scores were mid-range when compared to the
other entities.
With regard to influenza immunizations for patients under the age of 65, CCI outperformed all
organizations reporting data, which included Kaiser, commercial plans, and the VA; for older
patients, CCI’s rates were higher than Medicare but lower than the VA. However, CCI’s lower
performance for older adults’ flu shots can be attributed to patient refusals. The institution’s rates
for pneumococcal immunizations were lower than both Medicare and the VA. For colorectal cancer
screening, CCI’s rates closely matched or were higher than rates reported by Kaiser, commercial
plans, and Medicare; but the institution’s rates were lower than the VA’s. Again, this lower
performance can be attributed to patient refusals. Overall, CCI’s performance demonstrated by the
population-based metrics indicated that the chronic care program was well run and operating as
intended.
California Correctional Institution, Cycle 4 Medical Inspection Page ix
Office of the Inspector General State of California
INTRODUCTION
Under the authority of California Penal Code Section 6126, which assigns the Office of the
Inspector General (OIG) responsibility for oversight of the California Department of Corrections
and Rehabilitation (CDCR), and at the request of the federal Receiver, the OIG developed a
comprehensive medical inspection program to evaluate the delivery of medical care at each of
CDCR’s 35 adult prisons. For this fourth cycle of inspections, the OIG augmented the breadth and
quality of its inspection program used in prior cycles, adding a clinical case review component and
significantly enhancing the compliance component of the program.
The California Correctional Institution (CCI) was the ninth medical inspection of Cycle 4. During
the inspection process, the OIG assessed the delivery of medical care to patients using 12 primary
clinical health care indicators and two secondary administrative health care indicators applicable to
the institution. It is important to note that while the primary quality indicators represent the clinical
care being provided by the institution at the time of the inspection, the secondary quality indicators
are purely administrative and are not reflective of the actual clinical care provided.
The OIG is committed to reporting on each institution’s delivery of medical care to assist in
identifying areas for improvement, but the federal court will ultimately determine whether any
institution’s medical care meets constitutional standards.
ABOUT THE INSTITUTION
The California Correctional Institution (CCI) is made up of five separate facilities housing inmates
of varying security levels, from minimum to maximum security, including inmates housed in CCI’s
security housing unit (SHU), the highest level of security in California State prisons. The institution
runs seven medical clinics where staff members handle non-urgent requests for medical services,
including five facility clinics, a specialty clinic, and a 16-bed onsite outpatient housing unit (OHU).
CCI treats patients who require assistance with the activities of daily living but who do not require a
higher level of inpatient care in its OHU. The institution treats inmates needing urgent or emergency
care in its triage and treatment area (TTA). CCI has been designated as a “basic care prison,”
located in a rural area away from tertiary care centers and specialty care providers whose services
would likely be used frequently by higher-risk patients. At the time of the inspection, CCI had not
yet received a review from the Commission on Accreditation for Corrections, a professional peer
review process based on national standards set by the American Correctional Association. The
institution’s first review is planned for late 2016 or early 2017.
California Correctional Institution, Cycle 4 Medical Inspection Page 1
Office of the Inspector General State of California
Based on staffing data the OIG obtained from the institution, CCI’s vacancy rate among licensed
medical managers, primary care providers (PCPs), supervisors, and rank-and-file nurses was
17 percent in July 2015, with the highest vacancy percentages among nursing supervisors
(26 percent) and nursing staff (18 percent). According to the chief executive officer, an offer was
pending for one supervising registered nurse II (SRN II) position, and two other positions were
being advertised. Also, CCI received approval to hire 10.6 registered nurses in April 2015, and of
13 positions being advertised, five had offers pending.
CCI Health Care Staffing Resources — July 2015
Primary Care Nursing
Management Nursing Staff Totals
Providers Supervisors
Description Number % Number % Number % Number % Number %
Authorized
5 4% 10 9% 11.5 10% 89.5 77% 116 100%
Positions
Filled Positions 5 100% 10 100% 8.5 74% 73 82% 96.5 83%
Vacancies 0 0% 0 0% 3 26% 16.5 18% 19.5 17%
Recent Hires
(within 12 1 20% 2 20% 2 24% 4 5% 9 9%
months)
Staff Utilized
0 0% 0 0% 0 0% 0 0% 0 0%
from Registry
Redirected Staff
(to Non-Patient 0 0% 0 0% 0 0% 0 0% 0 0%
Care Areas)
Staff under
Disciplinary 0 0% 0 0% 0 0% 2 3% 2 2%
Review
Staff on
Long-term 0 0% 0 0% 1 12% 8 11% 9 9%
Medical Leave
Note: CCI Health Care Staffing Resources data was not validated by the OIG.
California Correctional Institution, Cycle 4 Medical Inspection Page 2
Office of the Inspector General State of California
As of June 8, 2015, the Master Registry for CCI showed that the institution had 3,696
inmate-patients. Within that total population, 0.6 percent were designated High-Risk, Priority 1
(High 1), and 3.4 percent were designated High-Risk, Priority 2 (High 2). Patients’ assigned risk
levels are based on the complexity of their required medical care related to their specific diagnoses,
frequency of higher levels of care, age, and abnormal labs and procedures. High 1 has at least two
high-risk conditions; High 2 has only one. High-risk patients are more susceptible to poor health
outcomes than medium- or low-risk patients. High-risk patients also typically require more health
care services than do patients with lower assigned risk levels. The chart below illustrates the
breakdown of the institution’s medical risk levels at the start of the OIG medical inspection.
CCI Master Registry Data as of June 8, 2015
Risk Level # of Inmate-Patients Percentage
High 1 21 0.57%
High 2 124 3.36%
Medium 1,725 46.67%
Low 1,826 49.40%
Total 3,696 100.0%
California Correctional Institution, Cycle 4 Medical Inspection Page 3
Office of the Inspector General State of California
Commonly Used Abbreviations
ACLS Advanced Cardiovascular Life Support HIV Human Immunodeficiency Virus
AHA American Heart Association HTN Hypertension
ASU Administrative Segregation Unit INH Isoniazid (anti-tuberculosis medication)
BLS Basic Life Support IV Intravenous
CBC Complete Blood Count KOP Keep-on-Person (in taking medications)
CC Chief Complaint LPT Licensed Psychiatric Technician
CCHCS California Correctional Health Care Services LVN Licensed Vocational Nurse
CCP Chronic Care Program MAR Medication Administration Record
California Department of Corrections and
CDCR MRI Magnetic Resonance Imaging
Rehabilitation
CEO Chief Executive Officer MD Medical Doctor
CHF Congestive Heart Failure NA Nurse Administered (in taking medications)
CME Chief Medical Executive N/A Not Applicable
CMP Comprehensive Metabolic (Chemistry) Panel NP Nurse Practitioner
CNA Certified Nursing Assistant OB Obstetrician
CNE Chief Nurse Executive OHU Outpatient Housing Unit
C/O Complains of OIG Office of the Inspector General
COPD Chronic Obstructive Pulmonary Disease P&P Policies and Procedures (CCHCS)
CP&S Chief Physician and Surgeon PA Physician Assistant
CPR Cardio-Pulmonary Resuscitation PCP Primary Care Provider
CSE Chief Support Executive POC Point of Contact
CT Computerized Tomography PPD Purified Protein Derivative
CTC Correctional Treatment Center PRN As Needed (in taking medications)
DM Diabetes Mellitus RN Registered Nurse
Directly Observed Therapy (in taking
DOT Rx Prescription
medications)
Dx Diagnosis SNF Skilled Nursing Facility
Subjective, Objective, Assessment, Plan,
EKG Electrocardiogram SOAPE
Education
ENT Ear, Nose and Throat SOMS Strategic Offender Management System
ER Emergency Room S/P Status post
eUHR electronic Unit Health Record TB Tuberculosis
FTF Face-to-Face TTA Triage and Treatment Area
History and Physical (reception center
H&P UA Urinalysis
examination)
HIM Health Information Management UM Utilization Management
California Correctional Institution, Cycle 4 Medical Inspection Page 4
Office of the Inspector General State of California
OBJECTIVES, SCOPE, AND METHODOLOGY
In designing the medical inspection program, the OIG reviewed CCHCS policies and procedures,
relevant court orders, and guidance developed by the American Correctional Association. The OIG
also reviewed professional literature on correctional medical care; reviewed standardized
performance measures used by the health care industry; consulted with clinical experts; and met
with stakeholders from the court, the Receiver’s office, CDCR, the Office of the Attorney General,
and the Prison Law Office to discuss the nature and scope of the OIG’s inspection program. With
input from these stakeholders, the OIG developed a medical inspection program that evaluates
medical care delivery by combining clinical case reviews of patient files, objective tests of
compliance with policies and procedures, and an analysis of outcomes for certain population-based
metrics.
To maintain a metric-oriented inspection program that evaluates medical care delivery consistently
at each State prison, the OIG identified 14 primary (clinical) and two secondary (administrative)
quality indicators of health care to measure. The primary quality indicators cover clinical categories
directly relating to the health care provided to patients, whereas the secondary quality indicators
address the administrative functions that support a health care delivery system. The 14 primary
quality indicators are Access to Care, Diagnostic Services, Emergency Services, Health Information
Management (Medical Records), Health Care Environment, Inter- and Intra-System Transfers,
Pharmacy and Medication Management, Prenatal and Post-Delivery Services, Preventive Services,
Quality of Nursing Performance, Quality of Provider Performance, Reception Center Arrivals,
Specialized Medical Housing (OHU, CTC, SNF, Hospice), and Specialty Services. The two
secondary quality indicators are Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications.
The OIG rates each of the quality indicators applicable to the institution under inspection based on
case reviews conducted by OIG clinicians and compliance tests conducted by OIG deputy
inspectors general. The ratings may be derived from the case review results alone, the compliance
test results alone, or a combination of both these information sources. For example, the ratings for
the primary quality indicators Quality of Nursing Performance and Quality of Provider
Performance are derived entirely from the case review results, while the ratings for the primary
quality indicators Health Care Environment and Preventive Services are derived entirely from
compliance test results. As another example, primary quality indicators such as Diagnostic Services
and Specialty Services receive ratings derived from both sources. At CCI, 14 of the quality
indicators were applicable, consisting of 12 primary clinical indicators and two secondary
administrative indicators. Of the 12 primary indicators, seven were rated by both case review
clinicians and compliance inspectors, three were rated by case review clinicians only, and two were
rated by compliance inspectors only; both secondary indicators were rated by compliance inspectors
only.
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Consistent with the OIG’s agreement with the Receiver, this report only addresses the conditions
found related to medical care criteria. The OIG does not review for efficiency and economy of
operations. Moreover, if the OIG learns of an inmate-patient needing immediate care, the OIG
notifies the chief executive officer of health care services and requests a status report. Additionally,
if the OIG learns of significant departures from community standards, it may report such departures
to the institution’s chief executive officer or to CCHCS. Because these matters involve confidential
medical information protected by State and federal privacy laws, specific identifying details related
to any such cases are not included in the OIG’s public report.
In all areas, the OIG is alert for opportunities to make appropriate recommendations for
improvement. Such opportunities may be present regardless of the rating awarded to any particular
quality indicator; therefore, recommendations for improvement should not necessarily be
interpreted as indicative of deficient medical care delivery.
CASE REVIEWS
The OIG has added case reviews to the Cycle 4 medical inspections at the recommendation of its
stakeholders. At the conclusion of Cycle 3, the federal Receiver and the Inspector General
determined that the health care provided at the institutions was not fully evaluated by the
compliance tool alone, and that the compliance tool was not designed to provide comprehensive
qualitative assessments. Accordingly, the OIG added case reviews in which OIG physicians and
nurses evaluate selected cases in detail to determine the overall quality of health care provided to
the inmate-patients. The OIG’s clinicians perform a retrospective chart review of selected patient
files to evaluate the care given by an institution’s primary care providers and nurses. Retrospective
chart review is a well-established review process used by health care organizations that perform
peer reviews and patient death reviews. Currently, CCHCS uses retrospective chart review as part
of its death review process and in its pattern-of-practice reviews. CCHCS also uses a more limited
form of retrospective chart review when performing appraisals of individual primary care providers.
PATIENT SELECTION FOR RETROSPECTIVE CASE REVIEWS
Because retrospective chart review is time consuming and requires qualified health care
professionals to perform it, OIG clinicians must carefully sample patient records. Accordingly, the
group of patients the OIG targeted for chart review carried the highest clinical risk and utilized the
majority of medical services. A majority of the patients selected for retrospective chart review were
classified by CCHCS as high-risk patients. The reason the OIG targeted these patients for review is
twofold:
1. The goal of retrospective chart review is to evaluate all aspects of the health care system.
Statewide, high-risk and high-utilization patients consume medical services at a
disproportionate rate; 11 percent of the total patient population are considered high-risk and
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account for more than half of the institution’s pharmaceutical, specialty, community
hospital, and emergency costs.
2. Selecting this target group for chart review provides a significantly greater opportunity to
evaluate all the various aspects of the health care delivery system at an institution.
Underlying the choice of high-risk patients for detailed case review are three assumptions:
1. If the institution is able to provide adequate clinical care to the most challenging patients
with multiple complex and interdependent medical problems, it will be providing adequate
care to patients with less complicated health care issues. Because clinical expertise is
required to determine whether the institution has provided adequate clinical care, the OIG
utilizes experienced correctional physicians and registered nurses to perform this analysis.
2. The health of less complex patients is more likely to be affected by processes such as timely
appointment scheduling, medication management, routine health screening, and
immunizations. To review these processes, the OIG simultaneously performs a broad
compliance review.
3. Patient charts generated during death reviews, sentinel events (an unexpected occurrence
involving death or serious injury, or risk thereof), and hospitalizations are mostly of
high-risk patients.
BENEFITS AND LIMITATIONS OF TARGETED SUBPOPULATION REVIEW
Because the selected patients utilize the broadest range of services offered by the health care
system, the OIG’s retrospective chart review provides adequate data for a qualitative assessment of
the most vital system processes (referred to as “primary quality indicators”). Retrospective chart
review provides an accurate qualitative assessment of the relevant primary quality indicators as
applied to the targeted subpopulation of high-risk and high-utilization patients. While this targeted
subpopulation does not represent the prison population as a whole, the ability of the institution to
provide adequate care to this subpopulation is a crucial and vital indicator of how the institution
provides health care to its whole patient population. Simply put, if the institution’s medical system
does not adequately care for those patients needing the most care, then it is not fulfilling its
obligations, even if it takes good care of patients with less complex medical needs.
Since the targeted subpopulation does not represent the institution’s general prison population, the
OIG cautions against inappropriate extrapolation of conclusions from the retrospective chart
reviews to the general population. For example, if the high-risk diabetic patients reviewed have
poorly-controlled diabetes, one cannot conclude that the entire diabetic population is inadequately
controlled. Similarly, if the high-risk diabetic patients under review have poor outcomes and require
significant specialty interventions, one cannot conclude that the entire diabetic population is having
similarly poor outcomes.
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Nonetheless, the health care system’s response to this subpopulation can be accurately evaluated
and yields valuable systems information. In the above example, if the health care system is
providing appropriate diabetic monitoring, medication therapy, and specialty referrals for the
high-risk patients reviewed, then it can be reasonably inferred that the health care system is also
providing appropriate diabetic services to the entire diabetic subpopulation. However, if these same
high-risk patients needing monitoring, medications, and referrals are generally not getting those
services, it is likely that the health care system is not providing appropriate diabetic services to the
greater diabetic subpopulation.
CASE REVIEWS SAMPLED
As indicated in Appendix B, Table B–1, CCI Sample Sets, the OIG clinicians evaluated medical
charts for 63 unique inmate-patients. Both nurses and physicians reviewed charts for 18 of those
patients, for 81 reviews in total. Appendix B–4, CCI Case Review Sample Summary, clarifies that
physicians performed detailed reviews of 30 charts, and nurses performed detailed reviews of 15
charts, totaling 45 detailed reviews. For detailed case reviews, the clinicians looked at all encounters
occurring in approximately six months of medical care. Nurses also performed a limited or focused
review of medical records for an additional 36 inmate-patients. These generated 1,075 clinical
events for review (Appendix B, Table B–3: CCI Event-Program). The reporting format provides
details on whether the encounter was adequate or had significant deficiencies, and identifies
deficiencies by programs and processes to help the institution focus on improvement areas.
While the sample method specifically pulled only six chronic care patient records, three diabetes
patients and three anticoagulation patients (Appendix B, Table B–1, CCI Sample Sets), the 63 unique
inmate-patients sampled included patients with 159 chronic care diagnoses, including 11 additional
patients with diabetes (for total of 14), and one additional anticoagulation patient (for a total of four)
(Appendix B, Table B–2, CCI Chronic Care Diagnoses). The OIG’s sample selection tool evaluated
many chronic care programs because the complex and high-risk patients selected from the different
categories often had multiple medical problems. While the OIG did not evaluate every chronic
disease or health care staff member, the overall operation of the institution’s system and staff were
assessed for adequacy. The OIG’s case review methodology and sample size matched other
qualitative research. The empirical findings, supported by expert statistical consultants, showed
adequate conclusions after 10 to 15 charts had undergone full clinician review. In qualitative
statistics, this phenomenon is known as “saturation.” The OIG asserts that the sample size of over
30 detailed reviews certainly far exceeds the saturation point necessary for an adequate qualitative
review. With regard to reviewing charts from different providers, the case review is not intended to
be a focused search for poorly performing providers; rather, it is focused on how the system cares
for those patients who need care the most. Nonetheless, while not sampling cases by each provider
at the institution, the OIG’s inspections adequately review most providers. Providers would only
escape OIG case review if institutional management successfully mitigated patient risk by having
the more poorly performing PCPs care for the less complicated, low-utilizing, and lower-risk
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patients. The OIG concluded that the case review sample size was more than adequate to assess the
quality of services provided.
