OIG
Central California Women’s Facility Cycle 6 Medical Inspection Report
Read the report at CDCR ↗
Amarik K. Singh, Inspector General Bryan B. Beyer, Chief Deputy Inspector General
OFFICE of the
OIG
INSPECTOR GENERAL
Independent Prison Oversight January 2022
Cycle 6
Medical Inspection
Report
Central California
Women's Facility
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at 916-255-1131.
Contents
Introduction 1
Summary 3
Overall Rating: Adequate 3
Medical Inspection Results 7
Deficiencies Identified During Case Review 7
Case Review Results 7
Compliance Testing Results 8
Population-Based Metrics 9
HEDIS Results 9
Recommendations 12
Indicators 16
Access to Care 16
Diagnostic Services 23
Emergency Services 27
Health Information Management 32
Health Care Environment 38
Transfers 46
Medication Management 53
Prenatal and Postpartum Care 61
Preventive Services 64
Nursing Performance 67
Provider Performance 73
Reception Center 79
Specialized Medical Housing 83
Specialty Services 88
Administrative Operations 95
Appendix A. Methodology 99
Case Reviews 100
Compliance Testing 103
Indicator Ratings and the Overall Medical Quality Rating 104
Appendix B. Case Review Data 105
Appendix C. Compliance Sampling Methodology 108
California Correctional Health Care Services’ Response 116
Cycle 6, Central California Women’s Facility | iv
Illustrations
Tables
1. Central California Women’s Facility Summary Table 3
2. Central California Women’s Facility Policy Compliance Scores 4
3. Central California Women’s Facility Master Registry Data as of January 2021 5
4. Central California Women’s Facility Health Care Staffing Resources as of January 2021 6
5. Central California Women’s Facility Results Compared with State HEDIS Scores 11
6. Access to Care 20
7. Other Tests Related to Access to Care 21
8. Diagnostic Services 25
9. Health Information Management 35
10. Other Tests Related to Health Information Management 36
11. Health Care Environment 44
12. Transfers 50
13. Other Tests Related to Transfers 51
14. Medication Management 58
15. Other Tests Related to Medication Management 59
16. Prenatal and Postpartum Care 63
17. Preventive Services 65
18. Reception Center 81
19. Other Tests Related to Reception Center 82
20. Specialized Medical Housing 86
21. Specialty Services 92
22. Other Tests Related to Specialty Services 93
23. Administrative Operations 97
A–1. Case Review Definitions 99
B–1. Case Review Sample Sets 105
B–2. Case Review Chronic Care Diagnoses 106
B–3. Case Review Events by Program 107
B–4. Case Review Sample Summary 107
Figures
A–1. Inspection Indicator Review Distribution 99
A–2. Case Review Testing 102
A–3. Compliance Sampling Methodology 103
Photographs
1. A Clinic Outdoor Waiting Area 39
2. A Clinic’s Extra Folding Chairs Used to Practice Social Distancing 39
3. D Clinic Indoor Waiting Area 40
4. Expired Glucose Gel, Dated February 2021 and March 2021 42
Cover: Rod of Asclepius courtesy of Thomas Shafee
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 1
Introduction
Pursuant to California Penal Code section 6126 et seq., the Office of the
Inspector General (the OIG) is responsible for periodically reviewing
and reporting on the delivery of the ongoing medical care provided to
incarcerated persons1 in the California Department of Corrections and
Rehabilitation (the department).2
In Cycle 6, the OIG continues to apply the same assessment
methodologies used in Cycle 5, including clinical case review and
compliance testing. These methods provide an accurate assessment of
how the institution’s health care systems function regarding patients
with the highest medical risk who tend to access services at the highest
rate. This information helps to assess the performance of the institution
in providing sustainable, adequate care.3
We continue to review institutional care using 15 indicators, as in prior
cycles. Using each of these indicators, our compliance inspectors
collect data in answer to compliance- and performance-related
questions as established in the medical inspection tool (MIT).4 We
determine a total compliance score for each applicable indicator and
consider the MIT scores in the overall conclusion of the institution’s
performance. In addition, our clinicians complete document reviews of
individual cases and also perform on-site inspections, which include
interviews with staff.
In reviewing the cases, our clinicians examine whether providers used
sound medical judgment in the course of caring for a patient. In the
event we find errors, we determine whether such errors were clinically
significant or led to a significantly increased risk of harm to the
patient.5 At the same time, our clinicians examine whether the
institution’s medical system mitigated the error. The OIG rates the
indicators as proficient, adequate, or inadequate.
1 In this report, we use the terms patient and patients to refer to incarcerated persons.
2 The OIG’s medical inspections are not designed to resolve questions about the
constitutionality of care, and the OIG explicitly makes no determination regarding the
constitutionality of care the department provides to its population.
3 In addition to our own compliance testing and case reviews, the OIG continues to offer
selected Healthcare Effectiveness Data and Information Set (HEIDIS) measures for
comparison purposes.
4 The department regularly updates its policies. The OIG updates our policy-compliance
testing to reflect the department’s updates and changes.
5 If we learn of a patient needing immediate care, we notify the institution’s chief
executive officer.
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Cycle 6, Central California Women’s Facility | 2
The OIG has adjusted Cycle 6 reporting in two ways. First,
commencing with this reporting period, we interpret compliance and
case review results together, providing a more holistic assessment of
the care; and second, we consider whether institutional medical
processes lead to identifying and correcting provider or system errors.
The review assesses the institution’s medical care on both system and
provider levels.
As we did during Cycle 5, our office is continuing to inspect both those
institutions remaining under federal receivership and those delegated
back to the department. There is no difference in the standards used for
assessing a delegated institution versus an institution not yet delegated.
At the time of the Cycle 6 inspection of Central California Women’s
Facility (CCWF), the receiver had delegated this institution back to
the department.
We completed our sixth inspection of CCWF, and this report presents
our assessment of the health care provided at that institution during the
inspection period between August 2020 to January 2021.6 The data
obtained for CCWF, and the on-site inspections occurred during the
COVID-19 pandemic.7
Central California Women’s Facility is located in Chowchilla, Madera
County. California’s largest female institution, CCWF is the only
female prison designated as a reception center. In addition, the
institution houses the only death row for women in California. The
institution’s medical clinics provide routine health care services.
Patients also receive care at CCWF’s on-site specialty clinic, and there
is a separate clinic for patients in administrative segregation. The
institution’s medical staff screen arriving and departing patients at the
receiving and release clinic (R&R) and also treat patients requiring
urgent or emergent care at the treatment and triage area (TTA).
California Correctional Health Care Services (CCHCS) has designated
CCWF as an intermediate health care institution.
6 Samples are obtained per case review methodology shared with stakeholders in prior
cycles. The case reviews include noncardiopulmonary resuscitation (non-CPR) reviews
between January 2020 and September 2020, death reviews between November 2019 and
September 2020, diabetes reviews between August 2020 and February 2021, perinatal
services reviews between February 2020 and January 2021, high-risk reviews between
August 2020 and February 2021, specialty service reviews between August 2020 and
February 2021, and RN sick call reviews between August 2020 and April 2021.
7 As of October 10, 2021, the department’s public tracker reports 81 percent of CCWF’s
incarcerated population is fully vaccinated, while 62 percent of CCWF’s staff are fully
vaccinated: www.Population COVID-19 Tracking - COVID-19 Information ca.gov.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 3
Summary
We completed the Cycle 6 inspection of Central California
Women’s Facility (CCWF) in May 2021. OIG inspectors
monitored the institution’s medical care that occurred
between August 2020 and January 2021.
The OIG rated the overall quality of health care at CCWF
as adequate. We list the individual indicators and ratings
applicable for this institution in the CCWF Summary
Table below.
Table 1. CCWF Summary Table
Cycle 6 Cycle 6 Cycle 6 Change
Health Care Indicators Case Review Compliance Overall Since
Rating Rating Rating Cycle 5
Access to Care Adequate Adequate Adequate
Diagnostic Services Adequate Adequate Adequate
Emergency Services Inadequate N/A Inadequate
Health Information Management Adequate Proficient Adequate
Health Care Environment N/A Adequate Adequate
Transfers Adequate Inadequate Adequate
Medication Management Inadequate Inadequate Inadequate
Prenatal and Postpartum Care Proficient Proficient Proficient
Preventive Services N/A Adequate Adequate
Nursing Performance Adequate N/A Adequate
Provider Performance Adequate N/A Adequate
Reception Center Adequate Adequate Adequate
Specialized Medical Housing Adequate Adequate Adequate
Specialty Services Adequate Adequate Adequate
Administrative Operations† N/A Inadequate Inadequate
* The symbols in this column correspond to changes that occurred in indicator ratings between the medical
inspections conducted during Cycle 5 and Cycle 6. The equals sign means there was no change in the rating. The
single arrow means the rating rose or fell one level, and the double arrow means the rating rose or fell two levels
(green, from inadequate to proficient; pink, from proficient to inadequate).
† Administrative Operations is a secondary indicator and is not considered when rating the institution’s overall
medical quality.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Central California Women’s Facility | 4
To test the institution’s policy compliance, our compliance inspectors,
(a team of registered nurses) monitored the institution’s compliance
with its medical policies by answering a standardized set of questions
that measure specific elements of health care delivery. Our compliance
inspectors examined 437 patient records and 1,285 data points and used
the data to answer 107 policy questions. In addition, we observed
CCWF processes during an on-site inspection in April 2021. Table 2
below lists CCWF average scores from Cycles 4, 5, and 6.
Table 2. CCWF Policy Compliance Scores
Scoring Ranges
100%–85.0% 84.9%–75.0% 74.9%–0
Medical Cycle 4 Cycle 5 Cycle 6
Inspection Policy Compliance Category Average Average Average
Tool (MIT) Score Score Score
1 Access to Care 66.3% 83.2% 80.5%
2 Diagnostic Services 64.0% 76.7% 75.8%
4 Health Information Management 67.1% 93.0% 89.3%
5 Health Care Environment 84.1% 61.7% 79.6%
6 Transfers 69.0% 75.1% 61.1%
7 Medication Management 61.3% 73.9% 67.8%
8 Prenatal and Postpartum Care 71.4% 83.3% 100%
9 Preventive Services 74.2% 85.2% 76.8%
12 Reception Center 40.7% 72.5% 75.0%
13 Specialized Medical Housing 98.0% 95.0% 77.5%
14 Specialty Services 69.5% 89.6% 75.9%
15 Administrative Operations 69.0%* 81.4% 71.2%
* In Cycle 4, there were two secondary (administrative) indicators, and this score reflects the average of
those two scores. In Cycle 5 and moving forward, the two indicators were merged into one, with only one
score as the result.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Central California Women’s Facility | 5
The OIG clinicians (a team of physicians and nurse consultants)
reviewed 48 cases, which contained 1,617 patient-related events. After
examining the medical records, our clinicians conducted a follow-up
on-site inspection to verify their initial findings. The OIG physicians
rated the quality of care for 26 comprehensive case reviews. Of these
26 cases, our physicians rated 23 adequate and three inadequate. Our
physicians did not identify any adverse events during this inspection.
The OIG then considered the results from both case review and
compliance testing, and drew overall conclusions, which we report in
the 15 health care indicators. Multiple OIG physicians and nurses
performed quality control reviews; their subsequent collective
deliberations ensured consistency, accuracy, and thoroughness. Our
clinicians acknowledged institutional structures that catch and resolve
mistakes that may occur throughout the delivery of care. As noted
above, we listed the individual indicators and ratings applicable for this
institution in Table 1, the CCWF Summary Table.
In March 2021, the Health Care Services Master Registry showed that
CCWF had a total population of 2,132. A breakdown of the medical risk
level of the CCWF population as determined by the department is set
forth in Table 3 below.8
Table 3. CCWF Master Registry Data as of March 2021
Medical Risk Level Number of Patients Percentage
High 1 149 7.0%
High 2 188 8.8%
Medium 1,142 53.6%
Low 653 30.6%
Total 2,132 100.0%
Source: Data for the population medical risk level were obtained
from the CCHCS Master Registry dated 3-19-21.
8 For a definition of medical risk, see CCHCS HCDOM 1.2.14, Appendix 1.9.
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Based on staffing data the OIG obtained from California Correctional
Health Care Services (CCHCS), as identified in Table 4 below, CCWF
had one executive leadership position vacancy, zero primary care
provider vacancies, 1.2 nursing supervisor vacancies, and 20 nursing
staff vacancies.
Table 4. CCWF Health Care Staffing Resources as of March 2021
Executive Primary Care Nursing Nursing
Positions Leadership* Providers Supervisors Staff† Total
Authorized Positions 5 11.5 15.2 125.8 157.5
Filled by Civil Service 4 13.5 14 95.4 126.9
Vacant 1 0 1.2 20 22.2
Percentage Filled by Civil Service 80% 117.4% 92.1% 75.8% 80.6%
Filled by Telemedicine 0 0 0 0 0
Percentage Filled by Telemedicine 0 0 0 0 0
Filled by Registry 0 1 0 14 15
Percentage Filled by Registry 0 8.7% 0 11.1% 9.5%
Total Filled Positions 4 14.5 14 109.4 141.9
Total Percentage Filled 80.0% 126.1% 92.1% 87.0% 90.1%
Appointments in Last 12 Months 1 3 6 36 46
Redirected Staff 0 0 0 0 0
Staff on Extended Leave‡ 0 0 1 9 10
Adjusted Total: Filled Positions 4 14.5 13 100.4 131.9
Adjusted Total: Percentage Filled 80.0% 126.1% 85.5% 79.8% 83.7%
* Executive Leadership includes the Chief Physician and Surgeon.
† Nursing Staff includes Senior Psychiatric Technician and Psychiatric Technician.
‡ In Authorized Positions.
Notes: The OIG does not independently validate staffing data received from the department. Positions are based
on fractional time-base equivalents.
Source: Cycle 6 medical inspection preinspection questionnaire received March 2021, from California Correctional
Health Care Services.
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Medical Inspection Results
Deficiencies Identified During Case Review
Deficiencies are medical errors that increase the risk of patient harm.
Deficiencies can be minor or significant, depending on the severity of
the deficiency.
An adverse event occurs when the deficiency caused harm to the patient.
All major health care organizations identify and track adverse events.
We identify deficiencies and adverse events to highlight concerns
regarding the provision of care and for the benefit of the institution’s
quality improvement program to provide an impetus for improvement.9
Our inspectors did not find any adverse events at CCWF in the cases
reviewed during the Cycle 6 inspection.
Case Review Results
OIG case reviewers assessed 12 of the 15 indicators applicable to
CCWF. Of these 12 indicators, OIG clinicians rated one proficient, nine
adequate, and two inadequate. The OIG physicians also rated the overall
adequacy of care for each of the 26 detailed case reviews they
conducted. Of these 26 cases, 23 were adequate and three were
inadequate. In the 1,617 events reviewed, there were 388 deficiencies,
77 of which the OIG clinicians considered to be of such magnitude that,
if left unaddressed, would likely contribute to patient harm.
Our clinicians found the following strengths at CCWF:
•
Medical leadership was well respected by staff. Despite
COVID-19 restrictions, leadership, providers, and nursing staff
were dedicated to patient care. Providers and nurses continued
to see patients and utilized creative solutions to provide care to
the patient population, such as telemedicine evaluations
through laptops.
•
Nursing leadership was instrumental in ensuring staff received
regular updates on the rapidly changing COVID-19 guidelines.
Supervising registered nurses (SRN II’s) used a hands-on
approach and assumed staff duties in emergency situations,
when needed.
•
The institution held population management meetings which
included all members of the patient care team. Patient care
teams were very knowledgeable about their patients,
9 For a further discussion of an adverse event, see Table A-1.
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collaborated to provide care to even the most difficult patients,
and documented progress notes for morning huddles.
Our clinicians found the following weakness at CCWF:
•
Although the institution focused efforts on high-risk yards and
kept those backlogs low, CCWF still had a problematic number
of patient backlogs.
•
During emergency situations, TTA nurses struggled with
critical decision making, timely evaluations for patients, and
delayed notification to providers of abnormal findings. Also,
there were notable problems with medical reconciliation for
patients returning from the hospital.
•
Although most providers made clear and reasonable medical
decisions, some providers made questionable decisions. We
noted an improvement in provider decision-making compared
with Cycle 5.
Compliance Testing Results
Our compliance inspectors assessed 12 of the 15 indicators applicable
to CCWF. Of these 12 indicators, our compliance inspectors rated two
proficient, seven adequate, and three inadequate. We tested only policy
compliance in the Health Care Environment, Preventative Services, and
Administrative Operations indicators, as these do not have a case
review component.
CCWF demonstrated a high rate of policy compliance in the
following areas:
•
Pregnant patients had timely provider visits, and nursing staff
documented vital information. The institution offered lower-
tier housing and lower-bunk accommodations and provided
prenatal screening tests to pregnant patients.
•
Medical staff timely scanned initial health care screening
forms, community hospital discharge reports, and requests for
health care services into patients’ electronic medical records.
•
Nursing staff reviewed health care services request forms and
performed face-to-face encounters timely.
•
CCWF provided timely appointments for patients returning
from hospital admission and specialty services.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
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CCWF demonstrated a low rate of policy compliance in the following areas:
•
Patients did not always receive their chronic-care medications
within the required time frames. Medication continuity was
poor for patients returning from hospitalizations, admitted to
specialized medical housing, arriving from non-CDCR
facilities, and transferring within CCWF.
•
The institution performed poorly in completing the emergency
medical response event checklist. Also, medical staff did not
submit initial inmate death reports to CCHCS per policy
requirements.
•
Medication nurses did not follow universal hand hygiene
precautions when administering medication.
Population-Based Metrics
In addition to our own compliance testing and case reviews, as noted
above, the OIG presents selected measures from the Healthcare
Effectiveness Data and Information Set (HEDIS) for comparison
purposes. The HEDIS is a set of standardized quantitative performance
measures designed by the National Committee for Quality Assurance to
ensure that the public has the data it needs to compare the performance
of health care plans. Because the Veterans Administration no longer
publishes its individual HEDIS scores, we removed them from our
comparison for Cycle 6. Likewise, Kaiser (commercial plan) no longer
publishes HEDIS scores. However, through the California Department
of Health Care Services’ Medi-Cal Managed Care Technical Report, the
OIG obtained Kaiser Medi-Cal HEDIS scores for three of five diabetic
measures to use in conducting our analysis, and we present them here
for comparison.
HEDIS Results
We considered CCWF’s performance with population-based metrics to
assess the macroscopic view of the institution’s health care delivery.
CCWF’s results compared favorably with those found in State health
plans for diabetic care measures. We list the eleven HEDIS measures in
Table 5.
Comprehensive Diabetes Care
When compared with statewide Medi-Cal programs—California
Medi-Cal, Kaiser Northern California (Medi-Cal), and Kaiser Southern
California (Medi-Cal)—CCWF performed better in two of the three
diabetic measures that have statewide comparative data, poor HbA1c
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 10
control and blood pressure control. Kaiser NorCal and Kaiser SoCal
outperformed CCWF in HbA1c screening.
Immunizations
Statewide comparative data were also not available for immunization
measures; however, we include this data for informational purposes.
CCWF had a 71 percent influenza immunization rate for adults 18 to
64 years old and a 73 percent influenza immunization rate for adults
65 years of age and older.10 The pneumococcal vaccine rate was
90 percent.11
Cancer Screening
When compared with statewide Medi-Cal programs ( California
Medi-Cal, Kaiser Northern California (Medi-Cal), and Kaiser Southern
California (Medi-Cal), CCWF performed better in one of the two cancer
screening measures that have statewide comparative data: breast cancer
screening. Kaiser NorCal and Kaiser SoCal outperformed CCWF in
cervical cancer screening.
