OIG
California Medical Facility Medical Inspection Report Cycle 4
Read the report at CDCR ↗
Robert A. Barton Office of the Inspector General
Inspector General
California Medical Facility
Medical Inspection Results
Cycle 4
September 2016
Medical Inspection Unit Page 1
Office of the Inspector General State of California
Office of the Inspector General
CALIFORNIA MEDICAL FACILITY
Medical Inspection Results
Cycle 4
Robert A. Barton
Inspector General
Roy W. Wesley
Chief Deputy Inspector General
Shaun R. Spillane
Public Information Officer
September 2016
TABLE OF CONTENTS
Executive Summary ............................................................................................................................. i
Overall Assessment: Inadequate ........................................................................................... iii
Clinical Case Review and OIG Clinician Inspection Results ............................................... iii
Compliance Testing Results................................................................................................... v
Population-Based Metrics ..................................................................................................... ix
Introduction ......................................................................................................................................... 1
About the Institution ........................................................................................................................... 1
Objectives, Scope, and Methodology.................................................................................................. 5
Case Reviews ................................................................................................................................... 6
Patient Selection for Retrospective Case Reviews .................................................................... 6
Benefits and Limitations of Targeted Subpopulation Review .................................................. 7
Case Reviews Sampled ............................................................................................................. 8
Compliance Testing ......................................................................................................................... 9
Sampling Methods for Conducting Compliance Testing .......................................................... 9
Scoring of Compliance Testing Results .................................................................................... 9
Dashboard Comparisons ......................................................................................................... 10
Overall Quality Indicator Rating for Case Reviews and Compliance Testing .............................. 10
Population-Based Metrics .............................................................................................................. 11
Medical Inspection Results ............................................................................................................... 12
Primary (Clinical) Quality Indicators of Health Care .................................................................... 12
Access to Care ......................................................................................................................... 14
Case Review Results ............................................................................................................ 14
Compliance Testing Results................................................................................................. 16
Recommendations ................................................................................................................ 18
Diagnostic Services ................................................................................................................. 19
Case Review Results ............................................................................................................ 19
Compliance Testing Results................................................................................................. 21
Recommendation for CCHCS .............................................................................................. 22
Recommendations for CMF ................................................................................................. 22
Emergency Services................................................................................................................. 23
Case Review Results ............................................................................................................ 23
Recommendation for CCHCS .............................................................................................. 26
Recommendations for CMF ................................................................................................. 27
Health Information Management (Medical Records) ............................................................. 28
Case Review Results ............................................................................................................ 28
Compliance Testing Results................................................................................................. 30
Recommendations ................................................................................................................ 31
Health Care Environment ....................................................................................................... 32
Compliance Testing Results................................................................................................. 32
Recommendations ................................................................................................................ 34
California Medical Facility, Cycle 4 Medical Inspection Table of Contents
Office of the Inspector General State of California
Inter- and Intra-System Transfers ........................................................................................... 35
Case Review Results ............................................................................................................ 35
Compliance Testing Results................................................................................................. 37
Recommendations ................................................................................................................ 38
Pharmacy and Medication Management ................................................................................ 39
Case Review Results ............................................................................................................ 39
Compliance Testing Results................................................................................................. 40
Recommendations ................................................................................................................ 44
Preventive Services ................................................................................................................. 45
Compliance Testing Results................................................................................................. 45
Recommendations ................................................................................................................ 46
Quality of Nursing Performance ............................................................................................. 47
Case Review Results ............................................................................................................ 47
Recommendations ................................................................................................................ 54
Quality of Provider Performance ............................................................................................ 55
Case Review Results ............................................................................................................ 55
Recommendations ................................................................................................................ 59
Specialized Medical Housing (OHU, CTC, SNF, Hospice) .................................................... 60
Case Review Results ............................................................................................................ 60
Compliance Testing Results................................................................................................. 64
Recommendations ................................................................................................................ 65
Specialty Services .................................................................................................................... 66
Case Review Results ............................................................................................................ 66
Compliance Testing Results................................................................................................. 68
Recommendations ................................................................................................................ 69
Secondary (Administrative) Quality Indicators of Health Care..................................................... 70
Internal Monitoring, Quality Improvement, and Administrative Operations ......................... 71
Compliance Testing Results................................................................................................. 71
Recommendations ................................................................................................................ 73
Job Performance, Training, Licensing, and Certifications ..................................................... 74
Compliance Testing Results................................................................................................. 74
Recommendations ................................................................................................................ 75
Population-Based Metrics .............................................................................................................. 76
Appendix A — Compliance Test Results ......................................................................................... 80
Appendix B — Clinical Data ............................................................................................................ 94
Appendix C — Compliance Sampling Methodology ....................................................................... 97
California Correctional Health Care Services’ Response ................................................................. 98
California Medical Facility, Cycle 4 Medical Inspection Table of Contents
Office of the Inspector General State of California
LIST OF TABLES AND FIGURES
Health Care Quality Indicators ........................................................................................................... ii
CMF Executive Summary Table ..................................................................................................... viii
CMF Health Care Staffing Resources as of February 2016 ................................................................ 2
CMF Master Registry Data as of February 8, 2016 ............................................................................. 3
Commonly Used Abbreviations .......................................................................................................... 4
CMF Results Compared to State and National HEDIS Scores .......................................................... 79
California Medical Facility, Cycle 4 Medical Inspection List of Tables and Figures
Office of the Inspector General State of California
EXECUTIVE SUMMARY
Under the authority of California Penal Code Section 6126, which assigns the Office of the
Inspector General (OIG) responsibility for oversight of the California Department of Corrections
and Rehabilitation (CDCR), the OIG conducts a comprehensive inspection program to evaluate the
delivery of medical care at each of CDCR’s 35 adult prisons. The OIG explicitly makes no
determination regarding the constitutionality of care in the prison setting. That determination is left
to the Receiver and the federal court. The assessment of care by the OIG is just one factor in the
court’s determination whether care in the prisons meets constitutional standards. The court may find
that an institution the OIG found to be providing adequate care still did not meet constitutional
standards, depending on the analysis of the underlying data provided by the OIG. Likewise, an
institution that has been rated inadequate by the OIG could still be found to pass constitutional
muster with the implementation of remedial measures if the underlying data were to reveal easily
mitigated deficiencies.
The OIG’s inspections are mandated by the Penal Code and not aimed at specifically resolving the
court’s questions on constitutional care. To the degree that they provide another factor for the court
to consider, the OIG is pleased to provide added value to the taxpayers of California.
For this fourth cycle of inspections, the OIG added a clinical case review component and
significantly enhanced the compliance portion of the inspection process from that used in prior
cycles. In addition, the OIG added a population-based metric comparison of selected Healthcare
Effectiveness Data Information Set (HEDIS) measures from other State and national health care
organizations and compared that data to similar results for the California Medical Facility (CMF).
The OIG performed its Cycle 4 medical inspection at CMF from February to April 2016. The
inspection included in-depth reviews of 82 inmate-patient files conducted by clinicians, as well as
reviews of documents from 407 inmate-patient files, covering 92 objectively scored tests of
compliance with policies and procedures applicable to the delivery of medical care. The OIG
assessed the case review and compliance results at CMF using 14 health care quality indicators
applicable to the institution, made up of 12 primary clinical indicators and two secondary
administrative indicators. To conduct clinical case reviews, the OIG employs a clinician team
consisting of a physician and a registered nurse consultant, while compliance testing is done by a
team of deputy inspectors general and registered nurses trained in monitoring medical compliance.
Of the 12 primary indicators, seven were rated by both case review clinicians and compliance
inspectors, three were rated by case review clinicians only, and two were rated by compliance
inspectors only; both secondary indicators were rated by compliance inspectors only. See the Health
Care Quality Indicators table on page ii. Based on that analysis, OIG experts made a considered
and measured overall opinion that the quality of health care at CMF was inadequate.
California Medical Facility, Cycle 4 Medical Inspection Page i
Office of the Inspector General State of California
Health Care Quality Indicators
All Institutions– CMF
Fourteen Primary Indicators (Clinical)
Applicability Applicability
Both case review
1–Access to Care All institutions
and compliance
Both case review
2–Diagnostic Services All institutions
and compliance
3–Emergency Services All institutions Case review only
4–Health Information Management Both case review
All institutions
(Medical Records) and compliance
5–Health Care Environment All institutions Compliance only
Both case review
6–Inter- and Intra-System Transfers All institutions
and compliance
Both case review
7–Pharmacy and Medication Management All institutions
and compliance
Female institutions
8–Prenatal and Post-Delivery Services Not applicable
only
9–Preventive Services All institutions Compliance only
10–Quality of Nursing Performance All institutions Case review only
11–Quality of Provider Performance All institutions Case review only
Institutions with
12–Reception Center Arrivals Not applicable
reception centers
All institutions with
13–Specialized Medical Housing Both case review
an OHU, CTC, SNF,
(OHU, CTC, SNF, Hospice) and compliance
or hospice
Both case review
14–Specialty Services All institutions
and compliance
Two Secondary Indicators All Institutions– CMF
(Administrative) Applicability Applicability
15–Internal Monitoring, Quality
Improvement, and Administrative All institutions Compliance only
Operations
16–Job Performance, Training, Licensing,
All institutions Compliance only
and Certifications
California Medical Facility, Cycle 4 Medical Inspection Page ii
Office of the Inspector General State of California
Overall Assessment: Inadequate
Based on the clinical case reviews and compliance testing, the
OIG’s overall assessment rating for CMF was inadequate. Of the
Overall Assessment
12 primary (clinical) quality indicators applicable to CMF, the
Rating:
OIG found seven adequate and five inadequate. Of the two
secondary (administrative) quality indicators, the OIG found both
Inadequate
inadequate. To determine the overall assessment for CMF, the
OIG considered individual clinical ratings and individual
compliance question scores within each of the indicator
categories, putting emphasis on the primary indicators. Based on that analysis, OIG experts made a
considered and measured overall opinion about the quality of health care observed at CMF.
Clinical Case Review and OIG Clinician Inspection Results
The clinicians’ case reviews sampled patients with high medical needs and included a review of
1,283 patient care events.1 Of the 12 primary indicators applicable to CMF, ten were evaluated by
clinician case review; eight were adequate, and two were inadequate. When determining the overall
adequacy of care, the OIG paid particular attention to the clinical nursing and provider quality
indicators, as adequate health care staff can sometimes overcome suboptimal processes and
programs. The OIG clinicians identify inadequate medical care based on the risk of significant harm
to the patient, not the actual outcome. While CMF providers overcame many systemic problems,
they were not able to overcome poor nursing performance and an inadequate after-hours on-call
coverage system.
Patient care at CMF demanded frequent provider encounters and exceptional provider performance.
When those conditions were met, patients received adequate care, despite widespread problems
with non-existent or inadequate nursing evaluations. Most of the time, CMF providers successfully
mitigated these problems, as 22 of the 30 detailed physician-reviewed cases were judged adequate
or proficient. However, eight other cases had deficiencies that required a rating of inadequate.
The OIG clinicians rated two indicators inadequate: Emergency Services and Quality of Nursing
Performance. In each of these indicators, nurses failed to adequately perform independent or
thorough nursing evaluations. Insufficient physician coverage after hours did not allow providers to
mitigate nursing problems in Emergency Services. Both indicators address vital components of an
adequately performing institution.
1 Each OIG clinician team includes a board-certified physician and registered nurse consultant with experience in
correctional and community medical settings.
California Medical Facility, Cycle 4 Medical Inspection Page iii
Office of the Inspector General State of California
Program Strengths — Clinical
The institution had an extremely well-run hospice program. CMF providers, nurses, and
other staff provided exceptionally caring, compassionate, and high-quality care. CMF used a
multidisciplinary team approach to provide patients with maximum comfort and dignity at
the end of life.
Providers in the correctional treatment center (CTC) and outpatient housing unit (OHU)
performed at high levels. The history and physical (H&P) examination documentation and
corresponding discharge summaries demonstrated thorough review of records as well as
excellent assessment and decision-making.
Physicians and pharmacists at CMF provided proficient onsite HIV, hepatitis C, and
anticoagulation services.
Specialty services access at CMF was excellent, both for routine and for high-priority
referrals. The specialty department also developed a secondary process whereby all specialty
reports were tracked, retrieved, reviewed for recommendations, and forwarded to the PCP
for additional review. While this process was not documented in the medical record, it did
ensure that patients were provided with good specialty care.
Program Weaknesses — Clinical
The institution often failed to give patients a follow-up appointment with their PCP after
they were seen in the triage and treatment area (TTA) or when the on-call physician ordered
the appointment.2
Emergency response at CMF was inadequate. There was evidence that critical emergency
equipment was not readily available during a medical emergency. Case reviews identified a
strong pattern of inadequate nursing evaluations and delayed physician notification. On-call
providers occasionally made poor and inaccurate assessments over the telephone, which
markedly increased the risk of medical harm and likely contributed to one preventable death.
Nurses at CMF demonstrated poor performance in multiple areas, including emergency
services, return from hospital or specialty services, CTC, and sick call. When patients
submitted requests that described their symptoms, sick call nurses regularly failed to see
them. More importantly, sick call nurses frequently failed to recognize urgent symptoms and
often triaged their patients inappropriately.
2 CMF has a State-licensed stand-by emergency room that functions similarly to a TTA. For consistency with the
common terminology at the majority of institutions, the OIG refers to the stand-by emergency room as the TTA
throughout this report.
California Medical Facility, Cycle 4 Medical Inspection Page iv
Office of the Inspector General State of California
Nurses in the CTC failed to meet standards of nursing practice. They did not assess their
patients every shift. When CTC nurses did perform assessments, they were often inadequate.
Documentation was also poor. The OIG clinicians found deficiencies regarding even basic
observations, such as vital signs, patient safety during restraint, and fluid intake for patients
on fluid restriction.
Compliance Testing Results
Of the 14 total health care indicators applicable to CMF, 11 were evaluated by compliance
inspectors.3 There were 92 individual compliance questions within those 11 indicators, generating
1,412 data points, that tested CMF’s compliance with California Correctional Health Care Services
(CCHCS) policies and procedures.4 Those 92 questions are detailed in Appendix A — Compliance
Test Results. The institution’s inspection scores in the 11 applicable indicators ranged from
53.7 percent to 78.4 percent, with the secondary (administrative) indicator Internal Monitoring,
Quality Improvement, and Administrative Operations receiving the lowest score, and the primary
indicator Access to Care receiving the highest. Of the nine primary indicators applicable to
compliance testing, the OIG rated zero proficient, three adequate, and six inadequate. Of the two
secondary indicators, which involve administrative health care functions, both were rated
inadequate.
Program Strengths — Compliance
As the CMF Executive Summary Table on page viii indicates, the institution did not have any
primary or secondary indicator areas that received a proficient compliance rating. However, the
following are some of CMF’s strengths based on its compliance scores for individual questions in
all the primary health care indicators:
Nursing staff timely reviewed patient requests for medical services within the required time
frame, and patients received a timely provider visit when ordered by nursing staff.
The institution provided radiology and laboratory services within required time frames.
Staff ensured that CMF clinics’ invasive and non-invasive reusable equipment was properly
sterilized and disinfected, and clinics had operable sinks and sufficient quantities of hygiene
supplies.
Institution staff followed proper administrative controls during medication preparation for
medication pill lines.
3 The OIG’s compliance inspectors are trained deputy inspectors general and registered nurses with expertise in CDCR
policies regarding medical staff and processes.
4 The OIG used its own clinicians to provide clinical expert guidance for testing compliance in certain areas where
CCHCS policies and procedures did not specifically address an issue.
California Medical Facility, Cycle 4 Medical Inspection Page v
Office of the Inspector General State of California
The institution’s main and satellite pharmacies followed general security, organization, and
cleanliness management protocols; properly stored refrigerated and frozen medications; and
properly accounted for narcotic medication.
Nursing staff completed initial assessments on the same day a provider admitted a patient to
the CTC, OHU, or hospice units.
Patients received their high-priority and routine specialty services within required time
frames.
The following are some of the strengths identified within the two secondary administrative
indicators:
Emergency response drills at the institution were completed for each watch in the last
quarter that inspectors tested.
Providers received performance evaluations within required time frames.
Program Weaknesses — Compliance
The institution received ratings of inadequate, scoring below 75 percent, in the following six
primary indicators: Health Information Management (Medical Records), Health Care Environment,
Inter- and Intra-System Transfers, Pharmacy and Medication Management, Preventive Services,
and Specialty Services. The institution also received an inadequate score in the two secondary
indicators Internal Monitoring, Quality Improvement, and Administrative Operations and Job
Performance, Training, Licensing, and Certifications. The following are some of the weaknesses
identified by CMF’s compliance scores for individual questions in all the primary health care
indicators:
Nursing staff did not always complete SOAPE notes for sick call encounters.