Based on the collective results of clinicians’ case reviews, the OIG rated each quality indicator as
either proficient (excellent), adequate (passing), inadequate (failing), or not applicable. A separate
confidential CCI Supplemental Medical Inspection Results: Individual Case Review Summaries
report details the case reviews OIG clinicians conducted and is available to specific stakeholders.
For further details regarding the sampling methodologies and counts, see Appendix B — Clinical
Data, Table B–1; Table B–2; Table B–3; and Table B–4.
COMPLIANCE TESTING
SAMPLING METHODS FOR CONDUCTING COMPLIANCE TESTING
From July to August 2015, deputy inspectors general attained answers to 93 objective medical
inspection test (MIT) questions designed to assess the institution’s compliance with critical policies
and procedures applicable to the delivery of medical care. To conduct most tests, inspectors
randomly selected samples of inmate-patients for whom the testing objectives were applicable and
reviewed their electronic unit health records. In some cases, inspectors used the same samples to
conduct more than one test. In total, inspectors reviewed health records for 415 individual
inmate-patients and analyzed specific transactions within their records for evidence that critical
events occurred. Inspectors also reviewed management reports and meeting minutes to assess
certain administrative operations. In addition, during the week of July 13, 2015, field inspectors
conducted a detailed onsite inspection of CCI’s medical facilities and clinics; interviewed key
institutional employees; and reviewed employee records, logs, medical appeals, death reports, and
other documents. This generated 1,221 scored data points to assess care.
In addition to the scored questions, the OIG obtained information from the institution that it did not
score. This included, for example, information about CCI’s plant infrastructure, protocols for
tracking medical appeals and local operating procedures, and staffing resources.
For details of the compliance results, see Appendix A — Compliance Test Results. For details of the
OIG’s compliance sampling methodology, see Appendix C — Compliance Sampling Methodology.
SCORING OF COMPLIANCE TESTING RESULTS
The OIG rated the institution in the following nine primary (clinical) and two secondary
(administrative) quality indicators applicable to the institution for compliance testing:
Primary indicators: Access to Care, Diagnostic Services, Health Information Management
(medical records), Health Care Environment, Inter- and Intra-System Transfers, Pharmacy
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and Medication Management, Preventive Services, Specialized Medical Housing (OHU,
CTC, SNF, Hospice), and Specialty Services.
Secondary indicators: Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications.
After compiling the answers to the 93 questions, the OIG derived a score for each primary and
secondary quality indicator identified above by calculating the percentage score of all Yes answers
for each of the questions applicable to a particular indicator, then averaging those scores. Based on
those results, the OIG assigned a rating to each quality indicator of proficient (greater than 85
percent), adequate (between 75 percent and 85 percent), or inadequate (less than 75 percent).
DASHBOARD COMPARISONS
For some of the individual compliance questions, the OIG identified where similar metrics were
available within the CCHCS Dashboard, which is a monthly report that consolidates key health care
performance measures statewide and by institution. There is not complete parity between the
metrics due to time frames when data was collected. As a result, there is some difference between
the OIG’s findings and the Dashboard results. The OIG compared its compliance test results with
the institution’s Dashboard results and reported on that comparative data under various applicable
quality indicators within the Medical Inspection Results section of this report.
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OVERALL QUALITY INDICATOR RATING FOR CASE REVIEWS AND COMPLIANCE
TESTING
The OIG derived the final rating for each quality indicator by combining the ratings from the case
reviews and from the compliance testing, as applicable. When combining these ratings, the case
review evaluations and the compliance testing results usually agreed, but there were instances when
the rating differed for a particular quality indicator. In those instances, the inspection team assessed
the quality indicator based on the collective ratings from both components. Specifically, the OIG
clinicians and deputy inspectors general discussed the nature of individual exceptions found within
that indicator category and considered the overall effect on the ability of patients to receive
adequate medical care.
To derive an overall assessment rating for the institution’s medical inspection, the OIG evaluated
the various rating categories assigned to each of the quality indicators applicable to the institution,
giving more weight to the rating results for the primary quality indicators, which directly relate to
the health care provided to inmate-patients. Based on that analysis, OIG experts made a considered
and measured overall opinion about the quality of health care observed.
POPULATION-BASED METRICS
The OIG identified a subset of Healthcare Effectiveness Data Information Set (HEDIS) measures
applicable to the CDCR inmate-patient population. To identify outcomes for CCI, the OIG reviewed
some of the compliance testing results, randomly sampled additional inmate-patients’ records, and
obtained CCI data from the CCHCS Master Registry. The OIG compared those results to HEDIS
metrics reported by other statewide and national health care organizations.
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MEDICAL INSPECTION RESULTS
PRIMARY (CLINICAL) QUALITY INDICATORS OF HEALTH CARE
The primary quality indicators assess the clinical aspects of health care. As shown on the Health
Care Quality Indicators table on page ii of this report, 12 of the OIG’s primary indicators were
applicable to CCI. Of those 12 indicators, seven were rated by both the case review and compliance
components of the inspection, three were rated by the case review component alone, and two were
rated by the compliance component alone.
Summary of Case Review Results: The clinical case review component assessed 10 of the 12
primary (clinical) indicators applicable to CCI. For these ten indicators, two were proficient, seven
were adequate, and one was inadequate. The OIG physicians rated the overall adequacy of care for
each of the 30 detailed case reviews they conducted. Of these 30 cases, zero were proficient, 21
were adequate, and 9 were inadequate. For the 1,075 events reviewed, there were 351 deficiencies,
of which 21 were considered to be of such magnitude that they would likely contribute to patient
harm if left unaddressed.
Adverse Events Identified During Case Review: Medical care is a complex dynamic process with
many moving parts, subject to human error even within the best health care organizations. Adverse
events are typically identified and tracked by all major health care organizations for the purpose of
quality improvement. They are not generally representative of medical care delivered by the
organization. The OIG identified adverse events for the dual purposes of quality improvement and
the illustration of problematic patterns of practice found during the inspection. Because of the
anecdotal description of these events, the OIG cautions against drawing inappropriate conclusions
regarding the institution based solely on adverse events.
OIG clinicians identified one adverse event during the case reviews at CCI; the event was not
reflective of the overall quality of care at CCI:
In case 20, the provider reviewed a blood test that showed that the patient’s blood was too
thin and ordered the blood thinner (warfarin) to be held for two days. CCI did not process
the order, and the patient continued to receive the medication. This error temporarily caused
further thinning of the patient’s blood, but fortunately did not harm the patient.
Summary of Compliance Results: The compliance component assessed 9 of the 12 primary
(clinical) indicators applicable to CCI. For these nine indicators, OIG inspectors rate four proficient
and five adequate; there were no inadequate ratings in the primary indicators. The results of those
assessments are summarized within this section of the report. The test questions used to assess
compliance for each indicator are detailed in Appendix A.
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ACCESS TO CARE
This indicator evaluates the institution’s ability to provide
Case Review Rating:
inmate-patients with timely clinical appointments. Areas specific to
Proficient
inmate-patients’ access to care are reviewed, such as initial
Compliance Score:
assessments of newly arriving inmates, acute and chronic care
81.1%
follow-ups, face-to-face nurse appointments when an inmate-patient
Overall Rating:
requests to be seen, provider referrals from nursing lines, and
Adequate
follow-ups after hospitalization or specialty care. Compliance
testing for this indicator also evaluates whether inmate-patients have
Health Care Services Request forms (CDCR Form 7362) available in their housing units.
For this indicator, the OIG case review and compliance review processes yielded different results,
with the case review giving a proficient rating and the compliance review resulting in an adequate
score. The OIG’s internal review process considered those factors that led to both scores and
ultimately rated this indicator adequate. Although OIG clinicians found few deficiencies in this
indicator, compliance testing of randomly sampled patients revealed many deficiencies regarding
untimely provider appointments. As a result, the compliance testing score was deemed a more
accurate reflection of the appropriate overall rating.
Case Review Results
The OIG clinicians reviewed 774 provider and nurse encounters at CCI and identified only nine
deficiencies relating to Access to Care, eight of which involved the patient not being seen as
ordered. One deficiency was a result of a delay in provider follow-up after a specialty care visit. The
OIG’s case review found no significant problems with Access to Care. Appointments were
generally timely in all aspects reviewed, including nurse-to-provider sick call referrals, triage and
treatment area (TTA) and hospital follow-ups, intra-system transfers, specialty appointment
follow-ups, and outpatient provider and nursing follow-ups. CCI performed very well with regard to
Access to Care, and the case review rating was thus proficient.
Compliance Testing Results
The institution performed in the adequate range in the Access to Care compliance indicator, with a
compliance score of 81.1 percent. While CCI scored well in three of the nine tests conducted, it
performed just adequately in three areas and inadequately in three others.
As indicated below, CCI scored 100 percent in each of the following three areas tested:
Inmates had access to Health Care Services Request forms (CDCR Form 7362) at all five
housing units inspected (MIT 1.101).
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Inspectors sampled 30 CDCR Form 7362s submitted by inmate-patients across all facility
clinics. Nursing staff reviewed all service request forms on the same day they were received
(MIT 1.003).
The institution offered a follow-up appointment with a PCP to inmate-patients within five
days of discharge from a community hospital for the 30 inmate-patients sampled by the OIG
(MIT 1.007).
The following areas scored in the adequate range:
For 25 of the 30 inmate-patients sampled who submitted CDCR Form 7362s (83 percent),
nursing staff completed a face-to-face encounter with the inmate-patient within one business
day of reviewing the service request form. In all five exceptions, the nurse conducted the
visit one day late (MIT 1.004).
Out of five inmate-patients for whom the PCP determined a follow-up sick call appointment
was necessary, four (80 percent) received a timely appointment; one patient received his
follow-up appointment 24 days late (MIT 1.006).
Inspectors also sampled 24 inmate-patients who received a specialty service; 19 of them
(79 percent) received a timely follow-up appointment with a PCP. One patient received an
appointment that was two days late, and another, eight days late. Two additional patients had
timely initial follow-up appointments, but the PCP notes revealed the patients’ specialty
reports were not available at the time of their appointment and the patients were ultimately
seen 29 and 78 days late. A provider did not see one patient for a specialty service follow-up
appointment at all (MIT 1.008).
The following areas were rated inadequate:
Only 11 of the 25 inmate-patients sampled who transferred into CCI from other institutions
and were referred to a PCP for a routine appointment based on nursing staff’s initial health
care screening of the patient were seen timely (44 percent). For 13 patients, appointments
were held between 7 and 27 days late, and one patient was seen for a routine appointment
over four months late (MIT 1.002).
When the OIG reviewed recent appointments for 30 inmate-patients with chronic care
conditions, only 21 of the patients (70 percent) received timely routine appointments. One
patient’s appointment occurred one day late, three patients’ appointments occurred between
21 and 26 days late, and five patients’ appointments occurred more than three months late
(MIT 1.001).
For 15 health care service requests sampled where the nursing staff referred the
inmate-patient for a PCP appointment, 11 of the inmate-patients (73 percent) received a
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timely appointment. For three patients the follow-up appointment occurred between one and
13 days late. For another inmate-patient, there was no evidence the appointment occurred at
all (MIT 1.005).
CCHCS Dashboard Comparative Data
The Dashboard uses the average of nine medical access measure indicators to calculate the score for
Scheduling & Access to Care: Medical Services. The OIG compared applicable CCI compliance
scores with that Dashboard average.
As indicated in the table below, the OIG test results were based on a review of documents from the
most recent month as well as documents from the preceding 11 months; CCI’s July Dashboard data
reflected only the institution’s June 2015 results. Nevertheless, the OIG and Dashboard results were
consistent and within the proficient range.
Access to Care — CCI Dashboard and OIG Compliance Results
CCI DASHBOARD RESULTS OIG COMPLIANCE RESULTS
Scheduling & Access to Care: Access to Care (1.001, 1.004, 1.005, 1.007)
Medical Services Diagnostic Services (2.001, 2.004)
Specialty Services (14.001, 14.003)
July 2015 August 2014 – July 2015
96% 89%
Note: The CCHCS Dashboard data includes access to care for inmate-patients returning from CDCR inpatient
housing units and from emergency departments, whereas the OIG does not test follow-up appointments for
these patients.
Recommendations
No specific recommendations.
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DIAGNOSTIC SERVICES
This indicator addresses several types of diagnostic services.
Case Review Rating:
Specifically, it addresses whether radiology and laboratory
Proficient
services were timely provided to inmate-patients, whether the
Compliance Score:
primary care provider (PCP) timely reviewed the results, and
84.4%
whether the results were communicated to the inmate-patient
within the required time frames. In addition, for pathology Overall Rating:
services, the OIG determines whether the institution received a Proficient
final pathology report and whether the PCP timely reviewed and
communicated the pathology results to the patient. The case reviews also factor in the
appropriateness, accuracy, and quality of the diagnostic test(s) ordered and the clinical response to
the results.
For this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving a proficient rating and the compliance review resulting in an adequate
score. The OIG’s internal review process considered those factors that led to both scores and
ultimately rated this indicator proficient. The case review found few deficiencies in this indicator,
and the deficient areas revealed by compliance testing related to providers not always timely
communicating diagnostic test results to patients. Also, the compliance score of 84.4 percent was
very close to the proficient range.
Case Review Results
The OIG clinicians reviewed 199 diagnostic events and found 12 deficiencies. Six deficiencies
related to diagnostic tests not completed as ordered; three deficiencies related to inappropriate
provider review (discussed in the Quality of Provider Performance section); three deficiencies
related to health information management. The OIG found no significant problems with diagnostic
services. In general, staff successfully and timely completed diagnostic services, primary care
providers reviewed reports timely, and patients were notified of the test results quickly. CCI
performed very well with regard to Diagnostic Services, and the case review indicator rating is thus
proficient.
Compliance Testing Results
The institution received an adequate compliance score of 84.4 percent in the Diagnostic Services
indicator, which encompasses radiology, laboratory, and pathology services. For clarity, each type
of diagnostic service is discussed separately below.
Radiology Services
All ten of the radiology services sampled were timely performed (MIT 2.001). Additionally,
providers timely reviewed and communicated the diagnostic test results to eight of the ten
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patients (80 percent). The provider both reviewed the diagnostic report and communicated
the results only one day late to one patient; for another, the provider reviewed the report
eight days late and communicated the results to the patient ten days late (MIT 2.002, 2.003).
Laboratory Services
Patients received timely laboratory services for all ten inmate-patients sampled (MIT 2.004).
Providers also timely reviewed diagnostic test results for eight of those patients (80 percent);
the provider reviewed one document one day late, and another, seven days late (MIT 2.005).
Finally, providers timely communicated the results to seven of the patients (70 percent);
delinquent communications were between one and seven days late (MIT 2.006).
Pathology Services
For nine of ten inmate-patients sampled (90 percent), the institution timely received the final
diagnostic pathology reports and the providers timely reviewed the results. The institution
received a final report 28 days late for one patient, and a provider reviewed a final report 37
days late for another patient (MIT 2.007, 2.008). Also, providers timely communicated the
final results to seven of the ten inmate-patients (70 percent); one patient received his results
eight days late; another, 37 days late; and one patient did not receive results from the
provider at all (MIT 2.009).
Recommendations
No specific recommendations.
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EMERGENCY SERVICES
An emergency medical response system is essential to providing
Case Review Rating:
effective and timely emergency medical response, assessment,
Inadequate
treatment, and transportation 24 hours per day. Provision of
Compliance Score:
urgent/emergent care is based on a patient’s emergency situation,
Not Applicable
clinical condition, and need for a higher level of care. The OIG
reviews emergency response services including first aid, basic life Overall Rating:
support (BLS), and advanced cardiac life support (ACLS) Inadequate
consistent with the American Heart Association guidelines for
cardiopulmonary resuscitation (CPR) and emergency cardiovascular care, and the provision of
services by knowledgeable staff appropriate to each individual’s training, certification, and
authorized scope of practice.
The OIG evaluates this quality indicator entirely through clinicians’ reviews of case files and
conducts no separate compliance testing element.
Case Review Results
The OIG clinicians reviewed 63 urgent/emergent events and found 52 deficiencies, mainly in the
area of nursing care.
Provider Performance
While providers covering the triage and treatment area (TTA) generally made appropriate triage
decisions and sent patients to the appropriate levels of care, there were some notable exceptions.
These cases are also addressed in the Quality of Provider Performance section.
In case 7, a patient with possible epiglottitis (a potentially life-threatening illness) was
transferred to the local hospital by State vehicle rather than by ambulance.
In case 9, a patient with a possible drug overdose was not given activated charcoal and was
transferred to the local hospital by State vehicle rather than by ambulance.
In case 10, the patient complained of chest pain, throat pressure, cough, and shortness of
breath, and the TTA RN noted he was in “mild distress” with “much coughing.” This patient
was also transferred to the local hospital by State vehicle rather than by ambulance.
In case 62, the patient presented with complaints of headache and dizziness; an exam
revealed left upper extremity weakness. With the provider’s documentation indicating a
possible stroke, aspirin should not have been given until bleeding in the brain had been ruled
out.
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Nursing Performance
Several concerns were identified regarding nursing performance within urgent/emergent services.
Nurses routinely failed to provide thorough, appropriate “chest pain” care. Assessments were often
incomplete and lacked necessary documentation. There were delays in provider notification and
ambulance request.
In case 1, the patient had chest pain on two occasions. In both events the nurse failed to
administer additional nitroglycerin when chest pain continued and vital signs were stable.
Additionally, the nursing assessments were incomplete.
In case 2, the patient had left chest pain at rest for which only one dose of nitroglycerin was
administered. The nurse failed to administer additional nitroglycerin when chest pain
continued and vital signs were stable.