Statewide comparative data were not available for colorectal cancer
screening; however, we include these data for informational purposes.
CCWF had an 82 percent colorectal cancer screening rate.
10 The HEDIS sampling methodology requires a minimum sample of 10 patients to have a
reportable result. The sample for older adults did not include a full sample.
11 The pneumococcal vaccines administered are the 13 valent pneumococcal vaccine
(PCV13) or 23 valent pneumococcal vaccine (PPSV23), depending on the patient’s medical
conditions. For the adult population, the influenza or pneumococcal vaccine may have been
administered at a different institution other than the one in which the patient was currently
housed during the inspection period.
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Table 5. CCWF Results Compared with State HEDIS Scores
California California
CCWF
Kaiser Kaiser
California NorCal SoCal
Cycle 6 Medi-Cal Medi-Cal Medi-Cal
HEDIS Measure Results* 2018† 2018† 2018†
HbA1c Screening 86% 90% 94% 96%
Poor HbA1c Control (> 9.0%) ‡, § 5% 34% 25% 18%
HbA1c Control (< 8.0%) ‡ 86% – – –
Blood Pressure Control (< 140/90) ‡ 89% 65% 78% 84%
Eye Examinations 14% – – –
Influenza – Adults (18–64) 71% – – –
Influenza – Adults (65+) 73% – – –
Pneumococcal – Adults (65+) 90% – – –
Breast Cancer Screening (50–74) 85% 62% 82% 84%
Cervical Cancer Screening 76% 65% 87% 83%
Prenatal Care|| N/A 91% 96% 92%
Postpartum Care|| N/A 78% 82% 81%
Colorectal Cancer Screening 82% – – –
Notes and Sources
* Unless otherwise stated, data were collected in February 2021 by reviewing medical records from a sample of CCWF’s
population of applicable patients. These random statistical sample sizes were based on a 95 percent confidence level with
a 15 percent maximum margin of error.
†
HEDIS Medi-Cal data were obtained from the California Department of Health Care Services publication titled, Medi-Cal
Managed Care External Quality Review Technical Report, dated July 1, 2019–June 30, 2020 (published April 2021).
www.dhcs.ca.gov/documents/MCQMD/CA2019-20-EQR-Technical-Report-Vol3-F2.pdf.
‡
For this indicator, the entire applicable CCWF population was tested.
§
For this measure only, a lower score is better.
|| For this indicator CCWF had a nontestable sample size as only three patients transferred to the institution
requiring prenatal services, and only one patient delivered at CCWF during the 12-month test period.
Source: Institution information provided by the California Department of Corrections and Rehabilitation. Health care plan data
were obtained from the CCHCS Master Registry.
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Recommendations
As a result of our assessment of CCWF’s performance, we offer the
following recommendations to the department:
Access to Care
•
CCHCS leadership should implement policies to address
patient complaints within appropriate time frames in the
skilled nursing facilities and other specialized medical
housing units.
•
Medical leadership should ensure that if hospital or specialty
follow-up visits occur outside of regular clinic hours, that
ordering all follow-up visits and diagnostic studies is completed
upon return to the institution. This places the patient at risk of
loss to follow-up.
•
Medical leadership should ensure that patients with chronic
care follow-up appointments, nurse-to-provider referrals, and
subsequent specialty follow-up appointments are
timely received.
Diagnostic Services
•
Medical leadership should consider establishing a policy to
ensure patients in the Custody Community Transitional
Reentry Program (CCTRP) who return to the institution receive
routine standardized intake laboratory testing similar to
patients in the Reception Center.
•
Medical and nursing leadership should ensure providers
endorse stat laboratory results and nursing staff notify
providers within the required time frames.
Emergency Services
•
Medical and nursing leadership should consider incorporating
into the Emergency Medical Response Review Committee
(EMMRC) periodic reviews of medical emergencies which do
not require transfer to higher level of care.
•
Nursing leadership should ensure nurses notify the provider of
abnormal clinical findings in a timely manner.
•
Nursing leadership should provide refresher training on
completing reassessments for patients with urgent symptoms
in the TTA.
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Health Information Management
•
Medical leadership should determine the cause of untimely
retrieval of specialty reports and implement remedial measures
as appropriate.
•
The department should consider adjusting the menu on the
results letter in the electronic health records system (EHRS) to
default to patient letter instead of Developmental Disability
Program (DDP)-Scan letter and train providers to generate
letters appropriately.
•
Medical leadership should ensure providers relay pathology
results to patients timely.
•
The department should consider developing and implementing
a template that auto populates with all elements required per
CCHCS policy for patient results letters.
Health Care Environment
•
Executive leadership should consider performing random spot
checks to ensure medical supply storage areas located outside
the clinics store medical supplies adequately.
•
Nursing leadership should consider performing random spot
checks to ensure clinics meet the requirements for essential
core medical equipment and supplies.
•
Nursing leadership should direct each clinic nurse supervisor
to review the monthly emergency medical response bag (EMRB)
logs to ensure EMRBs are regularly inventoried including a
daily quality control of the glucometers.
Transfers
•
Nursing leadership should consider reminding nursing staff to
fully document tuberculosis (TB) symptoms as part of the
patient’s initial health assessment.
•
Medical and nursing leadership should ensure hospital
discharge and intra-facility transfer medications are reconciled,
ordered, and administered timely without interruption.
•
Medical and nursing leadership should consider establishing a
policy to require medication reconciliation prior to the next
scheduled medical administration.
•
The department should consider developing and implementing
an electronic alert to ensure nurses in the receiving and release
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Cycle 6, Central California Women’s Facility | 14
clinic (R&R) properly complete initial screening questions and
follow up as needed.
Medication Management
•
Medical and nursing leadership should identify the causes of
the challenges to medication continuity for chronic care,
hospital discharge, and specialized medical housing patients
and implement remedial measures as appropriate.
•
Medical and nursing leadership should ensure hospital
discharge, reception center transfers, intra-facility transfers,
chronic care, and newly ordered medications are timely
ordered, made available, and administered to the patients
without interruptions.
•
Nursing leadership should consider reminding nursing staff to
document patient refusals in medical administration records, as
described in the CCHCS policy and procedures.
Preventive Services
•
Nursing leadership and the public health nurse should educate
nursing staff to fully document TB symptoms as part of the
patient’s TB medication monitoring.
•
Nursing leadership and the public health nurse should educate
nursing staff in timely and accurate monitoring of patient’s
annual TB screening per CCHCS policy.
Nursing Performance
•
Nursing leadership should consider refresher training for
providers on the requirement that all transitional care unit
admissions have a detailed plan of care with measurable
objectives.
•
Nursing leadership shoulder remind certified nursing assistants
to report abnormal vital signs to a registered nurse or provider.
Provider Performance
•
Medical leadership should consider specific training on
improved documentation and monitored medical decision
making for providers who have the most deficiencies in our
case reviews.
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Reception Center
•
The department should consider developing and implementing
an electronic alert to ensure nurses in the R&R clinic complete
initial health screening questions and follow up with patients
as needed.
Specialized Medical Housing
•
Nursing leadership should ensure nurses in the skilled nursing
facility (SNF) thoroughly assess patients and document the
assessments along with wound care.
•
Nursing leadership should ensure nurses initiate care plans and
reassess patients at regular intervals.
Specialty Services
•
Medical leadership should ensure providers follow specialty
recommendations and, if not, that providers document
medical reasoning.
•
Medical leadership should ensure patients receive their ordered
follow-up specialty appointment services timely.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 16
Access to Care
In this indicator, OIG inspectors evaluated the institution’s ability to
provide patients with timely clinical appointments. Our inspectors Overall
reviewed the scheduling and appointment timeliness for newly arrived Rating
Adequate
patients, sick calls, and nurse follow-up appointments. We examined
referrals to primary care providers, provider follow-ups, and specialists. Case Review
Furthermore, we evaluated the follow-up appointments for patients Rating
who received specialty care or returned from an off-site hospitalization. Adequate
Compliance
Results Overview
Score
Adequate
Compared with Cycle 5, CCWF improved overall and provided good
(80.5%)
access to care. Compliance testing found the institution’s nursing
performed exceptionally well in responding timely to requests for
services. Providers performed well in following up with patients after
hospital discharge and specialty service appointments, but performed
poorly in seeing nursing referrals and intra-facility transfer patients
within required time frames. Also, chronic care appointments did not
occur timely; however, this was mitigated by provider chart reviews in
lieu of face-to-face visits. After reviewing all aspects of access to care,
the OIG rated this indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 280 provider, nursing, specialty, and hospital
events that required the institution to generate appointments. We
identified 18 deficiencies relating to access to care, eight of which
were significant.12
Access to Clinic Providers
Compliance testing found chronic care face-to-face follow-up
appointments occurred 52.0 percent of the time; however, this was
mitigated by chart reviews performed in lieu of face-to face visits
(MIT 1.001). Although the compliance score was low, we interpret
overall care as being acceptable because those patients who needed to
be seen, in fact, were evaluated by the provider. Due to movement
restrictions related to the COVID-19 pandemic, we considered most
cases of provider chart reviews as triage of nonurgent, low- or medium-
risk chronic care appointments as an acceptable alternative to face-to-
face or telephonic visits.
12 Deficiencies were found in cases 1, 2, 6, 8, 10, 17, 18, 34, 38, 44, 46, 49, 51, 52, and 54.
Significant deficiencies occurred in cases 2, 10, 17, 44, and 52.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 17
Compliance testing also found providers saw patients referred by a
nurse 55.6 percent of the time (MIT 1.005). Out of 30 samples, nine
required a provider follow-up appointment, and only five of the nine
were completed timely.
Providers saw patients referred by their primary care provider for
follow-up sick call appointments 100 percent of the time; however, the
sample size was only two (MIT 1.006). OIG clinicians reviewed
127 outpatient provider encounters and found provider visits usually
occurred within required time frames; however, eight deficiencies were
identified, two of which were significant:13
• In case 2, the patient was scheduled at the same time for a
dialysis appointment and a provider appointment, so the
patient was not able to see the provider.
• In case 44, the patient reported not having a menstrual cycle
and was scheduled for a provider appointment; however, the
provider saw her 36 days late.
Access to Specialized Medical Housing Providers
CCWF performed poorly on completing admission history and
physicals. Compliance testing revealed only 70.0 percent of patients in
the SNF had admission history and physicals performed timely
(MIT 13.002).
Access to Clinic Nurses
CCWF provided adequate access to clinic nurses. Compliance testing
found that same day triage appointments and RN clinic appointments
were timely (MIT 1.003, 76.7% and MIT 1.004, 86.7%). Our case reviews
found similar results; only three deficiencies were noted, one of which
was significant.14
Access to Specialty Services
CCWF performed well in obtaining initial specialty care for their
patients; however, the institution could improve in providing high-
priority specialty follow-up appointments. Compliance testing found
patients saw specialists within required time frames for high-priority
referrals 100 percent of the time, medium-priority referrals 86.7 percent
of the time, and routine-priority referrals 80.0 percent of the time
13 Deficiencies occurred in cases 2, 8, 18, 44, 46, 49, 51 and 54. Significant deficiencies
occurred in cases 2 and 44.
14 Deficiencies occurred in cases 46 and 49. The significant deficiency occurred in case 2.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 18
(MIT 14.001, MIT14.004, and MIT 14.007).OIG clinicians noted similar
findings, identifying only one minor deficiency in case 38.
The institution ensured follow-up specialty appointments for medium-
priority specialty visits occurred timely (MIT 14.006, 100%); however,
medium-priority and high-priority follow-up specialty appointments
had room for improvement (MIT 14.009, 71.4% and MIT 14.003, 50.0%).
OIG case reviewers found three deficiencies related to delayed specialty
follow-up appointments and all were considered significant:
•
In case 17, the patient had a broken hearing aid; however, the
patient’s follow-up audiology appointment occurred
176 days late.
•
Also in case 17, the patient required an ophthalmology
follow- up appointment for glaucoma, a condition that can
threaten vision. The specialist recommended the patient
receive a glaucoma follow-up appointment in one to two
months; however, the appointment only occurred over a year
after the referral.
•
In case 34, the provider ordered a cardiology follow-up
appointment for a patient in August 2020. At the time of our
onsite inspection, the appointment had not occurred.
Follow-Up After Specialty Service
CCHCS specialty follow-up policy has changed since our Cycle 5
inspection and now states that providers are only required to perform
face-to face appointments for patients with urgent priority referrals.
Providers may see patients after specialty medium- and routine-priority
appointments at the provider’s discretion. As in Cycle 5, CCWF
providers generally saw patients after specialty visits within ordered
time frames (MIT, 1.008, 90.5%). This is consistent with the OIG
clinician findings.
Follow-Up After Hospitalization
The institution generally ensured providers followed up with patients
returning from an outside hospital. Compliance testing found most
discharged patients had a punctual follow-up appointment with their
providers (MIT 1.007, 94.1%). Our case review findings were consistent
with the compliance review; however, our clinicians noted a pattern of
poor quality provider follow up when appointments occurred. These
deficiencies occurred in case 10, with one provider:
•
In case 10, a high-risk patient returned from a hospital visit
for chest pain and elevated blood pressure with a
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 19
recommendation for further outpatient testing with a heart
specialist. The provider saw the patient upon return from the
hospital and deferred the specialty referral to the patient’s
next appointment. However, the appointment did not occur
and the orders were not placed.
Follow-Up After Urgent or Emergent Care (TTA)
Our clinicians found provider follow up usually occurred after urgent or
emergent care and identified only one deficiency which was significant:
•
In case 52, the TTA provider ordered 24-hour follow up for
the patient after a visit for an ear procedure. The follow up
did not occur for 12 days.
Follow-Up After Transferring into the Institution
Providers performed well in completing history and physicals within
seven days of arrival (MIT 12.004, 100%), however, performed poorly in
patient follow up after the patient transferred into the institution. The
compliance score for the initial health screening by a clinician was
69.2 percent (MIT 1.002). OIG clinicians found no deficiencies in
provider appointment access for patients transferring into
the institution.
Clinician On-Site Inspection
The OIG clinicians met with medical leadership, scheduling
management, and staff during our on-site inspection. We found that
specialty services and scheduling were fully staffed during the review
period. Due to the COVID-19 pandemic, providers worked both
remotely and on-site during our review period and were available for
appointments. For 7,362 nursing referrals for providers, the backlog was
854 referrals and was between three to 172 days late, primarily for low-
risk yards. The RN clinic visit backlog was 81 patients, also with most
on low-risk yards. Specialty services had a backlog of 461 visits,
primarily from optometry, physical therapy, ophthalmology, and
general surgery. The facility advised these were difficult to obtain
services for during the COVID-19 pandemic.
Medical leadership said they spoke with the CCHCS headquarters
management regarding the ambiguity in the COVID-19 policy on how
to close, in the EHRS, outpatient provider appointments that were not
seen. They were advised to mark as cancelled, not completed, visits that
were not seen face-to-face or had a phone consultation. This is an
accurate representation of what patient care occurred.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 20
Compliance Testing Results
Table 6. Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
Chronic care follow-up appointments: Was the patient’s most recent
chronic care visit within the health care guideline’s maximum
13 12 0 52.0%
allowable interval or within the ordered time frame, whichever is
shorter? (1.001) *
For endorsed patients received from another CDCR institution: Based
on the patient’s clinical risk level during the initial health screening,
9 4 0 69.2%
was the patient seen by the clinician within the required time frame?
(1.002) *
Clinical appointments: Did a registered nurse review the patient’s
23 7 0 76.7%
request for service the same day it was received? (1.003) *
Clinical appointments: Did the registered nurse complete a face-to-
face visit within one business day after the CDCR Form 7362 was 26 4 0 86.7%
reviewed? (1.004) *
Clinical appointments: If the registered nurse determined a referral to
a primary care provider was necessary, was the patient seen within the
5 4 21 55.6%
maximum allowable time or the ordered time frame, whichever is the
shorter? (1.005) *
Sick call follow-up appointments: If the primary care provider ordered
a follow-up sick call appointment, did it take place within the time 2 0 28 100%
frame specified? (1.006) *
Upon the patient’s discharge from the community hospital: Did the
patient receive a follow-up appointment within the required time 16 1 0 94.1%
frame? (1.007) *
Specialty service follow-up appointments: Did the clinician follow-up
visits occur within required time frames? (1.008) * , † 38 4 3 90.5%
Clinical appointments: Do patients have a standardized process to
6 0 0 100%
obtain and submit health care services request forms? (1.101)
Overall percentage (MIT 1): 80.5%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care
physician follow-up visits following specialty services. As a result, we tested MIT 1.008 only for high-
priority specialty services or when staff ordered follow-ups. The OIG continued to test the clinical
appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Central California Women’s Facility | 21
Table 7. Other Tests Related to Access to Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the 1 0 19 100%
required time frame? (12.003) *
For patients received from a county jail: Did the patient receive a
history and physical by a primary care provider within seven calendar 20 0 0 100%
days? (12.004) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time 7 3 0 70.0%
frame? (13.002) *
For OHU, CTC, SNF, and Hospice (applicable only for samples prior to
4/2019): Did the primary care provider complete the Subjective, Objective,
N/A N/A N/A N/A
Assessment, and Plan notes on the patient at the minimum intervals
required for the type of facility where the patient was treated?
(13.003) *
Did the patient receive the high-priority specialty service within?
14 calendar days of the primary care provider order or the Physician 15 0 0 100%
Request for Service? (14.001) *
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care provider? 4 4 7 50.0%
(14.003) *
Did the patient receive the medium-priority specialty service within
15–45 calendar days of the primary care provider order or the Physician 13 2 0 86.7%
Request for Service? (14.004) *
Did the patient receive the subsequent follow-up to the medium-
priority specialty service appointment as ordered by the primary care 6 0 9 100%
provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 12 3 0 80.0%
Request for Service? (14.007) *
Did the patient receive the subsequent follow-up to the routine-priority
specialty service appointment as ordered by the primary care provider? 5 2 8 71.4%
(14.009) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still had
State-mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of
provider follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Central California Women’s Facility | 22
Recommendations
•
CCHCS leadership should implement policies to address
patient complaints within appropriate time frames in the
skilled nursing facilities and other specialized medical
housing units.
•
Medical leadership should ensure that if hospital or specialty
follow-up visits occur outside of regular clinic hours, that
ordering all follow-up visits and diagnostic studies is completed
upon return to the institution. This places the patient at risk of
loss to follow-up.
•
Medical leadership should ensure that patients with chronic
care follow-up appointments, nurse-to-provider referrals, and
subsequent specialty follow-up appointments are
timely received.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 23
Diagnostic Services
In this indicator, OIG inspectors evaluated the institution’s ability to
timely complete radiology, laboratory, and pathology tests. Our Overall
inspectors determined whether the institution properly retrieved the Rating
resultant reports and whether providers reviewed the results correctly. Adequate
In addition, in Cycle 6, we examined the institution’s ability to timely
Case Review
complete and review immediate (stat) laboratory tests. Rating
Adequate
Results Overview
Compliance
Score
As in Cycle 5, CCWF had excellent performance in completing and
Adequate
retrieving diagnostic tests and usually retrieved and endorsed
(75.8%)
laboratory, radiology, and pathology results timely. However, pathology
reports were often not relayed to the patients. Overall, the OIG rated
this indicator adequate.
Case Review and Compliance Testing Results
We reviewed 381 diagnostic events and found 72 deficiencies, of which
only four were significant.15 Sixty deficiencies were related to health
information management, 10 were related to provider care, one
pertained to nursing, and one pertained to the completion of
diagnostic tests.
For health information management, we considered test reports that
were never retrieved or reviewed as severe a problem as tests that were
not performed.