Patients did not always receive a timely provider follow-up appointment upon return from a
community hospital or a specialty service appointment.
Providers did not always review and communicate pathology results within the required
time frames.
Providers did not timely review hospital discharge reports when patients returned to the
institution for the majority of sampled patients.
Clinical staff did not always use proper hand hygiene, clinic common areas and exam rooms
did not always have all essential equipment available, and some clinic exam rooms did not
have an adequate environment to allow a clinician perform a comprehensive examination.
California Medical Facility, Cycle 4 Medical Inspection Page vi
Office of the Inspector General State of California
Patients did not always receive their chronic care medication within required time frames.
The institution did not employ strong controls at medication line locations for narcotic
medications, and storage protocols were weak for both refrigerated and non-refrigerated
non-narcotic medication.
Nursing staff did not always follow proper hand hygiene protocols and administrative
procedures for medication distribution.
Patients at CMF did not always timely receive their tuberculosis medication, and the
institution’s monthly monitoring of these patients was poor. In addition, CMF did not
perform well with annual tuberculosis screenings.
Patients who arrived at CMF from another institution with pending specialty services
appointments did not always receive their appointments within the required time frame.
The following are some of the weaknesses identified within the two secondary administrative
indicators:
Nurse supervisors did not complete proper reviews of nursing staff, and the institution did
not provide new employee orientation training to all new nursing staff.
The CMF Executive Summary Table on the following page lists the quality indicators the OIG
inspected and assessed during the clinical case reviews and objective compliance tests, and provides
the institution’s rating in each area. The overall indicator ratings were based on a consensus
decision by the OIG’s clinicians and non-clinical inspectors.
California Medical Facility, Cycle 4 Medical Inspection Page vii
Office of the Inspector General State of California
CMF Executive Summary Table
Case
Compliance Overall Indicator
Primary Indicators (Clinical) Review
Rating Rating
Rating
Access to Care Adequate Adequate Adequate
Diagnostic Services Adequate Adequate Adequate
Emergency Services Inadequate Not Applicable Inadequate
Health Information Management
Adequate Inadequate Adequate
(Medical Records)
Health Care Environment Not Applicable Inadequate Inadequate
Inter- and Intra-System Transfers Adequate Inadequate Adequate
Pharmacy and Medication Management Adequate Inadequate Inadequate
Preventive Services Not Applicable Inadequate Inadequate
Quality of Nursing Performance Inadequate Not Applicable Inadequate
Quality of Provider Performance Adequate Not Applicable Adequate
Specialized Medical Housing
Adequate Adequate Adequate
(OHU, CTC, SNF, Hospice)
Specialty Services Adequate Inadequate Adequate
The Prenatal and Post-Delivery Services and Reception Center Arrivals indicators did not apply
to this institution.
Secondary Indicators (Administrative)
Internal Monitoring, Quality Improvement,
Not Applicable Inadequate Inadequate
and Administrative Operations
Job Performance, Training, Licensing, and
Not Applicable Inadequate Inadequate
Certifications
Compliance results for quality indicators are proficient (greater than 85.0 percent), adequate
(75.0 percent to 85.0 percent), or inadequate (below 75.0 percent).
California Medical Facility, Cycle 4 Medical Inspection Page viii
Office of the Inspector General State of California
Population-Based Metrics
Overall, population-based metrics showed that CMF’s State and national comparative performance
was generally adequate for diabetic and immunization measures, but has room for improvement for
colorectal cancer screening. Statewide, the institution outperformed Medi-Cal in all five diabetic
measures. In addition, the institution outperformed Kaiser North in four of the five diabetic
measures, with Kaiser outperforming the institution in blood pressure control. However, CMF only
outperformed Kaiser South in three of five diabetic measures, with Kaiser South outperforming the
institution in blood pressure control and eye exams. Nationally, CMF outperformed or matched
Medicaid, commercial entities (based on data obtained from health maintenance organizations),
Medicare, and the United States Department of Veterans Affairs (VA) in all five applicable diabetic
measures.
With regard to immunization measures, CMF scores were average, outperforming all statewide and
national health management organizations for administering influenza vaccinations for younger
adults. The institution outperformed Medicare for administering influenza vaccinations for older
adults and pneumococcal vaccinations, but underperformed compared to the VA for the same
immunization measures. The institution performed more poorly for colorectal cancer screening than
all statewide and national health care organizations, but a high rate of patient refusals for cancer
screenings negatively affected the institution’s score.
Overall, CMF’s performance demonstrated by population-based metrics indicated that the
comprehensive diabetes care and immunizations were average in comparison to statewide and
national health care organizations. Colorectal cancer screenings were below average; however, the
institution has room for improvement by making interventions to reduce the rate of patient refusals
for colorectal cancer screenings.
California Medical Facility, Cycle 4 Medical Inspection Page ix
Office of the Inspector General State of California
INTRODUCTION
Under the authority of California Penal Code Section 6126, which assigns the Office of the
Inspector General (OIG) responsibility for oversight of the California Department of Corrections
and Rehabilitation (CDCR), and at the request of the federal Receiver, the OIG developed a
comprehensive medical inspection program to evaluate the delivery of medical care at each of
CDCR’s 35 adult prisons. For this fourth cycle of inspections, the OIG augmented the breadth and
quality of its inspection program used in prior cycles, adding a clinical case review component and
significantly enhancing the compliance component of the program.
The California Medical Facility (CMF) was the 22nd medical inspection of Cycle 4. During the
inspection process, the OIG assessed the delivery of medical care to patients for 12 primary clinical
health care indicators and two secondary administrative health care indicators applicable to the
institution. It is important to note that while the primary quality indicators represent the clinical care
being provided by the institution at the time of the inspection, the secondary quality indicators are
purely administrative and are not reflective of the actual clinical care provided.
The OIG is committed to reporting on each institution’s delivery of medical care to assist in
identifying areas for improvement, but the federal court will ultimately determine whether any
institution’s medical care meets constitutional standards.
ABOUT THE INSTITUTION
The California Medical Facility was established in 1955 by the Legislature to provide a centrally
located medical psychiatric institution for the health care needs of the male felon population in
California’s prisons. CMF is designated an “intermediate care prison”; these institutions are located
in predominantly urban areas close to tertiary care centers and specialty care providers for the most
cost-effective care. The facility comprises a correctional treatment center, an outpatient housing
unit, a licensed elderly care unit, inpatient and outpatient psychiatric facilities, a hospice unit for
terminally ill inmates, housing and treatment for inmates identified with HIV/AIDS, general
population housing, and other special inmate housing. Along with multiple clinics that handle daily
non-urgent requests for medical services, CMF has a treatment and triage area (TTA or standby
emergency room). On August 16, 2015, the institution received national accreditation from the
Commission on Accreditation for Corrections. This accreditation program is a professional peer
review process based on national standards set by the American Correctional Association.
California Medical Facility, Cycle 4 Medical Inspection Page 1
Office of the Inspector General State of California
According to information provided by the institution (not audited by the OIG), CMF’s overall
vacancy rate among medical managers, primary care providers, nursing supervisors, and
non-supervisory nurses was 16 percent in February 2016. The highest number of vacancies was
among nursing staff with 38.9 vacant positions, resulting in a 16 percent vacancy rate. In addition,
14 nursing staff were on long-term medical leave. As a result, CMF used eight registry nurses to
compensate for nursing vacancies. Providers had three vacant positions, which resulted in a
20 percent vacancy rate, and management had one vacant position that resulted in a 25 percent
vacancy rate. Lastly, the CEO reported that no medical staff at CMF was redirected as of February
2016.
CMF Health Care Staffing Resources as of February 2016
Primary Care Nursing
Management Nursing Staff Totals
Providers Supervisors
Description Number % Number % Number % Number % Number %
Authorized
4 1% 15 5% 19.6 7% 244.9 87% 283.5 100%
Positions
Filled Positions 3 75% 12 80% 18 92% 206 84% 239 84%
Vacancies 1 25% 3 20% 1.6 8% 38.9 16% 44.5 16%
Recent Hires
(within 12 2 67% 0 0% 1 6% 28 14% 31 13%
months)
Staff Utilized from
0 0% 1 8% 0 0% 8 4% 9 4%
Registry
Redirected Staff
(to
0 0% 0 0% 0 0% 0 0% 0 0%
Non-Patient- Care
Areas)
Staff on
Long-term 0 0% 0 0% 0 0% 14 7% 14 6%
Medical Leave
Note: CMF Health Care Staffing Resources data was not validated by the OIG.
California Medical Facility, Cycle 4 Medical Inspection Page 2
Office of the Inspector General State of California
As of February 8, 2016, the Master Registry for CMF showed that the institution had a total
population of 2,549. Within that total population, 20.4 percent were designated as high medical risk,
Priority 1 (High 1), and 27.3 percent were designated as high medical risk, Priority 2 (High 2).
Patients’ assigned risk levels are based on the complexity of their required medical care related to
their specific diagnoses, frequency of higher levels of care, age, and abnormal labs and procedures.
High 1 has at least two high-risk conditions; High 2 has only one. Patients at high medical risk are
more susceptible to poor health outcomes than those at medium or low medical risk. Patients at high
medical risk also typically require more health care services than do patients with lower assigned
risk levels. The chart below illustrates the breakdown of the institution’s medical risk levels at the
start of the OIG medical inspection.
CMF Master Registry Data as of February 8, 2016
Medical Risk Level # of Inmate-Patients Percentage
High 1 519 20.4%
High 2 697 27.3%
Medium 1,043 40.9%
Low 290 11.4%
Total 2,549 100.0%
California Medical Facility, Cycle 4 Medical Inspection Page 3
Office of the Inspector General State of California
Commonly Used Abbreviations
ACLS Advanced Cardiovascular Life Support HIV Human Immunodeficiency Virus
AHA American Heart Association HTN Hypertension
ASU Administrative Segregation Unit INH Isoniazid (anti-tuberculosis medication)
BLS Basic Life Support IV Intravenous
CBC Complete Blood Count KOP Keep-on-Person (in taking medications)
CC Chief Complaint LPT Licensed Psychiatric Technician
CCHCS California Correctional Health Care Services LVN Licensed Vocational Nurse
CCP Chronic Care Program MAR Medication Administration Record
California Department of Corrections and
CDCR MRI Magnetic Resonance Imaging
Rehabilitation
CEO Chief Executive Officer MD Medical Doctor
CHF Congestive Heart Failure NA Nurse Administered (in taking medications)
CME Chief Medical Executive N/A Not Applicable
CMP Comprehensive Metabolic (Chemistry) Panel NP Nurse Practitioner
CNA Certified Nursing Assistant OB0 Obstetrician
CNE Chief Nurse Executive OHU Outpatient Housing Unit
C/O Complains of OIG Office of the Inspector General
COPD Chronic Obstructive Pulmonary Disease P&P Policies and Procedures (CCHCS)
CP&S Chief Physician and Surgeon PA Physician Assistant
CPR Cardio-Pulmonary Resuscitation PCP Primary Care Provider
CSE Chief Support Executive POC Point of Contact
CT Computerized Tomography PPD Purified Protein Derivative
CTC Correctional Treatment Center PRN As Needed (in taking medications)
DM Diabetes Mellitus RN Registered Nurse
Directly Observed Therapy (in taking
DOT Rx Prescription
medications)
Dx Diagnosis SNF Skilled Nursing Facility
Subjective, Objective, Assessment, Plan,
EKG Electrocardiogram SOAPE
Education
ENT Ear, Nose and Throat SOMS Strategic Offender Management System
ER Emergency Room S/P Status Post
eUHR electronic Unit Health Record TB Tuberculosis
FTF Face-to-Face TTA Triage and Treatment Area
History and Physical (reception center
H&P UA Urinalysis
examination)
HIM Health Information Management UM Utilization Management
California Medical Facility, Cycle 4 Medical Inspection Page 4
Office of the Inspector General State of California
OBJECTIVES, SCOPE, AND METHODOLOGY
In designing the medical inspection program, the OIG reviewed CCHCS policies and procedures,
relevant court orders, and guidance developed by the American Correctional Association. The OIG
also reviewed professional literature on correctional medical care; reviewed standardized
performance measures used by the health care industry; consulted with clinical experts; and met
with stakeholders from the court, the Receiver’s office, CDCR, the Office of the Attorney General,
and the Prison Law Office to discuss the nature and scope of the OIG’s inspection program. With
input from these stakeholders, the OIG developed a medical inspection program that evaluates
medical care delivery by combining clinical case reviews of patient files, objective tests of
compliance with policies and procedures, and an analysis of outcomes for certain population-based
metrics.
To maintain a metric-oriented inspection program that evaluates medical care delivery consistently
at each State prison, the OIG identified 14 primary (clinical) and two secondary (administrative)
quality indicators of health care to measure. The primary quality indicators cover clinical categories
directly relating to the health care provided to patients, whereas the secondary quality indicators
address the administrative functions that support a health care delivery system. The 14 primary
quality indicators are Access to Care, Diagnostic Services, Emergency Services, Health Information
Management (Medical Records), Health Care Environment, Inter- and Intra-System Transfers,
Pharmacy and Medication Management, Prenatal and Post-Delivery Services, Preventive Services,
Quality of Nursing Performance, Quality of Provider Performance, Reception Center Arrivals,
Specialized Medical Housing (OHU, CTC, SNF, Hospice), and Specialty Services. The two
secondary quality indicators are Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications.
The OIG rates each of the quality indicators applicable to the institution under inspection based on
case reviews conducted by OIG clinicians and compliance tests conducted by OIG deputy
inspectors general and registered nurses. The ratings may be derived from the case review results
alone, the compliance test results alone, or a combination of both these information sources. For
example, the ratings for the primary quality indicators Quality of Nursing Performance and Quality
of Provider Performance are derived entirely from the case review results, while the ratings for the
primary quality indicators Health Care Environment and Preventive Services are derived entirely
from compliance test results. As another example, primary quality indicators such as Diagnostic
Services and Specialty Services receive ratings derived from both sources. At CMF, 14 of the
quality indicators were applicable, consisting of 12 primary clinical indicators and two secondary
administrative indicators. Of the 12 primary indicators, seven were rated by both case review
clinicians and compliance inspectors, three were rated by case review clinicians only, and two were
rated by compliance inspectors only; both secondary indicators were rated by compliance inspectors
only.
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Consistent with the OIG’s agreement with the Receiver, this report only addresses the conditions
found related to medical care criteria. The OIG does not review for efficiency and economy of
operations. Moreover, if the OIG learns of an inmate-patient needing immediate care, the OIG
notifies the chief executive officer of health care services and requests a status report. Additionally,
if the OIG learns of significant departures from community standards, it may report such departures
to the institution’s chief executive officer or to CCHCS. Because these matters involve confidential
medical information protected by State and federal privacy laws, specific identifying details related
to any such cases are not included in the OIG’s public report.
In all areas, the OIG is alert for opportunities to make appropriate recommendations for
improvement. Such opportunities may be present regardless of the score awarded to any particular
quality indicator; therefore, recommendations for improvement should not necessarily be
interpreted as indicative of deficient medical care delivery.
CASE REVIEWS
The OIG has added case reviews to the Cycle 4 medical inspections at the recommendation of its
stakeholders. At the conclusion of Cycle 3, the federal Receiver and the Inspector General
determined that the health care provided at the institutions was not fully evaluated by the
compliance tool alone, and that the compliance tool was not designed to provide comprehensive
qualitative assessments. Accordingly, the OIG added case reviews in which OIG physicians and
nurses evaluate selected cases in detail to determine the overall quality of health care provided to
the inmate-patients. The OIG’s clinicians perform a retrospective chart review of selected patient
files to evaluate the care given by an institution’s primary care providers and nurses. Retrospective
chart review is a well-established review process used by health care organizations that perform
peer reviews and patient death reviews. Currently, CCHCS uses retrospective chart review as part
of its death review process and in its pattern-of-practice reviews. CCHCS also uses a more limited
form of retrospective chart review when performing appraisals of individual primary care providers.
PATIENT SELECTION FOR RETROSPECTIVE CASE REVIEWS
Because retrospective chart review is time consuming and requires qualified health care
professionals to perform it, OIG clinicians must carefully sample patient records. Accordingly, the
group of patients the OIG targeted for chart review carried the highest clinical risk and utilized the
majority of medical services. A majority of the patients selected for retrospective chart review were
classified by CCHCS as high-risk patients. The reason the OIG targeted these patients for review is
twofold:
1. The goal of retrospective chart review is to evaluate all aspects of the health care system.
Statewide, high-risk and high-utilization patients consume medical services at a
disproportionate rate; 11 percent of the total patient population are considered high-risk and
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account for more than half of the institution’s pharmaceutical, specialty, community
hospital, and emergency costs.