In case 10, the patient had chest pain with radiation at rest. An EKG was performed and was
abnormal. The nurse failed to promptly contact a provider, failed to administer aspirin and
nitroglycerin, and failed to assess vital signs for 40 minutes. Also in case 10 but during a
separate event, the patient presented with chest pain, shortness of breath, anxiety, dizziness,
and tingling hands. The RN noted the patient was anxious and hyperventilating. An EKG
was performed. The nurse inappropriately released the patient without reassessing his blood
pressure or contacting a PCP.
In case 12, three emergency events displayed deficiencies. The first event occurred when the
patient was transported by wheelchair to the TTA. He had become dizzy and had fallen. The
nurse failed to document details of the event, such as who transported the patient to the TTA
and whether the patient was “man down.” In the second event, he presented to the TTA with
chest pain and was found to be hypertensive and tachycardic. One dose of nitroglycerin was
administered without relief. The nurse failed to administer additional nitroglycerin. In the
third event, he also had chest pain and was hypertensive. The nurse failed to perform a
thorough assessment and administer additional nitroglycerin.
In case 15, the patient presented with chest pain at rest. The patient’s EKG was abnormal.
The nurse failed to administer aspirin and nitroglycerin, failed to assess vital signs for 31
minutes, and failed to obtain intravenous access prior to transferring the patient to a
community hospital.
In case 62, the patient was assessed as being “near syncope” (nearly unconscious). He was
found face down, heavily perspiring, and pale, and he could not independently answer
questions or follow commands. The nurse failed to assess extremities for weakness and did
not attempt to contact a provider for approximately 90 minutes.
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Some concerns were also noted in the management of respiratory distress.
In case 4, the patient was short of breath. Documentation did not clearly indicate events
prior to the patient’s arrival to the TTA. Upon arrival to the TTA, the nurse noted the patient
was pale and “gasping for air,” his oxygen saturation was low at 83 percent, he was not able
to speak normally, and he was using accessory muscles to breathe. The nurse failed to
reassess blood pressure, pulse, and respirations for 23 minutes; failed to monitor cardiac rate
and rhythm and the amount of oxygen given; failed to obtain intravenous access; failed to
document the time of physician contact; and failed to promptly arrange a higher level of care
transport, which occurred after 1 hour and 20 minutes.
Events prior to patients’ TTA arrivals were frequently not found in the eUHR. This lack of
documentation affected the OIG’s ability to assess the totality of these events and form conclusions.
In case 3, the patient was referred to the TTA to prepare for an unscheduled ambulance
transport. The nurse failed to perform an assessment, did not assess vital signs, and did not
document the site at which intravenous access was established or the time of ambulance
arrival and departure.
In case 10, the patient presented to the TTA with abdominal pain. The nurse failed to
document that the patient was “man down” and required wheelchair transport. In addition,
the first medical response documentation was not present in the eUHR.
Emergency Medical Response Review Committee
The Emergency Medical Response Review Committee (EMRRC) reviewed all death incidents but
often failed to review the unscheduled urgent/emergent medical transfers out to community
hospitals for higher levels of care. During the onsite visit, the chief nurse executive and director of
nursing explained that the purpose of reviewing TTA nursing care by nursing supervisors was to
identify training needs. However, the supervising RN (SRN) responsible for these reviews indicated
that clinical reviews were not being completed. The following cases support the need for clinical
review of all unscheduled urgent/emergent medical transfers out for higher level of care:
In case 1, two emergency events occurred. The patient experienced chest pain and was sent
to a community hospital. A nursing supervisor performed an audit of this event and failed to
identify the incomplete assessment and interventions. The second chest pain event occurred
18 days later, and involved deficiencies in nursing assessment and intervention. This second
event was not reviewed.
In cases 2 and 5, the patients had chest pain and were sent to a community hospital for
further treatment. These events were not reviewed.
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Office of the Inspector General State of California
In case 3, two unscheduled transports occurred in one month. The first event was not
reviewed. The second event, which occurred in the OHU, was reviewed by the EMRRC.
The delays in oxygen administration and lack of cardiac monitoring were not identified. The
delay in ambulance request was inappropriately justified with the note “this gap pertains to
doctor treatment.”
In case 4, the patient had difficulty breathing and was transferred to a community hospital.
This event was not reviewed.
In case 10, the patient had chest pain and was transferred to a community hospital. The SRN
performed an audit of this event but failed to identify the nurse’s deficiencies.
Case 12 had two urgent/emergent events, which led to unscheduled transports; neither was
appropriately reviewed.
In cases 15 and 62, the unscheduled transports were not appropriately reviewed.
Conclusion
Emergency Services at CCI were found to be inadequate. The nurses routinely failed to demonstrate
appropriate assessment and interventions. SRN audits failed to identify events with inadequate care.
The leadership at CCI failed to follow the Emergency Medical Response Review process, and
frequently failed to address incidents with inadequacies.
Recommendations
The OIG recommends the cases identified above regarding provider performance be
reviewed with the providers involved.
The OIG recommends nurses receive training in the appropriate assessment and treatment of
chest pain and respiratory distress, and appropriate documentation; nursing supervisors
responsible for performing audits receive training in the appropriate methodology for
performing audits; and leadership at CCI review these audits to ensure adequacy.
The OIG recommends leadership implement a process to ensure that clinical staff document
the events leading to patients’ arrivals at the TTA (CCHCS has first responder forms for
these types of events). The OIG also recommends CCI leadership revise its EMRRC review
process to expand the types of events requiring reviews, such as non-scheduled emergency
transfers, to improve the adequacy of reviews and to enhance training for events found to be
deficient.
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Office of the Inspector General State of California
HEALTH INFORMATION MANAGEMENT (MEDICAL RECORDS)
Health information management is a crucial link in the delivery of
Case Review Rating:
medical care. Medical personnel require accurate information in
Adequate
order to make sound judgments and decisions. This indicator
Compliance Score:
examines whether the institution adequately manages its health care 78.2%
information. This includes determining whether the information is
correctly labeled and organized and available in the electronic unit Overall Rating:
Adequate
health record (eUHR); whether the various medical records
(internal and external, e.g., hospital and specialty reports and
progress notes) are obtained and scanned timely into the inmate-patient’s eUHR; whether records
routed to clinicians include legible signatures or stamps; and whether hospital discharge reports
include key elements and are timely reviewed by providers.
Case Review Results
The OIG clinicians found minor to moderate deficiencies during case review of California
Correctional Institution’s Health Information Management. Out of the 347 (total) deficiencies
identified from the case reviews, 64 related to health information management processes. The OIG
considered all but one of the deficiencies (case 28) unlikely to contribute to patient harm, so the
case review rating is adequate. The OIG clinicians’ findings are identified in the following indicator
subcategories:
Inter-Departmental Transmission
The OIG clinicians found deficiencies related to orders not carried through to various
departments. Examples include test results not found in the eUHR (it was unclear if they
were performed) and specialty visits not being scheduled as requested.
Hospital Records
Hospital records were generally retrieved, reviewed, and scanned into the eUHR in a timely
manner.
Specialty Services
Two Health Information Management deficiencies were related to providers failing to
properly sign specialty services reports and the reports not being scanned into the eUHR in a
timely manner. For case 28, the provider failed to sign a consult note prior to eUHR
scanning. This resulted in a two-day delay for the patient receiving the recommended eye
drops. Another deficiency related to a specialty report not found in the eUHR and one CCI
provider’s illegible signature on a referral form. There was also one instance when a
California Correctional Institution, Cycle 4 Medical Inspection Page 22
Office of the Inspector General State of California
specialty or diagnostic report was not available for the specialist to review at the time of the
specialty appointment. These findings are also discussed in the Specialty Services indicator.
Diagnostic Reports
Diagnostic reports were generally reviewed and scanned into the eUHR in a timely manner.
Urgent/Emergent Records
The handful of Health Information Management deficiencies relating to urgent/emergent
records were due to illegible signatures and lack of time stamps. There were also some
issues regarding the lack of first responder records prior to the patient’s arrival in the TTA.
These issues are addressed in the Emergency Services section.
Scanning Performance
While scanning times for most documents were adequate, there were a few deficiencies
relating to scanning performance. As already noted, some documents were mislabeled or
misfiled.
Legibility
More than one-fourth of the Health Information Management deficiencies were related to
illegible notes and signatures (without name stamps) for providers. This can pose a
significant medical risk to patients, especially when these notes are required to be reviewed
by other staff, such as when a patient is transferred to another care team or another
institution.
Legacy Notes
More than one-third of the Health Information Management deficient cases contained legacy
notes. These notes were either cloned copies of prior notes with a few changes made or a
compilation of notes from prior visits with a few sentences added. In many of these cases,
portions of the notes were misleading as they had not been changed from prior visits. For
example, in one case, physical exam notes documented a moderate-sized prostate after the
patient had undergone surgery to remove the entire prostate. In another example, physical
exam notes documented an ingrown nail even after it was removed. In yet another example,
a patient who suffered from a lower extremity skin infection was repeatedly noted to have
“moderate swelling, mild redness, tenderness, peeling, dried blisters.” In these same notes, it
was noted the skin infection had resolved. In cases like these, the use of legacy notes
brought into question whether providers were actually performing physical exams. Not only
could this cause confusion for subsequent providers, it ultimately created a risk for harm to
patients.
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Office of the Inspector General State of California
Miscellaneous
There were a number of instances when provider and nursing notes, and sometimes other
documents (referrals, refusals, etc.), were not found in the eUHR or were incorrectly filled
out. With these notes not being found in the eUHR, the OIG clinicians could not ascertain
whether they were lost prior to scanning or if they were written at all.
Compliance Testing Results
The institution received an adequate compliance score of 78.2 percent in the Health Information
Management (Medical Records) indicator and has an opportunity for improvement in the following
areas:
The institution scored 50 percent in its labeling and filing of documents scanned into
inmate-patients’ electronic unit health records; the most common error was mislabeled
documents, such as a radiology report scanned and labeled as a lab report (MIT 4.006).
The institution timely scanned specialty services consultant reports into the inmate-patient’s
eUHR file within five days of the appointment (or service) for only 11 of the 20 documents
reviewed (55 percent). Untimely scanning for eight specialty reports was between one and
eight days late; one was untimely by 40 days (MIT 4.003).
When the OIG reviewed various medical documents, including hospital discharge reports,
initial health screening forms, certain medication records, and specialty services reports, to
ensure that clinical staff legibly documented their names on the forms, only 22 of 32
samples (69 percent) showed compliance (MIT 4.007).
The institution scored 70 percent for the timely scanning of dictated or transcribed provider
progress notes into inmate-patients’ eUHR files. Timely scanning occurred within five days
of the PCP visit with the patient for seven of the ten sampled documents; three exceptions
were scanned between three and five days late (MIT 4.002).
The institution performed well in its management of the following health care documents:
The institution timely scanned miscellaneous non-dictated documents into patients’ eUHRs,
including providers’ progress notes and inmate-patients’ initial health screening forms and
requests for health care services, for all 20 documents sampled (MIT 4.001). CCI also timely
scanned all 20 medication administration records reviewed into patients’ eUHRs
(MIT 4.005).
CCI timely scanned community hospital discharge reports or treatment records into patients’
eUHRs for 19 of the 20 sampled reports (95 percent); one report was untimely by 25 days
(MIT 4.004).
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Office of the Inspector General State of California
The OIG reviewed eUHR files for 30 sampled patients sent or admitted to the hospital to
determine if a CCI provider reviewed the patients’ hospital discharge reports or treatment
records within three calendar days of discharge. Providers timely reviewed the records for
26 patients (87 percent). The provider reviewed the discharge report one day late for two
patients and did not document the review date for another. Also, the institution did not
receive a discharge report at all for one patient, and the OIG did not find evidence that CCI
followed up with the hospital to obtain the information (MIT 4.008).
CCHCS Dashboard Comparative Data
As indicated below, the compliance results for CCI’s availability of non-dictated medical
documents and community hospital discharge documents were consistent with CCI’s July 2015
Dashboard data; results varied only by three and five percentage points, respectively. However, for
the two remaining measures, dictated and specialty documents, the OIG’s compliance results were
much lower than the July Dashboard results. As noted in the following tables, the OIG testing
results were based on its review of sampled documents that were up to 11 months old; CCI’s July
Dashboard data reflected only the institution’s June 2015 results. This disparity in the sampling
review periods for OIG compliance scores and Dashboard results may have contributed to the
inconsistencies for those two measures.
Health Information Management —
CCI Dashboard and OIG Compliance Results
CCI DASHBOARD RESULTS OIG COMPLIANCE RESULTS
Availability of Health Information: Health Information Management (4.001)
Non-Dictated Documents Non-Dictated Medical Documents
July 2015 October 2014 – July 2015
97% 100%
Note: The Dashboard results were obtained from the Non-Dictated Documents Drilldown data for “Medical
Documents 3 Days.”
CCI DASHBOARD RESULTS OIG COMPLIANCE RESULTS
Availability of Health Information: Health Information Management (4.002)
Dictated Documents Dictated Documents
July 2015 August 2014 – July 2015
100% 70%
Note: The Dashboard results were obtained from the Dictated Documents Drilldown data for “Medical Dictated
Documents 5 Days.”
California Correctional Institution, Cycle 4 Medical Inspection Page 25
Office of the Inspector General State of California
CCI DASHBOARD RESULTS OIG COMPLIANCE RESULTS
Availability of Health Information: Health Information Management (4.003)
Specialty Notes Specialty Documents
July 2015 October 2014 – March 2015
93% 55%
Note: The Dashboard measure includes specialty notes from dental, optometry, and physical therapy appointments,
which the OIG omits from its sample.
CCI DASHBOARD RESULTS OIG COMPLIANCE RESULTS
Availability of Health Information: Health Information Management (4.004)
Community Hospital Records Community Hospital Discharge Documents
July 2015 January 2015 – May 2015
100% 95%
Recommendations
Although the OIG found numerous issues related to Health Information Management, these issues
are easily remedied.
The OIG recommends clinicians who review medical documents print their names or use
name stamps in addition to their signatures or initials to improve legibility on all health care
documents. For providers with illegible handwriting, the OIG recommends they be
mandated to dictate or type notes.
The OIG recommends CCI implement a process requiring administrative staff members who
scan health care documents to send notes and orders back to the provider if they are not
time-stamped. The OIG further recommends that mislabeled and improperly scanned
documents be targeted for accuracy improvement, even while the institution awaits the
implementation of CDCR’s new electronic health record system.
The OIG recommends CCI prohibit clinicians’ use of legacy or cloned notes.
California Correctional Institution, Cycle 4 Medical Inspection Page 26
Office of the Inspector General State of California
HEALTH CARE ENVIRONMENT
This indicator addresses the general operational aspects of the
Case Review Rating:
institution’s clinics, including certain elements of infection control
Not Applicable
and sanitation, medical supplies and equipment management, the
Compliance Score:
availability of both auditory and visual privacy for inmate-patient
84.4%
visits, and the sufficiency of facility infrastructure to conduct
comprehensive medical examinations. Overall Rating:
Adequate
Rating of this component is based entirely on the compliance
testing results from the visual observations inspectors make at the
institution during their onsite visit.
Compliance Testing Results
The institution received an adequate compliance score of 84.4 percent in the Health Care
Environment indicator, scoring well in several test areas, as described below:
The institution appropriately disinfected, cleaned, and sanitized all seven clinics observed
(MIT 5.101). Also, the seven clinics all had operable sinks and sufficient quantities of
hygiene supplies in clinical areas (MIT 5.103).
OIG inspectors observed clinicians’ encounters with patients in six clinics and found that all
clinicians followed good hand hygiene practices (MIT 5.104).
The institution’s non-clinic bulk medical supply storage area properly followed the supply
management process and supported the needs of the medical health care program, resulting
in a score of 100 percent (MIT 5.106).
All seven of CCI’s clinics had an adequate environment conducive to providing medical
services (MIT 5.109).
When inspecting for proper protocols to mitigate exposure to blood-borne pathogens and
contaminated waste, the OIG inspectors found six of the seven clinics (86 percent)
compliant. In one clinic, the PCP exam room did not have a puncture-resistant container
available to medical staff for expended needles/sharps (MIT 5.105).
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Office of the Inspector General State of California
Inspectors found that six of the seven clinics
(86 percent) followed adequate medical supply
storage and management protocols. As shown in
Figure 1, one clinic’s storage room for bulk
medical supplies was not orderly, making it
difficult to easily identify supplies; the room was
cluttered and some supplies were stored on the
floor (MIT 5.107).
Inspectors examined emergency response bags to Figure 1: Disorganized bulk supply
determine if the bags were inspected daily and storage room
inventoried monthly, and whether they contained
all essential items; bags were compliant in six of the seven clinical locations where they
were stored (86 percent). While medical staff timely inspected and inventoried all
emergency response bags, one bag did not contain a required non-rebreather oxygen mask
(MIT 5.111).
The institution has room for improvement in the following three areas:
Inspectors found the institution furnished three of the seven clinics (43 percent) with
essential supplies and core equipment necessary to conduct a comprehensive exam.
Examples of deficiencies included missing hemoccult cards and a developer in one PCP
exam room, expired or unmarked equipment calibrations, and no permanent distance marker
for the Snellen vision chart. Moreover, inspectors noted that, based on the eye chart’s fixed
location, the maximum distance available to a patient from the chart was approximately
14 feet instead of the standard distance of 20 feet (MIT 5.108).
In only four of seven applicable clinics inspected
(57 percent), clinical health care staff ensured that
reusable invasive and non-invasive medical
equipment was properly sterilized or disinfected.