Test Completion
CCWF performed well in timely radiology and laboratory test
completion (MIT 2.001, 100% and MIT 2.004, 80.0%). Compliance
testing found 80.0 percent of stat laboratory tests were collected as
ordered (MIT 2.007). The OIG clinicians found no issues with stat labs
and identified only one minor deficiency in test completion.
Although routine testing is usually required for new patients in the
reception center, our clinicians noted that returning patients in the
Custody Community Transitional Reentry Program (CCTRP) do not
receive routine intake laboratory tests that are normally ordered for
reception center patients.
15 Deficiencies occurred in cases 1, 3- 15, 17, 32, 33, 34, 36-38, and 39. Significant
deficiencies occurred in cases 1, 14, and 36.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 24
Health Information Management
Compliance testing found radiology and laboratory reports were usually
received and endorsed timely (MIT 2.002, 100% and MIT 2.005, 90.0%).
Pathology reports were received and endorsed timely 80.0 percent of the
time (MIT 2.011), but pathology results were often not relayed to the
patients (MIT 2.012, 40.0%). Compliance testing found STAT labs were
always endorsed by the provider timely (MIT 2.009, 100%). Our case
reviewers found no deficiencies in STAT or pathology reports.
The OIG case reviewers found 60 deficiencies in diagnostic services
related to health information management. Most were minor
deficiencies related to missing test dates and whether patient results
letters showed normal results. Thirteen of the deficiencies were due to
mislabeled, misfiled, or duplicate medical documents and not
retrieving or endorsing medical documents.16 Only three deficiencies
were significant:
•
In case 14, a urine culture result was not retrieved or scanned
into the patient’s electronic medical record.
•
In case 38, a provider endorsed an imaging study to evaluate
for metastatic cancer almost three months late.
•
In case 36, the patient had an important body scanning study
performed; however, the result was not scanned into the
patient’s electronic medical record.
We also noted a pattern of providers not endorsing urine dip results.17
Clinician On-Site Inspection
Our case review team met with laboratory and radiology supervisors
and staff during the on-site inspection. The facility performed most
laboratory and radiology tests timely, despite the significant increase in
workload from the COVID-19 pandemic.
According to CCWF medical leadership, CCHCS policy does not
consider CCTRP patients new intakes, even though these patients can
spend an extended amount of time in the community, are at risk of
contracting diseases such as HIV, Hepatitis C, gonorrhea, and
chlamydia, and can transmit these diseases to other inmates. Medical
leadership advised they would consider applying new intake testing to
these inmates if they return from the community.
16 Deficiencies were noted in cases 3, 7, 9, 11, 33, 36, 38, and 39.
17 Urine dip results were not endorsed in cases 3, 10, and 14.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 25
Compliance Testing Results
Table 8. Diagnostic Services
Scored Answer
Comp liance Questions Yes No N/A Yes %
Radiology: Was the radiology service provided within the time frame
10 0 0 100%
specified in the health care provider’s order? (2.001) *
Radiology: Did the ordering health care provider review and endorse
10 0 0 100%
the radiology report within specified time frames? (2.002) *
Radiology: Did the ordering health care provider communicate the
results of the radiology study to the patient within specified time 6 4 0 60.0%
frames? (2.003)
Laboratory: Was the laboratory service provided within the time frame
8 2 0 80.0%
specified in the health care provider’s order? (2.004) *
Laboratory: Did the health care provider review and endorse the
9 1 0 90.0%
laboratory report within specified time frames? (2.005) *
Laboratory: Did the health care provider communicate the results of
3 7 0 30.0%
the laboratory test to the patient within specified time frames? (2.006)
Laboratory: Did the institution collect the STAT laboratory test and
8 2 0 80.0%
receive the results within the required time frames? (2.007) *
Laboratory: Did the provider acknowledge the STAT results, OR did
nursing staff notify the provider within the required time frames (2.008) 6 4 0 60.0%
*
Laboratory: Did the health care provider endorse the STAT laboratory
10 0 0 100%
results within the required time frames? (2.009)
Pathology: Did the institution receive the final pathology report within
9 1 0 90.0%
the required time frames? (2.010) *
Pathology: Did the health care provider review and endorse the
8 2 0 80.0%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results of
the pathology study to the patient within specified time frames? 4 6 0 40.0%
(2.012)
Overall percentage (MIT 2): 75.8%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 26
Recommendations
•
Medical leadership should consider establishing a policy to
ensure patients in the Custody Community Transitional
Reentry Program (CCTRP) who return to the institution receive
routine standardized intake laboratory testing similar to
patients in the Reception Center.
•
Medical and nursing leadership should ensure providers
endorse stat laboratory results and nursing staff notify
providers within the required time frames.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 27
Emergency Services
In this indicator, OIG clinicians evaluated the quality of emergency
medical care. Our clinicians reviewed emergency medical services by Overall
examining the timeliness and appropriateness of clinical decisions Rating
Inadequate
made during medical emergencies. Our evaluation included examining
the emergency medical response, cardiopulmonary resuscitation (CPR)
Case Review
quality, triage and treatment area (TTA) care, provider performance,
Rating
and nursing performance. Our clinicians also evaluated the Emergency Inadequate
Medical Response Review Committee’s (EMRRC) ability to identify
Compliance
problems with its emergency services. The OIG assessed the
Score
institution’s emergency services through case review only; we did not
(N/A)
perform compliance testing for this indicator.
Results Overview
CCWF performed poorly in emergency care. Similar to Cycle 5, CCWF
nurses continued to perform incomplete nursing reassessments,
frequently failed to elevate symptomatic patients with significantly
abnormal vital signs to providers, and delayed interventions ordered by
providers. However, providers generally made appropriate clinical
decisions. The institution showed significant improvement in
documenting the first medical responder form and identifying training
deficiencies in EMRRC. Overall, the OIG rated this
indicator inadequate.
Case Review Results
We reviewed 76 urgent and emergent events and identified
52 emergency care deficiencies, 17 of which were significant.18
Emergency Medical Response
CCWF staff responded promptly to emergencies throughout the
institution. They initiated cardiopulmonary resuscitation (CPR),
activated emergency medical services (EMS), and notified TTA staff in a
timely manner.
Provider Performance
CCWF providers performed adequately in urgent and emergent
situations, and after-hours care. In most cases, the providers were
available to respond to emergencies, demonstrated good medical
judgement, and documented appropriately.
18 Significant deficiencies occurred in cases 1, 2, 9, 10, 33, and 34.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 28
Of the 49 deficiencies identified in emergency care, seven were related
to provider performance, of which three were significant. Two of the
three significant deficiencies are discussed below:19
•
In case 10, the patient with high cardiac risk was sent to the
TTA for chest pain and extremely elevated blood pressure.
The provider delayed sending the patient to a higher level of
care for nearly 45 minutes.
•
Also in case 10, the patient again presented to the TTA with
extremely elevated blood pressure, chest pain, and nausea
with vomiting. The provider waited four hours to order blood
pressure treatment, did not order an electrocardiogram (EKG)
to evaluate whether symptoms were heart related, and did
not write an on-call note to justify medical reasoning.
Nursing Performance
CCWF nurses had prompt responses, but did not perform well in
emergency events. Similar to Cycle 5, TTA nurses continued to have
incomplete nursing assessments and failed to notify providers when
patients warranted further evaluation and treatment. In addition, the
TTA nurses did not transport some patients with acute and urgent
symptoms to TTA for continued observation and treatment. The nurses’
failure to observe patients in TTA led to a delay in medically necessary
treatment for high-risk patients with acute conditions.
The following cases illustrate nurses responding timely to patient
symptoms, yet not performing appropriate interventions.
•
In case 1, the high-risk patient with multiple chronic
conditions complained of abdominal pain. The patient was
seen two days earlier for nausea, vomiting, and jaundice.20
The TTA nurse responded to the housing unit and advised
the patient to submit a sick call request for additional
symptoms, but did not intervene appropriately by
transporting the patient to the TTA for further assessment.
Subsequently, the patient sought urgent medical care for
similar symptoms, and was transported to higher level of care
at a community hospital where she was diagnosed with
pancreatic cancer.
•
In case 34, the patient complained of chest pain and had
cardiac risk factors of hypertension, hyperlipidemia, and oral
19 Two minor deficiencies occurred in separate events on case 34 and once in case 1. Two
significant deficiencies were identified in case 10.
20 Jaundice is yellowish discoloration of the skin, which is a sign indicating possible
liver disease.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 29
contraceptives. The patient was released to housing instead
of being transported to the TTA to perform an EKG and
notify the provider.
In the following cases, CCWF nurses performed incomplete
assessments for patients evaluated for urgent symptoms:
•
In case 1, the patient was under observation in TTA for
abdominal pain with nausea and vomiting. The TTA nurses
received orders to transport the patient to higher level of care
via state car. However, the nurses did not reassess the patient
for four hours pending transport to a higher level of care or
provide hand-off communication to the receiving facility.
•
In case 10, the patient received emergency care for abdominal
pain, nausea, and vomiting. Nurses observed the patient in
the Transitional Care Unit (TCU) without contacting the
provider, resulting in a 45-minute delay transporting the
patient to TTA. Later, the patient was transferred to a higher
level of care.
•
Later on in case 10, the patient received emergency care for
severe chest pain, nausea, and vomiting. During observation,
the patient’s blood pressure remained abnormally elevated
after pain medication was administered. The TTA nurse did
not reassess the effectiveness of the pain medication or notify
the provider 2 ½ hours later of abnormal vital signs. For five
hours, the TTA nurse also failed to reassess the patient’s
respiratory rate, pulse, temperature, and oxygen saturation,
important parameters to assess the medical stability of a
patient’s respiratory status.
•
In case 33, the patient received urgent care for chest pain and
was monitored in the TTA for two and a half hours. The TTA
nurse did not reassess the patient after the initial assessment
or prior to discharge. Furthermore, the nurse did not notify
the provider of the patient’s condition.
•
In case 34, a medical emergency was called for the patient
who had symptoms of chest pain and facial and eye swelling.
The TTA nurse did not assess the patient’s face for
complaints of swelling.
Nursing Documentation
As in Cycle 5, CCWF continued to struggle with nursing
documentation. Although nursing staff improved significantly in
documenting the first medical responder form, during our review we
found the following:
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 30
•
In case 1, the patient was sent to higher level of care to
evaluate for symptoms of abdominal pain. The TTA nurse did
not document the patient’s condition or an assessment prior
to transfer.
•
In case 2, the TTA nurse did not document the patient’s
respiratory assessment after the TTA nurse administered
breathing treatments to the patient.
•
In case 33, the patient was observed in TTA for chest pain.
The TTA nurse did not document a cardiac reassessment for
two and a half hours.
Emergency Medical Response Review Committee
Our inspectors reviewed ten EMRRC events in eight cases. CCWF staff
regularly conducted clinical reviews of nonscheduled emergency
transports each business day. The chief medical executive (CME) and
chief nursing executive (CNE) or designee reviewed each event and
determined whether each case should be assigned to EMRRC for
further review. The institution maintained a log of all EMRRC events
along with the disposition of the final actions of the review. In addition,
EMRRC reviewed all emergency responses and identified most
opportunities for improvement.
Clinician On-Site Inspection
The TTA is staffed 24-hours a day with two RNs on each shift, a
certified nursing assistant on second watch, and a provider on daily
assignment. During the Covid-19 pandemic, the TTA provider
performed face-to-face visits for patients requiring assessments from
clinic provider appointments which occurred via telework. The medical
officer of the day was assigned to take calls after 4pm, and the TTA
rover (an RN) responded to all medical emergencies throughout the
institution. In addition to medical emergencies, TTA staff process all
patients returning from the hospital and specialty appointments and
triage weekend sick call requests for emergent and urgent symptoms.
Prior to our on-site visit, the CCWF nursing leadership team had
identified lapses in documentation for nursing assessments and
protocols and implemented a monitoring plan to evaluate the
progression of nursing documentation.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 31
Recommendations
•
Medical and nursing leadership should consider incorporating
into the Emergency Medical Response Review Committee
(EMMRC) periodic reviews of medical emergencies which do
not require transfer to higher level of care.
•
Nursing leadership should ensure nurses notify the provider of
abnormal clinical findings in a timely manner.
•
Nursing leadership should provide refresher training on
completing reassessments for patients with urgent symptoms
in the TTA.
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Cycle 6, Central California Women’s Facility | 32
Health Information Management
In this indicator, OIG inspectors evaluated the flow of health
information, a crucial link in high-quality medical care delivery. Our Overall
Rating
inspectors examined whether the institution retrieved and scanned
Adequate
critical health information (progress notes, diagnostic reports,
specialist reports, and hospital discharge reports) into the medical Case Review
record in a timely manner. Our inspectors also tested whether Rating
clinicians adequately reviewed and endorsed those reports. In addition, Adequate
our inspectors checked whether staff labeled and organized documents
Compliance
in the medical record correctly. Score
Proficient
Results Overview (89.3%)
As in Cycle 5, CCWF performed well scanning health care service
request forms, hospital discharge records, diagnostic results, and
specialty reports. Most hospital discharge records contained all
medically required components. However, specialty report retrievals
were often delayed. Also, providers did not always complete patient
result letters according to CCHCS policy and did not always send
pathology result letters to patients. The OIG rated this
indicator adequate.
Case Review and Compliance Results
The clinicians reviewed 1,616 events and found 82 deficiencies related
to health information management, six of which were significant.21
Hospital Discharge Reports
Compliance testing revealed that all hospital records were received,
scanned into the medical record and reviewed properly (MIT 4.003,
100% and MIT 4.005, 100%). OIG clinicians reviewed 18 hospital visits
and identified two deficiencies in health information management, only
one of which was significant:
•
In case 34, the records from the patient’s visit to the
emergency room were not retrieved or scanned into the
patient’s electronic medical record.
Specialty Reports
Similar to Cycle 5, CCWF had adequate performance with specialty
reports. Compliance testing found specialty documents were generally
21 Deficiencies occurred in cases 1-5, 7-15, 17, 32-34, 36-38, and 39. Significant deficiencies
occurred in cases 14, 33, 34, 36, and 38.
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Cycle 6, Central California Women’s Facility | 33
scanned timely (MIT 4.002, 80.0%). High-priority specialty consultation
reports were received and reviewed timely (MIT 14.002, 80.0%);
however, retrieval and review of medium- and routine-priority specialty
consultation reports needed improvement (MIT 14.005, 46.7% and
MIT 14.008, 71.4%).
Of the 84 specialty consultations our clinicians reviewed,
13 deficiencies were identified related health information management,
only one of which was significant. Deficiencies included late or missing
provider endorsements, delayed receipt of specialty consultation
reports, and misfiled reports. One specialty consultation note was sent
to the wrong provider, resulting in delayed cancer care follow up.22 We
discuss these finding in more detail in the Specialty Services indicator.
Diagnostic Reports
CCWF performed poorly with diagnostic reports. The providers
reviewed and endorsed diagnostic tests timely, but often did not
communicate the results to the patient. Compliance testing found
providers frequently reviewed and endorsed pathology results; however,
they usually did not relay the results to the patient (MIT 2.011, 80.0%
and MIT 2.012, 40.0%). Nurses advised providers of stat laboratory
results and the providers acknowledged the results only 60.0 percent of
the time (MIT 2.008).
The OIG clinicians reviewed 387 diagnostic events. Of these
387 diagnostic events, the clinicians identified 60 deficiencies related to
health information management, three of which were significant.23
Most deficiencies were due to patient result letters missing all required
components. Case reviewers found a pattern of urine dip results not
being endorsed. However, we found two pathology reports which were
reviewed and discussed with the patient timely. We discuss the
deficiencies further in the Diagnostic Services indicator.
Urgent and Emergent Records
OIG clinicians reviewed 64 emergency care events and found CCWF
nurses recorded these events sufficiently. Providers usually recorded
their emergency care sufficiently, but deficiencies in documentation did
occur. Additional information regarding emergency care
documentation can be found in the Emergency Services indicator.
22 Minor deficiencies were noted in cases 1-3, 7, 9, 17, 33, and 36. One significant deficiency
was noted in case 38.
23 Minor diagnostic HIM deficiencies were noted in cases 1, 3-5, 7-15, 17, 32-34, 36-38, and
39. Significant deficiencies were found in cases 14, 36, and 38.
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Scanning Performance
CCWF performed poorly with scanning and labeling documents. Three
of five patient letters reviewed were mislabeled as DDP document types
rather than patient letters. Two specialty documents were not scanned
(MIT 4.004, 66.7%). The OIG clinicians also identified late retrieval and
endorsement of specialty documents. These findings are discussed
further in the Specialty Services indicator. The OIG clinicians found
most hospital and emergency room notes and laboratories were
endorsed timely.
Our clinicians identified 13 deficiencies related to mislabeled, misfiled,
and duplicate medical documents, and medical documents that were
not scanned.24 Four of the deficiencies were significant:
•
In case 14, a urine culture was not scanned into the patient’s
electronic medical record.
•
In case 33, an EKG was performed but not scanned into the
patient’s electronic medical record.
•
In case 34, the report from the patient’s emergency room visit
was not retrieved.
•
In case 36, the patient’s body imaging scan was not scanned
into their electronic medical record.
Clinician On-Site Inspection
We discussed health information management processes with CCWF
nurses, providers, office technicians, health information management
supervisors, and ancillary and diagnostic staff. During the COVID-19
pandemic, the institution was well staffed and maintained social
distancing guidelines by alternating days off for staff as telework was
not available for health information management staff.
Health information management staff explained that the radiology staff
was responsible for scanning radiology results into the medical record,
the laboratory staff ensured laboratory results were imported into the
medical record, and health information management staff monitored
endorsements of documents by providers. The OIG clinicians learned
that in 2020, health information management staff started sending
reports to providers detailing missing endorsements and beginning in
2021, they initiated an active role in following up with medical
management to ensure endorsements were completed.
24 Minor deficiencies were noted in cases 3, 7, 9, 11, 33, 36, and 39.
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Many problems identified in this indicator were due to incomplete
patient results notifications. Providers reported they were either not
aware of the requirement to include the identifying date in the letter or
they used the default template provided in the electronic health record
system (EHRS), which does not include all letter components. Health
information management reported that medical leadership is
responsible for training providers on the appropriate components of
patient results letters. Health information management also advised
they are not responsible for ensuring provider documents are complete,
include all necessary medical components, or do not contain
cloned elements.
Compliance Testing Results
Table 9. Health Information Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Are health care service request forms scanned into the patient’s
electronic health record within three calendar days of the encounter 20 0 10 100%
date? (4.001)
Are specialty documents scanned into the patient’s electronic health
24 6 15 80.0%
record within five calendar days of the encounter date? (4.002) *
Are community hospital discharge documents scanned into the
patient’s electronic health record within three calendar days of 15 0 2 100%
hospital discharge? (4.003) *
During the inspection, were medical records properly scanned,
16 8 0 66.7%
labeled, and included in the correct patients’ files? (4.004) *
For patients discharged from a community hospital: Did the
preliminary or final hospital discharge report include key elements
17 0 0 100%
and did a provider review the report within five calendar days of
discharge? (4.005) *
Overall percentage (MIT 4): 89.3%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 10. Other Tests Related to Health Information
Management
Scored Answer
Compliance Questions Yes No N/A Yes %
Radiology: Did the ordering health care provider review and endorse the
10 0 0 100%
radiology report within specified time frames? (2.002) *
Laboratory: Did the health care provider review and endorse the
9 1 0 90.0%
laboratory report within specified time frames? (2.005) *
Laboratory: Did the provider acknowledge the STAT results, OR did
6 4 0 60.0%
nursing staff notify the provider within the required time frames? (2.008) *
Pathology: Did the institution receive the final pathology report within
9 1 0 90.0%
the required time frames? (2.010) *
Pathology: Did the health care provider review and endorse the
8 2 0 80.0%
pathology report within specified time frames? (2.011) *
Pathology: Did the health care provider communicate the results of the
4 6 0 40.0%
pathology study to the patient within specified time frames? (2.012)
Did the institution receive and did the primary care provider review the
high-priority specialty service consultant report within the required time 12 3 0 80.0%
frame? (14.002) *
Did the institution receive and did the primary care provider review the
medium-priority specialty service consultant report within the required 7 8 0 46.7%
time frame? (14.005) *
Did the institution receive and did the primary care provider review the
routine-priority specialty service consultant report within the required 10 4 1 71.4%
time frame? (14.008) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
•
Medical leadership should determine the cause of untimely
retrieval of specialty reports and implement remedial measures
as appropriate.