2. Selecting this target group for chart review provides a significantly greater opportunity to
evaluate all the various aspects of the health care delivery system at an institution.
Underlying the choice of high-risk patients for detailed case review, the OIG clinical experts made
the following three assumptions:
1. If the institution is able to provide adequate clinical care to the most challenging patients
with multiple complex and interdependent medical problems, it will be providing adequate
care to patients with less complicated health care issues. Because clinical expertise is
required to determine whether the institution has provided adequate clinical care, the OIG
utilizes experienced correctional physicians and registered nurses to perform this analysis.
2. The health of less complex patients is more likely to be affected by processes such as timely
appointment scheduling, medication management, routine health screening, and
immunizations. To review these processes, the OIG simultaneously performs a broad
compliance review.
3. Patient charts generated during death reviews, sentinel events (unexpected occurrences
involving death or serious injury, or risk thereof), and hospitalizations are mostly of
high-risk patients.
BENEFITS AND LIMITATIONS OF TARGETED SUBPOPULATION REVIEW
Because the selected patients utilize the broadest range of services offered by the health care
system, the OIG’s retrospective chart review provides adequate data for a qualitative assessment of
the most vital system processes (referred to as “primary quality indicators”). Retrospective chart
review provides an accurate qualitative assessment of the relevant primary quality indicators as
applied to the targeted subpopulation of high-risk and high-utilization patients. While this targeted
subpopulation does not represent the prison population as a whole, the ability of the institution to
provide adequate care to this subpopulation is a crucial and vital indicator of how the institution
provides health care to its whole patient population. Simply put, if the institution’s medical system
does not adequately care for those patients needing the most care, then it is not fulfilling its
obligations, even if it takes good care of patients with less complex medical needs.
Since the targeted subpopulation does not represent the institution’s general prison population, the
OIG cautions against inappropriate extrapolation of conclusions from the retrospective chart
reviews to the general population. For example, if the high-risk diabetic patients reviewed have
poorly-controlled diabetes, one cannot conclude that the entire diabetic population is inadequately
controlled. Similarly, if the high-risk diabetic patients under review have poor outcomes and require
significant specialty interventions, one cannot conclude that the entire diabetic population is having
similarly poor outcomes.
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Nonetheless, the health care system’s response to this subpopulation can be accurately evaluated
and yields valuable systems information. In the above example, if the health care system is
providing appropriate diabetic monitoring, medication therapy, and specialty referrals for the
high-risk patients reviewed, then it can be reasonably inferred that the health care system is also
providing appropriate diabetic services to the entire diabetic subpopulation. However, if these same
high-risk patients needing monitoring, medications, and referrals are generally not getting those
services, it is likely that the health care system is not providing appropriate diabetic services to the
greater diabetic subpopulation.
CASE REVIEWS SAMPLED
As indicated in Appendix B, Table B–1, CMF Sample Sets, the OIG clinicians evaluated medical
charts for 82 unique inmate-patients. Appendix B, Table B–4, CMF Case Review Sample Summary,
clarifies that both nurses and physicians reviewed charts for 18 of those patients, for 100 reviews in
total. Physicians performed detailed reviews of 30 charts, and nurses performed detailed reviews of
19 charts, totaling 49 detailed reviews. For detailed case reviews, physicians or nurses looked at all
encounters occurring in approximately six months of medical care. Nurses also performed a limited
or focused review of medical records for an additional 51 inmate-patients. These generated 1,283
clinical events for review (Appendix B, Table B-3, CMF Event-Program). The reporting format
provides details on whether the encounter was adequate or had significant deficiencies, and
identifies deficiencies by programs and processes to help the institution focus on improvement
areas.
While the sample method specifically pulled only six chronic care patient records, i.e., three
diabetes patients and three anticoagulation patients (Appendix B, Table B–1, CMF Sample Sets), the
82 unique inmate-patients sampled included patients with 344 chronic care diagnoses, including 25
additional patients with diabetes (for a total of 28) and one additional anticoagulation patient (for a
total of four) (Appendix B, Table B–2, CMF Chronic Care Diagnoses). The OIG’s sample selection
tool evaluated many chronic care programs because the complex and high-risk patients selected
from the different categories often had multiple medical problems. While the OIG did not evaluate
every chronic disease or health care staff member, the overall operation of the institution’s system
and staff were assessed for adequacy. The OIG’s case review methodology and sample size
matched other qualitative research. The empirical findings, supported by expert statistical
consultants, showed adequate conclusions after 10 to 15 charts had undergone full clinician review.
In qualitative statistics, this phenomenon is known as “saturation.” The OIG asserts that the
physician sample size of over 30 detailed reviews certainly far exceeds the saturation point
necessary for an adequate qualitative review. With regard to reviewing charts from different
providers, the case review is not intended to be a focused search for poorly performing providers;
rather, it is focused on how the system cares for those patients who need care the most. Nonetheless,
while not sampling cases by each provider at the institution, the OIG inspections adequately review
most providers. Providers would only escape OIG case review if institutional management
successfully mitigated patient risk by having the more poorly performing providers care for the less
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complicated, low-utilizing, and lower-risk patients. The OIG’s clinicians concluded that the case
review sample size was more than adequate to assess the quality of services provided.
Based on the collective results of clinicians’ case reviews, the OIG rated each quality indicator as
either proficient (excellent), adequate (passing), inadequate (failing), or not applicable. A separate
confidential CMF Supplemental Medical Inspection Results: Individual Case Review Summaries
report details the case reviews OIG clinicians conducted and is available to specific stakeholders.
For further details regarding the sampling methodologies and counts, see Appendix B — Clinical
Data, Table B–1; Table B–2; Table B–3; and Table B–4.
COMPLIANCE TESTING
SAMPLING METHODS FOR CONDUCTING COMPLIANCE TESTING
From February to April 2016, deputy inspectors general and registered nurses attained answers to
92 objective medical inspection test (MIT) questions designed to assess the institution’s compliance
with critical policies and procedures applicable to the delivery of medical care. To conduct most
tests, inspectors randomly selected samples of inmate-patients for whom the testing objectives were
applicable and reviewed their electronic unit health records. In some cases, inspectors used the same
samples to conduct more than one test. In total, inspectors reviewed health records for 407
individual inmate-patients and analyzed specific transactions within their records for evidence that
critical events occurred. Inspectors also reviewed management reports and meeting minutes to
assess certain administrative operations. In addition, during the week of February 22, 2016, field
inspectors conducted a detailed onsite inspection of CMF’s medical facilities and clinics;
interviewed key institutional employees; and reviewed employee records, logs, medical appeals,
death reports, and other documents. This generated 1,412 scored data points to assess care.
In addition to the scored questions, the OIG obtained information from the institution that it did not
score. This included, for example, information about CMF’s plant infrastructure, protocols for
tracking medical appeals and local operating procedures, and staffing resources.
For details of the compliance results, see Appendix A — Compliance Test Results. For details of the
OIG’s compliance sampling methodology, see Appendix C — Compliance Sampling Methodology.
SCORING OF COMPLIANCE TESTING RESULTS
The OIG compliance team scored the institution in the following nine primary (clinical) and two
secondary (administrative) quality indicators applicable to the institution:
Primary indicators: Access to Care, Diagnostic Services, Health Information Management
(Medical Records), Health Care Environment, Inter- and Intra-System Transfers, Pharmacy
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and Medication Management, Preventive Services, Specialized Medical Housing (OHU,
CTC, SNF, Hospice), and Specialty Services.
Secondary indicators: Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications.
After compiling the answers to the 92 questions, the OIG derived a score for each primary and
secondary quality indicator identified above by calculating the percentage score of all Yes answers
for each of the questions applicable to a particular indicator, then averaging those scores. Based on
those results, the OIG assigned a rating to each quality indicator of proficient (greater than
85 percent), adequate (between 75 percent and 85 percent), or inadequate (less than 75 percent).
DASHBOARD COMPARISONS
In the first ten medical inspection reports of Cycle 4, the OIG identified where similar metrics for
some of the individual compliance questions were available within the CCHCS Dashboard, which is
a monthly report that consolidates key health care performance measures statewide and by
institution. However, there was not complete parity between the metrics due to differing time
frames for data collecting and differences in sampling methods, rendering the metrics
non-comparable. Some of the OIG’s stakeholders suggested removing the Dashboard comparisons
from future reports to eliminate confusion. Dashboard data is available on CCHCS’s website,
www.cphcs.ca.gov.
OVERALL QUALITY INDICATOR RATING FOR CASE REVIEWS AND COMPLIANCE
TESTING
The OIG derived the final rating for each quality indicator by combining the ratings from the case
reviews and from the compliance testing, as applicable. When combining these ratings, the case
review evaluations and the compliance testing results usually agreed, but there were instances when
the rating differed for a particular quality indicator. In those instances, the inspection team assessed
the quality indicator based on the collective ratings from both components. Specifically, the OIG
clinicians and deputy inspectors general discussed the nature of individual exceptions found within
that indicator category and considered the overall effect on the ability of patients to receive
adequate medical care.
To derive an overall assessment rating of the institution’s medical inspection, the OIG evaluated the
various rating categories assigned to each of the quality indicators applicable to the institution,
giving more weight to the rating results of the primary quality indicators, which directly relate to the
health care provided to inmate-patients. Based on that analysis, OIG experts made a considered and
measured overall opinion about the quality of health care observed.
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POPULATION-BASED METRICS
The OIG identified a subset of Healthcare Effectiveness Data Information Set (HEDIS) measures
applicable to the CDCR inmate-patient population. To identify outcomes for CMF, the OIG
reviewed some of the compliance testing results, randomly sampled additional inmate-patients’
records, and obtained CMF data from the CCHCS Master Registry. The OIG compared those
results to HEDIS metrics reported by other statewide and national health care organizations.
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MEDICAL INSPECTION RESULTS
PRIMARY (CLINICAL) QUALITY INDICATORS OF HEALTH CARE
The primary quality indicators assess the clinical aspects of health care. As shown on the Health
Care Quality Indicators table on page ii of this report, 12 of the OIG’s primary indicators were
applicable to CMF. Of those 12 indicators, seven were rated by both the case review and
compliance components of the inspection, three were rated by the case review component alone,
and two were rated by the compliance component alone.
The CMF Executive Summary Table on page viii shows the case review and compliance ratings for
each applicable indicator.
Summary of Case Review Results: The clinical case review component assessed 10 of the 12
primary (clinical) indicators applicable to CMF. Of these ten indicators, OIG clinicians rated eight
adequate and two inadequate.
The OIG physicians rated the overall adequacy of care for each of the 30 detailed case reviews they
conducted. Of these 30 cases, three were proficient, 19 were adequate, and eight were inadequate.
In the 1,283 events reviewed, there were 590 deficiencies, of which 146 were considered to be of
such magnitude that, if left unaddressed, they would likely contribute to patient harm.
Adverse Events Identified During Case Review: Medical care is a complex dynamic process with
many moving parts, subject to human error even within the best health care organizations. Adverse
events are typically identified and tracked by all major health care organizations for the purpose of
quality improvement. They are not generally representative of medical care delivered by the
organization. The OIG identified adverse events for the dual purposes of quality improvement and
the illustration of problematic patterns of practice found during the inspection. Because of the
anecdotal description of these events, the OIG cautions against drawing inappropriate conclusions
regarding the institution based solely on adverse events. For CMF, while these events were not
representative of usual care delivery in the institution, they were illustrative of the serious problems
that contributed to the inadequate rating for the institution.
There were four unsafe conditions and sentinel events identified in the case reviews at CMF. Case
26 is also discussed in the Quality of Nursing Services indicator. Cases 9, 11, and 13 are discussed
in the Emergency Services indicator.
In case 26, the sick call nurse saw the patient, who was taking warfarin (blood thinner). He
fell from the top bunk, hit his head, and developed headache, dizziness, nausea, and
vomiting. These symptoms indicated possible life-threatening bleeding in the brain. Despite
this, the sick call nurse treated the patient for diarrhea and planned to make a routine 14-day
physician referral. Fortunately, the patient’s symptoms resolved, and the patient suffered no
harm. This event was classified as an unsafe condition.
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In case 9, the patient had end-stage liver disease and presented to the TTA with a fever of
102.4° F and low blood pressure. However, the on-call physician treated the patient for a
viral syndrome and did not consider a possible life-threatening infection or order a prompt
physician follow-up. Three days later, the patient was sent to the hospital, where he was
diagnosed with a spinal abscess. Fortunately, the patient recovered and suffered no
permanent harm from the delayed emergency response.
In case 13, the patient presented to the TTA with confusion and a severely swollen, bruised,
and blistered leg that was oozing copious amounts of fluid. He had low blood pressure, low
oxygen levels, and an extremely low body temperature of 92° F. The on-call physician did
not order any meaningful interventions, and ordered only a routine transportation to the
hospital. The patient left the facility more than two hours after the medical emergency, and
subsequently died of an overwhelming infection. While the death was not preventable, the
on-call physician did not recognize the gravity of the patient’s condition and was responsible
for the inadequate emergency response.
In case 11, the patient had chronic lung disease and came to the TTA with increased
shortness of breath. The on-call physician sent the patient back to housing after
improvement with breathing treatments and a high dose of steroids to decrease lung
inflammation. However, the physician did not perform a face-to-face evaluation, prescribe
empiric antibiotics, obtain a chest x-ray, or arrange a prompt physician follow-up. The
physician missed the diagnosis of pneumonia. Three days later, the patient had respiratory
failure and, despite hospitalization, died. The death was potentially preventable had the
patient received appropriate care in the TTA three days prior to him being sent to the
hospital.
Summary of Compliance Results: The compliance component assessed 9 of the 12 primary
(clinical) indicators applicable to CMF. Of these nine indicators, OIG inspectors rated three
adequate and six inadequate. The results of those assessments are summarized within this section of
the report. The test questions used to assess compliance for each indicator are detailed in
Appendix A.
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ACCESS TO CARE
This indicator evaluates the institution’s ability to provide
Case Review Rating:
inmate-patients with timely clinical appointments. Areas specific to
Adequate
inmate-patients’ access to care are reviewed, such as initial
Compliance Score:
assessments of newly arriving inmates, acute and chronic care
Adequate
follow-ups, face-to-face nurse appointments when an inmate-patient (78.4%)
requests to be seen, provider referrals from nursing lines, and
Overall Rating:
follow-ups after hospitalization or specialty care. Compliance
Adequate
testing for this indicator also evaluates whether inmate-patients have
Health Care Services Request forms (CDCR Form 7362) available
in their housing units.
Case Review Results
The OIG clinicians reviewed 551 provider, nursing, specialty, and outside hospital encounters in
which a follow-up visit needed to be scheduled, and found 38 deficiencies relating to Access to
Care. Twenty-six of the 38 deficiencies were significant, and more likely than not to cause patient
harm if not rectified and allowed to persist. However, due to the relatively low frequency of
problems in this area (less than 5 percent), Access to Care at CMF was rated adequate.
Provider-to-Provider Follow-up Appointments
CMF performed well with provider-ordered follow-up appointments. These are among the most
important aspects of the Access to Care indicator. Failure to accommodate provider-ordered
appointments can often result in lapses in care or in patients being lost to follow-up. The problem
was rare at CMF, with no pattern of problems in this area.
RN Sick Call Access
When nurses decided to see a patient with a sick call complaint, the patient received prompt nurse
access. Unfortunately, sick call nurses often failed to perform nursing evaluations when the patients
needed them. This poor sick call nursing performance is further discussed in the Quality of Nursing
Performance indicator, and did not negatively affect the Access to Care indicator.
RN-to-RN Follow-up Appointments
CMF nurses did not refer patients for nursing follow-up appointments in any of the cases reviewed.
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Nurse-to-Provider Referrals
Any properly functioning health care system must allow nurses to refer a patient for a provider
evaluation if the patient’s medical needs are beyond the nurse’s scope of practice. CMF performed
well, with nearly all nurse-to-provider referrals resulting in an appointment.
Provider Follow-up After Specialty Services
CMF usually provided patients with provider follow-up visits after their specialty services
encounters. The OIG clinicians reviewed 84 diagnostic and consultative specialty services and
found only four instances in which the provider follow-up did not occur or was delayed.
Intra-System Transfers
The OIG clinicians reviewed five transfer-in patients and found no instances of deficient access to
care in this area.