Inspectors observed sterilized instruments hung
by their packaging in specialty clinics; at each of
three clinic locations, inspectors noted one
instrument bag with a hook or nail puncture below
its seal (see Figure 2), resulting in contamination
Figure 2: Equipment contamination
of the instrument. Inspectors also observed that a
PCP failed to change the exam table paper
between examinations in one clinic (MIT 5.102).
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Office of the Inspector General State of California
The OIG inspected exam rooms in CCI’s clinics and
found that five of the seven clinical exam rooms or
treatment spaces observed (71 percent) had sufficient
space, configuration, supplies, and equipment to allow
clinicians to perform a proper clinical exam. One
treatment space was too small to allow for adequate
inmate-patient examinations, and as shown in Figure 3,
the placement of the exam table in another room did not
allow the patient to lie in a fully extended supine
position on the table (MIT 5.110).
Figure 3: Poor exam table
placement
Other Information Obtained from Non-Scored Results
The OIG gathered information to determine if the institution’s physical infrastructure was
maintained in a manner that supported health care management’s ability to provide timely or
adequate health care. This question is not scored and is only collected and reported for
informational purposes. When OIG inspectors interviewed health care management, staff did not
express concerns about the facility’s infrastructure or its effect on staff’s ability to provide adequate
health care. At the time of the inspection, the institution had a master infrastructure project
underway, which included renovating CCI’s radiology room and enlarging multiple primary care
clinics, as well as constructing new buildings for two primary care clinics, a pharmacy, and
laboratory services. According to management staff, the project was on track with completion dates
targeted for September 2017 (MIT 5.999).
Recommendations
While most compliance scores were within the proficient range for this indicator, the institution had
deficiencies in a few areas and could easily improve its overall score by implementing the following
specific recommendations:
To mitigate contamination of reusable invasive and non-invasive medical equipment, store
this equipment in a protected area that does not involve puncturing the equipment
packaging.
Properly maintain and stock clinic areas with a full complement of core equipment,
including permanent distance markers for Snellen vision charts at the standard distance of 20
feet. Stock the exam rooms where providers work with hemoccult cards and a developer.
Monitor calibration expiration dates for applicable medical equipment to ensure equipment
items are calibrated within required time frames and calibration dates are clearly
documented.
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Office of the Inspector General State of California
Position exam tables in exam rooms so a patient can lie fully extended on the exam table and
clinicians can have unimpeded access to the patient.
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Office of the Inspector General State of California
INTER- AND INTRA-SYSTEM TRANSFERS
This indicator focuses on the management of inmate-patients’
Case Review Rating:
medical needs and continuity of patient care during the inter- and
Adequate
intra-facility transfer process. The patients reviewed for Inter- and Compliance Score:
Intra-System Transfers include inmates received from other CDCR 84.1%
facilities and inmates transferring out of CCI to another CDCR
Overall Rating:
facility. The OIG review includes evaluation of the institution’s
Adequate
ability to provide and document health screening assessments,
initiation of relevant referrals based on patient needs, and the
continuity of medication delivery to patients arriving from another institution. For those patients,
the OIG clinicians also review the timely completion of pending health appointments, tests, and
requests for specialty services. For inmate-patients who transfer out of the facility, the OIG
evaluates the ability of the institution to document transfer information that includes pre-existing
health conditions, pending appointments, tests and requests for specialty services, medication
transfer packages, and medication administration prior to transfer. The OIG clinicians also evaluate
the care provided to patients returning to the institution from an outside hospital and check to ensure
appropriate implementation of the hospital assessment and treatment plans.
Case Review Results
The OIG clinicians reviewed 42 encounters relating to Inter- and Intra-System Transfers, including
information from both the sending and receiving institutions. Additionally, the clinicians reviewed
60 hospitalization-related events. Twenty-eight of these events were actual hospitalizations or
emergency room visits, the majority of which resulted in transfers back to the institution (a few
events resulted in transfers to other hospitals or patient deaths). In general, CCI’s Inter- and
Intra-System Transfers processes were adequate. The majority of the deficiencies found related to
incomplete Health Care Transfer Information forms (CDCR 7371) for patients leaving CCI.
Specifically, the medical history, significant events, and pending appointments were not always
complete. Specific examples of case review findings are listed below.
Transfers In
Nurses generally performed adequate intake assessments and ensured continuity of medications.
Transfers Out
In case 3, the nurse failed to list the medical diagnoses of esophagitis and gastritis. The
nurse also omitted the patient’s last chronic care visit.
In case 34, the nurse failed to list pending endocrinology and cardiology specialty
appointments.
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Office of the Inspector General State of California
In case 35, the nurse failed to document a recent suicide attempt.
Hospitalizations
Patients returning from hospitalizations are some of the highest risk encounters due to two factors.
First, these patients are generally hospitalized for a severe illness or injury. Second, they are at risk
due to potential lapses in care that can occur during any transfer. At CCI, Facility B TTA or OHU
nurses assessed patients returning from hospitals. Follow-up by the primary care providers was
generally timely. A few minor deficiencies were noted:
In case 12, a medication reconciliation did not occur, resulting in failure to discontinue
ibuprofen and to start nitroglycerin as the hospital recommended. Failure to perform a
medication reconciliation also occurred in case 5.
In cases 2 and 10, the nurses failed to document review and receipt of hospital discharge
records and recommendations.
Onsite Visit
While the OIG was onsite, nursing supervisors shared recent nurse training documentation specific
to patient transfers. This training was conducted in June 2015. Since that training, nurses were
utilizing the “Patient Care Summary” to assist in completing the Health Care Transfer form (CDCR
7371). The OIG believes this training will improve some of the transfer problems.
Compliance Testing Results
The institution obtained an adequate compliance score of 84.1 percent in the Inter- and
Intra-System Transfers indicator; however, it scored within the proficient range in three of the five
areas tested, as described below:
The institution scored 100 percent when the OIG tested one inmate-patient who transferred
out of the institution during the onsite inspection to determine whether his transfer package
included the required medications and related documentation. Although two inmates
transferred out on the testing day, only one was prescribed medications (MIT 6.101).
Inspectors tested 29 inmate-patients who transferred into CCI from another CDCR
institution and found that for 26 of them (90 percent), nursing staff completed the
assessment and disposition section of the Initial Health Screening (CDCR Form 7277) on
the same day staff completed an initial screening of the patient. For three patients, nursing
staff did not sign and date the form in the “RN Assessment/Disposition” section.
Additionally, for one of those patients, the initial screening revealed that the patient
experienced unexplained signs and symptoms associated with tuberculosis, but the nurse
failed to immediately refer the inmate-patient to the TTA for a clinical evaluation
(MIT 6.002).
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Office of the Inspector General State of California
Fourteen of the sampled inmate-patients who transferred into CCI had an existing
medication order upon arrival. Inspectors found that 12 of those patients (86 percent)
received their medications without interruption; nursing staff failed to reissue medications to
two patients upon their arrival (MIT 6.003).
The institution scored within the adequate range for the following test:
The institution scored 75 percent when the OIG tested 20 inmate-patients who transferred
out of CCI to another CDCR institution to determine whether CCI listed the patients’
pending specialty service appointments on the Health Care Transfer Information form
(CDCR Form 7371). The institution failed to include specialty service appointments on the
transfer forms for five patients (MIT 6.004).
The institution has an opportunity to improve in the following area:
The OIG reviewed the initial health screenings for 30 inmate-patients who transferred into
CCI from another CDCR institution and found nursing staff conducted timely and complete
screenings for only 21 of the patients sampled (70 percent). For nine patients, the nurse
neglected to answer or insufficiently completed one or more of the screening form
questions. Missing information related to medications prescribed, mental health and medical
conditions, specialty appointments pending, and allergies (MIT 6.001).
Recommendations
The institution can easily improve its overall rating of adequate for this indicator. The OIG makes
the following specific recommendations:
Leadership has an opportunity to improve continuity of health care information by
developing a transfer audit tool. This tool should assess each component essential for
transfer continuity and evaluate data accuracy and thoroughness.
Improvement can also occur for patients arriving without essential medications by tracking
these omissions and reporting them to the sending institution. This practice (already
underway at the California Rehabilitation Center), if implemented statewide, can be the first
step in creating statewide medication accountability.
The OIG recommends that CCI implement formal training, along with audits and
competency testing, for nurses who complete Initial Health Screening forms (CDCR Form
7277) and Health Care Transfer Information forms (CDCR Form 7371).
California Correctional Institution, Cycle 4 Medical Inspection Page 33
Office of the Inspector General State of California
PHARMACY AND MEDICATION MANAGEMENT
This indicator is an evaluation of the institution’s ability to provide
Case Review Rating:
appropriate pharmaceutical administration and security
Adequate
management, encompassing the process from the written
Compliance Score:
prescription to the administration of the medication. By combining 93.2%
both a quantitative compliance test with case review analysis, this
assessment identifies issues in various stages of the medication Overall Rating:
Adequate
management process, including ordering and prescribing,
transcribing and verifying, dispensing and delivering,
administering, and documenting and reporting. Because effective medication management is
affected by numerous entities across various departments, this assessment considers internal review
and approval processes, pharmacy, nursing, health information systems, custody processes, and
actions taken by the PCP prescriber, staff, and patient.
For this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance review resulting in a proficient
score. The OIG’s internal review process considered those factors that led to both scores and
ultimately rated this indicator adequate. The key factor was the failure of this system to assure
medications were timely discontinued, when required. As a result, the case review results were
deemed a more accurate reflection of the appropriate overall indicator rating.
Case Review Results
Case review found that for the majority of cases, patients received their medications timely and as
prescribed. However, the following four cases are examples in which patients mistakenly received
medications despite providers’ orders that the medications were to be discontinued or held.
In case 9, the ophthalmologist recommended a certain eye drop be stopped. This eye drop
continued despite the order to discontinue.
In case 12, the patient received ibuprofen on three separate occasions after an order to
discontinue.
In case 13, orders were given to stop medications for pain and cancer treatment as the
patient was found to be noncompliant. This order was not followed, and the patient
continued to receive these medications.
In case 20, the provider ordered blood-thinning medication stopped due to excessive levels
as measured by the INR test at 4.7. Because of this order not being followed, the INR further
increased to 6.2 and placed the patient at a higher risk for bleeding.
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Office of the Inspector General State of California
Compliance Testing Results
The institution received a proficient compliance score of 93.2 percent for the Pharmacy and
Medication Management indicator. For discussion purposes below, this indicator is divided into
three sub-indicators: Medication Administration, Observed Medication Practices and Storage
Controls, and Pharmacy Protocols.
Medication Administration
For this sub-indicator, the institution received an average score of 85 percent and performed well in
the following areas:
Nursing staff administered medications without interruption to one inmate-patient who was
en route from one institution to another and had a temporary layover at CCI, resulting in a
score of 100 percent. The four other patients en route during the testing time period were not
taking medications (MIT 7.006).
The institution administered new medication orders to patients timely for 26 of 30 samples
the OIG reviewed, receiving a proficient score of 87 percent for this test. Three patients
received medications between one and six days late, while one patient did not receive his
medication at all (MIT 7.002).
CCI ensured that 25 of 30 patients sampled (83 percent) received their medications without
interruption when they transferred from one housing unit to another; the remaining five
patients did not receive their medication at the proper dosing interval (MIT 7.005).
Inmate-patients timely received chronic care medications for 21 of 27 samples the OIG
reviewed (78 percent). One patient did not receive all ordered medications or receive
required counseling for missed doses, and five patients did not receive their medications at
all (MIT 7.001).
The institution timely provided hospital discharge medications to 23 of 30 patients sampled
who had returned from a community hospital (77 percent); the remaining seven patients
received their medications from one to three days late (MIT 7.003).
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Office of the Inspector General State of California
Observed Medication Practices and Storage Controls
For this sub-indicator, the institution received an average score of 94 percent and performed well in
the following four areas:
The institution employed strong medication security controls over narcotic medications in
all seven clinic and medication line locations inspected that stored narcotics (MIT 7.101).
The institution properly stored non-narcotic medications that do not require refrigeration at
all 13 of the applicable clinics and medication line storage locations sampled (MIT 7.102).
At all six medication preparation and administration locations inspectors observed, nursing
staff followed proper hand hygiene protocols when administering medications to patients
(MIT 7.104).
Nursing staff also practiced appropriate administrative controls and protocols during
medication preparation at all six locations tested (MIT 7.105).
CCI has an opportunity for improvement in the following two areas:
The institution properly stored non-narcotic medications that require refrigeration at five of
the six applicable clinics, receiving a score of 83 percent (MIT 7.103).
When observing the medication distribution process at six pill line locations, inspectors
found that five (83 percent) were compliant with appropriate administrative controls and
protocols. One clinic postponed the morning pill-pass time by over an hour, thereby
compromising dosing intervals (MIT 7.106).
Pharmacy Protocols
For this sub-indicator, the institution received 100 percent in all five of the main pharmacy related
tests, as follows:
In its main pharmacy, the institution followed general security, organization, and cleanliness
management protocols; properly stored non-refrigerated and refrigerated medications; and
maintained adequate controls and properly accounted for narcotic medications
(MIT 7.107, 7.108, 7.109, 7.110).
The pharmacist-in-charge followed key medication error reporting protocols (MIT 7.111).
Other Information Obtained from Non-Scored Results
In addition to testing reported medication errors, OIG inspectors follow up on any significant
medication errors found during the case reviews or compliance testing to determine whether the
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Office of the Inspector General State of California
institution properly identified and reported errors. At CCI, the OIG did not find any applicable
medication errors (MIT 7.998).
The OIG tested inmate-patients in isolation units to determine if they had immediate access to their
prescribed keep-on-person (KOP) rescue inhalers and nitroglycerin medications. Fourteen of the 15
inmates interviewed (94 percent) had access to their rescue medications; custody confiscated one
patient’s asthma rescue inhaler because it did not have proper labeling. While the patient had been
without his rescue inhaler for two weeks, the institution reissued a new one while the OIG was
onsite (MIT 7.999).
CCHCS Dashboard Comparative Data
The Dashboard uses performance measures from the Medication Administration Process
Improvement Program (MAPIP) audit tool to calculate the average score for its Medication
Administration measure. The OIG compared similar CCI compliance scores with applicable July
2015 Dashboard results. As noted in the table below, the OIG based its compliance on a review of
current documents as well as documents dating up to nine months back; CCI’s July Dashboard data
reflected only the institution’s June 2015 results. Given these variable time frames, the OIG’s score
was 14 percentage points lower than the Dashboard score with regard to medication administration.
Pharmacy and Medication Management —
CCI Dashboard and OIG Compliance Results
CCI DASHBOARD RESULTS OIG COMPLIANCE RESULTS
Medication Administration (7.001, 7.002)
Medication Management:
(Chronic Care & New Meds)
Medication Administration
Preventive Services (9.001)
(Administering INH Medication)
July 2015
October 2014 – July 2015
98% 84%
Note: The Dashboard results were obtained from the Medication Administration Drilldown data for Chronic Care
Meds — Medical; New Outpatient Orders — Medical; New Outpatient Orders — Psychiatric; and
Administration — TB Medications. Variances may exist because CCHCS includes medication administration
of KOP medications only for the first two drilldown measures, while the OIG tests KOP, DOT, and
nurse-administered (NA) medication administration.
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
PREVENTIVE SERVICES
This indicator assesses whether the institution offers or provides
Case Review Rating:
various preventive medical services to inmate-patients. These
Not Applicable
include cancer screenings, tuberculosis screenings, and influenza Compliance Score:
and chronic care immunizations. This indicator also assesses 88.8%
whether certain institutions take preventive actions to relocate
Overall Rating:
inmate-patients identified as being at higher risk for contracting
Proficient
coccidioidomycosis (valley fever).
Compliance Testing Results
The institution performed proficiently with a score of 88.8 percent in the Preventive Services
indicator. As indicated below, the institution scored at the proficient level in all but one test for this
indicator:
The OIG found that all 30 inmate-patients sampled received annual tuberculosis screenings
(MIT 9.003).
Inmate-patients timely received or were timely offered influenza vaccinations during the
most recent influenza season for all 30 patients sampled (MIT 9.004).
The institution offered colorectal cancer screenings to all 30 sampled inmate-patients subject
to the annual screening requirement (MIT 9.005).
The OIG tested whether the institution offered required influenza, pneumonia, and hepatitis
vaccinations to patients who suffered from a chronic care condition and found that 19 of the
20 patients sampled (95 percent) received them; one patient was not offered one or more of
the vaccinations (MIT 9.008).
The institution scored 87 percent for administering anti-tuberculosis medications (INH) to
inmate-patients; 26 of 30 patients sampled timely received all required INH doses during the
three-month test period, while the medication administration records indicated one or more
missed doses for the remaining four patients (MIT 9.001). Also, the institution completed
the required monthly tuberculosis monitoring for 27 of the patients (90 percent), but failed to
consistently document the patient’s weight and applicable weight change for three patients
during the test period (MIT 9.002).
The institution scored low in the following key preventive services test:
The OIG tested two inmate-patients who during the test period were medically restricted
from CCI because of their high risk of coccidioidomycosis infection (valley fever).
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Office of the Inspector General State of California
Inspectors found CCI transferred one patient from the institution timely, scoring 50 percent;
the other patient tested was transferred 15 days late (MIT 9.009).
CCHCS Dashboard Comparative Data
As indicated below, the OIG’s proficient compliance results for colon cancer screening agreed with
the data reported within the CCHCS Dashboard for CCI.
Preventive Services — CCI Dashboard and OIG Compliance Results
CCI DASHBOARD RESULTS OIG COMPLIANCE RESULTS
Colon Cancer Screening Colon Cancer Screening (9.005)
July 2015 July 2015
100% 100%
Recommendations
No specific recommendations.