•
The department should consider adjusting the menu on the
results letter in the electronic health records system (EHRS) to
default to patient letter instead of Developmental Disability
Program (DDP)-Scan letter and train providers to generate
letters appropriately.
•
Medical leadership should ensure providers relay pathology
results to patients timely.
•
The department should consider developing and implementing
a template that auto populates with all elements required per
CCHCS policy for patient results letters.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
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Health Care Environment
In this indicator, OIG compliance inspectors tested clinics’ waiting
areas, infection control, sanitation procedures, medical supplies,
equipment management, and examination rooms. Inspectors also tested Overall
Rating
clinics’ ability to maintain auditory and visual privacy for clinical
Adequate
encounters. Compliance inspectors asked the institution’s health care
administrators to comment on their facility’s infrastructure and its
Case Review
ability to support health care operations. The OIG rated this indicator
Rating
solely on the compliance score, using the same scoring thresholds as in
(N/A)
the Cycle 4 and Cycle 5 medical inspections. Our case review clinicians
do not rate this indicator. Compliance
Score
Results Overview Adequate
(79.6%)
CCWF’s performance improved in health care environment when
compared with the Cycle 5 inspection. The institution improved in
adherence to universal hand hygiene precautions and medical supply
management protocols. In addition, with some of the Health Care
Facility Improvement Program projects completed, CCWF's common
clinic areas and clinic exam rooms were conducive in providing medical
services. However, various aspects of the institution’s health care
environment still needed improvement: multiple clinics were missing
essential medical equipment; daily performance checks on automated
external defibrillator (AED) were either not properly logged or not
recorded at all; and inventories were not performed for emergency
medical response bags (EMRBs). We rated this indicator adequate.
Outdoor Waiting Areas
We examined CCWF’s outdoor patient waiting areas (see Photo 1, next
page). Health care and custody staff reported the existing waiting areas
had sufficient seating capacity. The clinic provided additional folding
chairs to practice social distancing (see Photo 2, next page). According
to staff, they only call patients close to their appointment time during
inclement weather.
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Photo 1. A clinic outdoor waiting area (photographed April 16, 2021).
Photo 2. A clinic’s extra folding chairs used to practice social distancing (photographed April 16, 2021).
Indoor Waiting Areas
We inspected CCWF’s indoor waiting areas. Health care and custody
staff reported the existing indoor waiting areas had sufficient seating
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 40
capacity that provided patients protection from inclement weather (see
Photo 3, below). Custody staff reported they bring in a few patients at a
time to prevent overcrowding the indoor waiting areas and to maintain
safe social distancing during the pandemic. During our inspection, we
did not observe overcrowding in the clinics’ waiting areas.
Photo 3. D clinic indoor waiting area (photographed April 15, 2021).
Clinic Environment
All clinic environments were sufficiently conducive for medical care;
they provided reasonable auditory privacy, appropriate waiting areas,
wheelchair accessibility, and nonexamination room workspace
(MIT 5.109, 100%).
All applicable clinics contained appropriate space, configuration,
supplies, and equipment to allow their clinicians to perform proper
clinical examinations (MIT 5.110, 100%).
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Clinic Supplies
Eight of the 10 clinics followed adequate medical supply storage and
management protocols (MIT 5.107, 80.0%). In two clinics, we found
unidentified medical supplies.
Six of the 10 clinics met the requirements for essential core medical
equipment and supplies (MIT 5.108, 60.0%). We found one or more of
the following deficiencies in four clinics: missing nebulization unit, and
staff either did not properly log the results of the automated external
defibrillator (AED) checklist or the clinic did not have an AED log for
staff to record test results within the last 30 days.
We examined emergency medical response bags (EMRBs) to determine
whether they contained all essential items. We checked if staff
inspected the bags daily and inventoried them monthly. Only five of the
nine EMRBs passed our test (MIT 5.111, 55.6%). In one clinic, staff
failed to ensure daily glucometer quality control was completed. In the
remaining three clinics, staff had not inventoried EMRBs when the seal
tags were replaced.
Medical Supply Management
None of the medical supply storage areas located outside the medical
clinics stored medical supplies adequately (MIT 5.106, zero). We found
medications stored temporarily in the medical warehouse (see Photo 4,
next page).
According to the chief executive officer (CEO), the institution did not
have any concerns about the medical supplies process. Health care
managers and medical warehouse managers expressed no concerns
about the medical supply chain or their communication process with
the existing system.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
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Photo 4. Expired glucose gel, dated February 2021and March 2021 (photographed April 12, 2021).
Infection Control and Sanitation
Staff appropriately cleaned, sanitized, and disinfected all applicable
clinics (MIT 5.101, 100%).
Staff in all applicable clinics properly sterilized or disinfected medical
equipment (MIT 5.102, 100%).
We found operating sinks and hand hygiene supplies in examination
rooms in all applicable clinics (MIT 5.103, 100%).
We observed patient encounters in five clinics. In one of the five clinics,
although the provider rinsed his hands before and after patient
encounters, he did not use an antiseptic soap or alcohol-based sanitizer
(MIT 5.104, 80.0%).
Health care staff in all applicable clinics followed proper protocols to
mitigate exposure to blood-borne pathogens and contaminated waste
(MIT 5.105, 100%).
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
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Physical Infrastructure
The institution’s health care management and plant operations
manager reported that all clinical area infrastructures were in good
working order. At the time of our medical inspection, CCWF’s
administrative team reported fourteen Health Care Facility
Improvement Program (HCFIP) construction projects. Some projects
were pending completion of other projects, while others had already
broken ground or were nearing project completion. All fourteen
projects were renovation of clinic spaces designed to provide
improvements in the quality of patient care. The institution reported
that completion of the majority of the projects would be delayed due to
the COVID-19 pandemic (MIT 5.999).
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Compliance Testing Results
Table 11. Health Care Environment
Scored Answer
Compliance Questions
Yes No N/A Yes %
Infection control: Are clinical health care areas appropriately
10 0 0 100%
disinfected, cleaned, and sanitary? (5.101)
Infection control: Do clinical health care areas ensure that reusable
invasive and noninvasive medical equipment is properly sterilized or 10 0 0 100%
disinfected as warranted? (5.102)
Infection control: Do clinical health care areas contain operable sinks
10 0 0 100%
and sufficient quantities of hygiene supplies? (5.103)
Infection control: Does clinical health care staff adhere to universal
4 1 5 80.0%
hand hygiene precautions? (5.104)
Infection control: Do clinical health care areas control exposure to
10 0 0 100%
blood-borne pathogens and contaminated waste? (5.105)
Warehouse, conex, and other nonclinic storage areas: Does the
medical supply management process adequately support the needs 0 1 0 0
of the medical health care program? (5.106)
Clinical areas: Does each clinic follow adequate protocols for
8 2 0 80.0%
managing and storing bulk medical supplies? (5.107)
Clinical areas: Do clinic common areas and exam rooms have
6 4 0 60.0%
essential core medical equipment and supplies? (5.108)
Clinical areas: Are the environments in the common clinic areas
10 0 0 100%
conducive to providing medical services? (5.109)
Clinical areas: Are the environments in the clinic exam rooms
9 0 1 100%
conducive to providing medical services? (5.110)
Clinical areas: Are emergency medical response bags and emergency
crash carts inspected and inventoried within required time frames, 5 4 1 55.6%
and do they contain essential items? (5.111)
Does the institution’s health care management believe that all clinical This is a nonscored test. Please
areas have physical plant infrastructures that are sufficient to provide see the indicator for discussion
adequate health care services? (5.999) of this test.
Overall percentage (MIT 5): 79.6%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results
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Cycle 6, Central California Women’s Facility | 45
Recommendations
•
Executive leadership should consider performing random spot
checks to ensure medical supply storage areas located outside
the clinics store medical supplies adequately.
•
Nursing leadership should consider performing random spot
checks to ensure clinics meet the requirements for essential
core medical equipment and supplies.
•
Nursing leadership should direct each clinic nurse supervisor
to review the monthly emergency medical response bag (EMRB)
logs to ensure EMRBs are regularly inventoried including a
daily quality control of the glucometers.
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Transfers
In this indicator, OIG inspectors examined the transfer process for
those patients who transferred into the institution, as well as for those
Overall
who transferred to other institutions. For newly arrived patients, our Rating
inspectors assessed the quality of health screenings and the continuity Adequate
of provider appointments, specialist referrals, diagnostic tests, and
medications. For patients who transferred out of the institution, Case Review
inspectors checked whether staff reviewed patient medical records and Adequate
determined the patient’s need for medical holds. They also assessed if
staff transferred patients with their medical equipment and gave Compliance
correct medications before patients left. In addition, our inspectors Score
Inadequate
evaluated the ability of staff to communicate vital health transfer
(61.1%)
information, such as preexisting health conditions, pending
appointments, tests, and specialty referrals; and inspectors
confirmed if staff sent complete medication transfer packages to the
receiving institution. For patients who returned from off-site
hospitals or emergency rooms, inspectors reviewed whether staff
appropriately implemented the recommended treatment plans,
administered necessary medications, and scheduled appropriate
follow-up appointments.
Results Overview
CCWF had a mixed performance in this indicator. Our clinicians found
nursing assessments and interventions improved at CCWF compared
with Cycle 5. The institution significantly improved in assessing
patients transferring out of the institution with complete vital signs.
When patients arrived at CCWF, nurses performed appropriate
assessments, notified specialty of pending appointments, and
communicated well with the care management teams. However, the
institution still struggled with continuity of patient care and
medication for patients returning from the hospital. Overall, the OIG
rated this indicator adequate.
Case Review and Compliance Testing Results
OIG clinicians reviewed 22 cases in which patients transferred into or
out of the institution or returned from an off-site hospital or emergency
room. We identified 14 deficiencies, two of which were significant.25
Transfers In
CCWF had a mixed performance in the transfer-in process. Compliance
testing showed R&R nurses made incomplete initial assessments
25 Deficiencies occurred in cases 2, 8, 10, 14 23, ,30, 32, 33, and 36. Significant deficiencies
occurred in cases 33 and 36.
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(MIT 6.001, zero). The nurses did not address the signs and symptoms of
fatigue when screening for tuberculosis (TB). However, case review
clinicians found newly arrived patients were screened within the
required time frames and received appropriate assessments. Our
clinicians identified minor opportunities for improvement. In one case
the nurse did not take the blood sugar of a diabetic patient on dialysis
and in another case, nursing staff did not complete COVID-19
quarantine rounding for three of the 14 days within the
quarantine period.
In compliance testing, CCWF scored low in managing patients
transferring into the institution with preapproved specialty
appointments (MIT 14.010, 50.0%). There were only two samples in this
compliance test. However, our case review clinicians did not find any
deficiencies for transfer-in patients with specialty appointments.
Transfers Out
CCWF’s transfer-out process was adequate. Although our compliance
team was not able to observe CCWF’s transfer-out process because no
patients transferred out on the day of the OIG compliance on-site
inspection, our case reviewers found that patients generally had
assessments prior to transfer, notification of pending specialty
appointments was completed, and patients transferred with their
medication and durable medical equipment. Our clinicians reviewed
seven transfer-out events. We found one minor deficiency in which the
patient did not receive her newly prescribed vitamin D as ordered due
to the patient transferred out two days after the medication was
ordered. However, the patient received the medication at the
receiving facility.
This is a significant improvement compared with Cycle 5 during which
nurses frequently did not assess patients prior to transfer. In this new
cycle, our clinicians did not find any deficiencies in our case review.
Hospitalizations
Patients returning from an off-site hospitalization or emergency room
are at high-risk for lapses in care. These patients typically experience
severe illness or injury. They require more care and place strain on the
institution’s resources. Also, because these patients have complex
medical issues, the successful transfer of health information is critical
for good quality care. Any lapse can result in serious consequences for
these patients.
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Our clinicians reviewed 20 hospital or emergency room returns in nine
cases.26 We identified 11 deficiencies, two of which were significant.27
We found that TTA nurses generally assessed patients appropriately
when they returned from the hospital or emergency room, reviewed and
informed providers of hospital recommendations, and notified
providers when patients returned to the facility. Providers appropriately
ordered recommended specialty referrals. However, staff did not always
properly reconcile mediations when the patient returned to
the institution.
All hospital discharge documentations were scanned into the patient’s
electronic health record within three calendar days of discharge
(MIT 4.003, 100%). Compliance testing also found providers routinely
reviewed and endorsed documents in a timely manner
(MIT 4.005, 100%).
In contrast, compliance testing showed CCWF had room for
improvement in medication continuity. Ordered medications were
administered, made available, or delivered to patients within the
required timeframes only 28.6 percent of the time (MIT 7.003). Both
clinical case reviews and compliance testing found lapses in the
continuity of essential medications. Our case reviewers identified five
deficiencies, one of which was significant.28 Two deficiencies are
described below.
•
In case 10, the patient returned from the hospital and
medication continuity did not occur for the patient’s
chemotherapy medication, diabetes insulin, and stomach
ulcer medication.
•
In case 36, the patient returned to the institution after a heart
catheterization procedure. The patient’s blood pressure,
cholesterol, and depression medications were not
appropriately reconciled with the correct dosages. In
addition, our case reviewers did not find any documentation
confirming that the hospital received the patient’s active
medication list at the time of hospital admission.
26 Events occurred in cases 1, 2, 10, 13, 14, 15, 32,and 36.
27 Deficiencies occurred in cases 8,10, 14, 32, 33, and 36. Significant deficiencies occurred in
cases 33 and 36.
28Deficiencies occurred in cases 8, 10, 14, and 36. Significant deficiencies also occurred in
case 36.
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 49
Clinician On-Site Inspection
During our on-site inspection, the OIG clinicians discussed the
transfer-in and transfer-out processes with the R&R nurse and SRN II.
We also discussed hospital returns with the TTA nursing staff.
The R&R nurse triages the transfer-in and transfer-out patients. A
provider is assigned to R&R daily for order reconciliation. The nurse
reported having good communication with their sister facility,
California Institution for Women (CIW), which helps to ensure
continuity of care for medication management. Our clinicians
confirmed this on their case reviews.
According the nursing staff, there is a nursing shortage; however, the
SRN II assists the nurses with intake screening and transfer-out
patients when staffing is low.
For information on the on-site inspection for reception center arrivals,
please see the Reception Center indicator.
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Cycle 6, Central California Women’s Facility | 50
Compliance Testing Results
Table 12. Transfers
Scored Answers
Compliance Questions Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: Did nursing staff complete the initial health screening and
0 13 0 0
answer all screening questions within the required time frame?
(6.001) *
For endorsed patients received from another CDCR institution or
COCF: When required, did the RN complete the assessment and
disposition section of the initial health screening form; refer the 13 0 0 100%
patient to the TTA if TB signs and symptoms were present; and
sign and date the form on the same day staff completed the health
screening? (6.002)
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
10 2 1 83.3%
were medications administered or delivered without interruption?
(6.003) *
For patients transferred out of the facility: Do medication transfer
packages include required medications along with the corresponding N/A N/A N/A N/A
transfer packet required documents? (6.101) *
Overall percentage (MIT 6): 61.1%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Central California Women’s Facility | 51
Table 13. Other Tests Related to Transfers
Scored Answer
Compliance Questions
Yes No N/A Yes %
For endorsed patients received from another CDCR institution: Based on
the patient’s clinical risk level during the initial health screening, was the 9 4 0 69.2%
patient seen by the clinician within the required time frame? (1.002) *
Upon the patient’s discharge from the community hospital: Did the
patient receive a follow-up appointment with a primary care provider 16 1 0 94.1%
within the required time frame? (1.007) *
Are community hospital discharge documents scanned into the
patient’s electronic health record within three calendar days of hospital 15 0 2 100%
discharge? (4.003) *
For patients discharged from a community hospital: Did the preliminary
or final hospital discharge report include key elements and did a
17 0 0 100%
provider review the report within five calendar days of discharge?
(4.005) *
Upon the patient’s discharge from a community hospital: Were all
ordered medications administered, made available, or delivered to the 4 10 3 28.6%
patient within required time frames? (7.003) *
Upon the patient’s transfer from one housing unit to another: Were
16 9 0 64.0%
medications continued without interruption? (7.005) *
For patients en route who lay over at the institution: If the temporarily
housed patient had an existing medication order, were medications N/A N/A N/A N/A
administered or delivered without interruption? (7.006) *
For endorsed patients received from another CDCR institution: If the
patient was approved for a specialty services appointment at the 1 1 0 50.0%
sending institution, was the appointment scheduled at the receiving
institution within the required time frames? (14.010) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Cycle 6, Central California Women’s Facility | 52
Recommendations
•
Nursing leadership should consider reminding nursing staff to
fully document (tuberculosis) TB symptoms as part of the
patient’s initial health assessment.
•
Medical and nursing leadership should ensure that hospital
discharge and intra-facility transfer medications are reconciled,
ordered, and administered timely without interruption.
•
Medical and nursing leadership should consider establishing a
policy to require medication reconciliation prior to the next
scheduled medical administration.
•
The department should consider developing and implementing
an electronic alert to ensure nurses in receiving and release
(R&R) properly complete initial screening questions and follow
up as needed.
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Medication Management
In this indicator, OIG inspectors evaluated the institution’s ability to
administer prescription medications on time and without interruption.
The inspectors examined this process from the time a provider Overall
Rating
prescribed medication until the nurse administered the medication to
Inadequate
the patient. When rating this indicator, the OIG strongly considered
the compliance test results, which tested medication processes to a
Case Review
much greater degree than case review testing. In addition to examining
Rating
medication administration, our compliance inspectors also tested many
Inadequate
other processes, including medication handling, storage, error
reporting, and other pharmacy processes. Compliance
Score
Results Overview
Inadequate
(67.8%)
CCWF performed poorly in this indicator. Compliance testing showed
that when compared with Cycle 5, CCWF had significantly more
deficiencies in chronic care medication, new medication, and hospital
medication continuity. We found a pattern of patients not receiving
their 30-day supply of keep-on-person (KOP) chronic care medications
within the required time frames. However, in this cycle, CCWF
improved continuity of transfer medication for new arrivals. When
considering the case review and compliance results together, we rated
this indicator inadequate.
Case Review and Compliance Testing Results
We reviewed 169 events related to medication management and found
32 medication deficiencies, six of which were significant.29
New Medication Prescriptions
CCWF had 194 new medication prescriptions. Compliance testing
showed most newly prescribed medications were not available and not
administered or delivered within the required time frames
(MIT 7.002, 68.0%). Our clinicians also found newly prescribed
medications that were not administered timely:
•
In case 7, the patient’s asthma inhaler was received five
days late.
•
In case 16, the patient received an antibiotic medication
(Amoxicillin) to treat a dental infection one day late.
29 Deficiencies occurred in cases 1, 2, 3, 5, 6, 7,10,15, 17, 20, 30, 34, 36, 39, 47, and 51.
Significant deficiencies occurred in cases 3, 5, 15, 16, 34, and 36.
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•
In case 51, the patient did not receive a newly prescribed
rescue medication for acute asthma attacks (Xopenex) for
a month.