Follow-up After Hospitalization
CMF did well at ensuring that providers followed up with their patients after the patients’ return
from an outside hospital or an emergency department. OIG clinicians reviewed 28 hospitalization
and outside emergency events and found only one case in which CMF delayed a provider
follow-up.
Follow-up After Urgent/Emergent Care
CMF had significant difficulty providing PCP follow-up appointments for patients seen in the TTA
or when the on-call physician ordered a follow-up appointment. Most of these patients had a change
in medical status and were at high risk for medical complications. CMF’s failure to provide PCP
follow-up care in these situations placed the patient at even higher risk. Of the 70 urgent/emergent
encounters reviewed, 32 required a PCP follow-up appointment. Provider follow-up appointments
were delayed or did not occur in cases 8, 11, 12, 16, 24, and 29.
In case 12, medical staff saw the patient in the TTA for a decreased mental status and
turning blue in the lips and the eyelids. He had very low blood pressure and low oxygen
levels. The patient refused transfer to the hospital, and the TTA provider ordered a
three-to-five-day follow-up with the PCP. The appointment did not occur until ten days
later. Fortunately, no immediate harm resulted from this deficiency.
In case 16, the patient went to the TTA due to pelvic pain and bleeding after he felt
something rupture while performing his own bladder catheterization. The TTA provider
inserted a Foley catheter into the patient’s bladder, and ordered a five-to-seven-day PCP
follow-up. The appointment did not occur. Fortunately, no immediate harm resulted from
this deficiency.
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Specialized Medical Housing
CMF performed well with provider access during and after admission to the correctional treatment
center (CTC). A provider usually visited CTC patients at appropriate intervals. The OIG clinicians
reviewed 15 CTC admissions with 106 CTC provider encounters. A provider did not perform timely
CTC rounds in only two instances.
Specialty Access
The institution generally performed well in this area, as is further discussed in the Specialty Services
indicator.
Diagnostic Results Follow-up
CMF provided adequate follow-up after providers received abnormal diagnostic tests. After
reviewing diagnostic results, a provider indicated whether the patient required a follow-up
appointment on the Notification of Diagnostic Test Results (CDCR Form 7393). CMF sometimes
had difficulty processing those forms, occasionally scanning them into the medical record without
scheduling appointments.
Clinician Onsite Inspection
At the onsite inspection, the OIG clinicians tried to determine if any process problems could explain
CMF’s trouble ensuring that PCPs followed up with their patients after the patients were seen in the
TTA or when the on-call physician ordered a follow-up. CMF staff explained that the process was
dependent on the TTA log. The process in place had remained the same for years. Every morning,
the primary care team reviewed the patients listed on the TTA log and arranged a follow-up
appointment. CMF could not explain the pattern of missed appointments in this area.
Clinician Summary
CMF demonstrated good overall ability to provide patients with adequate Access to Care. The OIG
clinicians found good performance in almost all areas, with only two notable exceptions: CMF had
difficulty giving patients follow-up PCP appointments after they had been seen in the TTA, and
when the on-call physician ordered a follow-up appointment, it did not reliably occur. Despite those
problems, the OIG clinicians rated this indicator adequate.
Compliance Testing Results
The institution received an adequate compliance score of 78.4 percent in the Access to Care
indicator, and scored in the proficient range in the following four test areas:
Inmates had access to Health Care Services Request forms (CDCR Form 7362) at all six
housing units inspected (MIT 1.101).
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All 24 sampled health care service requests on which nursing staff referred the patient for a
PCP appointment resulted in the patient receiving a timely appointment (MIT 1.005).
Nursing staff reviewed 29 out of 30 sampled Health Care Services Request forms (CDCR
Form 7362) on the same day they were received (97 percent). For one sample, no date
evidence was documented to demonstrate that a nurse promptly reviewed the form after it
was collected (MIT 1.003).
Primary care provider visits occurred timely for 25 of the 29 sampled patients who
transferred into CMF with a pre-existing chronic care PCP visit need or who, upon arrival,
received a new PCP referral from the CMF screening nurse (86 percent). Four other patients
received their provider visits from six to seven days late (MIT 1.002).
CMF performed in the adequate range on the following test:
Recent routine appointments were timely for 31 of the 40 sampled patients with chronic
conditions (78 percent). Nine patients received their follow-up appointments from one to
189 days late (MIT 1.001).
The institution scored within the inadequate range on the following four tests:
Inspectors sampled 29 Health Care Service Request forms (CDCR Form 7362) submitted by
patients across all facility clinics. For 13 samples (45 percent), nursing staff completed a
face-to-face encounter with the patient within one business day of reviewing the service
request form. However, for 15 other samples, the nurse had a face-to-face encounter with the
patient, but did not document the event with supporting SOAPE notes. For one additional
sample, the RN did not document the encounter date to demonstrate the event was timely
(MIT 1.004).
The OIG tested 30 patients discharged from a community hospital to determine if they
received a PCP follow-up appointment at CMF within five calendar days of their return to
the institution, or earlier if a TTA provider ordered the appointment to occur sooner. Only
18 of the patients (60 percent) received a timely PCP follow-up appointment. Twelve
patients received their appointment from one to 50 days late (MIT 1.007).
Inspectors also sampled 30 patients who received a specialty service; only 21 of them
(70 percent) received a timely follow-up appointment with a provider. Eight patients
received their follow-up appointments from one to 55 days late, and two other patients never
received a provider follow-up appointment (MIT 1.008).
The OIG sampled 24 patients who submitted a sick call request and were subsequently seen
by a provider. Out of the 24 patient encounters, providers ordered ten of the patients to
return for a second follow-up visit. Of the ten patients, only seven (70 percent) received their
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follow-up appointments timely. One patient received his follow-up appointment two days
late, and two other patients never received their follow-up appointments (MIT 1.006).
Recommendations
No specific recommendations.
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DIAGNOSTIC SERVICES
This indicator addresses several types of diagnostic services.
Case Review Rating:
Specifically, it addresses whether radiology and laboratory services
Adequate
were timely provided to inmate-patients, whether the primary care
Compliance Score:
provider (PCP) timely reviewed the results, and whether the results
Adequate
were communicated to the inmate-patient within the required time (76.3%)
frames. In addition, for pathology services, the OIG determines
Overall Rating:
whether the institution received a final pathology report and
Adequate
whether the PCP timely reviewed and communicated the pathology
results to the patient. The case reviews also factor in the
appropriateness, accuracy, and quality of the diagnostic test(s) ordered and the clinical response to
the results.
Case Review Results
The OIG clinicians reviewed 151 diagnostic events and found 31 deficiencies, of which 26 were
related to health information management and five were related to the non-completion of ordered
tests.
CMF performed the majority of diagnostic services in a timely manner. However, not completing
diagnostic tests is a serious system deficiency that can lead to significant delays or even lapses in
care. CMF errors whereby tests were not completed within the provider’s ordered time frame were
uncommon, but were more likely to occur when tests were ordered with short processing time
frames.
In case 11, the patient had multiple injuries, including several facial fractures. The PCP was
concerned about the possibility of rib fractures and ordered a chest x-ray and a TTA
follow-up to occur the following morning. Neither of these occurred until the PCP noticed
the error three days later. The subsequent x-ray did confirm rib fractures, but, fortunately, no
acute intervention was required and the patient was not harmed from this lapse in care.
CMF demonstrated inconsistent performance with retrieving radiology reports from the radiology
information system (RIS) and scanning them into the eUHR. At the onsite inspection, CMF
leadership explained that they had stopped scanning radiology reports from RIS into the primary
medical record (eUHR) based on a memo from CCHCS headquarters. This new process, however,
increased the risk of patient harm due to the chance of a lapse in care because of a provider being
unaware of the report. Even if the ordering provider initially was notified of the report and reviewed
it in the radiology information system, the report would still not be readily available to any
subsequent medical staff. Any nurse or provider caring for the patient in the coming months or
years would face a tremendous barrier, as the main information base used for patient care, the
eUHR, would lack a scanned copy of the report. Though CMF leadership admitted that the
institution had stopped scanning reports from RIS to the eUHR, case reviews demonstrated only a
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moderate pattern of deficiencies in this area. The OIG clinicians identified deficiencies in the
retrieval and scanning of radiology reports in cases 11, 13, 39, and 41. CMF clinicians did a good
job ensuring that they reviewed the reports, despite the extra barrier to reviewing those results.
However, in these cases, the corresponding patient notification form was not completed, and CMF
did not send the patient notification of the test results. In one case (case 13), the provider did not
review the report at all.
In case 13, the PCP and a cancer specialist were following the patient for liver cancer. An
ultrasound showed a 3.6 cm mass, but institution staff did not scan the report into the eUHR
and the provider did not review the report. Fortunately, the interventional radiology
specialist monitored the patient closely, and no harm resulted from the oversight.
In addition to radiology reports, CMF sometimes did not retrieve laboratory reports or scan them
into the eUHR. This occurred in cases 11, 13, 29, and 41. CMF providers admitted that the use of
the main medical record (eUHR) to review labs was unreliable due to a high frequency of missing
lab reports. Most providers used another information system directly from the laboratory provider to
review those reports. At the onsite inspection, the lab supervisor confirmed that the lab report was
retrieved in case 29. The lab report and a CDCR Form 7393 (for patient notification of results) was
sent to the PCP for completion. The breakdown in the lab reporting process may have been
occurring after the provider was sent the lab report for review.
CMF providers did not consistently review diagnostic test results in a timely manner. Delays in
diagnostic test reviews occurred in cases 13, 16, 18, 20, 22, 31, and 39. Some review delays were
excessive and constituted severe deficiencies:
In case 13, the institution completed the labs, but a provider did not review them for more
than five weeks.
In case 16, the institution completed the labs, but a provider did not review them for more
than three weeks.
CMF providers did not review routine EKG tests and complete patient notification forms that
relayed the results of the diagnostic test. This occurred in cases 7 and 22.
On rare occasions, CMF providers did not date or initial the diagnostic test reports when they
reviewed them. This occurred in cases 13, 16, and 20.
Clinician Summary
The institutions staff completed radiology and laboratory tests in a timely manner, with only rare
occurrences of tests not being completed, usually when tests were required within very short time
frames. Retrieval of diagnostic test results was sometimes problematic, with intermittent failures to
scan radiology reports from RIS to the eUHR. Failure to place radiology reports into the primary
medical record presented a significant and ongoing risk for lapses in care. CMF providers did not
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Office of the Inspector General State of California
consistently review diagnostic test results in a timely manner and did not always complete patient
notification forms. Despite suboptimal services, diagnostic services were sufficient to provide basic
medical care to CMF’s patient population, and the indicator was rated adequate.
Compliance Testing Results
The institution received an adequate compliance score of 76.3 percent in the Diagnostic Services
indicator, which encompasses radiology, laboratory, and pathology services. For clarity, each type
of diagnostic service is discussed separately below:
Radiology Services
All ten of the radiology services sampled were timely performed (MIT 2.001). In addition,
CMF providers initialed and dated the radiology report, evidencing they reviewed the report
within two business days of receipt, for eight of those patients (80 percent). For two patients,
providers documented no evidence that the reports were timely reviewed (MIT 2.002).
Lastly, provider’s timely communicated radiology results to nine of ten patients sampled
(90 percent). There was no evidence the provider communicated the radiology results to one
patient (MIT 2.003).
Laboratory Services
CMF performed all ten laboratory services sampled within the required time frame
(MIT 2.004). The institution’s providers also reviewed eight of ten laboratory reports within
the required time frame (80 percent). However, a provider reviewed one laboratory report
two days late, and a different provider failed to review another laboratory report at all
(MIT 2.005). CMF providers timely communicated the laboratory results to nine of ten
patients sampled (90 percent). For one patient, the provider communicated the laboratory
results six days late (MIT 2.006).
Pathology Services
The institution documented eUHR evidence that it timely received a final pathology report
for eight of ten patients sampled (80 percent). For one patient, CMF received the pathology
report three days late, and for another patient, the institution never received a pathology
report (MIT 2.007). Further, of the nine sampled patients for whom the institution received a
final report, providers evidenced their timely review of the report results for only two of
them (22 percent). For the other seven sampled reports, the OIG could not find any eUHR
evidence that a provider reviewed them (MIT 2.008). OIG inspectors also found that only
four of the nine patients for whom the institution received a final pathology report
(44 percent) had their pathology results communicated to them by a provider. Two patients
received their pathology results 9 and 12 days late, while three other patients never received
their results (MIT 2.009).
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Office of the Inspector General State of California
Recommendation for CCHCS
The OIG recommends that, to avoid risk of patient harm, CCHCS review the current process of not
scanning radiology reports into the eUHR and develop a better process for staff to access radiology
reports.
Recommendations for CMF
No specific recommendations.
California Medical Facility, Cycle 4 Medical Inspection Page 22
Office of the Inspector General State of California
EMERGENCY SERVICES
An emergency medical response system is essential to providing
Case Review Rating:
effective and timely emergency medical response, assessment,
Inadequate
treatment, and transportation 24 hours per day. Provision of
Compliance Score:
urgent/emergent care is based on a patient’s emergency situation,
Not Applicable
clinical condition, and need for a higher level of care. The OIG
reviews emergency response services including first aid, basic life Overall Rating:
support (BLS), and advanced cardiac life support (ACLS) consistent Inadequate
with the American Heart Association guidelines for
cardiopulmonary resuscitation (CPR) and emergency cardiovascular care, and the provision of
services by knowledgeable staff appropriate to each individual’s training, certification, and
authorized scope of practice.
The OIG evaluates this quality indicator entirely through clinicians’ reviews of case files and
conducts no separate compliance testing element.
Case Review Results
The OIG clinicians reviewed 70 urgent/emergent events and found 64 deficiencies. Of those, 43
were related to nursing and nine were related to provider care. With few exceptions, TTA providers
made accurate assessments and triage decisions when patients were evaluated in person. However,
on-call providers sometimes performed inadequate assessments by telephone, leading to poor
decisions and inadequate follow-ups. A strong pattern emerged of inadequate nursing assessment
and delayed physician notification. CMF also demonstrated lack of preparedness for emergency
response when an automated external defibrillator (AED) was not readily available at the scene.
These factors resulted in an inadequate rating for this indicator.
Provider Performance
On-call and TTA providers performed well in most cases. However, on-call providers sometimes
made inadequate assessments, which increased the risk of poor decisions, such as in the following
examples:
In case 9, the patient had end-stage liver disease and presented to the TTA with fever of
102.4° F and low blood pressure. The on-call physician treated the patient for a viral
syndrome by ordering oral fluids. The physician confined the patient to quarters with a nurse
follow-up in the morning. The patient was at high risk for recurrent severe infection related
to his liver disease, but the on-call physician failed to evaluate the high-risk patient face to
face, failed to consider possible life-threatening infection, and failed to ensure close
physician monitoring. The following day, the patient developed confusion and had a
persistent fever of 102.5° F. He was re-evaluated by the TTA nurse, but the nurse failed to
refer the patient to the physician. On the third day, institution staff sent the patient to the
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Office of the Inspector General State of California
hospital for worsening confusion and a severe infection. The hospital determined the patient
had a spinal abscess. Fortunately, the patient recovered and suffered no permanent harm
from the severely delayed emergency response.
In case 11, the patient had long-standing lung disease and presented to the TTA with five
days of shortness of breath, productive cough, and brownish to greenish phlegm. The nurse
noted that the patient’s breathing was rapid and labored and that he was coughing and
wheezing. Initially, the patient’s oxygen levels were low, even after nurses gave him
supplemental oxygen. The patient also had an abnormally rapid heart rate of 126 beats per
minute and a high respiratory rate of 26 breaths per minute. The on-call physician gave the
patient breathing treatments and a high dose of steroids to decrease lung inflammation. The
physician sent the patient back to housing after his symptoms seemed to improve in the
TTA. The physician did not perform a face-to-face evaluation, prescribe empiric antibiotics,
obtain a chest x-ray, or arrange close physician follow-up. The physician missed the
diagnosis of pneumonia. Three days later, the patient came back to the TTA with respiratory
failure and was immediately hospitalized. The patient was transferred to the intensive care
unit and placed on a breathing machine, but did not survive his pneumonia that had turned
into an overwhelming infection. The death was potentially preventable had the patient
received appropriate care in the TTA three days prior to being sent to the hospital.