California Correctional Institution, Cycle 4 Medical Inspection Page 39
Office of the Inspector General State of California
QUALITY OF NURSING PERFORMANCE
The Quality of Nursing Performance indicator is a qualitative
Case Review Rating:
evaluation of the institution’s nursing services. The evaluation is
Adequate
completed entirely by OIG nursing clinicians within the case
Compliance Score:
review process, and, therefore, does not have a score under the
Not Applicable
compliance testing component. The OIG nurses conduct case
reviews that include reviewing face-to-face encounters related to Overall Rating:
nursing sick call requests identified on the Health Care Services Adequate
Request form (CDCR Form 7362), urgent walk-in visits, referrals
for medical services by custody staff, RN case management, RN utilization management, clinical
encounters by licensed vocational nurses (LVNs) and licensed psychiatric technicians (LPTs), and
any other nursing service performed on an outpatient basis. The OIG case review also includes
activities and processes performed by nursing staff that are not considered direct patient encounters,
such as the initial receipt and review of CDCR Form 7362 service requests and follow-up with
primary care providers and other staff on behalf of the patient. Key focus areas for evaluation of
outpatient nursing care include appropriateness and timeliness of patient triage and assessment,
identification and prioritization of health care needs, use of the nursing process to implement
interventions including patient education and referrals, and documentation that is accurate,
thorough, and legible. Nursing services provided in the outpatient housing unit (OHU), correctional
treatment center (CTC), or other inpatient units are reported under the Specialized Medical Housing
indicator. Nursing services provided in the triage and treatment area (TTA) or related to emergency
medical responses are reported under Emergency Services.
Case Review Results
OIG nursing clinicians rated the Quality of Nursing Performance at CCI adequate. The OIG
clinicians evaluated 346 nursing encounters for CCI case reviews; 128 of these were
outpatient-nursing encounters with 52 deficiencies. Despite the large number of deficiencies relative
to encounters, case reviews demonstrated most triage RN deficiencies were minor in nature and
resulted in generally satisfactory outcomes. However, case reviews also revealed deficiency patterns
that affected the quality of outpatient nursing performance in the areas of triage, assessment, and
documentation. The Quality of Nursing Performance deficiencies included the following:
Nursing Assessment/Documentation
In case 8, the patient submitted a complaint for ear pain and “multiple muscle pain.” The
nurse failed to assess both complaints. Failure to assess all complaints was also seen in cases
11, 18, and 48. The OIG clinicians also found two encounters with deficiencies in case 11. A
supervising registered nurse (SRN) at CCI audited the same encounters, but found them
adequate.
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Office of the Inspector General State of California
In case 12, the patient was seen for postsurgical pain with high blood pressure (168/100).
The nurse failed to conduct a thorough assessment prior to contacting the primary care
provider and did not recognize an elevated blood pressure as a potential sign of pain.
In case 13, the patient submitted a complaint for a dressing change, dry hands, and chest
pain. The triage nurse failed to conduct an urgent face-to-face assessment. The next day the
patient was seen in the medical clinic, and the nurse failed to document a chest pain
assessment. A SRN audited this event and found adequate care.
In case 16, the patient complained of left leg inflammation and swelling after an injury two
days prior. The nurse failed to conduct an urgent face-to-face assessment. Failure to provide
urgent triage was also seen in case 15.
Onsite Inspection
The OIG clinicians reviewed selected face-to-face nursing supervisor audits during the onsite visit.
The OIG found SRNs failed to identify deficiencies the OIG clinicians identified during the case
reviews. Similar concerns emerged regarding audits of urgent/emergent events and are discussed in
the Emergency Services section.
Conclusion
The outpatient nursing care at CCI was rated adequate. However, nursing performance displayed
patterns of poor nursing assessment, documentation, and triage. Because most complaints were
minor in nature, these failures did not negatively affect the overall care. Still, a thorough assessment
is an essential nursing function and must be accurately completed and documented.
The pattern of poor nursing performance was compounded by inadequate nursing supervisor audits
that failed to identify these deficiencies.
Recommendations
The OIG recommends the nursing sick call audit process be revised, as the method being used at the
time of the inspection did not identify nursing deficiencies. The audit process should include
documentation of the supervisors’ evaluation of the nurse’s knowledge and ability to assess patients
and perform appropriate nursing services, and the interventions carried out to improve the quality of
nursing care.
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Office of the Inspector General State of California
QUALITY OF PROVIDER PERFORMANCE
In this indicator, the OIG physicians provide a qualitative
Case Review Rating:
evaluation of the adequacy of provider care at the institution.
Adequate
Appropriate evaluation, diagnosis, and management plans are
Compliance Score:
reviewed for programs including, but not limited to, nursing sick Not Applicable
call, chronic care programs, TTA, specialized medical housing,
and specialty services. The assessment of provider care is Overall Rating:
performed entirely by OIG physicians. There is no compliance Adequate
testing component associated with this quality indicator.
Case Review Results
The OIG clinicians reviewed 528 medical provider encounters at CCI and identified 76 deficiencies
related to provider performance. Of those 76, 15 were considered serious enough to put patients at
an increased risk of harm. Five of these 15 more serious deficiencies were caused by one provider.
Assessment and Decision-Making
Twenty-five of the provider deficiencies were related to provider assessments and decision-making.
These deficiencies ranged from incomplete documentation (to support assessments and plans) to
assessments and plans being inappropriate.
In case 3, a patient’s recent hospital diagnosis of severe esophagitis and gastritis was lost
after another hospitalization for a possible transient ischemic attack (temporary stroke). As a
result, in addition to proper medications not being prescribed for the esophagitis and
gastritis, medications known to exacerbate esophagitis and gastritis were prescribed.
In the same case, a provider failed to perform and document a neurological exam despite the
patient recently being discharged with a possible transient ischemic attack (symptoms of
impending stroke), and still complaining of right-sided weakness.
In case 12, a provider failed to document a pertinent history when the patient presented with
abdominal pain. Despite a urinalysis showing the possibility of a urinary tract infection, the
provider failed to provide treatment.
In case 18, documentation in the progress note failed to support a diagnosis of purulent
rhino-sinusitis (a sinus infection that requires antibiotics), for which antibiotics was
prescribed.
In case 27, the patient’s urinary incontinence and urinary tract infections (following surgery
for prostate cancer) were not adequately treated. Documentation of progress notes was also
insufficient.
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Office of the Inspector General State of California
Review of Records
Thirteen of the provider care deficiencies were related to records not being adequately reviewed.
This resulted in unnecessary send-outs (to the local hospitals), unnecessary tests, and inappropriate
orders. This also led to inaccurate notifications of test results to patients and follow-up with
specialists not occurring. Some examples are listed below:
In case 1, incomplete review of records led to the patient being sent out for a possible heart
attack just a few weeks after a negative cardiac stress test (indicating a healthy heart). This
incomplete review of records also resulted in unnecessarily repeating certain diagnostic
tests, i.e., a chest x-ray and labs.
In case 4, a provider sent notification to the patient indicating his chest x-ray was
“essentially within normal limits” or “unchanged and no other provider follow-up is
required.” The chest x-ray actually showed a right central fullness versus mass, for which a
follow-up chest x-ray or CT scan was recommended (there were no prior imaging studies in
the eUHR to indicate this was an “unchanged” or stable finding).
In case 7, a “stat” neck x-ray was not reviewed until the following day. When it was
reviewed, the provider sent notification to the patient noting the cervical spine x-ray was
negative or unchanged, when, in fact, the results noted a possibility of epiglottitis (a
potentially life-threatening infection of the throat).
In cases 12 and 29, it was apparent providers did not review records as the assessments and
plans were not up to date.
In case 17, warfarin was adjusted twice after a provider failed to note another provider had
already made adjustments for an abnormally high blood coagulation test (indicating a high
bleeding risk).
In case 27, insufficient provider documentation indicated a provider did not review records,
which should have prompted a discussion with the patient to encourage follow-up with
specialists (this patient with recent surgery for prostate cancer had failed to follow-up with
urology and oncology). The lack of adequate review of records may have also contributed to
suboptimal treatment of urinary tract infections.
In case 29, after more recent labs were not reviewed, the same labs were unnecessarily
reordered. In case 30, a lack of review resulted in a CT being reordered despite one having
been done just three weeks prior.
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Office of the Inspector General State of California
Emergency Care
The quality of provider performance as it related to emergency care was generally adequate.
However, a few deficiencies were noted. The seriousness of some of these deficiencies is reflected
in the Emergency Services indicator summary.
In case 7, a provider noted the patient had possible epiglottitis and admitted the patient to the
outpatient housing unit. As epiglottitis is a life-threatening condition, the patient should have
immediately transferred to a higher level of care (instead of the outpatient housing unit).
In the same case, after a nurse contacted another provider and recommended the patient be
transferred out, the provider ordered the patient be transferred via State vehicle rather than
by ambulance.
In case 9, the patient was seen in the TTA for a possible drug overdose. Activated charcoal
(which can be effective at reducing drug absorption) should have been administered but was
not. In addition, when the patient was sent out for further evaluation and treatment, the
transfer should have been via ambulance rather than State vehicle.
In case 10, based on the patient’s symptoms (“epigastric chest pain, throat pressure,
dyspnea, and cough”) and exam (“mild distress, much coughing”), the patient should have
been transferred out in an ambulance rather than a State vehicle.
In case 62, the patient presented with complaints of headache and dizziness, and exam
revealed left hand weakness. With the provider’s documentation indicating a possible stroke,
aspirin should not have been given until bleeding in the brain had been ruled out.
Chronic Care
Twenty of the provider deficiencies noted were due to the delivery of chronic care being
inadequate. Six of these deficiencies were the result of inadequate anticoagulation management by
one provider (in case 21).
The management of anticoagulation was inadequate in cases 14, 17, and 21. In case 21,
various aspects of this patient’s anticoagulation were repeatedly mismanaged; the warfarin
dosing was deficient despite pharmacy recommendations (which appeared to have been
ignored by the providers); and CCHCS guidelines were not followed, with timing of lab
draws and follow-up intervals being inappropriate.
Elevated blood pressures were not adequately addressed in cases 16 and 29.
In cases 7, 24, 25, and 29, the management of diabetes was suboptimal at times.
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Office of the Inspector General State of California
In case 22, this patient with uncontrolled gastroesophageal reflux disease (GERD) continued
to receive naproxen (known to exacerbate GERD).
Specialty Services
Review of the specialty services referrals revealed that CCI providers generally requested specialty
services appropriately. When patients were seen by providers for follow-up after specialty services,
providers usually reviewed the reports adequately and took appropriate actions. A few exceptions
were noted:
In case 9, the patient was referred to an ophthalmologist for a suspected pending retinal
detachment. The referral should have been ordered “emergent” rather than “urgent,” as a
retinal detachment is an emergency requiring prompt action.
In case 13, a prostate cancer medication was mistakenly ordered for six months instead of
one month.
In case 27, a medication recommended by urology was not renewed by a provider during a
follow-up visit. This resulted in the patient not receiving this medication despite ongoing
urinary symptoms.
In case 30, a provider allowed the patient to walk using orthopedic boots. This was in
contradiction to the orthopedic recommendation that the patient not bear weight at all.
Health Information Management
As noted in the Health Information Management indicator, a culture of legacy or cloned notes was
pervasive among the providers at CCI. It was notable that six of the ten regular providers at CCI at
least once utilized a form of legacy notes during the time frame reviewed. Providers also did not
always time-stamp their progress notes and orders.
Onsite Inspection
CCI providers were generally content with their work, leadership, and ancillary services. They felt
their workload was appropriate and manageable. They felt the ancillary services, including
laboratory, pharmacy, radiology, and specialty services, were functioning well.
Discussion with some providers revealed concerns regarding the working relationship between
providers and nursing staff. Challenging relationships between providers and nurses could result in
poor communication and contribute to inadequate patient care. Further review of some deficiencies
revealed poor communication may have been a contributing factor.
The providers at CCI did not have access to the eUHR when on call. Compounded with possible
communication issues with nursing, this could create situations in which the provider did not have
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Office of the Inspector General State of California
all the necessary information, e.g., medical history, to appropriately order treatment for patients
when the provider was not onsite.
Pharmacy and Medication Management
Pharmacy and medication management by providers was adequate. A few cases with deficiencies
were noted above, e.g., anticoagulation and prostate cancer medications.
Conclusion
Of the 30 detailed case reviews, 21 were adequate, and 9 were inadequate. Of the 528 provider
encounters, 76 deficiencies were found, 15 of which were likely to put patients at increased risk of
harm. Analysis of the CCI case reviews revealed three of the inadequate cases were due to one
provider. Two case reviews had inadequate appointments and scheduling. The remaining four
inadequate cases involved different providers. Further analysis revealed that 5 of the 15 more
serious deficiencies found for Quality of Provider Performance were attributed to the same one
provider, who was responsible for three of the inadequate cases. The OIG made the leadership at
CCI and CCHCS aware of these findings, and requested further review of this provider.
While some of the above deficiencies illustrated in this section were serious, they did not represent
the large majority of care that was delivered, which was good. Still, based on the number and types
of deficiencies found relating to provider performance, the OIG expects these issues will be
reviewed and hopes to see marked improvements in subsequent inspection cycles. After taking all
factors into consideration, the OIG rated CCI’s provider performance adequate.
Recommendations
The OIG recommends that providers be educated on the dangers of legacy notes, and that
CCI management prohibit the use of these notes.
The OIG recommends that CCI’s medical leadership review their provider evaluation
processes to ensure detection of deficient patterns of practice in assessment and management
of all chronic patient care issues.
The OIG recommends that CCI’s medical leadership analyze the poor communication
process between some providers and nurses, and work to improve the relationships.
The OIG recommends CCI management provide training for its providers on conducting a
more complete review of patients’ medical records to improve patient care and avoid
unnecessary send-outs and diagnostic testing.
The OIG recommends that providers review the CCHCS care guides for anticoagulation and
diabetes management.
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Office of the Inspector General State of California
The OIG recommends that on-call providers have access to the eUHR to ensure they have
all necessary information when decisions are made.
The OIG recommends that providers time-stamp their progress notes and orders.
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Office of the Inspector General State of California
SPECIALIZED MEDICAL HOUSING (OHU, CTC, SNF, HOSPICE)
This indicator addresses whether the institution follows appropriate
Case Review Rating:
policies and procedures when admitting inmate-patients to onsite
Adequate
inpatient facilities, including completion of timely nursing and
Compliance Score:
provider assessments. The chart review assesses all aspects of
100%
medical care related to these housing units, including quality of
Overall Rating:
provider and nursing care. CCI’s only specialized medical housing
Adequate
unit is an onsite 16-bed outpatient housing unit (OHU).
For this indicator, the OIG’s case review and compliance review
processes yielded different results, with the case review giving an adequate rating and the
compliance testing resulting in a proficient score. The OIG’s internal review process considered
those factors that led to both scores and ultimately rated this indicator adequate. The key factors
were that the case review had a larger sample size, and the case review focused on the quality of
care provided. As a result, the case review testing results were deemed a more accurate reflection of
the appropriate overall rating.
Case Review Results
The OIG clinicians reviewed 87 provider encounters and 104 nursing encounters relating to the
OHU for 12 cases. These included admissions to the medical OHU for medical and mental health
conditions.
Provider Performance
In general, OHU provider performance was adequate. Of the 87 OHU provider encounters
reviewed, only nine deficiencies were identified. Of those nine deficiencies, two were considered
serious enough to place the patient at increased risk for harm.
In case 7, this patient with possible epiglottitis (a potentially life-threatening condition) was
inappropriately admitted to the OHU. Upon nursing recommendations, the patient was
transferred to a higher level of care. However, the provider ordered the patient be transferred
via State vehicle rather than via ambulance. This case is also discussed in the Emergency
Services and Quality of Provider Performance sections.
In case 2, the patient was admitted to the OHU after hospital discharge, but the admission
history and physical was sparse and incomplete and did not address the full spectrum of the
patient’s health problems, as would be expected for this type of encounter. In cases 17 and
21, the anticoagulation management was suboptimal. Case 21, in which the patient also
received care in the OHU, is discussed in more detail in the Quality of Provider
Performance indicator.
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Provider documentation in the OHU was sometimes illegible (cases 17 and 21).
Nursing Performance
The majority of practice issues for nursing performance in the OHU related to inadequate
assessment and documentation and failure to consistently perform tasks such as dressing changes
and thorough neurological assessments. While most of the 64 deficiencies in the OHU nursing
services were not likely to contribute to patient harm, the number of these deficiencies was cause
for concern.
In case 3, the patient returned from a community hospital; his wrist showed signs of prior
IV infiltration. The nurse failed to document assessment of pain, temperature, and degree of
swelling at the prior IV site. The nurse also failed to notify a provider and apply a warm
compress.
In case 16, the nurse failed to adequately assess an elevated blood pressure of 160/102.
In case 17, the provider wrote admission orders the day after the patient was admitted to the
OHU. The nurse performed an incomplete admission assessment, failing to assess his
upper-respiratory complaint. In addition, the nurses failed several times to document the
degree of lower extremity edema and to assess circulation.
In case 62, nurses failed to perform thorough assessments. The patient complained of
headache and congestion. He had a fever and abnormal lung sounds. The nurse failed to
perform a thorough respiratory assessment and failed to contact a provider. Two days later,
he had a fever, elevated pulse, and dark urine. The nurse failed to assess his skin, mucus
membranes, and oral intake, and failed to reassess his vital signs. Additionally, nurses failed
to perform neurological assessments for several days.
In case 63, nurses did not always perform dressing changes at the proper intervals and often
documented incomplete assessments and interventions. This diabetic patient had two
wounds on his right foot, but documentation often reflected only one wound. The nurses
assessed the patient’s pulse but failed to document the location his pulse was taken. Also, on
one encounter, despite three very low blood sugar results (34, 36, and 39 mg per deciliter),
the nurse failed to reassess his blood sugar after a meal.