Chronic Medication Continuity
Compliance testing found most patients did not receive their chronic
care medications within the required time frames (MIT 7.001, 11.1%).
Analysis of the compliance data showed KOP medications were not
made available one business day prior to exhaustion or refused by
patients, but when medication was refused, the reason for the refusal
was not documented. In contrast, our clinicians found most patients
received their chronic care medications within the required time
frames; however, there were four significant deficiencies:30
•
In case 5, the patient received the chronic care diabetic
medication five days late.
•
In case 16, the patient received the chronic care hypertension
medication three days late.
•
In case 34, the patient received the chronic care hypertension
medication four days late.
•
In case 36, the patient received chronic care hypertension
medication four days late.
Hospital Discharge Medications
Compliance testing showed most patients returning from an off-site
hospital or emergency room did not receive their medications within
the required time frames (MIT 7.003, 28.6%). However, our case
reviewers found most patients received their medications in a timely
manner. One case had two deficiencies on separate hospital returns:
•
In case 10, the patient returned from a hospital admission
and missed two doses of an essential medication for diabetes
(regular insulin) and received chemotherapy medication for
breast cancer one day late.
•
Also in case 10, the patient missed one dose of blood pressure
medication prescribed for uncontrolled blood pressure after
returning from the hospital. Also, the patient’s cholesterol-
lowering medication was administered in the morning
instead of the prescribed time at bedtime.
30 Significant deficiencies occurred in cases 3, 5, 15, 16, 34, and 36.
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Specialized Medical Housing Medications
Our clinicians found the majority of the skilled nursing facility (SNF)
nurses administered medications to patients within required time
frames. In contrast, compliance testing found medications were not
made available or administered within the required time frames in most
cases (MIT 13.004, 40.0%). One patient did not receive one dose of
insulin ordered for diabetes three times a day. Some patients did not
receive their essential KOP medications, rescue inhalers for shortness
of breath and nitroglycerin for chest pain, by the physician’s ordered
medication administration date.
Transfer Medications
In compliance testing, CCWF performed well in continuity of
medications for patients transferring into the institution
(MIT 6.003, 83.3%). Our clinicians had similar findings. Please refer to
the Transfers indicator for more details.
Medication Administration
Compliance testing showed nurses administered TB medications
within required time frames (MIT 9.001, 80.0%). However, the
institution did not thoroughly monitor patients taking TB medications
as required by policy (MIT 9.002, 15.0%). Our clinicians found nurses
generally adminstered medications properly; however, they identified
opportunities for improvement in medication administration:
•
In case 15, the patient received antidepression medication
five days late. Although the medication was a stock
medication in the outpatient medication area, the nurses did
not administer the medication timely.
Clinician On-Site Inspection
Our clinicians interviewed medication nurses and found them
knowledgeable about the medication process. During the huddle, the
care teams discussed medication compliance, including medication
nonadherence and medication continuity for patients transferring into
the institution or arriving from another yard. We also met with the
pharmacist in charge and nurse managers to discuss some of
our findings.
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Compliance Testing Results
Medication Practices and Storage Controls
The institution adequately stored and secured narcotic medications in
all of eight clinic and medication line locations (MIT 7.101, 100%).
CCWF appropriately stored and secured nonnarcotic medications in
nine of ten clinic and medication line locations (MIT 7.102, 90.0%). One
location lacked a clearly labeled designated area for medications that
were to be returned to the pharmacy.
Staff kept medications protected from physical, chemical, and
temperature contamination in seven of the 10 clinic and medication line
locations (MIT 7.103, 70.0%). In three clinics, staff did not store oral and
topical medications separately.
Staff successfully stored valid, unexpired medications in eight of the
10 applicable medication line locations (MIT 7.104, 80.0%). In two
clinics, medication nurses failed to label the multi-use medication as
required by CCHCS policy.
Nurses exercised proper hand hygiene and contamination control
protocols in four of six locations (MIT 7.105, 66.7%). In two locations,
some nurses neglected to wash or sanitize their hands before each
subsequent regloving.
Staff in five of six medication preparation and administration areas
demonstrated appropriate administrative controls and protocols
(MIT 7.106, 83.3%). In one location, medication nurses did not maintain
unissued medications in its original packaging.
In two of six medication areas, staff used appropriate administrative
controls and protocols when distributing medications to their patients
(MIT 7.107, 33.3%). In four locations, medication nurses did not reliably
observe patients while they swallowed direct observation
therapy medications.
Pharmacy Protocols
Pharmacy staff followed general security, organization, and cleanliness
management protocols in its main pharmacy (MIT 7.108, 100%). Staff
properly stored nonrefrigerated (MIT 7.109, 100%) and refrigerated or
frozen medications in its pharmacy (MIT 7.110, 100%).
The pharmacist in charge (PIC) did not thoroughly review monthly
inventories of controlled substances in the institution’s clinic and
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medication storage locations. Specifically, the pharmacists and nurses
present at the time of the medication area inspection did not correctly
complete several medication area inspection checklists (CDCR Form
7477). These errors resulted in a score of zero in this test (MIT 7.111).
We examined 25 medication error reports. The PIC timely and correctly
processed all of these reports (MIT 7.112, 100%).
Nonscored Tests
In addition to testing the institution’s self-reported medication errors,
our inspectors followed up on any significant medication errors found
during compliance testing. We did not score this test; we provide these
results for informational purposes only. At CCWF, the OIG did not find
any applicable medication errors (MIT 7.998).
The OIG interviewed patients in restricted housing units to determine
whether they had immediate access to their prescribed asthma rescue
inhalers or nitroglycerin medications. All ten applicable patients
interviewed indicated they had access to their rescue medications
(MIT 7.999).
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Compliance Testing Results
Table 14. Medication Management Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive all chronic care medications within the required
time frames or did the institution follow departmental policy for refusals or 2 16 7 11.1%
no-shows? (7.001) *
Did health care staff administer, make available, or deliver new order
prescription medications to the patient within the required time frames? (7.002) 17 8 0 68.0%
Upon the patient’s discharge from a community hospital: Were all ordered
medications administered, made available, or delivered to the patient within 4 10 3 28.6%
required time frames? (7.003) *
For patients received from a county jail: Were all medications ordered by
the institution’s reception center provider administered, made available, or 7 5 8 58.3%
delivered to the patient within the required time frames? (7.004) *
Upon the patient’s transfer from one housing unit to another: Were
medications continued without interruption? (7.005) * 16 9 0 64.0%
For patients en route who lay over at the institution: If the temporarily housed
patient had an existing medication order, were medications administered or N/A N/A N/A N/A
delivered without interruption? (7.006) *
All clinical and medication line storage areas for narcotic medications: Does
the institution employ strong medication security controls over narcotic 8 0 2 100%
medications assigned to its storage areas? (7.101)
All clinical and medication line storage areas for nonnarcotic medications:
Does the institution properly secure and store nonnarcotic medications in the 9 1 0 90.0%
assigned storage areas? (7.102)
All clinical and medication line storage areas for nonnarcotic medications:
Does the institution keep nonnarcotic medication storage locations free of 7 3 0 70.0%
contamination in the assigned storage areas? (7.103)
All clinical and medication line storage areas for nonnarcotic medications: Does
the institution safely store nonnarcotic medications that have yet to expire in 8 2 0 80.0%
the assigned storage areas? (7.104)
Medication preparation and administration areas: Do nursing staff employ
and follow hand hygiene contamination control protocols during medication 4 2 4 66.7%
preparation and medication administration processes? (7.105)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when preparing medications 5 1 4 83.3%
for patients? (7.106)
Medication preparation and administration areas: Does the institution employ
appropriate administrative controls and protocols when administering 2 4 4 33.3%
medications to patients? (7.107)
Pharmacy: Does the institution employ and follow general security,
organization, and cleanliness management protocols in its main and remote 1 0 0 100%
pharmacies? (7.108)
Pharmacy: Does the institution’s pharmacy properly store nonrefrigerated
medications? (7.109) 1 0 0 100%
Pharmacy: Does the institution’s pharmacy properly store refrigerated or frozen
medications? (7.110) 1 0 0 100%
Pharmacy: Does the institution’s pharmacy properly account for narcotic
medications? (7.111) 0 1 0 0
Pharmacy: Does the institution follow key medication error reporting
protocols? (7.112) 25 0 0 100%
Pharmacy: For Information Purposes Only: During compliance testing, did the This is a nonscored test. Please
OIG find that medication errors were properly identified and reported by the see the indicator for discussion of
institution? (7.998) this test.
Pharmacy: For Information Purposes Only: Do patients in restricted This is a nonscored test. Please
housing units have immediate access to their KOP prescribed rescue see the indicator for discussion of
inhalers and nitroglycerin medications? (7.999) this test.
Overall percentage (MIT 7): 67.8%
* The OIG clinicians considered these compliance tests along with their case review findings when determining the
quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 15. Other Tests Related to Medication
Management
Scored Answer
Compliance Questions
Yes No N/A Yes %
For endorsed patients received from another CDCR institution or
COCF: If the patient had an existing medication order upon arrival,
10 2 1 83.3%
were medications administered or delivered without interruption?
(6.003) *
For patients transferred out of the facility: Do medication transfer
packages include required medications along with the corresponding N/A N/A N/A N/A
transfer-packet required documents? (6.101) *
Patients prescribed TB medication: Did the institution administer the
16 4 0 80.0%
medication to the patient as prescribed? (9.001) *
Patients prescribed TB medication: Did the institution monitor the
patient per policy for the most recent three months he or she was on 3 17 0 15.0%
the medication? (9.002) *
Upon the patient’s admission to specialized medical housing: Were all
medications ordered, made available, and administered to the patient 4 6 0 40.0%
within required time frames? (13.004) *
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
•
Medical and nursing leadership should identify the causes of
the challenges to medication continuity for chronic care,
hospital discharge, and specialized medical housing patients
and implement remedial measures as appropriate.
•
Medical and nursing leadership should ensure hospital
discharge, reception center transfers, intra-facility transfers,
chronic care, and newly ordered medications are timely
ordered, made available, and administered to the patients
without interruptions.
•
Nursing leadership should consider reminding nursing staff to
document patient refusals in medical administration records, as
described in the CCHCS policy and procedures.
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Prenatal and Postpartum Care
This indicator evaluates the institution’s capacity to provide timely and
Overall
appropriate prenatal, delivery, and postnatal services to pregnant
Rating
patients. This includes the ordering and monitoring of indicated
Proficient
screening tests, follow-up visits, referrals to higher levels of care, for
example, high-risk obstetrics clinic, when necessary, and postnatal Case Review
follow-up. Rating
Proficient
Results Overview
Compliance
Score
CCWF performed very well in this indicator. OIG clinicians reviewed
Proficient
four cases and found care timely and appropriate in all cases with
(100%)
minimal deficiencies. Compliance testing showed the institution
provided excellent prenatal and postpartum care. We rated this
indicator proficient.
Case Review and Compliance Testing Results
Our clinicians reviewed four cases and 23 events related to prenatal and
postpartum care. All cases transferred to CCWF from county jails. We
identified five minor deficiencies in cases 12, 13 and 14 related to
incomplete nursing assessments. Overall, nurses conducted appropriate
health screenings and made appropriate referrals. All patients received
timely and appropriate prenatal care.
Prenatal Care
CCWF had excellent performance in prenatal care. Compliance testing
found all patients received appropriate housing, vitamin and meal
supplementation, and timely provider care (MITs 8.001, 8.002, 8.003, all
100%). Referrals to the obstetrician were timely and visits occurred
within the required time frames. The medical staff always obtained
patients’ weights, blood pressures, and fundal heights (MITs 8.004 and
8.006, both 100%). Prenatal care was predominantly performed by on-
site providers; however, when off-site services were necessary, they
were provided within appropriate time frames. OIG clinicians did not
find any significant deficiencies in prenatal care.
Postpartum Care
Only one case had postpartum care, and CCWF performed well with
postpartum care for this patient. The patient arrived late in her
pregnancy term and received proactive and appropriate care.
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Clinician On-Site Inspection
OIG clinicians met with the on-site obstetrician-gynecologist, nursing
staff, medical leadership, and scheduling staff. The provider saw
patients on-site since telemedicine was not utilized during the
COVID-19 pandemic. Having a skilled obstetrician-gynecologist was
beneficial to both the institution and the patients. Especially during the
COVID-19 pandemic, the retention of a board-certified specialist on-
site greatly reduced the frequency of off-site appointments, improved
access to care, provided excellent continuity of care, and reduced
potential exposure of patients to COVID-19.
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Compliance Testing Results
Table 16. Prenatal and Postpartum Care
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients identified as pregnant, did the institution timely offer 3 0 0 100%
initial provider visits? (8.001) *
Was the pregnant patient timely issued a comprehensive
accommodation chrono for a lower bunk and lower-tier housing and 2 0 1 100%
did the patient receive the correct housing placement? (8.002)
Did medical staff promptly order recommended vitamins, extra daily 3 0 0 100%
nutritional supplements and food for the patient? (8.003) *
Did timely patient encounters occur with an OB physician or OB nurse
practitioner in accordance with the pregnancy encounter guidelines? 3 0 0 100%
(8.004) *
Were the results of the patient’s initial prenatal screening tests 3 0 0 100%
timely completed and reviewed? (8.005) *
Was the patient’s weight, fundal height, and blood pressure 3 0 0 100%
documented at each clinic OB visit? (8.006) *
Did the patient receive her six-week postpartum obstetric visit? 0 0 3 N/A
(8.007) *
Overall percentage (MIT 8): 100%
Source: The Office of the Inspector General medical inspection results.
Recommendations
The OIG offers no recommendations for this indicator.
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Preventive Services
In this indicator, OIG compliance inspectors tested whether the
Overall
institution offered or provided cancer screenings, tuberculosis (TB)
Rating
screenings, influenza vaccines, and other immunizations. If the
Adequate
department designated the institution as high risk for
coccidioidomycosis (valley fever), we tested the institution’s ability to
Case Review
transfer out patients quickly. The OIG rated this indicator solely based Rating
on the compliance score, using the same scoring thresholds as in the (N/A)
Cycle 4 and Cycle 5 medical inspections. Our case review clinicians do
Compliance
not rate this indicator.
Score
Adequate
Results Overview
(76.8%)
CCWF staff had mixed performance in preventive services. Staff
performed well in administering TB medications as prescribed, offering
patients an influenza vaccine for the most recent influenza season,
offering colorectal cancer screening for all patients ages 50 through 75,
offering mammogram, pap smear, and required immunizations to
chronic care patients. The institution did not always monitor patients
who were taking prescribed TB medication or screen patients annually
for TB. We rated this indicator adequate.
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Compliance Testing Results
Table 17. Preventive Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Patients prescribed TB medication: Did the institution administer the
16 4 0 80.0%
medication to the patient as prescribed? (9.001)
Patients prescribed TB medication: Did the institution monitor the
patient per policy for the most recent three months he or she was on 3 17 0 15.0%
the medication? (9.002) †
Annual TB screening: Was the patient screened for TB within the last
15 10 0 60.0%
year? (9.003)
Were all patients offered an influenza vaccination for the most recent
25 0 0 100%
influenza season? (9.004)
All patients from the age of 50 through the age of 75: Was the
24 1 0 96.0%
patient offered colorectal cancer screening? (9.005)
Female patients from the age of 50 through the age of 74: Was the
25 0 0 100%
patient offered a mammogram in compliance with policy? (9.006)
Female patients from the age of 21 through the age of 65: Was
20 5 0 80.0%
patient offered a pap smear in compliance with policy? (9.007)
Are required immunizations being offered for chronic care patients?
15 3 7 83.3%
(9.008)
Are patients at the highest risk of coccidioidomycosis (valley fever)
N/A N/A N/A N/A
infection transferred out of the facility in a timely manner? (9.009)
Overall percentage (MIT 9): 76.8%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† In April 2020, after our review but before this report was published, CCHCS reported adding the
symptom of fatigue into the EHRS PowerForm for tuberculosis symptom monitoring.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
•
Nursing leadership and the public health nurse should educate
nursing staff to fully document TB symptoms as part of the
patient’s TB medication monitoring.
•
Nursing leadership and the public health nurse should educate
nursing staff in timely and accurate monitoring of patient’s
annual TB screening per CCHCS policy.
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Nursing Performance
In this indicator, the OIG clinicians evaluated the quality of care
delivered by the institution’s nurses, including registered nurses (RNs),
Overall
licensed vocational nurses (LVNs), psychiatric technicians (PTs), and
Rating
certified nursing assistants (CNAs). Our clinicians evaluated nurses’
Adequate
ability to make timely and appropriate assessments and interventions.
We also evaluated the institution’s nurses’ documentation for accuracy Case Review
and thoroughness. Clinicians reviewed nursing performance in many Rating
Adequate
clinical settings and processes, including sick call, outpatient care, care
coordination and management, emergency services, specialized medical
Compliance
housing, hospitalizations, transfers, specialty services, and medication Score
management. The OIG assessed nursing care through case review only (N/A)
and performed no compliance testing for this indicator.
When summarizing overall nursing performance, our clinicians
understand that nurses perform numerous aspects of medical care. As
such, specific nursing quality issues are discussed in other indicators,
such as Emergency Services, Specialty Services, and Specialized
Medical Housing.
Results Overview
CCWF delivered satisfactory nursing care. Compared with Cycle 5, the
institution improved in chronic care management. The institution’s
population management sessions provided multidisciplinary
collaboration in the care of patients with chronic conditions. However,
nurses continued to show opportunities for improvement in
assessments and emergency care for patients with urgent symptoms.
Overall, these deficiencies did not significantly impact the patient care
provided. Therefore, OIG rated this indicator adequate.
Case Review Results
We reviewed 425 nursing encounters in 47 cases. Of the nursing
encounters we reviewed, 324 were in the outpatient setting. We
identified 97 nursing performance deficiencies, 16 of which
were significant.31
Nursing Assessment and Interventions
A critical component of nursing care is the quality of nursing
assessment, which includes both subjective (patient interview) and
31 Deficiencies occurred in cases 1, 2, 3, 4, 6, 8, 9, 10, 11 ,13 ,15 ,16, 17, 18, 19, 20, 32, 33, 34,
36, 39, 41, 45, 47, 48, 49, 50, 51, 52, 53, 54, and 55. Significant deficiencies occurred in cases
1, 3, 4, 6, 9, 17, 32, 33, 34, 36, 39, 47, 51, and 52.
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objective (observation and examination) elements. CCWF nurses
generally provided adequate nursing assessments and interventions.
However, nursing assessment, documentation, and plans of care had
room for improvement in the transitional care unit (TCU).
Nursing Documentation
Complete and accurate nursing documentation is an essential
component of patient care. Without proper documentation, health care
staff can overlook changes in a patient’s condition. Nursing
documentation of care provided was good in specialty, prenatal and
postpartum care, and reception center assessments. In contrast, our
clinicians identified opportunities to improve nursing documentation
in the TCU, specialized medical housing (SMU), emergency services,
and hospitalization.
Nursing Sick Call
Our clinicians reviewed 107 sick call requests. Most nurses reviewed
symptomatic sick call requests appropriately and saw patients timely.
However, we identified 15 significant deficiencies related to incomplete
assessments, not consulting the provider of urgent symptoms, and not
evaluating patients the same day for possible emergent conditions. The
examples below demonstrate room for improvement our clinicians
identified in the case reviews:
•
In case 1, the patient complained of yellow skin (jaundice),
fatigue for two to three days, and diarrhea for two months.
The sick call nurse did not perform a complete abdominal
and skin assessment for the patient or take orthostatic vital
signs (vital signs performed while in three different
positions). In addition, the nurse did not address the patient’s
weight loss of 11 pounds.