In case 13, the patient presented to the TTA with confusion and a severely swollen, bruised,
and blistered leg that was oozing copious amounts of fluid. He had low blood pressure, low
oxygen levels, and an extremely low body temperature of 92° F. The on-call physician did
not order any meaningful interventions, such as intravenous fluids or antibiotics, and
ordered only a routine transportation to the hospital. The patient did not leave the facility for
more than two hours after the medical emergency, and subsequently died of an
overwhelming infection. The death was not preventable because there was evidence that
patient was already in septic shock by the time he arrived in the TTA. It was unlikely that
earlier intervention could have prevented his death. Nevertheless, the on-call physician did
not recognize the gravity of the patient’s condition and was responsible for the inadequate
emergency response.
The OIG clinicians classified cases 9, 11, and 13 as unsafe conditions or sentinel events. They are
duplicated in the Medical Inspection Results: Adverse Events Identified During Case Review section
of the report beginning on page 12.
Nursing Performance
The TTA nurses demonstrated significantly delayed performance in notifying the on-call physician
and custody staff of patients’ medical conditions and medical emergencies:
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Office of the Inspector General State of California
In case 4, the patient was found unresponsive in the OHU, and staff initiated CPR. The AED
machine was not readily available in the unit because it was locked in the treatment room
and thus was not applied until the patient arrived in the TTA.
In case 7, the patient presented to the TTA with chest pain. It took 20 minutes for the TTA
nurse to contact the on-call physician. It also took nine minutes from the time of the
physician contact to notify the watch commander of the emergency transport.
In case 8, there was a delay of more than 30 minutes in notifying the physician of a patient
with difficulty breathing, severe pain, and abnormal vital signs.
In case 9, there was a delay of more than 45 minutes in notifying the physician of a patient
with altered mental status and severe abdominal pain. On another occasion, the patient was
brought to the TTA for persistent fever and altered level of consciousness. The TTA RN did
not refer the patient to the physician for immediate medical evaluation.
In case 12, on two occasions, there was a delay of more than one hour notifying the
physician of the patient’s altered mental status and low blood pressure.
In case 20, it took more than 30 minutes for the RN to contact the on-call physician for a
patient with severe abdominal pain and fever.
In case 21, the RN took 45 minutes to contact the on-call physician for a poorly controlled
diabetic patient with chest pain and high blood pressure. Additionally, the RN did not start
the chest pain protocol until after contacting the physician. There was also a delay in
notifying the watch commander of the medical transport.
In case 80, it took 23 minutes for the RN to call 9-1-1 for a patient with severe chest pain.
The TTA nursing staff had inadequate assessment and documentation in the following cases:
In case 6, the RN did not assess the patient’s neck for any injury or address pain after a
reported fall.
In cases 8, 11, and 12, after administrating breathing treatments, the RN did not assess the
patients for effectiveness of the medication.
In case 21, The TTA RN did not closely monitor the patient’s vital signs. The RN did not
check the patient’s vital signs for more than two hours after the initial reading and the RN
took vitals only four other times during his seven-hour-plus stay in the TTA.
In case 24, after the physician evaluated the patient, the TTA RN did not continue to assess
the patient’s condition and document the nursing care provided prior to the patient’s transfer
to the hospital.
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Office of the Inspector General State of California
In cases 9, 12, 20, and 24, the RN failed to document the patient’s condition, the nursing
care provided while in the TTA, and the care provided prior to the patient’s transfer of care.
Nurses must document all critical information chronologically during an emergency medical
response. Complete documentation identifies the quality of assessment and care provided to the
patient and the timeliness and coordination of emergency response. Omissions in documenting the
time when custody or EMS were notified and the times when EMS arrived and left the facility were
found in cases 8, 9, 11, 12, 13, 19, 20, 21, and 24.
Emergency Medical Response Review Committee
The EMRRC reviewed emergency medical responses on a regular basis and generally identified the
deficiencies in first responder performance, documentation, and coordination of emergency medical
response during its reviews. Case 12 was the only deficient instance reviewed; the committee failed
to identify that there was more than a one-hour delay in notifying the physician of the patient’s
condition.
Clinician Onsite Inspection
The CMF TTA staff was responsible for responding to all medical emergencies, but they did not
have any emergency vehicles available for use. This was especially problematic when responding to
medical emergencies that occurred in distant yards, such as CMF’s C and D yards. TTA nurses
explained it took as long as 15 minutes for them to gather their emergency equipment and walk or
run to a medical emergency.
CMF physicians expressed extreme dissatisfaction with recent changes to the after-hours coverage
system. The physicians claimed that in the spring of 2015, CMF changed after-hours coverage from
onsite physician coverage (MOD – medical officer of the day) to offsite coverage (POC – provider
on call). Because of CMF’s high-risk population, most physicians felt the change had significantly
compromised patient care and that with no after-hours physician onsite to evaluate patients who
required emergency assessments, the risk of inaccurate assessments over the telephone markedly
increased. The institution’s chief medical executive (CME) explained that the directive to change
the after-hours coverage came from CCHCS despite his objections. The CME agreed that the
change in coverage had dramatically lowered physician morale and created a serious problem with
retention of high-quality physicians. This problem is further discussed in the Quality of Provider
Performance indicator.
Recommendation for CCHCS
The OIG recommends that CCHCS reinstate the onsite after-hours physician coverage for
intermediate health care prisons because intermediate level medical facilities, such as CMF, house
large numbers of medically complex patients who require frequent utilization of emergency
resources. Telephone coverage by the on-call physician increases the risk of inaccurate physician
California Medical Facility, Cycle 4 Medical Inspection Page 26
Office of the Inspector General State of California
assessments, which can result in poor decisions and patient harm, as documented by the OIG’s
clinical reviews.
Recommendations for CMF
The OIG recommends the institution do the following:
Provide vehicles for TTA staff so that they can respond promptly to medical emergencies.
Require that the EMRRC prioritize the review of critical emergency response measures,
such as length of time until physician notification. In addition, ensure that the EMRRC’s
review includes the quality of emergency nursing assessments.
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Office of the Inspector General State of California
HEALTH INFORMATION MANAGEMENT (MEDICAL RECORDS)
Health information management is a crucial link in the delivery of
Case Review Rating:
medical care. Medical personnel require accurate information in
Adequate
order to make sound judgments and decisions. This indicator
Compliance Score:
examines whether the institution adequately manages its health care Inadequate
information. This includes determining whether the information is (61.7%)
correctly labeled and organized and available in the electronic unit
Overall Rating:
health record (eUHR); whether the various medical records (internal
Adequate
and external, e.g., hospital and specialty reports and progress notes)
are obtained and scanned timely into the inmate-patient’s eUHR;
whether records routed to clinicians include legible signatures or stamps; and whether hospital
discharge reports include key elements and are timely reviewed by providers.
In this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance testing resulting in an
inadequate score. The OIG’s internal review process considered those factors that led to both
results. Although the compliance review found providers did not timely review hospital discharge
reports and inspectors identified miss-scanned and mislabeled documents, the case review clinicians
were able to conclude that CMF provider’s review time of hospital discharge reports did not affect
the quality of patient care, and mislabeled documents did not significantly hinder their reviews. As a
result, the OIG’s medical inspection team concluded that the appropriate overall score for this
indicator should be adequate.
Case Review Results
Inter-Departmental Transmission
CMF performed adequately with interdepartmental transmission. Nurses properly noted and
processed provider orders to the appropriate department.
CMF demonstrated a moderate pattern of missing documents across various aspects of the
institution. Missing documents included clinic provider notes, emergency first responder notes,
TTA nursing notes, post-hospitalization nursing notes, clinic nursing notes, and CTC
documentation. Missing documents were identified in cases 9, 14, 15, 19, 21, 24, 25, and 74.
Hospital Records
CMF did well with the retrieval of emergency department (ED) physician reports and hospital
discharge summaries. The OIG clinicians reviewed 11 outside ED events and 17 community
hospital events. Except in cases 6 and 21, CMF staff retrieved and scanned ED reports and hospital
discharge summaries in the required time frame. However, providers failed to review and initial the
ED physician report or the hospital discharge summary, and provider initials were missing on
outside hospital reports in almost all cases.
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Office of the Inspector General State of California
Specialty Services
Findings regarding specialty report handling are discussed in the Specialty Services indicator.
Diagnostic Reports
Findings regarding diagnostic report handling are discussed in the Diagnostic Services indicator.
Urgent/Emergent Records
CMF nurses sometimes did not properly document their urgent or emergent encounters. Cases 9, 19,
and 21 were missing emergency or TTA documentation.
CMF on-call providers also did not reliably document their telephone encounters. Cases 7, 9, and 16
were missing on-call provider documentation.
Scanning Performance
Erroneously scanned documents can create lapses in care by hindering providers’ ability to find
relevant clinical information. CMF performed adequately in this area with no significant pattern of
mislabeled documents. However, cases 7, 19, 25, and 38 had documents misfiled (into the wrong
patient chart). Scanning times for documents were generally good.
Documentation Quality and Legibility
Provider documentation was often scarce. In the majority of cases, the care management was
adequate, but providers often failed to document their thought processes and reasoning in their
progress notes.
Poor legibility greatly increases the risk for medical errors, especially in medical systems where
continuity of care is poor. Fortunately, continuity of care was good in most of the reviewed cases.
Nevertheless, extremely poor legibility was a significant problem across nearly all health care staff,
including the majority of nurses and providers. CMF health care staff rarely utilized name stamps.
CMF leadership expressed optimism that the implementation of the upcoming electronic health
record system (EHRS) will solve legibility concerns.
Clinician Summary
CMF health care staff performed poorly with regard to documenting their review of important
health care information. Providers generally did not initial or date hospital discharge summaries or
specialty consult notes to indicate their review. Providers also did not reliably document their
review of these reports in their progress notes. Providers often did not document their
decision-making thought processes. CMF nurses and providers displayed extremely poor legibility
throughout all cases reviewed.
In-depth chart reviews also showed evidence that, despite insufficient documentation, CMF
providers appropriately reviewed and considered the vast majority of hospital discharge summaries
California Medical Facility, Cycle 4 Medical Inspection Page 29
Office of the Inspector General State of California
and specialty reports. The specialty department used a locally developed tracking form to track the
documents and all the specialty recommendations to ensure the provider was aware of those
recommendations. The specialty department retrieved specialty reports and carefully reviewed them
for any action needed. With respect to poor provider documentation and legibility, continuity of
primary care providers minimized those risks. Overall, the OIG clinicians rated this indicator
adequate.
Compliance Testing Results
The institution received an inadequate compliance score of 61.7 percent in the Health Information
Management (Medical Records) indicator and scored in the inadequate range in the following three
tests:
The institution scored zero in its labeling and filing of documents scanned into patients’
electronic unit health records; most documents were mislabeled, such as non-CDCR hospital
admission reports that were commonly mislabeled as History and Physical forms. For this
test, once the OIG identifies 12 mislabeled or misfiled documents, the maximum points are
lost and the resulting score is zero. During the CMF medical inspection, inspectors identified
a total of 17 documents with scanning errors, five more than the maximum allowable
number (MIT 4.006).
The OIG reviewed hospital discharge reports and treatment records for 30 sampled patients
whom the institution sent to the hospital for a higher level of care; providers only reviewed
nine reports within the required time frame (30 percent). Providers reviewed 15 reports from
one to 13 days late, and six other reports were never reviewed (MIT 4.008).
When the OIG reviewed various medical documents such as hospital discharge reports,
initial health screening forms, certain medication administration records, and specialty
service reports to ensure that clinical staff legibly documented their names on the forms,
only 23 of 32 samples (72 percent) showed compliance. Nine of the samples tested did not
have a legible signature or stamp to clearly identify the clinician (MIT 4.007).
The following three tests scored in the adequate range:
Among 20 sampled miscellaneous non-dictated documents, including providers’ progress
notes and patients’ initial health screening forms and requests for health care services, the
institution timely scanned 16 of the documents (80 percent). Four initial health screening
forms were scanned one to three days late (MIT 4.001).
CMF timely scanned community hospital discharge reports or treatment records into each
patient’s eUHR for 16 of the 20 sampled reports (80 percent); four reports were scanned
between one and three days late (MIT 4.004).
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Office of the Inspector General State of California
CMF staff timely scanned medication administration records (MARs) into the patient’s
eUHR for 15 of 20 samples tested (75 percent). Five MARs were scanned three to ten days
late (MIT 4.005).
The institution scored in the proficient range on the following test:
For 19 of 20 specialty service consultant reports sampled (95 percent), CMF staff scanned
the reports into the patient’s eUHR file within five calendar days. The institution scanned
one routine specialty services report a day late (MIT 4.003).
Recommendations
No specific recommendations.
California Medical Facility, Cycle 4 Medical Inspection Page 31
Office of the Inspector General State of California
HEALTH CARE ENVIRONMENT
This indicator addresses the general operational aspects of the Case Review Rating:
institution’s clinics, including certain elements of infection control Not Applicable
and sanitation, medical supplies and equipment management, the Compliance Score:
Inadequate
availability of both auditory and visual privacy for inmate-patient
(72.5%)
visits, and the sufficiency of facility infrastructure to conduct
comprehensive medical examinations. Rating of this component is Overall Rating:
based entirely on the compliance testing results from the visual Inadequate
observations inspectors make at the institution during their onsite
visit.
Compliance Testing Results
The institution received an inadequate compliance score of 72.5 percent in the Health Care
Environment indicator with the following three tests receiving scores in the inadequate range:
Only one of 14 clinic locations (7 percent) met compliance
requirements for essential core medical equipment and
supplies. The remaining 13 clinics were missing functional
core equipment or supplies necessary to conduct a
comprehensive exam. Various clinic locations were missing
one or more of the following: Snellen eye exam chart, AED,
nebulization unit, functional ophthalmoscope, functional
portable light source (Figure 1), emergency medical response
bag, glucometer and strips, medication refrigerator, peak
flow meter and disposable tips, and Hemoccult cards and
developer (MIT 5.108).
Figure 1: Exam Room light
fixture without a light bulb
Inspectors observed clinician’s encounters with patients in
nine clinics and found only one clinic location (11 percent)
followed good hand hygiene practices. Clinicians at eight
clinics did not routinely sanitize their hands before or after
patient contact, before putting on gloves, or after
administering injections (MIT 5.104).
Inspectors examined 14 clinics to determine if appropriate
space, configuration, supplies, and equipment allowed
clinicians to perform a proper clinical exam. Only six clinic
locations (43 percent) were in compliance. Seven clinics had
Figure 2: Exam table with
exam room tables with tears and cracks on the vinyl covers
worn vinyl area that could
(Figure 2). In addition, the R&R did not have a portable harbor infection
California Medical Facility, Cycle 4 Medical Inspection Page 32
Office of the Inspector General State of California
privacy screen to ensure visual privacy (Figure
3) (MIT 5.110).
CMF scored in the adequate range in the following
test areas:
The clinic common areas generally had an
adequate environment conducive to providing
medical services; however, there were
Figure 3: Exam room without privacy screen,
opportunities for improvement. While seven of viewable from common hallway
nine clinic locations received adequate scores
(78 percent), two clinic’s triage areas had a lack of auditory privacy at blood draw and vital
signs stations (MIT 5.109).
Inspectors examined emergency response bags to determine if they were inspected daily and
inventoried monthly and whether they contained all essential items. Emergency response
bags were compliant in four of the five clinical locations where bags were stored
(80 percent). In one clinic, an emergency response bag contained two emergency oxygen
tanks, and neither was fully charged (MIT 5.111).
The institution scored within the proficient range on the following six tests:
Health care staff properly sterilized and disinfected reusable invasive and non-invasive
medical equipment in all 12 clinics locations tested (MIT 5.102).
All of CMF’s 14 clinic locations had adequate hygiene supplies available and operable sinks
(MIT 5.103).
CMF’s non-clinic medical storage areas generally met the supply management process and
support needs of the medical health care program (MIT 5.106).
CMF appropriately disinfected, cleaned, and sanitized 13 of 14 clinics locations tested
(93 percent). At one clinic, staff did not sign inmate-porters’ cleaning logs to validate the
areas were properly cleaned (MIT 5.101).
When inspecting for proper protocols to mitigate exposure to blood-borne pathogens and
contaminated waste, staff members at 13 of the 14 clinic locations (93 percent) followed
proper protocols, one clinic did not have a sharps container (MIT 5.105).
Inspectors found 13 of 14 clinic locations (93 percent) followed adequate medical supply
storage and management protocols. The only exception was the R&R clinic, in which the
exam room storage shelf was not clearly labeled for easy identification of items
(MIT 5.107).
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Office of the Inspector General State of California
Other Information Obtained from Non-Scored Results
The OIG gathered information to determine if the institution’s physical infrastructure was
maintained in a manner that supported health care management’s ability to provide adequate health
care. The OIG did not score this question. When OIG inspectors interviewed health care
management, they did not identify any concerns. CMF had a number of significant infrastructure
projects underway (MIT 5.999):
Project A:
New 5,600-square-foot central health services specialty clinic: March 2017.