Onsite Inspection
During their onsite interviews, OIG clinicians asked CCI’s supervising registered nurses how they
measured nursing quality in the OHU. The supervisors produced two audit tools, both of which
focused on compliance measures solely. While compliance measures, such as a functioning call
light system and cell access, are important, they are insufficient to assess the quality of nursing care
in the OHU.
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Office of the Inspector General State of California
Clinician Summary
The providers’ performance in the indicator compensated for the poor nursing performance.
Therefore, the case review portion was rated adequate. The nursing performance in this section was
weak due to the high number of repeated failures in adequate assessment, documentation, and
interventions. Fortunately, the majority of deficiencies were not likely to put patients at increased
risk for harm. The pattern of these failures is also discussed in the Quality of Nursing Performance
and Emergency Services indicators.
Compliance Testing Results
The institution received a proficient compliance score of 100 percent for the Specialized Medical
Housing indicator, which focused on the institution’s outpatient housing unit (OHU). The five test
results for this indicator consisted of the following:
For all ten inmate-patients sampled, nursing staff timely completed an initial assessment on
the day the patient was admitted to the OHU (MIT 13.001).
Providers evaluated all ten inmate-patients within 24 hours of admission and completed a
history and physical within 72 hours of admission (MIT 13.002, 13.003). Providers also
completed their subjective, objective, assessment, plan, and education (SOAPE) notes at
required 14-day intervals for each of the nine patients who had a stay long enough to require
one (MIT 13.004).
When the OIG observed the working order of a sample of call buttons in OHU patient
rooms, inspectors found the call buttons were working properly. According to staff during
interviews, custody officers and clinicians respond and access inmate-patients’ rooms in less
than one minute when an emergent event occurs (MIT 13.101).
Recommendations
The OIG recommends a process to evaluate nursing assessment, intervention, and documentation in
the OHU be implemented. This quality improvement initiative should be ongoing, measurable,
reported on, and reviewed by leadership.
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Office of the Inspector General State of California
SPECIALTY SERVICES
This indicator focuses on specialist care from the time a request for
Case Review Rating:
services or physician’s order for specialist care is completed to the
Adequate
time of receipt of related recommendations from specialists. This
Compliance Score:
indicator also evaluates the providers’ timely review of specialist 85.7%
records and documentation reflecting the patients’ care plans,
including course of care when specialist recommendations were not Overall Rating:
Adequate
ordered, and whether the results of specialists’ reports are
communicated to the patients. For specialty services denied by the
institution, the OIG determines whether the denials are timely and appropriate, and whether the
inmate-patient is updated on the plan of care.
For this indicator, the case review and compliance review processes yielded different results, with
the case review giving an adequate rating and the compliance review resulting in a proficient score.
The OIG’s internal review process considered those factors that led to both scores and ultimately
rated this indicator adequate. The key factors were that compliance testing revealed deficiencies in
two areas, and the compliance score of 85.7 percent was very close to the adequate range. As a
result, the OIG’s inspection team concluded that the appropriate overall rating for this indicator was
adequate.
Case Review Results
The OIG clinicians reviewed 127 events related to Specialty Services, the majority of which were
specialty consultations and procedures. The OIG clinicians found 21 deficiencies in this indicator
and noted findings in the following indicator subcategories:
Access to Specialty Services
Urgent and routine specialty services were generally timely and adequate, although there
were occasional minor delays in specialty follow-up appointments.
Nursing Performance
Nursing performance as it related to Specialty Services was adequate.
Provider Performance
Six provider deficiencies were identified. Three related to providers not ordering referrals
appropriately, and three related to recommendations not being followed (or failure to
document reasons for not following the recommendations).
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Office of the Inspector General State of California
Health Information Management
Five of the deficiencies found in Specialty Services were related to health information
management. Two of these deficiencies were due to a delay in specialty reports being
retrieved, reviewed by a provider, or scanned into the eUHR. One deficiency related to a
specialty report not being found in the eUHR. One deficiency related to a provider signature
not being legible on a referral form. Lastly, one deficiency was due to diagnostic results not
being available to the specialist during a follow-up consultation. These deficiencies are also
discussed in the Health Information Management section.
Onsite Inspection
The onsite visit and discussions with the specialty services department at CCI during case review
confirmed the adequacy of Specialty Services. Personnel responsible for onsite specialty care,
offsite specialty care, telemedicine services, and utilization management were located in the same
geographical vicinity. They regularly communicated with each other and provided coverage for
each other when needed. There was also good communication with the providers. The staff
indicated that when a pending specialty appointment not included in transfer forms was discovered
after a patient had already transferred out, the staff contacted the receiving facility to make staff
there aware of this.
Compliance Testing Results
The institution received a proficient compliance score of 85.7 percent in the Specialty Services
indicator. While CCI received an inadequate rating for two areas, the institution scored in the
proficient range for five other areas, including three scored at 100 percent:
For 13 of the 15 inmate-patients sampled (87 percent), their high-priority specialty services
appointment occurred within 14 calendar days of the provider’s order. One patient received
his specialty service 4 days late, and another, 14 days late (MIT 14.001). Providers reviewed
the specialists’ reports within three business days of the services for all 14 applicable
patients sampled (MIT 14.002).
All 15 of the inmate-patients sampled received their routine specialty service appointment
within 90 calendar days of the provider’s order (MIT 14.003).
The OIG tested the timeliness of CCI’s denials of provider specialty services requests for 17
patients; all of the denials occurred within the required time frame (MIT 14.006). However,
providers did not always communicate the denial status to patients within 30 calendar days;
15 of the 16 patients (94 percent) were notified timely. The provider informed one patient
one day late (MIT 14.007).
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Office of the Inspector General State of California
The institution has opportunity for improvement in the following two areas:
When the institution ordered routine specialty services, providers did not always review the
specialists’ reports within three business days after the service occurred. A provider timely
reviewed only 6 of the 11 reports sampled (55 percent); the provider reviewed four reports
from two to five days late and did not review another report at all (MIT 14.004).
When an institution approves or schedules a patient for specialty services appointments and
then transfers the patient to another institution, policy requires that the receiving institution
ensure a patient’s appointment occurs timely. At CCI, only 13 of the 20 patients sampled
(65 percent) received their specialty services appointment within the required action date.
Five patients received their appointments between 4 and 28 days late, and two additional
patients did not receive an appointment at all (MIT 14.005).
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
SECONDARY (ADMINISTRATIVE) QUALITY INDICATORS OF HEALTH CARE
The last two quality indicators (Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications) involve health care
administrative systems and processes. Testing in these areas applies only to the compliance
component of the process. Therefore, there is no case review assessment associated with either of
the two indicators. As part of the compliance component for the first of these two indicators, the
OIG did not score several questions. Instead, the OIG presented the findings for informational
purposes only. For example, the OIG described certain local processes in place at CCI.
To test both the scored and non-scored areas within these two secondary quality indicators, OIG
inspectors interviewed key institutional employees and reviewed documents during their onsite visit
to CCI in July 2015. They also reviewed documents obtained from the institution and from CCHCS
prior to the start of the inspection.
For comparative purposes, the CCI Executive Summary Table on page viii of this report shows the
case review ratings and compliance scores for each applicable indicator.
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Office of the Inspector General State of California
INTERNAL MONITORING, QUALITY IMPROVEMENT, AND ADMINISTRATIVE OPERATIONS
This indicator focuses on the institution’s administrative health care
Case Review Rating:
oversight functions. The OIG evaluates whether the institution
Not Applicable
promptly processes inmate-patient medical appeals and addresses
Compliance Score:
all appealed issues. Inspectors also verify that the institution follows 71.7%
reporting requirements for adverse/sentinel events and inmate
deaths, and whether the institution is making progress toward its Overall Rating:
Inadequate
Performance Improvement Work Plan initiatives. In addition, the
OIG verifies that the Emergency Medical Response Review
Committee (EMRRC) performs required reviews and that staff perform required emergency
response drills. Inspectors also assess whether the Quality Management Committee (QMC) meets
regularly and adequately addresses program performance. For those institutions with licensed
facilities, inspectors also verify that required committee meetings are held.
Compliance Testing Results
CCI scored in the inadequate range for the Internal Monitoring, Quality Improvement, and
Administrative Operations indicator, receiving a compliance score of 71.7 percent. Although CCI
scored 100 percent in three of the eight test areas applicable to the institution, improvement could
be achieved in several areas.
When the OIG inspected documentation for nine emergency medical response incidents
reviewed by the Emergency Medical Response Review Committee (EMRRC) during the
prior six-month period, the incident packages did not include one or both of the required
documents for each of the incidents reviewed. Inspectors also determined that the EMRRC
did not review one critical incident timely, and the warden or CEO, or both, failed to sign
the meeting minutes for all incidents. As a result, CCI received a score of zero for this test
(MIT 15.007).
Medical staff reviewed and timely submitted the Initial Inmate Death Report (CDCR Form
7229A) to CCHCS’s Death Review Unit for two of four cases tested, resulting in a score of
50 percent. The CEO or chief medical executive (CME) failed to review and sign the death
report for one patient. For another patient, the institution did not submit the death report by
noon on the business day following the patient’s death; it was submitted 20 minutes late
(MIT 15.103).
CCI improved or reached targeted performance objectives for four of the six quality
improvement initiatives identified in its 2014 Performance Improvement Work Plan,
resulting in a score of 67 percent. Performance results declined for one initiative, and the
institution failed to provide any meaningful status for the targeted performance measures for
another (MIT 15.005).
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Office of the Inspector General State of California
Inspectors reviewed the summary reports and related documentation for three medical
emergency response drills conducted in the prior quarter. The institution conducted a
comprehensive response drill for the first and second watch, but the response drill during the
third watch lacked the completion of multiple required forms. Therefore, the institution
received a score of 67 percent for this test (MIT 15.101).
The institution scored in the proficient range in the following areas:
CCI promptly processed all inmate medical appeals timely in each of the most recent 12
months. Based on data received from the institution, only one of 1,112 medical appeals was
overdue during that period (MIT 15.001).
Inspectors reviewed six recent months of Quality Management Committee (QMC) meeting
minutes and confirmed that the institution’s QMC did meet monthly. During those meetings,
the QMC evaluated program performance and took action when improvement opportunities
were identified. Consequently, the institution received a score of 100 percent for this test
(MIT 15.003). Additionally, CCI scored 100 percent for taking adequate steps to ensure the
accuracy of its Dashboard data reporting (MIT 15.004).
For nine of the ten sampled second-level medical appeals (90 percent), the institution’s
response addressed all of the patient’s appealed issues (MIT 15.102).
Other Information Obtained From Non-Scored Areas
The OIG gathered non-scored data regarding the completion of death review reports. The
Death Review Committee at CCHCS headquarters did not timely complete its death review
summary for any of the four deaths that occurred during the testing period. The Death
Review Committee is required to complete a death review summary within 30 business days
of the death and submit it to the institution’s CEO. The committee completed all four CCI
death review summaries late; delinquent completions were from 22 to 89 days late (66 to
132 calendar days after the death). Consequently, the committee did not submit any of the
summaries to CCI timely (MIT 15.996).
Inspectors met with the institution’s CEO to inquire about CCI’s protocols for tracking
appeals. The medical appeals coordinator reviewed all health care appeals; when the
coordinator or management identified a problem, the Quality Management Committee
discussed it and took action as needed, such as development of a quality improvement
initiative (MIT 15.997).
Non-scored data gathered regarding the institution’s practices for implementing local
operating procedures (LOPs) indicated that the institution has a good process in place for
developing LOPs. The institution’s standards compliance coordinator (SCC) monitors new
and revised CCHCS policies and procedures and their possible impact on the institution’s
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Office of the Inspector General State of California
LOPs. A clinical subcommittee initially determines whether action is warranted, then CCI’s
subject matter experts work with the SCC to develop revisions to existing LOPs or draft new
LOPs. Ultimately, the Quality Management Committee reviews and finalizes the LOPs and
submits them to the CEO and warden for approval and signature. Once approved, staff
members receive training within 30 days and sign an on-the-job training form as proof that
training occurred. At the time of the inspection, the institution had implemented 45 of the 48
applicable stakeholder-recommended LOPs (94 percent) (MIT 15.998).
The institution’s health care staffing resources are discussed in the About the Institution
section on page 1 (MIT 15.999).
CHCS Dashboard Comparative Data
Both the Dashboard and the OIG testing results show that CCI demonstrated a high level of
compliance for timely processing its medical appeals.
Internal Monitoring, Quality Improvement, and Administrative Operations —
CCI Dashboard and OIG Compliance Results
CCI DASHBOARD RESULTS OIG COMPLIANCE RESULTS
Timely Appeals Medical Appeals-Timely Processing
(15.001)
July 2015 12-months ending May 2015
100% 100%
Note: The CCHCS Dashboard data includes appeal data for American Disability Act (ADA), mental health, dental,
and staff complaint areas; the OIG excluded these appeal areas.
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
JOB PERFORMANCE, TRAINING, LICENSING, AND CERTIFICATIONS
In this indicator, the OIG examines whether the institution
Case Review Rating:
adequately manages its health care staffing resources by evaluating
Not Applicable
whether job performance reviews are completed as required;
Compliance Score:
specified staff possess current, valid credentials and professional 95.8%
licenses or certifications; nursing staff receive new employee
orientation training and annual competency testing; and clinical and Overall Rating:
Proficient
custody staff have current medical emergency response
certifications.
Compliance Testing Results
The institution received a proficient compliance score of 95.8 percent in the Job Performance
Training, Licensing, and Certifications indicator. The institution scored 100 percent in seven of the
indicator’s eight tests, as follows:
All providers were current with their professional licenses, and nursing staff and the
pharmacist-in-charge were current with their professional licenses and certification
requirements (MIT 16.001, 16.105).
Nursing supervisors completed the required number of nursing reviews for all five of the
nurses the OIG sampled (MIT 16.101).
All of the ten nurses sampled who administered medications possessed current clinical
competency validations, and all nursing staff hired within the last year timely received new
employee orientation training (MIT 16.102, 16.107).
The OIG reviewed performance evaluation packets for the institution’s ten providers; the
institution met all performance review requirements for its providers (MIT 16.103).
The institution’s pharmacy and providers who prescribed controlled substances were current
with their Drug Enforcement Agency registration (MIT 16.106).
There is room for improvement in the following area:
The OIG tested provider, nursing, and custody staff records to determine if the institution
ensures that those staff members have current emergency response certifications. The
institution’s provider and nursing staff were all compliant, but custody managers were not.
While the California Penal Code exempts custody managers who primarily perform
managerial duties from medical emergency response certification training, CCHCS policy
does not allow for such an exemption. As a result, the institution received a score of
67 percent for this test (MIT 16.104).
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Recommendations
No specific recommendations.
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Office of the Inspector General State of California
POPULATION-BASED METRICS
The compliance testing and the case reviews give an accurate assessment of how the institution’s
health care systems are functioning with regard to the patients with the highest risk and utilization.
This information is vital to assess the capacity of the institution to provide sustainable, adequate
care. However, one significant limitation of the case review methodology is that it does not give a
clear assessment of how the institution performs for the entire population. For better insight into this
performance, the OIG has turned to population-based metrics. For comparative purposes, the OIG
has selected several Healthcare Effectiveness Data and Information Set (HEDIS) measures for
disease management to gauge the institution’s effectiveness in outpatient health care, especially
chronic disease management.
The Healthcare Effectiveness Data and Information Set is a set of standardized performance
measures developed by the National Committee for Quality Assurance with input from over 300
organizations representing every sector of the nation’s health care industry. It is used by over
90 percent of the nation’s health plans as well as many leading employers and regulators. It was
designed to ensure that the public (including employers, the Centers for Medicare and Medicaid
Services, and researchers) has the information it needs to accurately compare the performance of
health care plans. Healthcare Effectiveness Data and Information Set data is often used to produce
health plan report cards, analyze quality improvement activities, and create performance
benchmarks.
Methodology
For population-based metrics, the OIG used a subset of HEDIS measures applicable to the CDCR
inmate-patient population. Selection of the measures was based on the availability, reliability, and
feasibility of the data required for performing the measurement. The OIG collected data utilizing
various information sources, including the eUHR, the Master Registry (maintained by CCHCS), as
well as a random sample of patient records analyzed and abstracted by trained personnel. Data
obtained from the CCHCS Master Registry and Diabetic Registry was not independently validated
by the OIG and is presumed to be accurate. For some measures, the OIG used the entire population
rather than statistically random samples. While the OIG is not a certified HEDIS compliance
auditor, the OIG uses similar methods to ensure that measures are comparable to those published by
other organizations.
Comparison of Population-Based Metrics
For the California Correctional Institution, nine HEDIS measures were selected and are listed in the
following CCI Results Compared to State and National HEDIS Scores table. Multiple health plans
publish their HEDIS performance measures at the State and national levels. The OIG has provided
selected results for several health plans in both categories for comparative purposes.
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Office of the Inspector General State of California
Results of Population-Based Metric Comparison
Comprehensive Diabetes Care
For chronic care management, the OIG chose measures related to the management of diabetes.
Diabetes is the most complex common chronic disease requiring a high level of intervention on the
part of the health care system in order to produce optimal results. CCI performed very well with its
management of diabetes.
When compared statewide, CCI significantly exceeded the Medi-Cal scores in all five diabetic
measures selected. When compared to Kaiser Permanente, CCI also outperformed Kaiser in three of
the five diabetic measures (diabetic monitoring, diabetics considered to be under poor control, and
diabetics considered to be under good control). CCI’s score for diabetic patients’ blood pressure
control was 7 and 10 percentage points lower than the Kaiser North and South scores, respectively.
However, for diabetic patient eye exams, CCI was 6 percentage points higher than the Kaiser North
regional average score and 7 percentage points lower than the Kaiser South regional average.