•
In case 9, the patient with a recent history of stroke
complained of dizziness, nausea, and heart palpations. The
nurse did not assess the patient the same day, auscultate
patient’s heart sounds, or consult with the provider for
additional orders, such as order a follow-up provider
appointment or an EKG.
•
In case 17, the patient complained of not having a bowel
movement for two weeks. The sick call nurse did not take the
patient’s vital signs, complete an abdominal assessment, or
review the patient’s medication compliance.
•
In case 39, the patient submitted a sick call request for a
possible allergic reaction to glaucoma eye drops. The sick call
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nurse did not see the patient the same day the sick call slip
was reviewed.
Care Management/Coordinator
Our clinicians reviewed 34 events for care management and found
nurses generally performed appropriate assessments and interventions
for patients with chronic conditions. However, in two cases the
certified nursing assistant (CNA) completed vital signs for a TCU
patient, but did not report the abnormal findings to the RN or
the provider.32
Wound Care
We reviewed four cases in which wound care was provided for the
patients and found nurses did not always complete wound care as
ordered. In one case we found a minor opportunity for improvement
in assessment of the wound size for a patient in the correctional
treatment center (CTC). In another case, we identified two
significant deficiencies:
•
In case 1, wound care was not completed as ordered on five of
the 10 days wound care was ordered. On multiple occasions,
the provider noted the biliary drain was leaking, wanted
dressing changes done more often, and notified nursing to
perform wound care. On one occasion, the provider ordered
zinc ointment for the patient because the patient’s skin
was irritated.
Emergency Services
We reviewed 16 urgent or emergent cases. Our clinicians found first
medical responders responded promptly. However, we identified
incomplete reassessments and interventions, delayed notification to
providers of abnormal vital signs and assessment findings, and
inappropriate discharges to housing for patients presenting with urgent
symptoms. These findings are detailed further in the Emergency
Services indicator.
Hospital Returns
We reviewed 12 cases in which patients returned from a hospitalization
or an emergency room. The nurses generally provided good nursing
assessments for these patients. This is detailed further in the
Transfers indicator.
32 Deficiencies occurred in cases 9 and 17.
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Transfers
Our clinicians reviewed 10 cases that involved the transfer-in or
transfer-out processes at CCWF. Nurses evaluated patients within the
required time frames. However, in one case the nurse did not test the
blood sugar of the diabetic patient upon arrival. Please refer to the
Transfers indicator for further details on these findings.
Reception Care
Nurses had mixed performance in reception care. Compliance testing
found nurses did not always complete the initial health screening forms
thoroughly. However, nurses did sign and complete the assessment and
disposition portion of the health screening timely. Our clinicians did
not identify any significant deficiencies. More details are available in
the Reception Center indicator.
Prenatal and Postpartum Care
We reviewed 23 events related to prenatal and postpartum care in four
cases. CCWF nurses provided good perinatal screening assessments
and postpartum assessments within required time frames. We found
minor opportunities for improvement in assessments and
documentation.33 However, the deficiencies did not impact the patient
care provided.
Specialized Medical Housing
Our clinicians reviewed 29 events in five cases. The nurses provided
satisfactory assessments but showed room for improvement in
documentation. We discuss these finding in more detail in the
Specialized Medical Housing indicator.
Specialty Services
We reviewed 14 cases in which patients received specialty procedures
and consultations. Nurses performed good assessments, reviewed
specialist findings and recommendations, and communicated results to
the provider. The Specialty Services indicator provides
further information.
Medication Management
After reviewing 25 cases, our clinicians found nurses generally
administered medications to patients as prescribed. However, we found
incomplete medication reconciliation for patients returning from the
33 Deficiencies occurred in cases 12, 13, and 14.
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hospital. We also found nurses failed to administer medications,
reporting that medications were not available. During our on-site
inspection, we found that the medications were regularly stocked in the
nursing station. The Medication Management indicator provides
further information.
Clinician On-Site Inspection
Our clinicians spoke with nurse instructors and the nurses in the TTA,
SNF, R&R, TCU, specialty, outpatient clinics, and medication areas. We
attended organized huddles and population management working
sessions. We found clinical staff knowledgeable and familiar with their
patient population.
Our clinicians were impressed by CCWF’s population management
session and the multiple disciplines that were present and contributed
to the discussion. The population meeting was well-structured and
organized. The team was knowledgeable of their patient population and
coordinated the management of diabetic patients with dietary, mental
health, and medical staff. In addition, the specialty nurse reviewed the
vaccine registry, provided updates for varicella screening appointments,
and ordered follow-up appointments for refusals.
In response to the COVID-19 pandemic, the institution established the
incident command post in the late summer of 2020. The director of
nursing (DON) oversaw operations while the CNE gave direction from
the command post. The institution reported that the information
disseminated from CCHCS headquarters to the institution’s leadership
was not always clear. In response, the institution’s leadership provided
clear direction and training locally. All nursing supervisors interviewed
stated they also assisted with patient care in their areas of supervision.
The nursing staff stated they felt supported by the nursing supervisors,
especially when staffing was low, as they would assist with patient care.
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Recommendations
•
Nursing leadership should consider refresher training for
providers on the requirement that all transitional care unit
admissions have a detailed plan of care with measurable
objectives.
•
Nursing leadership shoulder remind certified nursing assistants
to report abnormal vital signs to a registered nurse or provider.
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Provider Performance
In this indicator, OIG case review clinicians evaluated the quality of
Overall
care delivered by the institution’s providers: physicians, physician
Rating
assistants, and nurse practitioners. Our clinicians assessed the
Adequate
institution’s providers’ ability to evaluate, diagnose, and manage their
patients properly. We examined provider performance across several Case Review
clinical settings and programs, including sick call, emergency services, Rating
outpatient care, chronic care, specialty services, intake, transfers, Adequate
hospitalizations, and specialized medical housing. We assessed
Compliance
provider care through case review only and performed no compliance Score
testing for this indicator. (N/A)
Results Overview
CCWF providers delivered adequate care. Of the 26 cases reviewed by
the OIG clinicians, 23 were adequate and three were inadequate. In
Cycle 5, this indicator was inadequate due to pervasive issues with poor
provider medical decision making, failure to examine patients, failure
to order medically appropriate follow-ups, and poor review of records.
While some problems persisted, the OIG clinicians saw improvement
overall. Strengths identified in Cycle 6 were continuity of care,
willingness of the providers to see their patients during the COVID-19
pandemic, and participation in robust population management
meetings. We rated this indicator adequate.
Case Review Results
The OIG clinicians examined the care quality in 26 comprehensive case
reviews. We found a total of 69 provider performance deficiencies, 21 of
which were significant, spanning five cases.34
Assessment and Decision-Making
CCWF providers generally made appropriate assessments and sound
medical plans for their patients. They diagnosed medical conditions
correctly, ordered appropriate tests, and referred their patients to
proper specialists. However, the majority of the deficiencies involved
the same three providers.35 The OIG noted areas of excellent and good
care by other providers, and even good care by these providers at times.
34 Deficiencies were noted in cases 1, 2, 3, 6, 9, 10, 12, 15, 33, 34, 36, 38, 39, and 47.
Significant deficiencies were noted in cases 1, 3, 10, 34, and 36.
35 Assessment and decision-making deficiencies occurred in cases 1, 3, 6, 9, 10, 12, 15, 33,
34, and 36. Significant deficiencies occurred in cases 1, 3, 10, 34, and 36.
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The following are examples our clinicians found of poor assessment and
decision making:
•
In case 1, the outpatient clinic provider did not order
specialty follow up as required, ordered diabetic follow up
laboratory work for three months when it should have been
ordered sooner, and did not recognize the patient had lost
over 18 pounds in five months. The patient was later
diagnosed with terminal cancer.
•
In case 10, the high-risk patient complained of syncopal
episodes, which can be a harbinger of life-threatening cardiac
or neurologic conditions. The provider stated the patient’s
episodes were due to low blood sugars without performing an
adequate history, review of systems, physical exam, or
diagnostic tests to rule out other more serious causes.
•
Also, in case 10, the provider reviewed a red blood cell count
test result that had dropped significantly which could
indicate the patient had internal bleeding or unknown cause
of red blood cell destruction. The provider acknowledged the
laboratory result but ordered no further tests, and did not rule
out serious causes.
CCWF prenatal and postpartum provider performance was excellent, as
noted earlier in the Prenatal and Postpartum care indicator. An
additional example of exemplary care by the obstetrician-gynecologist
on-site provider was noted:
•
In case 15, the provider’s diligence and proactive care was an
important factor in diagnosis and treatment of a gynecologic
cancer that may have saved the patient’s life. The provider
went over and above to provide this patient care and ensured
the patient received the specialty care she needed.
Review of Records
Usually providers reviewed records appropriately; however, we found
that errors were made on return from hospitalizations and on specialty
follow ups. These are discussed further in the Access to Care,
Transfers, and Specialty Services indicators.
Emergency Care
CCWF providers usually made appropriate triage decisions when
patients arrived in the TTA for emergency treatment. In addition,
providers were available for consultation with the TTA nursing staff.
We found two significant emergency care deficiencies; however, both
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were attributed to one provider and is discussed in the Emergency
Services indicator.
Chronic Care
In most instances, the CCWF providers appropriately managed their
patient’s chronic health conditions including hypertension, asthma,
hepatitis C infection, and cardiovascular disease; however, we
identified a pattern of providers not making appropriate diabetes
medication adjustments. There was also a pattern of providers sending
patient results letters on chronic care concerns stating that their
laboratory results were normal or unchanged, and that no follow up was
required. This was concerning because even when the laboratory results
were unchanged, they frequently were not normal, and required follow
up, which could lead patients to believe their uncontrolled conditions
were controlled.
Only one anticoagulation patient was identified and was
managed appropriately.
Specialty Services
Most CCWF providers appropriately referred and reviewed specialty
reports in a timely manner. Our clinicians identified nine specialty
deficiencies related to provider performance. Six of these deficiencies
were due to providers not following specialist’s recommendations, of
which three were considered significant. In two of the three significant
deficiencies, the provider did not order specialty services that were
needed.36 We discuss these findings in more details in the Specialty
Services indicator.
Documentation Quality
Most CCWF providers usually documented outpatient and TTA
encounters; however, our clinicians identified 21 deficiencies related to
no or poor documentation of outpatient care. Many of these
deficiencies were attributed to a small number of providers. We found
instances of providers making significant medical decisions but not
documenting reasons for these decisions.
The Health Information Management indicator provides more
information on these findings.
36 Deficiencies occurred in cases 1, 10, 34, and 38. Significant deficiencies occurred in cases
1,10, and 34.
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Provider Continuity
Provider continuity was generally very good. The permanent providers
had been assigned to their yards for an extended period of time.
Usually, the provider who ordered diagnostics or specialty services was
the same provider who reviewed the documents, saw the patient in
follow up, or recommended the treatment plan.
Clinician On-Site Inspection
OIG clinicians met with all levels of medical leadership and staff during
the on-site inspection and attended well-organized morning huddles at
the two main clinics.
Medical leadership explained that providers are generally assigned to a
clinic for two years, which supports continuity of provider care. CCWF
employs physicians and nurse practitioners.
The providers expressed job satisfaction and good morale. Some
providers reported that their nursing resources frequently changed, at
times daily, creating frequent interruptions to their clinics and
disrupting patient care activities which could possibly lead to medical
errors. Otherwise, resources were available for patient care.
The COVID-19 pandemic represented significant patient care and staff
challenges. The institution was relatively free of COVID-19 early in the
pandemic and worked under the CCHCS headquarters phase plan
which included patient movement restriction, frequent testing,
isolation and quarantine as needed, and staff modifications to meet
space and exposure requirements. CCWF experienced COVID-19 cases
in July and August 2020.The most significant surge with over one
thousand cases occurred in December, with daily COVID-19 cases in
the hundreds occurring for several months afterward.
According to medical leadership, in order to comply with early CCHCS
COVID-19 guidance, one half of the providers worked remotely from
home and the other half worked on-site. The groups alternated weekly
between remote and on-site work. When the guidance for high-risk
providers was released, six of the nine providers were determined to be
high risk and were given opportunities to continue to work from home.
We were advised that while on modified work schedules, providers
reviewed daily clinic lists for triage, prioritizing urgent and emergent
appointments. Early in the pandemic, following CCHCS guidelines,
providers usually deferred chronic care appointments and performed
chart review rather than conduct face-to-face visits. Once vaccinations
were available, most providers returned on-site.
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During our case review, OIG clinicians found that providers did see
patients throughout the pandemic; however, most visits were via
electronic interface and frequently the physical exams were not
completed properly. At the on-site visit, medical leadership advised
they did make attempts to use CCHCS formal telemedicine equipment,
as connectivity issues between the telemedicine systems and provider
at-home equipment prevented this. The most frequently described
approach was a clinic system comprised of a tablet, laptop, or desktop
affixed with a camera that the provider would use to visualize the
patients through a remote laptop they had at home. Medical leadership
said they also attempted to connect electronic stethoscopes to the
laptops, but technical issues arose that could not be corrected. There
were no peripheral devices available on these units, so heart and lung,
detailed dermatologic, and ears, nose, and throat examinations could
not be directly performed. Also, the only staff in the examination room
with the patient were medical assistants, who were not trained or
licensed to perform physical examinations, further limiting
examination capability. According to providers, if a more detailed,
urgent physical examination was needed, the clinic RN could assist in
the examination or an appointment could be made in an on-site clinic
or TTA; however, the RNs also had significant clinic responsibilities
during clinic hours. Although this solution limited physical
examination capabilities, the OIG applauds CCWF and the efforts of its
providers to see the patients and address clinical issues, despite the
movement and technology restrictions caused by the COVID-19
pandemic policies.
Our clinicians observed one clinic’s population management session
during our on-site visit. Medical and nursing leadership, providers,
nurses, and ancillary services and mental health staff worked well
together to address patients’ chronic care conditions. The providers
were knowledgeable about patients assigned to their patient panel and
provided direction regarding the overall management of their chronic
care patients. Polypharmacy and complex patients were reviewed
during these meetings as well.
The chief medical executive (CME) and acting chief physician and
surgeon (CP&S) were highly respected. At the time of our inspection,
the CP&S informed us she had accepted a position with headquarters
and was the “acting” CP&S. The providers expressed significant
appreciation for the guidance and support both the CME and
CP&S provided.
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Recommendations
•
Medical leadership should consider specific training on
improved documentation and monitored medical decision
making for providers who have the most deficiencies in our
case reviews.
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Reception Center
This indicator focuses on the management of medical needs and
continuity of care for patients arriving from outside the CDCR system. Overall
Rating
The OIG review evaluates the institution’s ability to provide and
Adequate
document initial health screenings and health assessments, continuity
of medications, and completion of required screening tests, as well as
Case Review
its ability to address and provide significant accommodations for
Rating
disabilities and health care appliance needs and to identify health care Adequate
conditions needing treatment and monitoring. The patients reviewed
Compliance
for reception center cases are those received from facilities that are not
Score
connected with the department, such as county jails. Adequate
(75.0%)
Results Overview
CCWF delivered acceptable care. The R&R nurses assessed the patients
timely, reviewed health records from county jails, made appropriate
referrals to providers, and ensured all patients were placed in
quarantine for COVID -19 precautions. Compared with Cycle 5, CCWF
significantly improved in timely provider appointments for patients for
the health and physical (H&P) within seven days. Overall, the OIG rated
this indicator adequate.
Case Review and Compliance Testing Results
Our clinicians reviewed four cases and identified five deficiencies.37
Provider Access
Compliance testing showed patients always received a history and
physical (H&P) examination by a provider within seven days, as
required by policy (MIT 12.004, 100%). Intake screening tests were
frequently offered or completed within the required time frames
(MIT 12.005, 90.0%). Likewise, case review did not find any deficiencies
with provider access.
Nursing Performance
Compliance testing found that the nurses did not complete the initial
health screening forms thoroughly (MIT 12.001, zero). The nurses did
not address the signs and symptoms of fatigue when screening
for TB. However, the R&R nurses timely signed and completed the
assessment and disposition portion of the health screening form
(MIT 12.002, 100%). Our clinicians reviewed four cases of patients
37 Deficiencies occurred in cases 11,12, and 13.
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arriving via the reception center and found five deficiencies, none of
which were significant.
Our clinicians found the nurses appropriately assessed and referred
patients to providers; however, there were minor deficiencies in three
cases, which did not negatively impact patient care.
Clinician On-Site Inspection
The nurses our clinicians interviewed were knowledgeable about their
job duties and the reception intake process. We met with the nurse
manager who shared with us CCWF’s current process of screening
patients for COVID-19 received from county jails.
Early in the COVID-19 pandemic, the institution established a
command center to better manage the COVID-19 outbreak. CCWF
assigned the CNE to act as the health care incident commander. At the
time of our on-site inspection, the CNE remained in this role, receiving
a list of patients scheduled to arrive to CCWF from the county jail and
reviewing the medical records with COVID-19 test results. Patients are
prescreened prior to arrival from the county jail. This process includes
review of the medical records and COVID-19 test results to determine
which patients will transfer to CCWF. The R&R staff is notified of the
patients arriving and chart reviews are completed ahead of time to
prepare for the arrival of the patients. Upon arrival to CCWF, custody
and medical staff, wear full PPE before contact with the patient.
Thereafter, patients are placed in quarantine for 14 days.
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Compliance Testing Results
Table 18. Tests Related to Reception Center
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: Prior to 4/2019: Did nursing
staff complete the initial health screening and answer all screening
questions on the same day the patient arrived at the institution?
0 20 0 0
Effective 4/2019: Did nursing staff complete the initial health screening
and answer all screening questions upon arrival of the patient at the
reception center? (12.001) *
For patients received from a county jail: Prior to 4/2019: When required,
did the RN complete the assessment and disposition section of the
health screening form, and sign and date the form on the same day staff
completed the health screening? Effective 4/2019: Did the RN complete 15 0 5 100%
the assessment and disposition section, and sign and date the
completed health screening form upon patient’s arrival at the reception
center? (12.002) *
For patients received from a county jail: If, during the assessment, the
nurse referred the patient to a provider, was the patient seen within the 1 0 19 100%
required time frame? (12.003) *
For patients received from a county jail: Did the patient receive a history
and physical by a primary care provider within seven calendar days? 20 0 0 100%
(12.004) *
For patients received from a county jail: Were all required intake tests
18 2 0 90.0%
completed within specified timelines? (12.005) *
For patients received from a county jail: Did the primary care provider
review and communicate the intake test results to the patient within 7 13 0 35.0%
specified timelines? (12.006)
For patients received from a county jail: Was a tuberculin test both
20 0 0 100%
administered and read timely? (12.007)
For patients received from a county jail: Was a Coccidioidomycosis
(Valley Fever) skin test offered, administered, read, or refused timely? 0 0 20 N/A
(12.008)
Overall percentage (MIT 12): 75.0%
* The OIG clinicians considered these compliance tests along with their case review findings when determining
the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 19. Other Tests Related to Reception Center
Scored Answer
Compliance Questions Yes No N/A Yes %
For patients received from a county jail: Were all medications ordered
by the institution’s reception center provider administered, made
7 5 8 58.3%
available, or delivered to the patient within the required time frames?
(7.004) *
* The OIG clinicians considered these compliance tests along with their case review findings when determining
the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
Recommendations
•
The department should consider developing and implementing
an electronic alert to ensure nurses in the R&R clinic complete
initial health screening questions and follow up with patients
as needed.
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Specialized Medical Housing
In this indicator, OIG inspectors evaluated the quality of care in the
specialized medical housing units. We evaluated the performance of the Overall
Rating
medical staff in assessing, monitoring, and intervening for medically
Adequate
complex patients requiring close medical supervision. Our inspectors
also evaluated the timeliness and quality of provider and nursing intake
Case Review
assessments and care plans. We assessed staff members’ performance in Rating
responding promptly when patients’ conditions deteriorated and looked Adequate
for good communication when staff consulted with one another while
Compliance
providing continuity of care. Our clinicians also interpreted relevant
Score
compliance results and incorporated them into this indicator. At the Adequate
time of our inspection, the CCWF specialized medical housing (77.5%)
consisted of a skilled nursing facility (SNF).