New 3,900-square-foot TTA between H and J wing buildings: March 2017.
10,000-square-foot renovation of B wing primary care, dialysis services, nurse triage,
radiology, emergency treatment, pharmacy services, and medical specialty services areas:
December 2017.
2,500-square-foot medical records space renovation: September 2017.
Project B:
New 370-square-foot C and D dorm medication distribution room: June 2016.
New 300-square-foot U and V wing medication distribution room: November 2016.
Recommendations
Conduct periodic training and refresher courses on proper hand sanitation techniques and
protocols that staff should follow when applying and removing protective gloves before,
during, and subsequent to patient encounters.
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Office of the Inspector General State of California
INTER- AND INTRA-SYSTEM TRANSFERS
This indicator focuses on the management of inmate-patients’
Case Review Rating:
medical needs and continuity of patient care during the inter- and
Adequate
intra-facility transfer process. The patients reviewed for Inter- and Compliance Score:
Intra-System Transfers include inmates received from other CDCR Inadequate
facilities and inmates transferring out of CMF to another CDCR (72.8%)
facility. The OIG review includes evaluation of the institution’s
Overall Rating:
ability to provide and document health screening assessments,
Adequate
initiation of relevant referrals based on patient needs, and the
continuity of medication delivery to patients arriving from another
institution. For those patients, the OIG clinicians also review the timely completion of pending
health appointments, tests, and requests for specialty services. For inmate-patients who transfer out
of the facility, the OIG evaluates the ability of the institution to document transfer information that
includes pre-existing health conditions, pending appointments, tests and requests for specialty
services, medication transfer packages, and medication administration prior to transfer. The OIG
clinicians also evaluate the care provided to patients returning to the institution from an outside
hospital and check to ensure appropriate implementation of the hospital assessment and treatment
plans.
In this indicator, the OIG’s case review and compliance review processes yielded different results,
with case reviews giving an adequate rating and the compliance review resulting in an inadequate
score. The OIG’s internal review process considered those factors that led to both results to
determine an overall rating score. The key factor in the decision was that while the compliance
review process found newly arrived patients did not always receive their medications without
interruption, the interruptions only caused one-day delays in patients receiving their medications,
which, from a qualitative standpoint, was insignificant. As a result, the inspection team concluded
that an overall rating of adequate was appropriate.
Case Review Results
Clinicians reviewed 38 encounters relating to Inter- and Intra-System Transfers, including
information from both the sending and receiving institutions. These included 28 outside emergency
room and hospitalization events, each of which resulted in a transfer back to the institution. Thirty
deficiencies were identified, of which six were significant. In general, the inter- and intra-system
transfer processes at CMF were adequate.
Transfers In
Of the five sampled cases of patients who transferred into CMF, the OIG clinicians found only one
significant deficiency (case 33) that could have likely contributed to patient harm:
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Office of the Inspector General State of California
In case 33, the patient arrived at CMF and reported feeling depressed for the last two weeks.
The patient also reported hearing voices or seeing things that were not there. The receiving
RN failed to refer the patient to a mental health clinician immediately. Fortunately, this did
not result in any harm and a mental health clinician saw the patient after six days.
In case 34, there was no evidence that nurses checked the patient’s blood sugar or
administered his insulin medication on the evening he arrived at CMF.
Transfers Out
OIG clinicians reviewed five cases of patients transferring out of CMF, and all five cases were
adequate. The patients’ health care transfer information forms were complete. All necessary
information and forms were available. Medications and health care appliances transferred with the
patients.
Hospitalizations
Patients returning from hospitalizations are some of the highest-risk encounters due to two factors:
First, these patients are generally hospitalized for a severe illness or injury. Second, they are at risk
due to potential lapses in care that can occur during any transfer. OIG clinicians reviewed 28 events
in which patients returned from an outside hospital or emergency department. TTA nurses
processed return patients upon return to CMF. Most discharge summaries were retrieved from
community hospitals and scanned into the eUHR within acceptable time frames, but discharge
summaries were generally not signed or dated by a provider. Medication continuity was acceptable
in the cases reviewed.
There were widespread problems with respect to the quality of nursing assessment and adequate
review of hospital discharge summaries by CMF nurses for patients returning from the hospital or
emergency department. Nursing assessments were unfocused and were barely adequate. The
following examples illustrate these concerns:
In cases 8 and 73, the institution sent the patient out for difficulty breathing. Upon the
patient’s return from the hospital, the RN did not assess his lungs and respiratory status.
In case 9, the institution sent the patient out for abdominal pain. When he returned to CMF,
the RN did not assess his abdomen.
In case 20, the patient returned from the emergency department, where he received treatment
for abdominal pain and constipation. The RN did not assess the patient’s abdomen, address
his elevated temperature, or check when he last received medication for fever. The RN
should have also scheduled the patient for a RN clinic follow-up in the morning to recheck
his temperature.
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Office of the Inspector General State of California
In case 24, CMF sent the patient out for leg edema and pain and was diagnosed with lower
extremity cellulitis and exacerbation of congestive heart failure. The RN did not assess the
patient’s leg.
In case 80, the patient had chest pain, and the institution sent him to the hospital. When he
returned, the RN did not assess him for chest pain, discomfort, or any other symptoms.
In the case below, the RN failed to provide patient education or instructions on hospital
recommendations.
In case 10, the RN did not adequately review the discharge medications and the discharge
summary, which instructed the patient to take a higher dose of carvedilol (blood pressure
medication). The lack of attention to detail resulted in the nurse missing a medication
change upon the patient’s return from the hospital.
Good provider performance largely mitigated the significant problems with nursing assessment after
the patients’ return to the institution. The institutions staff scheduled most returning patients to see
their PCPs within a few days. At those appointments, the PCPs reviewed the discharge summaries
and ensured proper intervention and follow-up.
Clinician Onsite Inspection
During the onsite visit, the OIG clinicians observed that the transfer processes were functioning
well. There was one RN assigned in the R&R each shift during weekdays. The R&R nurse was
knowledgeable of the transfer process and tracked in a log newly arrived patient referrals to mental
health, dental, and medical providers. The primary care team was informed of patients’ arrivals, and
pending specialty appointments were forwarded to the specialty nurse.
Compliance Testing Results
The institution earned an inadequate compliance score of 72.8 percent in the Inter- and
Intra-System Transfers indicator. CMF performed in the inadequate range on the three tests below:
The transfer packages of four patients who were transferring out of the facility were
examined by OIG inspectors to determine whether they included required medications and
support documentation. Only two of four transfer packages (50 percent) were compliant.
Two of the patients who transferred from CMF to another institution did not have all of their
required medication in their transfer packages (MIT 6.101).
Inspectors sampled 20 patients who transferred out of CMF to another CDCR institution to
determine whether the institution listed their scheduled specialty service appointments on
the Health Care Transfer Information form (CDCR Form 7371). CMF nursing staff only
correctly listed the pending specialty service for 11 of the 20 patients sampled who
transferred out of the institution (55 percent) (MIT 6.004).
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Among the 30 sampled patients who transferred into the institution, 16 had an existing
medication order that CMF should have administered or delivered without interruption. Ten
of the 16 patients (63 percent) received their medications timely. Six patients did not receive
all medications during the next required dosing interval, but patients received them the next
day after arrival (MIT 6.003).
The institution scored within the proficient range on the following tests:
Nursing staff properly completed the Initial Health Screening form (CDCR Form 7277) on
the same day the patient arrived for all 30 patients sampled who transferred into the
institution (MIT 6.001).
For 29 of 30 sampled patients who transferred into the institution, RN nursing staff timely
completed the assessment and disposition sections of the CDCR Form 7277 on the same day
that they performed the patient’s initial health screening (97 percent). The only exception
was one patient whom the RN did not refer to the TTA after showing possible signs and
symptoms of tuberculosis (MIT 6.002).
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
PHARMACY AND MEDICATION MANAGEMENT
This indicator is an evaluation of the institution’s ability to provide
Case Review Rating:
appropriate pharmaceutical administration and security management, Adequate
encompassing the process from the written prescription to the Compliance Score:
administration of the medication. By combining both a quantitative Inadequate
(68.8%)
compliance test with case review analysis, this assessment identifies
issues in various stages of the medication management process,
Overall Rating:
including ordering and prescribing, transcribing and verifying, Inadequate
dispensing and delivering, administering, and documenting and
reporting. Because effective medication management is affected by
numerous entities across various departments, this assessment considers internal review and
approval processes, pharmacy, nursing, health information systems, custody processes, and actions
taken by the PCP prescriber, staff, and patient.
In this indicator, the OIG’s case review and compliance review processes yielded different results,
with case review yielding an adequate rating and the compliance review giving an inadequate
score. The case reviews focused on qualitative measures, while the compliance review focused on
quantitative ones. Because the compliance testing for this indicator has more robust sampling and
testing, the compliance score outweighed the case review rating. As a result, the inspection team
determined an overall rating of inadequate for this indicator.
Case Review Results
The OIG clinicians evaluate pharmacy and medication management as secondary processes as they
relate to the quality of clinical care provided. Compliance testing is a more targeted approach and
the overall rating for this indicator relies on the comprehensive compliance testing.
Medication Continuity
For the majority of patients reviewed, medication continuity was not a significant problem for the
patients transferring into the institution, returning from a community hospital, and receiving
monthly chronic care medications. The following cases are provided for quality improvement
purposes.
In case 8, the patient’s theophylline (lung medication) prescription expired, but a provider
did not order a renewal of the medication. The institution sent the patient to the hospital six
weeks later for breathing problems. See the Quality of Provider Performance indicator for
additional discussion of this case.
In case 22, the hospital prescribed several new discharge medications prior to the patient’s
return to the institution. Institution staff administered the new cholesterol and asthma
medications one day late.
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In case 34, on the evening this diabetic patient transferred into CMF, no staff at the
institution checked the patient’s finger-stick glucose level or administered the patient’s dose
of regular insulin. This case is also discussed in the Inter- and Intra-System Transfers
indicator.
Medication Administration
In the majority of cases reviewed, patients received their medications timely and as prescribed, but
there were a few nursing medication administration errors:
In case 11, on five occasions, the patient did not receive doses of clonidine (blood pressure
medication and sedative).
In case 12, on one occasion, the medication nurse did not administer the evening glaucoma
medications to the patient or document why the patient did not receive the medications.
In case 14, on one occasion, the medication nurse did not administer timolol eye drops and
terazosin (prostate and blood pressure medication).
In case 38, the medication nurse did not administer dexamethasone (anti-inflammatory
steroid) on two occasions, and did not administer Revlimid (cancer medication) on three
occasions.
Pharmacy Errors
The OIG clinicians found extremely limited pharmacy documentation in the eUHR, and had
difficulty discerning if any of the various medication errors could have been attributed to pharmacy
services. The following error may have been a pharmacy error:
In case 20, a dentist prescribed antibiotics for the patient to start on the same day. There was
no evidence that pharmacy ever received the order, and the patient never received the
medications.
Clinician Summary
While there were a suboptimal number of medication administration and medication continuity
errors identified at CMF, there was not a significant pattern of deficiencies in this area. The OIG
clinicians rated this indicator adequate.
Compliance Testing Results
The institution received an inadequate compliance score of 68.8 percent in the Pharmacy and
Medication Management indicator. This indicator is divided into three sub-indicators: Medication
Administration, Observed Medication Practices and Storage Controls, and Pharmacy Protocols.
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Office of the Inspector General State of California
Medication Administration
In this sub-indicator, the institution received an average score of 74.7 percent, which fell into the
inadequate range. The institution scored poorly in the following area:
For 18 of 36 patients sampled, the institution timely and correctly administered all required
chronic care medications and followed proper protocols when patients refused or did not
show to receive their medications (50 percent) (MIT 7.001). Many notable instances led to
the low score in this sub-indicator, and for some patients sampled there was more than one
identified problem area. The following are examples of deficiencies:
o Three patients’ keep-on-person (KOP) medication administration records (MARs) did
not contain both a nurse’s signature and a date to evidence a timely and proper
medication administration.
o Three patients never received their monthly supply of KOP chronic care medications.
o Four patients missed or refused a dose of a critical medication, and never received
medication counseling.
o Seven patients received their chronic care medications from 2 to 29 days late.
o One patient was taking his critical HIV medication by directly observed therapy (DOT),
and the provider switched the medication to KOP, but the patient never received the
medication as KOP during the sample test period.
o One patient missed a DOT medication four days in a row, and never received medication
counseling. In addition, the patient missed two doses of insulin, but failed to receive
provider medication counseling by the provider.
The institution performed in the adequate range on the following three tests:
The OIG found that the institution timely administered or delivered new medication orders
to 32 of the 40 patients sampled (80 percent). Three patients received their medications from
one to two days late, and five patients had missing or incomplete eUHR MARs to
demonstrate that they received their medications (MIT 7.002).
Eight of the ten sampled patients who were in transit to another institution and were
temporarily laid over at CMF received their medications without interruption (80 percent).
Two patients each missed at least one dose of their required medications (MIT 7.006).
CMF timely provided hospital discharge medications to 23 of 30 patients sampled who had
returned from a community hospital (77 percent). For six patients, their discharge
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medications were one to six days late, and one patient did not receive his discharge
medication at all (MIT 7.003).
CMF scored in the proficient range on the test below:
Among 30 sampled patients at CMF who had transferred from one housing unit to another,
26 received their prescribed medications without interruption (87 percent). Four patients did
not receive their medication by the next dosing interval after the transfer occurred
(MIT 7.005).
Observed Medication Practices and Storage Controls
For this sub-indicator, the institution received an average score of 46.3 percent, scoring in the
inadequate range on the following five tests:
Among 11 inspected clinics and medication line
storage locations, non-narcotic medications that
require refrigeration were properly stored in only one
(9 percent). Some inspected locations had more than
one identified problem area. Deficiencies included:
ten sampled locations without a designated area for
return-to-pharmacy medications, two locations with
expired floor stock medications, two locations with
refrigerators whose temperature logs were missing
entries, and one clinic with medication vials that
nurses did not date when first opened. Finally, one
location had a refrigeration unit that was unsanitary
(Figure 4) (MIT 7.103).
The OIG interviewed nursing staff and inspected
narcotics storage areas at 13 applicable locations to
Figure 4: Unsanitary medication
assess narcotics security controls. Overall, only three refrigerator with grime on bottom shelf
area
clinic locations (23 percent) had good controls. In the
ten other sampled locations, nursing staff did not
always complete required control log entries. More specifically, for the OIG’s limited
30-day review period, log books were missing from 2 to 18 required signature entries,
generally relating to shift change narcotics count reconciliations, but also periodically
relating to the destruction of a wasted medication (MIT 7.101).
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The OIG inspected 16 applicable clinics and
medication line storage locations and found that
non-narcotic medications that did not require
refrigeration were properly stored at only five
(31 percent). Some inspected areas had more
than one identified problem area. Deficiencies
included seven locations that did not have a
designated area for return-to-pharmacy
medications; two locations that had a stash of
medications that were not properly controlled or
accounted for by the pharmacy (Figure 5), and
two locations with expired medications on hand. Figure 5: Stash of uncontrolled medications
Finally, one location had internal and external found in the R&R clinic area
medications unsafely stored together
(MIT 7.102).
Nursing staff at only four of seven sampled medication preparation and administration
locations followed proper hand hygiene contamination control protocols during the
medication preparation and administration processes (57 percent). Nursing staff at three
other locations did not always sanitize their hands prior to initially putting on protective
gloves or between subsequent glove changes (MIT 7.104).
Only four of seven toured medication areas demonstrated appropriate administrative
controls and protocols during medication distribution (57 percent). Nursing staff did not
verify the identification of two patients prior to administering medication at two locations,
and the nurse at one other location did not verify a patient’s identification and administered
a liquid medication for a patient from another patient’s bottle (MIT 7.106).
CMF scored in the proficient range on the following test:
Nursing staff at all seven of the inspected medication and preparation administration
locations followed appropriate administrative controls and protocols during medication
preparation (MIT 7.105).
Pharmacy Protocols
For this sub-indicator, the institution received an average score of 90.0 percent, scoring 100 percent
in the following test areas:
In its main and satellite pharmacies, CMF followed general security, organization, and
cleanliness management protocols; properly stored refrigerated and frozen medications; and
maintained adequate controls and properly accounted for narcotic medications (MIT 7.107,
7.109, 7.110).
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CMF’s pharmacist in charge timely processed all 30 inspector-sampled medication error
reports (MIT 7.111).