When compared nationally, CCI outperformed Medicaid, Medicare, and commercial health plans
(based on data obtained from health maintenance organizations) in all five of the diabetic measures
listed. CCI scored slightly higher than the U.S. Department of Veterans Affairs (VA) for diabetic
monitoring and outperformed the VA by 6 percentage points for its diabetic patients considered to
be under poor control. For blood pressure control and eye exams, CCI trailed the VA by 5 and
15 percentage points, respectively.
Immunizations
Comparative data for immunizations was only fully available for the VA (national) and partially
available for Kaiser Permanente (statewide), commercial plans (national), and Medicare (national).
For influenza shots for adults up to age 64, CCI scored 8 percentage points higher than Kaiser’s
highest regional average, 17 percentage points higher than commercial plans, and 2 percentage
points higher than the VA. However, with respect to influenza vaccinations for patients 65 and
older, CCI scored 3 percentage points lower than the VA and 1 percentage point higher than
Medicare; all 26 of the inmate-patients tested were offered the influenza vaccination, but 7 of them
(27 percent) refused it. With respect to pneumococcal vaccinations for older adults, CCI scored 5
percentage points lower than Medicare and 28 percentage points lower than the VA. Although one
patient tested was offered the immunization but refused it, eight other patients had no record of
being offered or receiving the vaccination within the 12-month review period.
Cancer Screening
For colorectal cancer screening, CCI performed the same as Kaiser North at 78 percent, but trailed
Kaiser South by 2 percentage points. The institution achieved scores 14 and 11 percentage points
higher than Medicare and commercial plans, respectively, but 4 percentage points lower than the
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VA. However, all 41 inmate-patients sampled were offered the screening timely, but nine of them
(22 percent) had subsequently refused the test.
Summary
California Correctional Institution’s population-based metrics performance was strong for most
diabetic measures and comparable to other State and national results for most immunizations and
cancer screening measures. CCI outperformed all State and national average scores for diabetic
monitoring, diabetics considered to be under poor control, and diabetics considered to be under
good control. With regard to blood pressure control and eye exams for diabetic patients, CCI’s
scores were mid-range when compared to the other entities.
For immunization measures, the institution performed well for patients under the age of 65,
receiving a higher score than Kaiser, commercial plans, and the VA, which were the only entities
that reported data in these areas. In patients 65 and older CCI performed lower than the VA for
influenza vaccinations but higher than Medicare, and performed lower than both Medicare and the
VA for pneumococcal vaccinations, but the institution’s score for influenza vaccinations was
negatively impacted by patients who were offered immunizations and refused them.
For colorectal cancer screening, CCI’s performance was mid-range when compared to the other
entities’ reporting data. The institution’s score was again negatively impacted by patients who were
offered cancer screenings but refused them.
Overall, CCI’s HEDIS performance reflects an adequately performing chronic care program, further
corroborated by the institution’s adequate score in the Access to Care indicator and proficient score
in the Preventive Services indicator. With regard to CCI’s performance in the immunization and
colorectal screening measures, the institution should make interventions to lower the rate of patient
refusal for influenza shots and colorectal cancer screening.
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Office of the Inspector General State of California
CCI Results Compared to State and National HEDIS Scores
California National
CCI HEDIS HEDIS HEDIS HEDIS
Clinical Measures Medi - Kaiser Kaiser HEDIS Com- HEDIS VA
Cycle 4 Cal (No.CA) (So.CA) Medicaid mercial Medicare Average
Results 2014 2014 2014 2015 2015 2015 2012
1 2 3 3 4 4 4 5
Comprehensive Diabetes Care
HbA1c Testing (Monitoring) 100% 83% 95% 94% 86% 91% 93% 99%
Poor HbA1c Control (>9.0%) 6,7 13% 44% 18% 21% 44% 31% 25% 19%
HbA1c Control (<8.0%) 6 77% 47% 70% 67% 47% 58% 65% -
Blood Pressure Control (<140/90) 75% 60% 82% 85% 62% 65% 65% 80%
Eye Exams 75% 51% 69% 82% 54% 56% 69% 90%
Immunizations
Influenza Shots - Adults (18–64) 8 67% - 59% 55% - 50% - 65%
Influenza Shots - Adults (65+) 73% - - - - - 72% 76%
Immunizations: Pneumococcal 65% - - - - - 70% 93%
Cancer Screening
Colorectal Cancer Screening 78% - 78% 80% - 64% 67% 82%
1. Unless otherwise stated, data was collected in July 2015 by reviewing medical records from a sample of CCI’s population of
applicable inmate-patients. These random statistical sample sizes were based on a 95 percent confidence level with a 15 percent
maximum margin of error.
2. HEDIS Medi-Cal data was obtained from the California Department of Health Care Services 2014 HEDIS Aggregate Report for the
Medi-Cal Managed Care Program.
3. Data was obtained from Kaiser Permanente November 2014 reports for the Northern and Southern California regions.
4. National HEDIS data for Medicaid, commercial plans, and Medicare was obtained from the 2015 State of Health Care Quality
Report, available on the NCQA website: www.ncqa.org. The results for commercial plans were based on data received from various
health maintenance organizations.
5. The Department of Veterans Affairs (VA) data was obtained from the VHA Facility Quality and Safety Report - Fiscal Year 2012
Data.
6. For this indicator, the entire applicable CCI population was tested.
7. For this measure only, a lower score is better. For Kaiser, the OIG derived the Poor HbA1c Control indicator using the reported data
for the <9.0% HbA1c control indicator.
8. The VA data is for the age range 50–64.
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Office of the Inspector General State of California
APPENDIX A — COMPLIANCE TEST RESULTS
California Correctional Institution
Range of Summary Scores: 71.67% - 100.00%
Indicator Overall Score (Yes %)
Access to Care 81.09%
Diagnostic Services 84.44%
Emergency Services Not Applicable
Health Information Management (Medical Records) 78.18%
Health Care Environment 84.42%
Inter- and Intra-System Transfers 84.07%
Pharmacy and Medication Management 93.2%
Prenatal and Post-Delivery Services Not Applicable
Preventive Services 88.81%
Quality of Nursing Performance Not Applicable
Quality of Provider Performance Not Applicable
Reception Center Arrivals Not Applicable
Specialized Medical Housing (OHU, CTC, SNF, Hospice) 100.00%
Specialty Services 85.71%
Internal Monitoring, Quality Improvement, and Administrative Operations 71.67%
Job Performance, Training, Licensing, and Certifications 95.83%
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Access to Care
Number Yes No No Yes % N/A
1.001 Chronic care follow-up appointments: Was the inmate-patient’s most 21 9 30 70.00% 0
recent chronic care visit within the health care guideline’s maximum
allowable interval or within the ordered time frame, whichever is
shorter?
1.002 For endorsed inmate-patients received from another CDCR 11 14 25 44.00% 5
institution: If the nurse referred the inmate-patient to a provider during
the initial health screening, was the inmate-patient seen within the
required time frame?
1.003 Clinical appointments: Did a registered nurse review the 30 0 30 100.00% 0
inmate-patient’s request for service the same day it was received?
1.004 Clinical appointments: Did the registered nurse complete a 25 5 30 83.33% 0
face-to-face visit within one business day after the CDCR Form 7362
was reviewed?
1.005 Clinical appointments: If the registered nurse determined a referral to 11 4 15 73.33% 15
a primary care provider was necessary, was the inmate-patient seen
within the maximum allowable time or the ordered time frame,
whichever is the shorter?
1.006 Sick call follow-up appointments: If the primary care provider 4 1 5 80.00% 25
ordered a follow-up sick call appointment, did it take place within the
time frame specified?
1.007 Upon the inmate-patient’s discharge from the community hospital: 30 0 30 100.00% 0
Did the inmate-patient receive a follow-up appointment within the
required time frame?
1.008 Specialty service follow-up appointments: Do specialty service 19 5 24 79.17% 6
primary care physician follow-up visits occur within required time
frames?
1.101 Clinical appointments: Do inmate-patients have a standardized 5 0 5 100.00% 0
process to obtain and submit health care services request forms?
Overall Percentage: 81.09%
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Diagnostic Services
Number Yes No No Yes % N/A
2.001 Radiology: Was the radiology service provided within the time frame 10 0 10 100.00% 0
specified in the provider’s order?
2.002 Radiology: Did the primary care provider review and initial the 8 2 10 80.00% 0
diagnostic report within specified time frames?
2.003 Radiology: Did the primary care provider communicate the results of 8 2 10 80.00% 0
the diagnostic study to the inmate-patient within specified time frames?
2.004 Laboratory: Was the laboratory service provided within the time 10 0 10 100.00% 0
frame specified in the provider’s order?
2.005 Laboratory: Did the primary care provider review and initial the 8 2 10 80.00% 0
diagnostic report within specified time frames?
2.006 Laboratory: Did the primary care provider communicate the results of 7 3 10 70.00% 0
the diagnostic study to the inmate-patient within specified time frames?
2.007 Pathology: Did the institution receive the final diagnostic report within 9 1 10 90.00% 0
the required time frames?
2.008 Pathology: Did the primary care provider review and initial the 9 1 10 90.00% 0
diagnostic report within specified time frames?
2.009 Pathology: Did the primary care provider communicate the results of 7 3 10 70.00% 0
the diagnostic study to the inmate-patient within specified time frames?
Overall Percentage: 84.44%
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Office of the Inspector General State of California
Emergency Services
Scored Answers
Assesses reaction times and responses to emergency situations. The OIG RN
clinicians will use detailed information obtained from the institution’s incident Not Applicable
packages to perform focused case reviews.
Scored Answers
Health Information Management (Medical Yes
Reference +
Records)
Number Yes No No Yes % N/A
4.001 Are non-dictated progress notes, initial health screening forms, and 20 0 20 100.00% 0
health care service request forms scanned into the eUHR within three
calendar days of the inmate-patient encounter date?
4.002 Are dictated / transcribed documents scanned into the eUHR within 7 3 10 70.00% 0
five calendar days of the inmate-patient encounter date?
4.003 Are specialty documents scanned into the eUHR within five calendar 11 9 20 55.00% 0
days of the inmate-patient encounter date?
4.004 Are community hospital discharge documents scanned into the eUHR 19 1 20 95.00% 0
within three calendar days of the inmate-patient date of hospital
discharge?
4.005 Are medication administration records (MARs) scanned into the eUHR 20 0 20 100.00% 0
within the required time frames?
4.006 During the eUHR review, did the OIG find that documents were 6 6 12 50.00% 0
correctly labeled and included in the correct inmate-patient’s file?
4.007 Did clinical staff legibly sign health care records, when required? 22 10 32 68.75% 0
4.008 For inmate-patients discharged from a community hospital: Did 26 4 30 86.67% 0
the preliminary hospital discharge report include key elements and did
a PCP review the report within three calendar days of discharge?
Overall Percentage: 78.18%
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Health Care Environment
Number Yes No No Yes % N/A
5.101 Infection Control: Are clinical health care areas appropriately 7 0 7 100.00% 2
disinfected, cleaned and sanitary?
5.102 Infection control: Do clinical health care areas ensure that reusable 4 3 7 57.14% 2
invasive and non-invasive medical equipment is properly sterilized or
disinfected as warranted?
5.103 Infection Control: Do clinical health care areas contain operable sinks 7 0 7 100.00% 2
and sufficient quantities of hygiene supplies?
5.104 Infection control: Does clinical health care staff adhere to universal 6 0 6 100.00% 3
hand hygiene precautions?
5.105 Infection control: Do clinical health care areas control exposure to 6 1 7 85.71% 2
blood-borne pathogens and contaminated waste?
5.106 Warehouse, Conex and other non-clinic storage areas: Does the 1 0 1 100.00% 8
medical supply management process adequately support the needs of
the medical health care program?
5.107 Clinical areas: Does each clinic follow adequate protocols for 6 1 7 85.71% 2
managing and storing bulk medical supplies?
5.108 Clinical areas: Do clinic common areas and exam rooms have 3 4 7 42.86% 2
essential core medical equipment and supplies?
5.109 Clinical areas: Do clinic common areas have an adequate environment 7 0 7 100.00% 2
conducive to providing medical services?
5.110 Clinical areas: Do clinic exam rooms have an adequate environment 5 2 7 71.43% 2
conducive to providing medical services?
5.111 Emergency response bags: Are TTA and clinic emergency medical 6 1 7 85.71% 2
response bags inspected daily and inventoried monthly, and do they
contain essential items?
5.999 For Information Purposes Only: Does the institution’s health care
management believe that all clinical areas have physical plant Information Only
infrastructures sufficient to provide adequate health care services?
Overall Percentage: 84.42%
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Inter- and Intra-System Transfers
Number Yes No No Yes % N/A
6.001 For endorsed inmate-patients received from another CDCR 21 9 30 70.00% 0
institution or COCF: Did nursing staff complete the initial health
screening and answer all screening questions on the same day the
inmate-patient arrived at the institution?
6.002 For endorsed inmate-patients received from another CDCR 26 3 29 89.66% 1
institution or COCF: When required, did the RN complete the
assessment and disposition section of the health screening form; refer
the inmate-patient to the TTA, if TB signs and symptoms were present;
and sign and date the form on the same day staff completed the health
screening?
6.003 For endorsed inmate-patients received from another CDCR 12 2 14 85.71% 16
institution or COCF: If the inmate-patient had an existing medication
order upon arrival, were medications administered or delivered without
interruption?
6.004 For inmate-patients transferred out of the facility: Were scheduled 15 5 20 75.00% 0
specialty service appointments identified on the Health Care Transfer
Information Form 7371?
6.101 For inmate-patients transferred out of the facility: Do medication 1 0 1 100.00% 1
transfer packages include required medications along with the
corresponding Medical Administration Record (MAR) and Medication
Reconciliation?
Overall Percentage: 84.07%
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Pharmacy and Medication Management
Number Yes No No Yes % N/A
7.001 Did the inmate-patient receive all chronic care medications within the 21 6 27 77.78% 3
required time frames or did the institution follow departmental policy
for refusals or no-shows?
7.002 Did health care staff administer or deliver new order prescription 26 4 30 86.67% 0
medications to the inmate-patient within the required time frames?
7.003 Upon the inmate-patient’s discharge from a community hospital: 23 7 30 76.67% 0
Were all medications ordered by the institution’s primary care provider
administered or delivered to the inmate-patient within one calendar day
of return?
7.004 For inmate-patients received from a county jail: Were all
medications ordered by the institution’s reception center provider
Not Applicable
administered or delivered to the inmate-patient within the required time
frames?
7.005 Upon the inmate-patient’s transfer from one housing unit to 25 5 30 83.33% 0
another: Were medications continued without interruption?
7.006 For inmate-patients en route who lay over at the institution: If the 1 0 1 100.00% 4
temporarily housed inmate-patient had an existing medication order,
were medications administered or delivered without interruption?
7.101 All clinical and medication line storage areas for narcotic 7 0 7 100.00% 7
medications: Does the institution employ strong medication security
controls over narcotic medications assigned to its clinical areas?
7.102 All clinical and medication line storage areas for non-narcotic 13 0 13 100.00% 1
medications: Does the institution properly store non-narcotic
medications that do not require refrigeration in assigned clinical areas?
7.103 All clinical and medication line storage areas for non-narcotic 5 1 6 83.33% 8
medications: Does the institution properly store non-narcotic
medications that require refrigeration in assigned clinical areas?
7.104 Medication preparation and administration areas: Do nursing staff 6 0 6 100.00% 8
employ and follow hand hygiene contamination control protocols
during medication preparation and medication administration
processes?
7.105 Medication preparation and administration areas: Does the 6 0 6 100.00% 8
institution employ appropriate administrative controls and protocols
when preparing medications for inmate-patients?
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7.106 Medication preparation and administration areas: Does the institution 5 1 6 83.33% 8
employ appropriate administrative controls and protocols when distributing
medications to inmate-patients?
7.107 Pharmacy: Does the institution employ and follow general security, 1 0 1 100.00% 0
organization, and cleanliness management protocols in its main and satellite
pharmacies?
7.108 Pharmacy: Does the institution’s pharmacy properly store non-refrigerated 1 0 1 100.00% 0
medications?
7.109 Pharmacy: Does the institution’s pharmacy properly store refrigerated or 1 0 1 100.00% 0
frozen medications?
7.110 Pharmacy: Does the institution’s pharmacy properly account for narcotic 1 0 1 100.00% 0
medications?
7.111 Pharmacy: Does the institution follow key medication error reporting 25 0 25 100.00% 0
protocols?
7.998 For Information Purposes Only: During eUHR compliance testing and
case reviews, did the OIG find that medication errors were properly Information Only
identified and reported by the institution?
7.999 For Information Purposes Only: Do inmate-patients in isolation housing
units have immediate access to their KOP prescribed rescue inhalers and Information Only
nitroglycerin medications?
Overall Percentage: 93.19%
California Correctional Institution, Cycle 4 Medical Inspection Page 71
Office of the Inspector General State of California
Prenatal and Post-Delivery Services
Scored Answers
This indicator is not applicable to this institution. Not Applicable
Scored Answers
Yes
Reference +
Preventive Services
Number Yes No No Yes % N/A
9.001 Inmate-patients prescribed INH: Did the institution administer the 26 4 30 86.67% 0
medication to the inmate-patient as prescribed?
9.002 Inmate-patients prescribed INH: Did the institution monitor the 27 3 30 90.00% 0
inmate-patient monthly for the most recent three months he or she was
on the medication?
9.003 Annual TB Screening: Was the inmate-patient screened for TB within 30 0 30 100.00% 0
the last year?
9.004 Were all inmate-patients offered an influenza vaccination for the most 30 0 30 100.00% 0
recent influenza season?
9.005 All inmate-patients from the age 50 through the age of 75: Was the 30 0 30 100.00% 0
inmate-patient offered colorectal cancer screening?