Results Overview
CCWF providers and nurses delivered satisfactory care to patients in
the skilled nursing facility (SNF). Nurses performed routine patient
assessments and provided interventions appropriately. Compared with
Cycle 5, CCWF had a slight decline in medication continuity, timely
provider history and physical assessments, and nursing assessments
and documentation of patient care. However, these findings did not
impact the patient care that was provided. Therefore, we rated this
indicator adequate.
Case Review and Compliance Testing Results
We reviewed 1,363 SNF events, including 49 provider and 29 nursing
events. Because of the care volume that occurs in specialized medical
housing units, each provider and nursing event represents up to one
month of provider care and two weeks of nursing care. We identified
46 deficiencies, 10 of which were significant.38
Provider Performance
Provider performance in the SNF was adequate. Of the 133 events our
clinicians reviewed, 84 were related to provider encounters, orders, or
review of laboratory results, and involved six cases. Most cases were
handled well by providers, and patients received adequate medical care.
Our clinicians identified 13 deficiencies.39 Six of the deficiencies were
significant, with four occurring in case 1:
38 Deficiencies occurred in cases 1, 3,15, 33, and 36. Significant deficiencies occurred in case
1, 3, and 36.
39 Significant deficiencies occurred in cases 1, 3, and 36.
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•
In case 1, the patient was diagnosed with a terminal illness.
Prior to being placed on hospice care, the patient’s kidney
function worsened, which the providers in the SNF did not
address on multiple occasions. While the patient was on
hospice care, the providers requested intravenous fluids and
the implementation of comfort care measures; however, these
were not completed.
•
In case 3, the patient, who had a history of significant vision-
threatening eye conditions, complained of blurred vision. The
provider did not see the patient and an eye exam or vision test
was not performed.
•
In case 36, the patient had a history of cardiac condition,
which could lead to fast, chaotic heart beats. The provider
placed the patient on a medication that can cause or worsen
this cardiac condition, even though a previous provider had
discontinued the same medication.
Compliance testing found providers performed admission histories and
physical examinations within required time frames only 70.0 percent of
the time (MIT 13.002). OIG clinicians reviewed SNF events in six cases,
four of which had new admissions during the review period, and found
admission history and physical examinations were performed timely
and documented thoroughly.
Nursing Performance
Compliance testing found SNF nurses performed timely admission
assessments (MIT 13.001, 100%). Case reviews also showed the nurses
completed admission assessments timely. SNF nurses conducted
regular rounds and generally provided satisfactory care. However, our
clinicians found opportunities for improvement in nursing assessments,
wound care, and reassessments after “as needed” medications were
administered and provided wound care was documented:
•
In case 1, wound care was not completed as ordered for a
biliary catheter drain on several occasions. In a progress note,
the provider described the patient’s dressing as completely
soaked and wanted the dressing changes done more often.
•
In case 3, the patient had an abnormally elevated blood
pressure. The certified nursing assistant (CNA) did not report
this finding to the RN. The RN on the next shift notified the
provider five hours later of the abnormal blood pressure. In
addition, nursing assessments were incomplete, and nurses
did not reassess the effectiveness of the “as needed”
pain medication.
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•
In case 15, the patient had a foley catheter after a
hysterectomy procedure. SNF nurses did not perform
catheter care as ordered by the provider. In addition, the
nurses did not perform complete documentation for the
intake and output for a patient with a catheter.
Medication Administration
Our clinicians found most patients received their medications within
the required time frames. Compliance testing showed 40.0 percent of
newly admitted patients received their medication within required time
frames (MIT 13.004). In half of the noncompliant samples we tested,
patients did not receive “as needed” rescue medication when the
provider ordered it.
Clinician On-Site Inspection
The institution’s SNF had 26 beds, including two negative pressure
rooms. At the time of our inspection, 18 beds were occupied. Our
compliance testing found that the call light system was functional and
working. The institution’s SNF had two designated providers, one full-
time and the other part-time. Both performed rounds with nursing staff.
Nurses provided 24-hour care at the SNF.
In the SNF, the provider generally sees the patient once a month and
more frequently for condition changes and as needed. Patients notify
the nurses of any complaints. New changes in the patient conditions are
discussed in the huddle, where the provider determines when the
patients should be seen.
SNF staff reported that during the COVID-19 pandemic, the COVID-19
vaccinations were prioritized for the SNF patients. California
Department of Public Health (CDPH) staff assisted CCWF in helping to
manage COVID-19 cases.
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Compliance Testing Results
Table 20. Specialized Medical Housing
Scored Answer
Compliance Questions Yes No N/A Yes %
For OHU, CTC, and SNF: Prior to 4/2019: Did the registered
nurse complete an initial assessment of the patient on the day of
admission, or within eight hours of admission to CMF’s Hospice? 10 0 0 100%
Effective 4/2019: Did the registered nurse complete an initial
assessment of the patient at the time of admission? (13.001) *
For CTC and SNF only (effective 4/2019, include OHU): Was a written
history and physical examination completed within the required time 7 3 0 70.0%
frame? (13.002) *
For OHU, CTC, SNF, and Hospice (applicable only for samples prior
to 4/2019): Did the primary care provider complete the Subjective,
Objective, Assessment, and Plan notes on the patient at the 0 0 10 N/A
minimum intervals required for the type of facility where the patient
was treated? (13.003) *, †
Upon the patient’s admission to specialized medical housing: Were
all medications ordered, made available, and administered to the 4 6 0 40.0%
patient within required time frames? (13.004) *
For OHU and CTC only: Do inpatient areas either have properly
working call systems in its OHU & CTC or are 30-minute patient
1 0 0 100%
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter patient’s cells? (13.101) *
For specialized health care housing (CTC, SNF, Hospice, OHU):
Do health care staff perform patient safety checks according to
0 0 1 N/A
institution’s local operating procedure or within the required time
frames? (13.102) *
Overall percentage (MIT 13): 77.5%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
† CCHCS changed its policies and removed mandatory minimum rounding intervals for patients located
in specialized medical housing. After April 2, 2019, MIT 13.003 only applied to CTCs that still have
State-mandated rounding intervals. OIG case reviewers continued to test the clinical appropriateness of
provider follow-ups within specialized medical housing units through case reviews.
Source: The Office of the Inspector General medical inspection results
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Recommendations
•
Nursing leadership should ensure nurses in the skilled nursing
facility (SNF) thoroughly assess patients and document the
assessments along with wound care.
•
Nursing leadership should ensure nurses initiate care plans and
reassess patients at regular intervals.
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Specialty Services
In this indicator, OIG inspectors evaluated the quality of specialty
Overall
services. The OIG clinicians focused on the institution’s ability to
Rating
provide needed specialty care. Our clinicians also examined specialty
Adequate
appointment scheduling, providers’ specialty referrals, and
medical staff’s retrieval, review, and implementation of any Case Review
Rating
specialty recommendations.
Adequate
Results Overview
Compliance
Score
CCWF provided adequate specialty services for their patients. Adequate
Compared with Cycle 5, CCWF improved in following specialist (75.9%)
recommendations. However, a few providers did not order specialty
follow-up appointments timely, did not follow specialist
recommendations, and did not document their medical reasoning,
causing delays in specialty care for affected patients. CCWF performed
well with high- and medium-priority access despite the COVID-19
pandemic. The OIG ultimately rated this indicator adequate.
Case Review and Compliance Testing Results
The OIG clinicians reviewed 171 events related to specialty services,
including 90 specialty encounters, 27 nursing encounters, and
16 provider encounters. Of the 90 specialty encounters, 51 were related
to off-site or telemedicine specialty visits and required provider follow-
up. Of the 171 specialty service events, we found 32 deficiencies, nine of
which were significant.40 Obstetrics or gynecology visits, which were
performed by most primary care providers, were not included as
specialty consultations. Due to the COVID-19 pandemic, we found
many specialty visits were deferred, but a large proportion were
reviewed and most critical and urgent specialty care was provided.
Access to Specialty Services
CCWF performed well in completing most high-priority, medium-
priority, and routine-priority specialty appointments within required
time frames (MIT 14.001, 100%, MIT 14.004, 86.7% and MIT 14.007,
80.0%). For patients arriving from another CDCR institution, only
50.0 percent of the patients’ specialty appointments occurred within the
required time frames (MIT 14.010); however, this compliance test only
had a sample size of two patients. OIG case reviewers found four access
40 Deficiencies were noted in cases 1, 2, 3, 7, 9, 10, 15, 17, 19, 32, 33, 34, 36, and 38.
Significant deficiencies occurred in cases 1, 10, 17, 34, 36, and 38.
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deficiencies, three of which were significant. The deficiencies were all
related to delayed follow-up appointments. These are discussed in more
detail in the Access to Care indicator.
Compared with Cycle 5, CCWF improved in providing adequate
physical therapy services; inpatient physical therapy continued seeing
patients, despite the COVID-19 pandemic. CCHCS dietary
consultations and obstetrics-gynecology care were also available
throughout the review period.
Provider Performance
CCWF providers performed poorly in the specialty services indicator.
In Cycle 5, providers often had problems making appropriate referrals
to a specialist and delayed or overlooked specialty recommendations.
OIG clinicians found this problem continued in Cycle 6, but was
isolated to a few providers. Compliance testing showed providers saw
patients for required post-specialty follow-up 90.5 percent of the time
(MIT 1.008).
While most CCWF providers appropriately referred and reviewed
specialty reports timely, they did not always follow specialty
recommendations. OIG clinicians reviewed 38 provider visits that
involved specialty consultation follow-up. Of the 38 visits, OIG
clinicians identified seven deficiencies. Five of the seven deficiencies
were due to providers not following specialty recommendations, three
of which were significant.41 The providers did not document reasons for
not following the specialist recommendations. Additionally, two
significant deficiencies were due to providers not ordering necessary
specialty services:
•
In case 1, the patient had a history of a precancerous
esophagus condition and enlarged esophageal veins, which
can lead to life-threatening bleeding. The specialist
recommended repeat stomach and esophageal endoscopy42 in
one to two years to monitor and ensure the conditions were
not worsening. The provider saw the patient but did not order
the study.
•
In case 10, the kidney specialist recommended treatment for
the patient’s elevated potassium. The provider endorsed the
specialist note and stated recommendations would be ordered
at the provider follow-up visit. This follow-up visit did not
41 Deficiencies occurred in case 10, 34, and 38. Significant deficiencies occurred in cases 10
and 34.
42 An endoscopy is a procedure where a medical scope is placed through the mouth into the
stomach to visualize the esophagus and stomach.
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occur, and the recommended orders were not written timely.
Three months later, the kidney specialist again saw the
patient and again recommended the medication to treat the
elevated potassium be ordered for the patient, along with
other recommendations. The provider again did not follow
the specialist’s recommendations. The patient was
hospitalized shortly thereafter for elevated potassium.
•
In case 34, the provider saw the patient for cardiology follow-
up. The provider did not order the recommended follow-up
testing and ordered a dose of medication four times larger
than the dose that specialist recommended. Following the
specialist’s recommendation was critical because the patient
had a history of low heart rate on this medication.
Nursing Performance
CCWR’s nursing performance in specialty services was adequate. OIG
clinicians identified 10 deficiencies, one which was significant.43 Nurses
did not always properly evaluate, assess, and educate patients returning
from off-site appointments. This is discussed further in the Nursing
Performance indicator.
Health Information Management
CCWF performed adequately in ensuring high-priority specialty reports
were received, but poorly in ensuring medium- and routine-specialty
reports were received and reviewed within CCHCS policy time frames
(MIT 14.002, 80.0%, MIT 14.005 46.7% and MIT 14.008 71.4%). The OIG
clinicians identified 10 specialty deficiencies related to health
information management out of 84 events, only one of which
was significant:44
•
In case 38, the cancer specialist recommended computed
tomography (CT) imaging, laboratory work, and a follow-up
in two weeks. Several errors occurred in this case, including
failure to complete imaging and laboratory work timely and
to complete the follow-up with the cancer specialist in
two weeks.
Compliance testing found CCWF had adequate performance in
scanning high- and medium-priority specialty consultation reports
timely (MIT 4.002, 80.0%). OIG clinicians found three of 10 specialty
deficiencies related to health information management were for
43 Deficiencies occurred in cases 2, 3, 15,19, 32, 36, and 38. A significant deficiency occurred
in case 36.
44 Deficiencies occurred in cases 2, 7, 9, 17, 33, 36, and 38. A significant deficiency occurred
in case 38.
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misfiling specialty consultation reports; however, most specialty reports
were endorsed timely. These findings are discussed further in the
Health Information Management indicator.
Clinician On-Site Inspection
OIG clinicians met with CCWF managers, supervisors, providers, and
utilization management nursing staff and discussed specialty referral
management. During the review period, the COVID-19 pandemic
affected specialty scheduling. Fortunately, the institution was fully
staffed during this time. According to CCWF, their backlog was due to
Phase 1 COVID-19 restrictions per CCHCS COVID-19 guidance, in
which many specialty types were not available or had restricted clinics
such as gastroenterology, optometry, and ophthalmology.
Medical leadership reviewed outstanding specialty appointments and
determined what could be postponed. We were advised only urgent and
emergent appointments were being processed and that care teams were
messaged about postponements. In addition, the providers reviewed
outstanding appointments for patients in quarantine and isolation to
determine if the appointment must be kept, postponed, or cancelled.
Specialty schedulers reported keeping a binder outside of the EHRS to
track which referrals were outstanding. They also tracked the status of
outstanding specialty consultation reports and results on an
Excel spreadsheet.
Several of the misfiling errors the OIG case reviewers found were not
identified by the health information management staff. However, staff
corrected them after the OIG notified them of the errors.
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Compliance Testing Results
Table 21. Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Did the patient receive the high-priority specialty service within 14
calendar days of the primary care provider order or the Physician 15 0 0 100%
Request for Service? (14.001) *
Did the institution receive and did the primary care provider review
the high-priority specialty service consultant report within the 12 3 0 80.0%
required time frame? (14.002) *
Did the patient receive the subsequent follow-up to the high-priority
specialty service appointment as ordered by the primary care 4 4 7 50.0%
provider? (14.003) *
Did the patient receive the medium-priority specialty service within
15-45 calendar days of the primary care provider order or Physician 13 2 0 86.7%
Request for Service? (14.004) *
Did the institution receive and did the primary care provider review
the medium-priority specialty service consultant report within the 7 8 0 46.7%
required time frame? (14.005) *
Did the patient receive the subsequent follow-up to the medium-
priority specialty service appointment as ordered by the primary care 6 0 9 100%
provider? (14.006) *
Did the patient receive the routine-priority specialty service within
90 calendar days of the primary care provider order or Physician 12 3 0 80.0%
Request for Service? (14.007) *
Did the institution receive and did the primary care provider review
the routine-priority specialty service consultant report within the 10 4 1 71.4%
required time frame? (14.008) *
Did the patient receive the subsequent follow-up to the routine-
priority specialty service appointment as ordered by the primary care 5 2 8 71.4%
provider? (14.009) *
For endorsed patients received from another CDCR institution: If the
patient was approved for a specialty services appointment at the
1 1 0 50.0%
sending institution, was the appointment scheduled at the receiving
institution within the required time frames? (14.010) *
Did the institution deny the primary care provider’s request for
15 1 0 93.8%
specialty services within required time frames? (14.011)
Following the denial of a request for specialty services, was the
patient informed of the denial within the required time frame? 13 3 0 81.3%
(14.012)
Overall percentage (MIT 14): 75.9%
* The OIG clinicians considered these compliance tests along with their case review findings when
determining the quality rating for this indicator.
Source: The Office of the Inspector General medical inspection results.
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Table 22. Other Tests Related to Specialty Services
Scored Answer
Compliance Questions Yes No N/A Yes %
Specialty service follow-up appointments: Did the clinician follow-up
38 4 3 90.5%
visits occur within required time frames? (1.008) *, †
Are specialty documents scanned into the patient’s electronic health 24 6 15 80.0%
record within five calendar days of the encounter date? (4.002) *
* The OIG clinicians considered these compliance tests along with their own case review findings
when determining the quality rating for this indicator.
† CCHCS changed its specialty policies in April 2019, removing the requirement for primary care
physician follow-up visits following most specialty services. As a result, we test 1.008 only for high-
priority specialty services or when the staff orders PCP or PC RN follow-ups. The OIG continues to test
the clinical appropriateness of specialty follow-ups through its case review testing.
Source: The Office of the Inspector General medical inspection results.
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Recommendations
•
Medical leadership should ensure providers follow specialty
recommendations and, if not, that providers document
medical reasoning.
•
Medical leadership should ensure patients receive their ordered
follow-up specialty appointment services timely.
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Administrative Operations
In this indicator, OIG compliance inspectors evaluated health care
administrative processes. Our inspectors examined the timeliness of the Overall
medical grievance process and checked whether the institution Rating
followed reporting requirements for adverse or sentinel events and Inadequate
patient deaths. Inspectors checked whether the Emergency Medical
Case Review
Response Review Committee (EMRRC) met and reviewed incident
Rating
packages. We reviewed and determined whether the institution
(N/A)
conducted the required emergency response drills. Inspectors also
assessed whether the Quality Management Committee (QMC) met Compliance
Score
regularly and addressed program performance adequately. In addition,
Inadequate
the inspectors examined if the institution provided training and job (71.2%)
performance reviews for its employees. They checked whether staff
possessed current, valid professional licenses, certifications, and
credentials. The OIG rated this indicator solely based on the
compliance score, using the same scoring thresholds as in the Cycle 4
and Cycle 5 medical inspections. Our case review clinicians do not rate
this indicator.
Because none of the tests in this indicator affected clinical patient care
directly (it is a secondary indicator), the OIG did not consider this
indicator’s rating when determining the institution’s overall
quality rating.
Results Overview
CCWF had mixed performance in this indicator. The institution scored
well in most applicable tests; however, a few areas had room for
improvement. The EMMRC had incomplete checklists. At the time of
our on-site inspection, we found the physician managers did not always
complete annual performance appraisals timely. In addition, nurse
educators completed onboarding for newly hired nurses late. We rated
this indicator inadequate.
Nonscored Results
We obtained CCHCS Death Review Committee (DRC) reporting data.
Two unexpected (Level 1) deaths and one expected (Level 2) death
occurred during our review period. The DRC must complete its death
review summary report within 60 calendar days of the death. When the
DRC completes the death review summary report, it must submit the
report to the institution’s CEO within seven calendar days of
completion. In our inspection, we found the DRC did not complete all
three death review reports promptly; the DRC finished three reports
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between 52 and 132 days late, and submitted them to the institution’s
CEO between five and 65 days late (MIT 15.998).