The institution scored in the inadequate range on the following test:
The institution scored 50 percent for storage of non-refrigerated medication in pharmacy
locations. Specifically, the main pharmacy (one of two CMF pharmacies) had medication
placed in bins and stored on the floor (MIT 7.108).
Non-Scored Tests
In addition to the OIG’s testing of reported medication errors, inspectors follow-up on any
significant medication errors that were found during the case reviews or compliance testing
to determine whether the errors were properly identified and reported. The OIG provides
those results for information purposes only. At CMF, the OIG did not find any applicable
medication errors (MIT 7.998).
The OIG tested patients in isolation units to determine if they had immediate access to their
prescribed KOP rescue asthma inhalers and nitroglycerin medications. Inspectors identified
three patients to which this test applied. Based on interviews with all three patients, all had
physical possession of their rescue medication (MIT 7.999).
Recommendations
The OIG recommends that as part of staff’s performance evaluation, CMF management should
evaluate clinicians’ compliance and understanding of good hand sanitation practices.
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PREVENTIVE SERVICES
This indicator assesses whether various preventive medical services Case Review Rating:
are offered or provided to inmate-patients. These include cancer Not Applicable
screenings, tuberculosis screenings, and influenza and chronic care Compliance Score:
Inadequate
immunizations. This indicator also assesses whether certain
(65.4%)
institutions take preventive actions to relocate inmate-patients
identified as being at higher risk for contracting coccidioidomycosis Overall Rating:
(valley fever). Inadequate
x
The OIG rates this indicator entirely through the compliance testing
component; the case review process does not include a separate qualitative analysis for this
indicator.
Compliance Testing Results
The institution performed in the inadequate range in the Preventive Services indicator, with a score
of 65.4 percent. The institution scored in the inadequate range on the following three tests:
CMF scored 53 percent in regard to conducting annual tuberculosis screenings. Although all
30 inmate-patients sampled were screened for tuberculosis within the prior year, only 6 of
the 15 patients identified as Code 22 (requiring a tuberculosis skin test in addition to
screening of signs and symptoms) were properly tested. For each of the other nine Code 22
patient screenings, inspectors identified one or more of the following errors: the
48-to-72-hour window to read test results was not clear because nursing staff did not
document either the administered (start) or read (end) date and time; test results were read
outside of the required 72-hour time period; an LVN read the test results rather than an RN,
public health nurse, or primary care provider; or nursing staff did not complete all required
sections of the Tuberculin Testing/Evaluation Report (CDCR Form 7331). In addition, five
of the 15 patients identified as Code 34 (requiring only a signs and symptoms screening) did
not receive a proper evaluation because nursing staff did not properly complete the history
section of the CDCR Form 7331 (MIT 9.003).
CMF scored 67 percent in regard to timely administration of anti-tuberculosis medications.
Of 18 patients sampled, 12 received all required doses of their medication in the most recent
three-month or 12-week period. Six patients did not receive all of their anti-tuberculosis
medications and did not receive provider counseling regarding the missed doses
(MIT 9.001). In addition, only one of 17 patients tested (6 percent) received monthly or
weekly monitoring while taking anti-tuberculosis medications. Nine patients received no
monitoring at all, and six patients only received monitoring sporadically while on the
medication. Finally, one patient received all of the required monitoring, but the monitoring
forms were not scanned into the eUHR after each monitoring visit (MIT 9.002).
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The institution scored in the proficient range on the following tests:
The institution offered annual influenza vaccinations to 28 of 30 sampled patients subject to
the annual screening requirement (93 percent). No evidence was found in the eUHR that two
patients received an influenza vaccination in the most recent influenza season (MIT 9.004).
The OIG found 26 of 30 patients sampled (87 percent) either had a normal colonoscopy
within the last ten years or that health care staff offered a colon cancer screening in the last
year. Four patients either did not have a normal colonoscopy within ten years or were not
offered a colon cancer screening in the last 12 months (MIT 9.005).
The OIG tested whether CMF offered required influenza, pneumonia, and hepatitis
vaccinations to patients who suffered from a chronic condition; 26 of the 30 patients
sampled (87 percent) received them; the institution did not offer four patients one or more of
the vaccinations (MIT 9.008).
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
QUALITY OF NURSING PERFORMANCE
The Quality of Nursing Performance indicator is a qualitative
Case Review Rating:
evaluation of the institution’s nursing services. The evaluation is
Inadequate
completed entirely by OIG nursing clinicians within the case
Compliance Score:
review process, and, therefore, does not have a score under the
Not Applicable
compliance testing component. The OIG nurses conduct case
reviews that include reviewing face-to-face encounters related to Overall Rating:
nursing sick call requests identified on the Health Care Services Inadequate
Request form (CDCR Form 7362), urgent walk-in visits, referrals
for medical services by custody staff, RN case management, RN utilization management, clinical
encounters by licensed vocational nurses (LVNs) and licensed psychiatric technicians (LPTs), and
any other nursing service performed on an outpatient basis. The OIG case review also includes
activities and processes performed by nursing staff that are not considered direct patient encounters,
such as the initial receipt and review of CDCR Form 7362 service requests and follow-up with
primary care providers and other staff on behalf of the patient. Key focus areas for evaluation of
outpatient nursing care include appropriateness and timeliness of patient triage and assessment,
identification and prioritization of health care needs, use of the nursing process to implement
interventions including patient education and referrals, and documentation that is accurate,
thorough, and legible. Nursing services provided in the outpatient housing unit (OHU), correctional
treatment center (CTC), and hospice are reported in the Specialized Medical Housing indicator.
Nursing services provided in the triage and treatment area (TTA) or related to emergency medical
responses are reported in the Emergency Services indicator.
Case Review Results
The OIG clinicians reviewed 183 outpatient nursing encounters, 152 of which were for sick call
requests or outpatient clinic nurse follow-up visits. There were 108 deficiencies identified related to
the quality of nursing care, with 29 that were significant. The majority of these deficiencies
involved failure to perform face-to-face assessments when Health Care Services Request forms
(CDCR Form 7362) described clinical symptoms. Some of these deficiencies contributed to
substantial lapses in care. Serious deficiencies also occurred when nurses reviewing sick call
requests failed to recognize the need for a same-day RN assessment and when outpatient clinic
nurses failed to refer patients to providers in a timely manner. There were serious concerns
regarding the lack of and inadequate nursing assessment and timely intervention. The OIG nursing
clinicians rated this indicator inadequate.
Nursing Sick Call
The National Commission of Correctional Health Care (NCCHC) has set a standard for
nonemergency health care requests and services to ensure that patients have access to care to meet
their health care needs. All patients should have the opportunity to request health care, and these
requests should be reviewed for immediacy of need. When a patient submits a sick call request
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describing clinical symptoms, a face-to-face encounter with a health care provider is required.
CCHCS policy requires that an RN see these patients face to face within the prescribed time frame,
adequately assess them, document the encounter, and ensure that an appropriate disposition is
implemented.
CMF health care staff collected and triaged Health Care Service Requests forms (CDCR 7362) in a
timely manner. However, case reviews showed that the outpatient clinic nurses consistently failed to
perform face-to-face assessments on patients with symptom complaints. Frequently, the outpatient
clinic nurses initiated referral to the provider or added medical requests on the next provider
appointment without performing a face-to-face assessment, and patients would wait several days or
even weeks to see a provider.
While on site reviewing sick call request forms, the OIG clinicians also noted that CMF sick call
nurses failed to see patients with symptoms face to face (these patients were in addition to the case
review samples). In one of the clinics, a patient submitted a sick call request because of leaking
fluid from his right ear. The sick call RN did not schedule the patient for face-to-face assessment
and instead added the complaint to the next provider appointment one week later. The RN stated
that the patient was just seen five days before by the ear, nose, and throat specialist (ENT) provider,
who noted no abnormal findings, but the leaking had started after the ENT encounter. Another
patient, who submitted a sick call request with complaints of neck, back, and knee pain and high
blood sugar for a month, was also referred to the provider line without an RN face-to-face
assessment as required by CCHCS policy and nursing standards of practice. In fact, CMF nurses
collected multiple sick call requests with symptom complaints, but CMF RN’s mostly deferred to
the provider without a nursing assessment.
Additionally, the outpatient clinic nurses sometimes failed to perform immediate face-to-face
assessments when medically necessary, perform adequate patient assessments, or formulate an
appropriate plan of care, such as a timely referral to the provider. While many of the patients
ultimately received adequate care, the pattern of nursing staff’s failure to see patients face to face, to
perform adequate assessments, and appropriately refer patients to a provider increased the potential
for patient harm. In the following examples, RN face-to-face encounters did not occur:
In case 11, the patient had a fall and sustained multiple facial fractures, which required
surgery. He also had an abscess on his leg and later developed pneumonia, which resulted in
an overwhelming infection and the patient’s death. He submitted multiple sick call requests
that were not addressed by the outpatient clinic nurse:
o In late June, the patient submitted a sick call request for pain, but the RN did not conduct
a face-to-face encounter. The RN referred him to the provider, who saw him ten days
later.
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o In mid-July, the patient submitted a sick call request for swelling, discharge, and pain in
the eye. The RN did not see the patient and instead deferred evaluation to the next
pending ophthalmology follow-up appointment in three months.
o In late August, the patient submitted a sick call request to see the provider for an
“emergency” and because he just returned from the hospital. The RN did not see the
patient face-to-face, and instead noted that a provider saw the patient two days prior and
scheduled the patient for routine provider appointment. The patient was seen in the TTA
later in the evening for shortness of breath.
In case 16, the outpatient clinic nurses repeatedly failed to see the patient face-to-face for
sick call requests with clinical symptoms:
o The patient submitted a sick call request for flushing, anxiety, bronchial constriction, and
tremors since his Nortriptyline medication were discontinued. The RN reviewed the sick
call slip but did not see the patient.
o Three days later the RN reviewed another sick call request describing the same clinical
symptoms and discussed it with the provider, who ordered a new medication. The RN
failed to perform a face-to-face assessment.
o One month later, the patient submitted a sick call request reporting problems with his
ability to self-catheterize his bladder. The RN did not see the patient face-to-face to
assess the patient’s ability to perform self-catheterization and provide instruction or
demonstration if necessary.
o Nearly three weeks after that, the patient submitted a sick call request stating he had torn
or ruptured his urethra over three weeks ago with daily blood in his urine and pain. The
RN did not see the patient face-to-face, and instead added the issue to the next provider
appointment. The provider saw the patient four days later.
o Less than one week later, the patient submitted a sick call request for severe pain and
hematuria (blood in the urine). The RN did not see the patient face-to-face.
In case 24, there were multiple sick call requests that were addressed inappropriately:
o The patient submitted a sick call form requesting Lyrica for his neuropathy and
complained of acid reflux and a hernia. The RN did not see the patient and instead added
the request to the upcoming provider appointment. The appointment occurred ten days
later.
o Six weeks later, the patient submitted a sick call request to discontinue Lyrica because of
side effects. He complained of high blood sugar, swelling, rash, and muscle pain. Not all
of the symptoms described by the patient could be attributed to the medication, and the
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patient may have been having symptoms for other medical reasons. The RN did not
assess the patient and did not make a new referral, but instead added the new issues to an
existing provider appointment. The appointment did not occur until five weeks later. By
failing to address the patient’s concerns at the time of the complaint, the nurse
contributed to a significant lapse in care.
o Another six weeks later, the patient submitted a sick call request for one month of
continued leg swelling. Despite multiple diagnostic tests and interventions provided, the
RN still did not see the patient.
o Five days later, the patient submitted a sick call request and wrote “emergency” and that
his legs had continued to get worse. The nurse did not see the patient and instead wrote
that a provider already saw the patient four days prior. The nurse should have brought
the patient in for an evaluation and had the provider readdress the medical problem.
In case 45, the patient submitted a sick call request for severe leg swelling and for refill of
his blood pressure medication, losartan. The RN did not see the patient face-to-face and only
noted that the request was sent to the provider to reorder medication.
In case 49, the patient submitted a sick call request for severe back and leg pain. The patient
also stated the he had not seen his provider since he arrived at CMF, and he requested to see
the podiatrist. The RN did not see the patient face-to-face and failed to review the eUHR,
which documented that the patient had multiple medical conditions, including a history of
deep vein thrombosis (blood clot). The RN referred the patient for a routine provider
appointment. A provider last saw the patient almost one month before. At that time, the
provider ordered a three- to five-day follow-up, but this did not occur. The RN should have
referred the patient to the provider sooner.
In case 51, the patient submitted multiple sick call requests to see the podiatrist because his
shoes were in disrepair, causing ankle and foot pain. Each time, the RN did not see the
patient for a face-to-face encounter.
In case 52, the patient submitted a sick call slip for abdominal symptoms. The RN did not
see the patient face-to-face.
In case 58, the patient submitted a sick call request for severe facial pain and headaches. The
RN did not perform a face-to-face assessment. Nine days later, the patient submitted another
sick call request for the same symptoms. Again, the RN did not see the patient or refer him
to the provider.
The outpatient clinic RN also failed to see the patient, in some instances multiple times, in
cases 6, 7, 8, 12, 19, 21, 22, 43, 46, 48, 56, 59, 60, 61, 63, 64, 65, 67, 70, and 71.
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In the following cases, the outpatient RN failed to see the patient with serious medical symptoms on
the same day:
In case 16, the patient woke up with his urine bag full of blood and submitted a sick call
request, but the RN did not see the patient until four days later.
In case 21, the patient submitted a sick call request for acute bleeding symptoms. He stated
that he was a diabetic and on blood thinners. The RN did not see the patient on the same
day.
In case 28, the patient submitted a sick call request because his pacemaker alarm continued
to beep. The RN did not assess the patient on the same day.
During RN face-to-face encounters with the patient, the outpatient RN failed to collect data and
perform an adequate nursing assessment relevant to each patient’s health and condition. The OIG
clinicians could not determine if the nurse asked important questions, examined pertinent areas of
the body, or performed necessary measurements. Nurses also failed to document the presence or
absence of common accompanying signs and symptoms.
In case 10, the patient submitted a sick call request for kidney pain. The RN failed to obtain
a urine test and assess the patient for abdominal distention, tenderness, or pain.
In case 17, the patient saw the outpatient RN for leg pain, numbness, and swelling. In
addition, the patient stated that he had not seen his provider for a follow-up for his
neurology consultation. The neurologist recommended medication changes, and the RN did
not adequately review the patient’s medical records and inform the provider of the
specialist’s recommendation.
In case 19, the patient saw the RN for stomach pain. The RN did not obtain adequate
history, such as time of symptom onset, duration and location of pain, any accompanying
signs and symptoms, last meal eaten, and current medications. The RN did not examine the
patient for any abnormal findings such as abdominal distention, guarding (tense abdominal
muscles), or tenderness.
In case 40, the patient submitted a sick call request for numbness in the hands and fingers
along with forearm cramps, swollen wrist, nerve tissue damage, and pain in the right
shoulder. The nurse did not perform an adequate assessment. Additionally, the RN added the
problem to an unrelated provider appointment, with no evidence that the nurse even
consulted with the provider first. Because of the nurses’ actions, the provider did not receive
the patients’ medical issues; therefore, the provider did not address them.
In case 46, the patient had back pain for two days. The RN did not examine the patient’s
back for swelling, tenderness, or range of motion. The patient submitted another sick call
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request for urinary problems, and swollen ankles and feet. The RN did not obtain a urine
dipstick test to check for possible infection.
In case 59, the patient submitted sick call requests for burning sensation after urination and
neck pain. The RN did not obtain adequate history such as onset or duration of symptoms,
any accompanying symptoms such as flank or lower abdominal pain, problems with voiding
such as dribbling or retention, color of urine, discharge, lesion, or bleeding in the area. The
RN also did not assess the patients’ neck.
In case 61, the patient saw the RN for arm and leg pain. The RN did not assess the patient’s
arms and legs for any swelling, circulation, sensation, or mobility problems.
In case 64, the patient saw the RN for pain and burning in his stomach. The RN did not
examine the patient’s abdomen, ask for the onset or duration of the condition, or any
accompanying signs and symptoms.
The outpatient nurses failed to utilize the nursing process and determine an appropriate intervention
or disposition, such as timely referral, to achieve a positive outcome.
In case 12, the LVN completed a sick call request on behalf of the patient. The patient
complained of having severe nausea and vomiting. The LVN did not immediately refer the
patient to the RN or provider. The patient was brought to the TTA the next morning for
shortness of breath and confusion.
In case 24, the RN saw the patient for irregular bowel movements, kidney concerns, and
retaining water in his hands and feet. The nurse did not create a new referral, but instead
added the patient to an existing provider appointment. The next appointment did not occur
until four weeks later. The nurse’s action contributed to a significant delay in care.