9.008 Are required immunizations being offered for chronic care 19 1 20 95.00% 0
inmate-patients?
9.009 Are inmate-patients at the highest risk of coccidioidomycosis (valley 1 1 2 50.00% 0
fever) infection transferred out of the facility in a timely manner?
Overall Percentage: 88.81%
California Correctional Institution, Cycle 4 Medical Inspection Page 72
Office of the Inspector General State of California
Quality of Nursing Performance
Scored Answers
The quality of nursing performance will be assessed during case reviews, conducted
by OIG clinicians, and is not applicable for the compliance portion of the medical
inspection. The methodologies OIG clinicians use to evaluate the quality of nursing Not Applicable
performance are presented in a separate inspection document entitled OIG MIU
Retrospective Case Review Methodology.
Quality of Provider Performance
Scored Answers
The quality of provider performance will be assessed during case reviews,
conducted by OIG clinicians, and is not applicable for the compliance portion of the
medical inspection. The methodologies OIG clinicians use to evaluate the quality of Not Applicable
provider performance are presented in a separate inspection document entitled OIG
MIU Retrospective Case Review Methodology.
Reception Center Arrivals
Scored Answers
This indicator is not applicable to this institution. Not Applicable
Scored Answers
Specialized Medical Housing (OHU, CTC, Yes
Reference +
SNF, Hospice)
Number Yes No No Yes % N/A
13.001 For all higher-level care facilities: Did the registered nurse complete 10 0 10 100.00% 0
an initial assessment of the inmate-patient on the day of admission, or
within eight hours of admission to CMF’s Hospice?
13.002 For OHU, CTC, & SNF only: Did the primary care provider for 10 0 10 100.00% 0
OHU or attending physician for a CTC & SNF evaluate the
inmate-patient within 24 hours of admission?
13.003 For OHU, CTC, & SNF only: Was a written history and physical 10 0 10 100.00% 0
examination completed within 72 hours of admission?
13.004 For all higher level care facilities: Did the primary care provider 9 0 9 100.00% 1
complete the Subjective, Objective, Assessment, Plan, and Education
(SOAPE) notes on the inmate-patient at the minimum intervals
required for the type of facility where the inmate-patient was treated?
13.101 For OHU and CTC Only: Do inpatient areas either have properly 1 0 1 100.00% 0
working call systems in its OHU & CTC or are 30-minute patient
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter inmate-patient’s cells?
Overall Percentage: 100.00%
California Correctional Institution, Cycle 4 Medical Inspection Page 73
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Specialty Services
Number Yes No No Yes % N/A
14.001 Did the inmate-patient receive the high-priority specialty service within 13 2 15 86.67% 0
14 calendar days of the PCP order?
14.002 Did the PCP review the high priority specialty service consultant report 14 0 14 100.00% 1
within the required time frame?
14.003 Did the inmate-patient receive the routine specialty service within 90 15 0 15 100.00% 0
calendar days of the PCP order?
14.004 Did the PCP review the routine specialty service consultant report 6 5 11 54.55% 4
within the required time frame?
14.005 For endorsed inmate-patients received from another CDCR 13 7 20 65.00% 0
institution: If the inmate-patient was approved for a specialty services
appointment at the sending institution, was the appointment scheduled
at the receiving institution within the required time frames?
14.006 Did the institution deny the primary care provider request for specialty 17 0 17 100.00% 0
services within required time frames?
14.007 Following the denial of a request for specialty services, was the 15 1 16 93.75% 1
inmate-patient informed of the denial within the required time frame?
Overall Percentage: 85.71%
California Correctional Institution, Cycle 4 Medical Inspection Page 74
Office of the Inspector General State of California
Scored Answers
Internal Monitoring, Quality Improvement, and Yes
Reference +
Administrative Operations
Number Yes No No Yes % N/A
15.001 Did the institution promptly process inmate medical appeals during the 12 0 12 100.00% 0
most recent 12 months?
15.002 Does the institution follow adverse/sentinel event reporting
Not Applicable
requirements?
15.003 Did the institution Quality Management Committee (QMC) meet at 6 0 6 100.00% 0
least monthly to evaluate program performance, and did the QMC take
action when improvement opportunities were identified?
15.004 Did the institution’s Quality Management Committee (QMC) or other 1 0 1 100.00% 0
forum take steps to ensure the accuracy of its Dashboard data
reporting?
15.005 For each initiative in the Performance Improvement Work Plan 4 2 6 66.67% 0
(PIWP), has the institution performance improved or reached the
targeted performance objective(s)?
15.006 For institutions with licensed care facilities: Does the local
governing body (LGB), or its equivalent, meet quarterly and exercise
Not Applicable
its overall responsibilities for the quality management of patient health
care?
15.007 Does the Emergency Medical Response Review Committee perform 0 9 9 0.00% 0
timely incident package reviews that include the use of required review
documents?
15.101 Did the institution complete a medical emergency response drill for 2 1 3 66.67% 0
each watch and include participation of health care and custody staff
during the most recent full quarter?
15.102 Did the institution’s second level medical appeal response address all 9 1 10 90.00% 0
of the inmate-patient’s appealed issues?
15.103 Did the institution’s medical staff review and submit the initial inmate 2 2 4 50.00% 0
death report to the Death Review Unit in a timely manner?
15.996 For Information Purposes Only: Did the CCHCS Death Review
Committee submit its inmate death review summary to the institution Information Only
timely?
15.997 For Information Purposes Only: Identify the institution’s protocols
Information Only
for tracking medical appeals.
15.998 For Information Purposes Only: Identify the institution’s protocols
Information Only
for implementing health care local operating procedures.
15.999 For Information Purposes Only: Identify the institution’s health care
Information Only
staffing resources.
Overall Percentage: 71.67%
California Correctional Institution, Cycle 4 Medical Inspection Page 75
Office of the Inspector General State of California
Scored Answers
Job Performance, Training, Licensing, and Yes
Reference +
Certifications
Number Yes No No Yes % N/A
16.001 Do all providers maintain a current medical license? 12 0 12 100.00% 0
16.101 Does the institution’s Supervising Registered Nurse conduct periodic 5 0 5 100.00% 0
reviews of nursing staff?
16.102 Are nursing staff who administer medications current on their clinical 10 0 10 100.00% 0
competency validation?
16.103 Are structured clinical performance appraisals completed timely? 10 0 10 100.00% 0
16.104 Is staff current with required medical emergency response 2 1 3 66.67% 0
certifications?
16.105 Are nursing staff and the Pharmacist-in-Charge current with their 5 0 5 100.00% 1
professional licenses and certifications?
16.106 Do the institution’s pharmacy and authorized providers who prescribe 1 0 1 100.00% 0
controlled substances maintain current Drug Enforcement Agency
(DEA) registrations?
16.107 Are nursing staff current with required new employee orientation? 1 0 1 100.00% 0
Overall Percentage: 95.83%
California Correctional Institution, Cycle 4 Medical Inspection Page 76
Office of the Inspector General State of California
APPENDIX B — CLINICAL DATA
Table B-1 CCI Sample Sets
Sample Set Total
Anticoagulation 3
CTC/OHU 2
Death Review/Sentinel Events 4
Diabetes 3
Emergency Services - Non-CPR 5
High Risk 5
Hospitalization 5
Intra-System Transfers in 3
Intra-System Transfers out 3
RN Sick Call 25
Specialty Services 5
63
California Correctional Institution, Cycle 4 Medical Inspection Page 77
Office of the Inspector General State of California
Table B-2 CCI Chronic Care Diagnoses
Diagnosis Total
Anemia 1
Anticoagulation 4
Arthritis/Degenerative Joint Disease 7
Asthma 7
COPD 2
Cardiovascular Disease 3
Chronic Kidney Disease 3
Chronic Pain 8
Cirrhosis/End Stage Liver Disease 3
Coccidioidomycosis 1
Deep Venous Thrombosis/Pulmonary Embolism 2
Diabetes 14
Gastroesophageal Reflux Disease 17
Hepatitis C 18
Hyperlipidemia 10
Hypertension 33
Mental Health 17
Migraine Headaches 1
Seizure Disorder 1
Sleep Apnea 3
Thyroid Disease 4
159
California Correctional Institution, Cycle 4 Medical Inspection Page 78
Office of the Inspector General State of California
Table B-3 CCI Event - Program
Program Total
Diagnostic Services 199
Emergency Care 45
Hospitalization 60
Intra-System Transfers in 21
Intra-System Transfers out 21
Not Specified 1
Outpatient Care 406
Specialized Medical Housing 195
Specialty Services 127
1,075
Table B-4 CCI Case Review Summary
Total
MD Reviews Detailed 30
MD Reviews Focused 0
RN Reviews Detailed 15
RN Reviews Focused 36
Total Reviews 81
Total Unique Cases 63
Overlapping Reviews (MD & RN) 18
California Correctional Institution, Cycle 4 Medical Inspection Page 79
Office of the Inspector General State of California
APPENDIX C — COMPLIANCE SAMPLING METHODOLOGY
California Correctional Institution
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Access to Care Chronic Care Master Registry Chronic care conditions (at least one condition per
(30—Basic Level) inmate-patient—any risk level)
(40—Inter Level) Randomize
Nursing Sick Call MedSATS Clinic (each clinic tested)
(5 per clinic) Appt. date (2–9 months)
(minimum of 30) Randomize
Returns from Inpatient Claims See Health Information Management (Medical
Community Hospital Data Records) (returns from community hospital)
(30)
Diagnostic Radiology Radiology Logs Appt. Date (90 days–9 months)
Services (10) Randomize
Abnormal
Laboratory Quest Appt. date (90 days–9 months)
(10) Order name (CBC or CMPs only)
Randomize
Abnormal
Pathology InterQual Appt. date (90 days–9 months)
(10) Service (pathology related)
Randomize
Health Timely Scanning OIG Qs: 1.001, Non-dictated documents
Information (20 each) 1.002, 1.006, & First 5 inmate-patients selected for each question
Management 9.004
(Medical OIG Q: 1.001 Dictated documents
Records) First 20 inmate-patients selected
OIG Qs: 14.002 Specialty documents
& 14.004 First 10 inmate-patients selected for each question
OIG Q: 4.008 Community hospital discharge documents
First 20 inmate-patients selected for the question
OIG Q: 7.001 MARs
First 20 inmate-patients selected
Legible Signatures OIG Qs: 4.008, First 8 inmates sampled
and Review 6.001/6.002, One source document per inmate-patient
(40) 7.001,
12.001/12.002, &
14.002
Complete and Documents for Any incorrectly scanned eUHR document
Accurate Scanning any tested inmate identified during OIG eUHR file review, e.g.,
mislabeled, misfiled, illegibly scanned, or missing
Returns from Inpatient Claims Date (2–8 months)
Community Hospital Data Most recent 6 months provided (within date range)
(30) Rx count
Discharge date
Randomize (each month individually)
First 5 inmate-patients from each of the 6 months
(if not 5 in a month, supplement from another, as
needed)
California Correctional Institution, Cycle 4 Medical Inspection Page 80
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Health Care Clinical Areas OIG Inspector Identify and inspect all onsite clinical areas.
Environment (number varies by Onsite Review
institution)
Inter- and Intra-System SOMS Arrival date (3–9 months)
Intra-System transfers Arrived from (another CDCR facility)
Transfers (30) Rx count
Randomize
Specialty Service MedSATS Date of Transfer (3–9 months)
Send-outs Randomize
(20)
Pharmacy and Chronic Care OIG Q: 1.001 See Access to Care
Medication Medication (At least one condition per inmate-patient—any
Management (30—Basic Level) risk level)
(40—Inter Level) Randomize
New Medication Master Registry Rx Count
Orders Randomize
(30—Basic Level) Ensure no duplication of inmate-patients tested in
(40—Inter Level) chronic care medications
Intra-Facility moves MAPIP Transfer Date of transfer (2–8 months)
(30) Data To location/from location (yard to yard and
to/from ASU)
Remove any to/from MHCB
NA/DOT meds (high–low)–inmate-patient must
have NA/DOT meds to qualify for testing
Randomize
En Route SOMS Date of transfer (2–8 months)
(10) Sending institution (another CDCR facility)
Randomize
Length of stay (minimum of 2 days)
NA/DOT meds
Returns from Inpatient Claims See Health Information Management (Medical
Community Hospital Data Records) (returns from community hospital)
(30)
Medication OIG Inspector Identify and inspect onsite clinical areas that
Preparation and Onsite Review prepare and administer medications
Administration Areas
Pharmacy OIG Inspector Identify and inspect onsite pharmacies
Onsite Review
Medication Error OIG Inspector Any medication error identified during OIG eUHR
Reporting Review file review, e.g., case reviews and/or compliance
testing
Prenatal and Recent Deliveries OB Roster Delivery date (2–12 months)
Post-Delivery (5) Most recent deliveries (within date range)
Services N/A at this institution
Pregnant Arrivals OB Roster Arrival date (2–12 months)
(5) Earliest arrivals (within date range)
N/A at this institution
California Correctional Institution, Cycle 4 Medical Inspection Page 81
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Preventive Chronic Care OIG Q: 1.001 Chronic care conditions (at least 1 condition per
Services Vaccinations inmate-patient—any risk level)
(30—Basic Level) Randomize
(40—Inter Level) Condition must require vaccination(s)
Not all conditions
require vaccinations
INH Maxor Dispense date (past 9 months)
(all applicable up to Time period on INH (at least a full 3 months)
30) Randomize
Colorectal Screening SOMS Arrival date (at least 1 year prior to inspection)
(30) Date of birth (51 or older)
Randomize
Influenza SOMS Arrival date (at least 1 year prior to inspection)
Vaccinations Randomize
(30) Filter out inmate-patients tested in chronic care
vaccination sample
TB Code 22, annual SOMS Arrival date (at least 1 year prior to inspection)
TST TB Code (22)
(15) Randomize
TB Code 34, annual SOMS Arrival date (at least 1 year prior to inspection)
screening TB Code (34)
(15) Randomize
Mammogram SOMS Arrival date (at least 2 years prior to inspection)
(30) Date of birth (age 52–74)
N/A at this institution Randomize
Pap Smear SOMS Arrival date (at least three years prior to
(30) inspection)
N/A at this institution Date of birth (age 24–53)
Randomize
Valley Fever Cocci Transfer Reports from past 2–8 months
(number will vary, up Status Report Institution
to 20) Ineligibility date (60 days prior to inspection date)
All
Reception RC SOMS Arrival date (2–8 months)
Center Arrivals (20) Arrived from (county jail, return from parole, etc.)
Randomize
N/A at this institution
Specialized OHU, CTC, SNF, CADDIS Admit date (1–6 months)
Medical Hospice Type of stay (no MH beds)
Housing (10 per housing area) Length of stay (minimum of 5 days)
Randomize
California Correctional Institution, Cycle 4 Medical Inspection Page 82
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Specialty High-Priority MedSATS Approval date (3–9 months)
Services Access (10) Randomize
Routine MedSATS Approval date (3–9 months)
(10) Remove optometry, physical therapy or podiatry
Randomize
Specialty Service MedSATS Arrived from (other CDCR institution)
Arrivals Date of transfer (3–9 months)
(20) Randomize
Denials InterQual Review date (3–9 months)
(20)* Randomize
IUMC/MAR Meeting date (9 months)
*Ten InterQual Meeting Minutes Denial upheld
Ten MARs
Randomize
Internal Medical Appeals Monthly Medical Medical appeals (12 months)
Monitoring, (all) Appeals Reports
Quality Adverse/Sentinel Adverse/Sentinel Adverse/sentinel events (2–8 months)
Improvement, Events Events Report
and (5)
Administrative QMC Meetings Quality Meeting minutes (12 months)
Operations (12) Management
Committee
Meeting Minutes
Performance Performance Performance Improvement Work Plan with
Improvement Plans Improvement updates (12 months)
(12) Work Plan
Local Governing Local Governing Meeting minutes (12 months)
Body Body Meeting
(12) Minutes
EMRRC EMRRC Meeting minutes (6 months)
(6) Meeting Minutes
Medical Emergency OIG Inspector Most recent full quarter
Response Drills Onsite Review Each watch
(3)
2nd Level Medical OIG Inspector Medical appeals denied (6 months)
Appeals Onsite Review
(10)
Death Reports OIG Inspector Death reports (12 months)
(10) Onsite Review
Local Operating OIG Inspector Review all
Procedures Onsite Review
(all)
California Correctional Institution, Cycle 4 Medical Inspection Page 83
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Job Performance RN Review OIG Inspector Current Supervising RN reviews
and Training, Evaluations Onsite Review
Licensing, and (5)
Certifications Nursing Staff OIG Inspector Review annual competency validations
Validations Onsite Review Randomize
(10)
Provider Annual OIG Inspector All required performance evaluation documents
Evaluation Packets Onsite Review
(all)
Medical Emergency OIG Inspector All staff
Response Onsite Review o Providers (ACLS)
Certifications o Nursing (BLS/CPR)
(all) o Custody (CPR/BLS)
Nursing staff and OIG Inspector All licenses and certifications
Pharmacist-in-charge Onsite Review
Professional Licenses
and Certifications
(all)
Pharmacy and OIG Inspector All current DEA registrations
Providers’ Drug Onsite Review
Enforcement Agency
(DEA) Registrations
(all)
Nursing Staff New OIG Inspector New employees (within the last 12 months)
Employee Onsite Review
Orientations
(all)
California Correctional Institution, Cycle 4 Medical Inspection Page 84
Office of the Inspector General State of California
C C
ALIFORNIA ORRECTIONAL
H C S ’
EALTH ARE ERVICES
R
ESPONSE
California Correctional Institution, Cycle 4 Medical Inspection Page 85
Office of the Inspector General State of California