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Compliance Testing Results
Table 23. Administrative Operations
Scored Answer
Compliance Questions Yes No N/A Yes %
For health care incidents requiring root cause analysis (RCA): Did the
N/A N/A N/A N/A
institution meet RCA reporting requirements? (15.001)
Did the institution’s Quality Management Committee (QMC) meet
6 0 0 100%
monthly? (15.002)
For Emergency Medical Response Review Committee (EMRRC)
reviewed cases: Did the EMRRC review the cases timely, and did
2 10 0 16.7%
the incident packages the committee reviewed include the required
documents? (15.003)
For institutions with licensed care facilities: Did the Local Governing
Body (LGB) or its equivalent meet quarterly and discuss local 3 1 0 75.0%
operating procedures and any applicable policies? (15.004)
Did the institution conduct medical emergency response drills during
each watch of the most recent quarter, and did health care and 3 0 0 100%
custody staff participate in those drills? (15.101)
Did the responses to medical grievances address all of the inmates’
10 0 0 100%
appealed issues? (15.102)
Did the medical staff review and submit initial inmate death reports
1 2 0 33.3%
to the CCHCS Death Review Unit on time? (15.103)
Did nurse managers ensure the clinical competency of nurses who
10 0 0 100%
administer medications? (15.104)
Did physician managers complete provider clinical performance
0 12 0 0
appraisals timely? (15.105)
Did the providers maintain valid state medical licenses? (15.106) 13 0 0 100%
Did the staff maintain valid Cardiopulmonary Resuscitation (CPR),
Basic Life Support (BLS), and Advanced Cardiac Life Support (ACLS) 2 0 1 100%
certifications? (15.107)
Did the nurses and the pharmacist-in-charge (PIC) maintain valid
professional licenses and certifications, and did the pharmacy 6 0 1 100%
maintain a valid correctional pharmacy license? (15.108)
Did the pharmacy and the providers maintain valid Drug Enforcement
1 0 0 100%
Agency (DEA) registration certificates? (15.109)
Did nurse managers ensure their newly hired nurses received the
0 1 0 0
required onboarding and clinical competency training? (15.110)
This is a nonscored test. Please
Did the CCHCS Death Review Committee process death review
refer to the discussion in this
reports timely? (15.998)
indicator.
This is a nonscored test. Please
What was the institution’s health care staffing at the time of the OIG
refer to Table 4 for CCHCS-
medical inspection? (15.999)
provided staffing information.
Overall percentage (MIT 15): 71.2%
Source: The Office of the Inspector General medical inspection results.
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Recommendations
The OIG offers no specific recommendations for this indicator.
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Appendix A: Methodology
In designing the medical inspection program, the OIG met with
stakeholders to review CCHCS policies and procedures, relevant court
orders, and guidance developed by the American Correctional
Association. We also reviewed professional literature on correctional
medical care; reviewed standardized performance measures used by the
health care industry; consulted with clinical experts; and met with
stakeholders from the court, the receiver’s office, the department, the
Office of the Attorney General, and the Prison Law Office to discuss
the nature and scope of our inspection program. With input from these
stakeholders, the OIG developed a medical inspection program that
evaluates the delivery of medical care by combining clinical case
reviews of patient files, objective tests of compliance with policies and
procedures, and an analysis of outcomes for certain population-
based metrics.
We rate each of the quality indicators applicable to the institution
under inspection based on case reviews conducted by our clinicians or
compliance tests conducted by our registered nurses. Figure A–1 below
depicts the intersection of case review and compliance.
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Case Reviews
The OIG added case reviews to the Cycle 4 medical inspections at the
recommendation of its stakeholders, which continues in the Cycle 6
medical inspections. Below, Table A–1 provides important definitions
that describe this process.
Table A–1. Case Review Definitions
Case, Sample, The medical care provided to one patient over a specific
or Patient period, which can comprise detailed or focused case reviews.
A review that includes all aspects of one patient’s medical care
assessed over a six-month period. This review allows the OIG
Comprehensive
clinicians to examine many areas of health care delivery, such as
Case Review
access to care, diagnostic services, health information
management, and specialty services.
A review that focuses on one specific aspect of medical care.
Focused This review tends to concentrate on a singular facet of patient
Case Review care, such as the sick call process or the institution’s
emergency medical response.
A direct or indirect interaction between the patient and the
health care system. Examples of direct interactions include
Event provider encounters and nurse encounters. An example of an
indirect interaction includes a provider reviewing a diagnostic
test and placing additional orders.
A medical error in procedure or in clinical judgment. Both
Case Review
procedural and clinical judgment errors can result in policy
Deficiency
noncompliance, elevated risk of patient harm, or both.
Adverse Event An event that caused harm to the patient.
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The OIG eliminates case review selection bias by sampling using a rigid
methodology. No case reviewer selects the samples he or she reviews.
Because the case reviewers are excluded from sample selection, there is
no possibility of selection bias. Instead, nonclinical analysts use a
standardized sampling methodology to select most of the case review
samples. A randomizer is used when applicable.
For most basic institutions, the OIG samples 20 comprehensive
physician review cases. For institutions with larger high-risk
populations, 25 cases are sampled. For the California Health Care
Facility, 30 cases are sampled.
Case Review Sampling Methodology
We obtain a substantial amount of health care data from the inspected
institution and from CCHCS. Our analysts then apply filters to identify
clinically complex patients with the highest need for medical services.
These filters include patients classified by CCHCS with high medical
risk, patients requiring hospitalization or emergency medical services,
patients arriving from a county jail, patients transferring to and from
other departmental institutions, patients with uncontrolled diabetes or
uncontrolled anticoagulation levels, patients requiring specialty
services or who died or experienced a sentinel event (unexpected
occurrences resulting in high risk of, or actual, death or serious injury),
patients requiring specialized medical housing placement, patients
requesting medical care through the sick call process, and patients
requiring prenatal or postpartum care.
After applying filters, analysts follow a predetermined protocol and
select samples for clinicians to review. Our physician and nurse
reviewers test the samples by performing comprehensive or focused
case reviews.
Case Review Testing Methodology
An OIG physician, a nurse consultant, or both review each case. As the
clinicians review medical records, they record pertinent interactions
between the patient and the health care system. We refer to these
interactions as case review events. Our clinicians also record medical
errors, which we refer to as case review deficiencies.
Deficiencies can be minor or significant, depending on the severity of
the deficiency. If a deficiency caused serious patient harm, we classify
the error as an adverse event. On the next page, Figure A–2 depicts the
possibilities that can lead to these different events.
After the clinician inspectors review all the cases, they analyze the
deficiencies, then summarize their findings in one or more of the health
care indicators in this report.
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Figure A–2. Case Review Testing
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Compliance Testing
Compliance Sampling Methodology
Our analysts identify samples for both our case review inspectors and
compliance inspectors. Analysts follow a detailed selection
methodology. For most compliance questions, we use sample sizes of
approximately 25 to 30. Figure A–3 below depicts the relationships and
activities of this process.
Figure A–3. Compliance Sampling Methodology
Compliance Testing Methodology
Our inspectors answer a set of predefined medical inspection tool (MIT)
questions to determine the institution’s compliance with CCHCS
policies and procedures. Our nurse inspectors assign a Yes or a No
answer to each scored question.
OIG headquarters nurse inspectors review medical records to obtain
information, allowing them to answer most of the MIT questions. Our
regional nurses visit and inspect each institution. They interview health
care staff, observe medical processes, test the facilities and clinics,
review employee records, logs, medical grievances, death reports, and
other documents, and obtain information regarding plant infrastructure
and local operating procedures.
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Scoring Methodology
Our compliance team calculates the percentage of all Yes answers for
each of the questions applicable to a particular indicator, then averages
the scores. The OIG continues to rate these indicators based on the
average compliance score using the following descriptors: proficient
(85.0 percent or greater), adequate (between 84.9 percent and
75.0 percent), or inadequate (less than 75.0 percent).
Indicator Ratings and the Overall Medical
Quality Rating
To reach an overall quality rating, our inspectors collaborate and
examine all the inspection findings. We consider the case review, and
the compliance testing results for each indicator. After considering all
the findings, our inspectors reach consensus on an overall rating for
the institution.
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Appendix B: Case Review Data
Table B–1. CCWF Case Review Sample Sets
Sample Set Total
Anticoagulation 1
Death Review/Sentinel Events 3
Diabetes 3
Emergency Services – Non-CPR 3
High Risk 6
Hospitalization 3
Intrasystem Transfers In 3
Intrasystem Transfers Out 2
Perinatal Services 4
RN Sick Call 16
Specialty Services 4
48
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Table B–2. CCWF Case Review Chronic Care
Diagnoses
Diagnosis Total
Anemia 4
Anticoagulation 3
Arthritis/Degenerative Joint Disease 6
Asthma 13
COPD 1
COVID-19 9
Cancer 5
Cardiovascular Disease 5
Chronic Kidney Disease 3
Chronic Pain 12
Cirrhosis/End-Stage Liver Disease 1
Deep Venous Thrombosis/Pulmonary Embolism 1
Diabetes 13
Gastroesophageal Reflux Disease 9
Hepatitis C 7
Hyperlipidemia 8
Hypertension 20
Mental Health 20
Migraine Headaches 3
Rheumatological Disease 1
Seizure Disorder 3
Sleep Apnea 2
Substance Abuse 13
Thyroid Disease 7
169
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Table B–3. CCWF Case Review Events by Program
Diagnosis Total
Diagnostic Services 387
Emergency Care 76
Hospitalization 45
Intrasystem Transfers In 13
Intrasystem Transfers Out 7
Outpatient Care 749
Prenatal and Postpartum Care 23
Reception Center Care 12
Specialized Medical Housing 133
Specialty Services 172
1617
Table B–4. CCWF Case Review Sample Summary
MD Reviews Detailed 26
MD Reviews Focused 0
RN Reviews Detailed 17
RN Reviews Focused 19
Total Reviews 62
Total Unique Cases 48
Overlapping Reviews (MD & RN) 14
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Appendix C. Compliance Sampling Methodology
Central California Women’s Facility
Quality No. of
Indicator Sample Category Samples Data Source Filters
Access to Care
MIT 1.001 Chronic Care 25 Master Registry • Chronic care conditions (at least
Patients one condition per patient—any
risk level)
• Randomize
MIT 1.002 Nursing Referrals 13 OIG Q: 6.001 • See Transfers
MITs 1.003–006 Nursing Sick Call 30 Clinic Appointment • Clinic (each clinic tested)
(6 per clinic) List • Appointment date (2–9 months)
• Randomize
MIT 1.007 Returns From 17 OIG Q: 4.005 • See Health Information
Community Management (Medical Records)
Hospital (returns from community hospital)
MIT 1.008 Specialty Services 45 OIG Q: 14.001, • See Specialty Services
Follow-Up 14.004 & 14.007
MIT 1.101 Availability of 6 OIG on-site review • Randomly select one housing unit
Health Care from each yard
Services Request
Forms
Diagnostic Services
MITs 2.001–003 Radiology 10 Radiology Logs • Appointment date
(90 days–9 months)
• Randomize
• Abnormal
MITs 2.004–006 Laboratory 10 Quest • Appt. date (90 days–9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.007–009 Laboratory STAT 10 Quest • Appt. date (90 days–9 months)
• Order name (CBC or CMPs only)
• Randomize
• Abnormal
MITs 2.010–012 Pathology 10 InterQual • Appt. date (90 days–9 months)
• Service (pathology related)
• Randomize
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Health Care Services 30 OIG Qs: 1.004 • Nondictated documents
Request Forms • First 20 Ips for MIT 1.004
MIT 4.002 Specialty Documents 45 OIG Qs: 14.002, • Specialty documents
14.005 & 14.008 • First 10 Ips for each question
MIT 4.003 Hospital Discharge 17 OIG Q: 4.005 • Community hospital discharge
Documents documents
• First 20 Ips selected
MIT 4.004 Scanning Accuracy 24 Documents for any • Any misfiled or mislabeled
tested inmate document identified during
OIG compliance review (24 or
more = No)
MIT 4.005 Returns From 17 CADDIS Off-site • Date (2–8 months)
Community Hospital Admissions • Most recent 6 months provided
(within date range)
• Rx count
• Discharge date
• Randomize
Health Care Environment
MITs 5.101–105 Clinical Areas 10 OIG inspector • Identify and inspect all on-site
MITs 5.107–111 on-site review clinical areas.
Transfers
MITs 6.001–003 Intrasystem Transfers 13 SOMS • Arrival date (3–9 months)
• Arrived from (another
departmental facility)
• Rx count
• Randomize
MIT 6.101 Transfers Out 0 OIG inspector • R&R IP transfers with medication
on-site review
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic Care 25 OIG Q: 1.001 See Access to Care
Medication • At least one condition per
patient—any risk level
• Randomize
MIT 7.002 New Medication 25 Master Registry • Rx count
Orders • Randomize
• Ensure no duplication of Ips
tested in MIT 7.001
MIT 7.003 Returns From 17 OIG Q: 4.005 • See Health Information
Community Hospital Management (Medical Records)
(returns from community hospital)
MIT 7.004 RC Arrivals—
20
OIG Q: 12.001 • See Reception Center
Medication Orders
MIT 7.005 Intrafacility Moves 25 MAPIP transfer • Date of transfer (2–8 months)
data • To location/from location (yard to
yard and to/from ASU)
• Remove any to/from MHCB
• NA/DOT meds (and risk level)
• Randomize
MIT 7.006 En Route 0 SOMS • Date of transfer (2–8 months)
• Sending institution (another
departmental facility)
• Randomize
• NA/DOT meds
MITs 7.101–103 Medication Storage Varies OIG inspector • Identify and inspect clinical
Areas by test on-site review & med line areas that store
medications
MITs 7.104–107 Medication Varies OIG inspector • Identify and inspect on-site
Preparation and by test on-site review clinical areas that prepare and
Administration Areas administer medications
MITs 7.108–111 Pharmacy 1 OIG inspector • Identify & inspect all on-site
on-site review pharmacies
MIT 7.112 Medication Error 25 Medication error • All medication error reports with
Reporting reports Level 4 or higher
• Select total of 25 medication
error reports (recent 12 months)
MIT 7.999 Restricted Unit
10
On-site active • KOP rescue inhalers &
KOP Medications medication listing nitroglycerin medications for Ips
housed in restricted units
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Quality No. of
Indicator Sample Category Samples Data Source Filters
Prenatal and Postpartum Care
MITs 8.001–007 Recent Deliveries
0
OB Roster • Delivery date (2–12 months)
• Most recent deliveries (within
date range)
Pregnant Arrivals
3
OB Roster • Arrival date (2–12 months)
• Earliest arrivals (within date
range)
Preventive Services
MITs 9.001–002 TB Medications 20 Maxor • Dispense date (past 9 months)
• Time period on TB meds
(3 months or 12 weeks)
• Randomize
MIT 9.003 TB Evaluation, 25 SOMS • Arrival date (at least 1 year prior
Annual Screening to inspection)
• Birth month
• Randomize
MIT 9.004 Influenza 25 SOMS • Arrival date (at least 1 year prior
Vaccinations to inspection)
• Randomize
• Filter out Ips tested in MIT 9.008
MIT 9.005 Colorectal Cancer 25 SOMS • Arrival date (at least 1 year prior
Screening to inspection)
• Date of birth (51 or older)
• Randomize
MIT 9.006 Mammogram
25
SOMS • Arrival date (at least 2 yrs. Prior
to inspection)
• Date of birth (age 52–74)
• Randomize
MIT 9.007 Pap Smear
25
SOMS • Arrival date (at least three yrs.
Prior to inspection)
• Date of birth (age 24–53)
• Randomize
MIT 9.008 Chronic Care 25 OIG Q: 1.001 • Chronic care conditions (at least
Vaccinations 1 condition per IP—any risk level)
• Randomize
• Condition must require
vaccination(s)
MIT 9.009 Valley Fever N/A at this Cocci transfer • Reports from past 2–8 months
institution status report • Institution
• Ineligibility date (60 days prior to
inspection date)
• All
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 112
Quality No. of
Indicator Sample Category Samples Data Source Filters
Reception Center
MITs 12.001–008 Reception Center
20
SOMS • Arrival date (2–8 months)
• Arrived from (county jail, return
from parole, etc.)
• Randomize
Specialized Medical Housing
MITs 13.001–004 Specialized Health 10 CADDIS • Admit date (2–8 months)
Care Housing Unit • Type of stay (no MH beds)
• Length of stay (minimum of
5 days)
• Rx count
• Randomize
MITs 13.101–102 Call Buttons All OIG inspector • Specialized Health Care Housing
on-site review • Review by location
Specialty Services
MITs 14.001–003 High-Priority 15 Specialty Services • Approval date (3–9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C,
HIV, orthotics, gynecology,
consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, and
radiology services
• Randomize
MITs 14.004–006 Medium-Priority 15 Specialty Services • Approval date (3–9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C,
HIV, orthotics, gynecology,
consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, and
radiology services
• Randomize
MITs 14.007–009 Routine-Priority 15 Specialty Services • Approval date (3–9 months)
Initial and Follow-Up Appointments • Remove consult to audiology,
RFS chemotherapy, dietary, Hep C,
HIV, orthotics, gynecology,
consult to public health/Specialty
RN, dialysis, ECG 12-Lead (EKG),
mammogram, occupational
therapy, ophthalmology,
optometry, oral surgery, physical
therapy, physiatry, podiatry, and
radiology services
• Randomize
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 113
MIT 14.010 Specialty Services 2 Specialty Services • Arrived from (other departmental
Arrivals Arrivals institution)
• Date of transfer (3–9 months)
• Randomize
MITs 14.011–012 Denials 16 InterQual • Review date (3–9 months)
• Randomize
N/A IUMC/MAR • Meeting date (9 months)
Meeting Minutes • Denial upheld
• Randomize
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 114
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.001 Adverse/sentinel 0 Adverse/sentinel • Adverse/Sentinel events
events (ASE) events report (2–8 months)
MIT 15.002 QMC Meetings 6 Quality • Meeting minutes (12 months)
Management
Committee
meeting minutes
MIT 15.003 EMRRC 12 EMRRC meeting • Monthly meeting minutes
minutes (6 months)
MIT 15.004 LGB 4 LGB meeting • Quarterly meeting minutes
minutes (12 months)
MIT 15.101 Medical Emergency 3 On-site summary • Most recent full quarter
Response Drills reports & • Each watch
documentation for
ER drills
MIT 15.102 Institutional Level 10 On-site list of • Medical grievances closed
Medical Grievances grievances/closed (6 months)
grievance files
MIT 15.103 Death Reports 3 Institution-list of • Most recent 10 deaths
deaths in prior • Initial death reports
12 months
MIT 15.104 Nursing Staff 10 On-site nursing • On duty one or more years
Validations education files • Nurse administers medications
• Randomize
MIT 15.105 Provider Annual 12 On-site • All required performance
Evaluation Packets provider evaluation documents
evaluation files
MIT 15.106 Provider Licenses 13 Current provider • Review all
listing (at start of
inspection)
MIT 15.107 Medical Emergency All On-site • All staff
Response certification ◦ Providers (ACLS)
Certifications tracking logs ◦ Nursing (BLS/CPR)
• Custody (CPR/BLS)
MIT 15.108 Nursing Staff and All On-site tracking • All required licenses and
Pharmacist in Charge system, logs, or certifications
Professional Licenses employee files
and Certifications
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 115
Quality No. of
Indicator Sample Category Samples Data Source Filters
Administrative Operations
MIT 15.109 Pharmacy and All On-site listing • All DEA registrations
Providers’ Drug of provider DEA
Enforcement Agency registration #s
(DEA) Registrations & pharmacy
registration
document
MIT 15.110
Nursing Staff New All
Nursing staff • New employees (hired within last
Employee training logs 12 months)
Orientations
MIT 15.998
Death Review 3
OIG summary log: • Between 35 business days &
Committee deaths 12 months prior
• California Correctional
Health Care Services death
reviews
Office of the Inspector General, State of California Inspection Period: August 2020 - February 2021 Report Issued: January 2022
Cycle 6, Central California Women’s Facility | 116
California Correctional Health Care
Services’ Response
Office of the Inspector General, State of California Inspection Period: June 2020 – November 2020 Report Issued: January 2022
Cycle 6
Medical Inspection Report
for
Central California Women’s Facility
OFFICE of the
INSPECTOR GENERAL
Amarik K. Singh
Inspector General
Bryan B. Beyer
Chief Deputy Inspector General
STATE of CALIFORNIA
January 2022
OIG