In case 26, the patient saw the RN because he fell off the top bunk, hit his head, and had
symptoms of vomiting, dizziness, headache, and diarrhea. The RN obtained further history
that the patient was taking blood thinners and referred the patient for a 14-day routine
follow-up. The nurse should have performed a neurological assessment and had a same day
provider consultation. The RN failed to consider an intracranial bleed in this situation, and
did not refer the patient to a provider timely (this event was classified as an unsafe condition
and is discussed in the Medical Inspection Results: Adverse Events Identified During Case
Review section on page 12).
Nursing Documentation
Nursing documentation in some of the cases reviewed was incomplete or illegible with most words
impossible to identify. Incomplete or illegible nursing notes may result in disruption in the
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continuity of patient care and potentially put the patient at risk (cases 8, 9, 12, 16, 18, 20, 46, 75,
and 81).
Specialty Services
The OIG clinicians reviewed 65 nursing encounters related to specialty services and found 44
nursing deficiencies. At CMF, patients returning from offsite specialty appointments were
processed in the TTA. Nurses generally spent a minimum amount of time assessing patients, which
often resulted in inadequate nursing assessment. Nurses rarely performed a thorough assessment
and documentation was often incomplete or illegible. There was no education or instructions
provided to the patient who underwent procedures. See the Specialty Services indicator for specific
findings on nursing performance.
Emergency Services
The OIG clinicians reviewed 70 urgent/emergent events and found 43 deficiencies related to
nursing care. The TTA nurses showed patterns of inadequate nursing assessments and delayed
provider notifications. See the Emergency Services indicator for specific findings.
Specialized Medical Housing
Overall, the nursing care provided in the specialized medical housing facilities was adequate. See
the Specialized Medical Housing indicator for specific findings.
Medication Administration
In the majority of cases reviewed, patients received their medications timely and as prescribed. See
the Pharmacy and Medication Management indicator for specific findings.
Inter- and Intra-System Transfers
Inter- and intra-system transfer processes were adequate. However, the OIG clinicians found
systemic concerns to the quality of nursing assessment and adequate review of hospital discharge
summaries by nurses for patients returning from the hospital or emergency department. See the
Inter- and Intra-System Transfers indicator for specific examples.
Clinician Onsite Inspection
At the time of the OIG inspection, there were six outpatient clinics at CMF located in one central
area and an RN clinic at each of the C and D dorms. There were two additional exam rooms in the
central area and a nursing station. The OIG clinicians visited the outpatient clinics and attended the
primary care team morning huddles. Most of the huddles started and ended on time, and were
attended by the providers, sick call nurses, and LVN care coordinators. Medication line nurses and
custody staff only attended if there were issues to address or communicate to the team. Daily huddle
reports included TTA log review for unscheduled transfers to higher level of care and patient
returns, significant diagnostic and laboratory results, new arrivals and recent transfers, medication
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issues, provider schedule, backlogs, staffing and supplies issues, and reviews of CDCR Form
7362’s received. However, there were no meaningful discussions from nursing on the sick call and
case management line or other clinical nursing issues.
The OIG clinicians interviewed outpatient clinic nurses and supervisors on the nursing sick call
process. On average, the outpatient clinic nurses saw five patients daily for face-to-face
assessments, including walk-ins. Nurses spent the rest of their time reviewing patient medical
information. One of the outpatient clinics did not have any RN face-to-face appointments
scheduled, but the clinic had received multiple sick call requests with symptom complaints. The
nurses verbalized having no major barriers with initiating communication with their providers,
supervisors, and custody staff regarding patient care needs. The nursing staff also reported that
CMF has implemented the Complete Care Model policy, and the institution assigned each patient to
a care team. However, the nurses did not fully understand their roles and responsibilities as a care
team member. This clinic nursing supervisor was proactive in her assigned unit and regularly
conducted audits of nursing sick call encounters.
The OIG clinicians interviewed nursing staff from other clinical areas, including specialty services,
telemedicine services, utilization management, public health, receiving and release areas, nursing
education, medication management, correctional treatment centers, outpatient housing units, and
hospice areas. The nursing and support staff were knowledgeable of their duties and responsibilities.
However, they demonstrated inconsistencies in job satisfaction and described problems such as
staffing issues, lack of communication, and clear directives from nursing management. The OIG
clinicians also interviewed the nurse educators and reviewed training files of nurses assigned in
different clinical areas. The nurse educators utilized a tracking log to ensure that CMF provided
nurses with the required and mandatory training in a timely manner. New nurses attended ten days
of classroom training prior to their orientation in the different clinical areas and nursing staff were
required to attend annual trainings, policy update reviews, and skills improvement classes. The
nurse educators also initiated mental health trainings recently for all nursing staff.
The OIG clinicians also reviewed supervisory files and found the most recent performance
evaluation in each of them. The file review did not identify any staff performance issues.
Recommendations
The OIG recommends providing nurses training on the sick call process to ensure that they
understand the CCHCS policy, appropriately review sick call requests, recognize cases
requiring same-day assessment, and implement timely nursing intervention and referral.
The OIG recommends nursing leadership review and improve the process of evaluating
nursing competency to reflect an accurate assessment of a nurse’s knowledge and skill.
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QUALITY OF PROVIDER PERFORMANCE
In this indicator, the OIG physicians provide a qualitative
Case Review Rating:
evaluation of the adequacy of provider care at the institution.
Adequate
Appropriate evaluation, diagnosis, and management plans are
Compliance Score:
reviewed for programs including, but not limited to, nursing sick Not Applicable
call, chronic care programs, TTA, specialized medical housing,
and specialty services. The assessment of provider care is Overall Rating:
performed entirely by OIG physicians. There is no compliance Adequate
testing component associated with this quality indicator.
Case Review Results
The OIG clinicians reviewed 195 medical provider encounters and identified 83 deficiencies, 32 of
which were significant, related to provider performance at CMF. There was a strong pattern of
deficiencies among two CMF physicians, who were responsible for the vast majority of the
deficiencies identified below. The OIG clinicians rated CMF provider performance adequate.
Assessment and Decision-Making
In the majority of encounters, CMF providers made good assessments and sound decisions, as the
following two cases demonstrate:
In case 10, the PCP proficiently managed the patient’s multiple chronic medical conditions
and coordinated multiple diagnostic tests. The PCP obtained a cardiac catheterization,
coronary stent placement, colonoscopy, and DEXA scan.
In case 39, the PCP expertly managed the patient’s medical care after the patient transferred
into CMF with a diagnosis of brain cancer. The PCP arranged multiple MRIs and
coordinated specialty care, including radiation oncology and neurosurgery consultations.
Despite the good care found in the majority of cases reviewed, the OIG clinicians identified a
significant pattern of problems with inadequate assessment and decision-making, as identified in
cases 8, 11, 12, 16, 17, 18, 24, 28, 30, 31, 38, and 40. In-depth analysis of these errors revealed that
two CMF physicians were responsible for the vast majority, as shown in the following examples:
In case 30, the patient had poorly controlled diabetes and hypertension. The provider did not
review the most recent lab reports and did not order required monitoring tests. The provider
ignored the patient’s elevated blood pressure. The patient required better mealtime blood
sugar control, but the provider did not offer the patient appropriate diabetic medications and
ordered an excessively long six-month follow-up.
In case 12, the provider saw the patient in the TTA for fever and low oxygen levels. After
the patient refused hospitalization, the TTA provider treated him with antibiotics. When the
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patient saw his PCP for follow-up three weeks later, the provider did not review the medical
record showing that the TTA provider recently saw the patient for a serious illness.
Review of Records
In most encounters, CMF providers performed an adequate review of records when caring for their
patients.
In case 6, the provider managed multiple chronic conditions, including seizures, low kidney
function, and HIV. The patient with persistent seizures was also hospitalized at one time.
The provider appropriately managed the patient’s medications based on various lab tests and
changes in condition. The provider’s good performance would not have been possible
without thorough review of multiple labs and hospital records.
Despite good performance by most CMF providers, the same two CMF physicians were also
responsible for the strong pattern of deficiencies where they performed a superficial and incomplete
review of records. The OIG clinicians identified this deficiency in cases 6, 12, 18, 20, 21, 24, 30,
31, 38, and the following case:
In case 8, the patient’s chronic lung medication (theophylline) had expired within the past
week. The PCP did not adequately review the records and failed to renew the patient’s
theophylline, which likely contributed to the patient’s hospitalization six weeks later. In
addition, the provider failed to recognize that the patient was seen in the TTA for a
man-down event within the last week, and did not address the problem. The provider wrote
that he last saw the patient more than two months prior; in fact, he had seen the patient only
three weeks prior, which further suggested that the provider did not review the medical
record.
Failure to review records combined with inadequate assessment or decision-making ultimately
resulted in medical problems that the provider did not address. Providers ignored and failed to
adequately address medical conditions in cases 8, 13, 16, 18, 22, 24, 28, 30, 31, 40, and the
following case:
In case 17, the patient had persistently elevated blood pressure in every clinical encounter
for the past three months. The provider assessed the hypertension as labile (abruptly
fluctuates), and failed to perform any intervention. The provider did not even order blood
pressure monitoring or a follow-up appointment.
Even when providers ignored or failed to address medical conditions, they still may have provided
adequate care if the provider saw the patient frequently for follow-up and re-evaluation. The
provider may have eventually realized the errors and intervened to correct them. Unfortunately, the
same two physicians were also responsible for the majority of errors in this area as well.
Deficiencies in which the provider did not order an appropriate follow-up interval occurred in cases
8, 16, 20, 21, 24, 28, 29, 31, and 38.
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Emergency Care
When CMF TTA providers evaluated patients in person, they generally made accurate assessments
and safe triage decisions. In 2015, at the direction of CCHCS headquarters, CMF removed
after-hours onsite physician coverage (MOD –medical officer of the day), and instituted after-hours
coverage by telephone (POC – physician on call). This type of coverage is inherently more risky for
a medically complex patient population. Good on-call coverage is dependent on meticulous,
accurate, and consistent clinical assessment and judgment on the part of both nurses and providers.
Telephone assessment is also prone to the limitations of audio-only communication. On-call
coverage at CMF was severely problematic. These findings are further discussed in the Emergency
Services indicator.
Chronic Care
The institution had two primary care physicians who managed HIV and hepatitis C patients. Both of
these specialized physicians demonstrated exceptional attention to detail, comprehensive
assessment, and sound decision-making.
The pharmacy department at CMF ran the anticoagulation clinic. The pharmacist performed clinical
evaluations at appropriate intervals, ordered and reviewed labs, and made warfarin medication
adjustments precisely according to the CCHCS anticoagulation protocol. The pharmacy staff ran the
anticoagulation clinic well, and they did not contribute to any significant deficiencies.
In cases 26 and 27, the anticoagulation clinic demonstrated close warfarin monitoring and
management. The clinic pharmacist ordered and reviewed lab tests in a timely manner. The
pharmacist inquired about side effects and any evidence of bruising or bleeding, made
appropriate medication adjustments in response to low or high warfarin levels, and referred
the patients back to the PCP when medication compliance became problematic.
Despite the good performance by the anticoagulation clinic, proper patient care depended on the
PCPs determining the appropriate warfarin target levels and communicating those targets to the
clinic, which did not always occur.
In case 28, the patient had a mechanical mitral valve, which required a higher warfarin target
level than normal. The target for this patient should have been to reach an INR (lab test for
warfarin levels) between 2.5 and 3.5. However, the PCP directed the anticoagulation clinic
to treat to a target level of only 2.0 to 3.0. This increased the patient’s risk of life-threatening
blood clots from the mitral valve. Fortunately, no harm occurred during the review period.
Diabetic management performance was inconsistent and was provider dependent. Those providers
who had demonstrated poor review of records, inadequate assessment, and poor decision-making
and who had ordered inappropriately long follow-up intervals also did not perform well with
diabetic management.
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In case 31, the patient had poorly controlled diabetes throughout the review period. The PCP
intermittently made efforts to control the patient’s diabetes. However, on several occasions,
the PCP did not review the finger-stick sugar logs, did not recommend appropriate changes
to insulin dosage, and ordered excessively long follow-up intervals. The provider also did
not follow current guidelines for treating the patient with lipid-lowering medications. These
provider errors increased the likelihood of the patient’s prolonged poorly controlled diabetes
and its associated harms.
Specialty Services
CMF providers referred appropriately and diligently at all times. Furthermore, CMF providers
ordered specialty services within appropriate time frames. When providers saw patients for
follow-up after specialty services, they appropriately reviewed reports and took appropriate actions.
Clinician Onsite Inspection
The institution has had stable physician leadership for many years with the CME and CP&S. Most
providers described the CP&S as supportive and fair, with good communication skills. The CP&S
was easily reachable and was always willing to help. Providers described the CME as a firm,
intelligent, and strong patient care advocate. Providers generally felt that they were well supervised
and that their management team was a strength of CMF’s medical program.
Providers universally described their own morale as poor. Providers were unhappy with the change
in after-hours coverage from onsite to on-call. They described the change as detrimental to patient
care; and felt frustrated about the perception that the providers were only concerned about their loss
of overtime pay, instead of the quality of patient care. The providers explained that with CMF’s
medically complex patient population, on-call providers were exposed to excessive medical risk
compared to providers in other CDCR institutions. CMF patients frequently became ill and required
multiple triage decisions on a daily basis. When performing a telephone encounter, the only way a
provider could mitigate those risks was to come into the facility and perform a face-to-face
evaluation. CMF providers did not consider travelling to and from the institution multiple times per
on-call night as a practical long-term solution. At the time of the OIG clinicians’ onsite inspection
(March 2016), six CMF providers had announced that they were leaving or had already retired or
transferred to other, less risky institutions because of this problem.
The CME acknowledged that CMF had a severe provider retention problem. After many years of
provider stability, the sudden loss of six providers in the span of less than a year posed significant
challenges for the institution to maintain adequate quality of care. The CME explained that CMF
traditionally did not have a recruitment problem, and did not describe any recent problems in
recruitment of new physicians. The CP&S and the CME were not aware of any quality concerns for
any of their providers, and were resistant to the idea that two of their providers might be performing
at a substandard level.
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Clinician Summary
Of the 30 detailed, physician-reviewed cases, three were proficient, 19 were adequate, and eight
were inadequate. An in-depth analysis of the CMF provider deficiencies revealed that 55 of the 83
provider performance deficiencies (66 percent) were attributed to only two providers. Likewise, 24
of the 32 significant provider performance deficiencies (75 percent) were attributed to the same two
providers. No patterns of deficiencies were found among the other 16 physicians who contributed to
care in the cases reviewed. After considering all factors, the OIG rated CMF provider performance
adequate.
Recommendations
The OIG recommends further clinical performance reviews for the two providers identified as
performing at a sub-optimal level.
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SPECIALIZED MEDICAL HOUSING (OHU, CTC, SNF, HOSPICE)
This indicator addresses whether the institution follows appropriate
Case Review Rating:
policies and procedures when admitting inmate-patients to onsite
Adequate
inpatient facilities, including completion of timely nursing and
Compliance Score:
provider assessments. The chart review assesses all aspects of Adequate
medical care related to these housing units, including quality of (76.5%)
provider and nursing care. CMF’s specialized medical housing
Overall Rating:
units are correctional treatment centers (CTC), outpatient housing
Adequate
unit (OHU) and hospice unit.
Case Review Results
At the time of the OIG’s inspection, CMF had a 55-bed medical CTC, a 47-bed OHU, and a 17-bed
hospice unit. There were designated negative pressure rooms (designed to minimize the spread of
airborne infection) in the CTC and OHU. The OIG clinicians reviewed 106 provider and 210
nursing encounters and identified only two provider deficiencies but 132 nursing deficiencies.
While there were significant problems identified with CTC nursing performance, excellent provider
performance largely mitigated those issues. The OIG clinicians rated the case review portion of this
indicator adequate.
Provider Performance (CTC, OHU, Hospice)
CMF provider performance in the specialized housing units was very good. CMF providers
demonstrated excellent assessments and close follow-ups. Extremely detailed and thorough
discharge summaries proved that CMF providers were well aware of and were thoughtfully
managing their patients’ numerous medical conditions. CMF providers ensured that patients
received adequate care, despite the questionable nursing performance in some of the specialized
housing units.
In case 9, the patient was hospitalized for confusion caused by his liver disease and a severe
infection. The patient was diagnosed with a small epidural (spinal) abscess. Upon the
patient’s return to the institution, the CTC provider thoroughly reviewed the records and
performed a detailed H&P. The regular CTC provider saw the patient within appropriate
intervals and closely monitored the patient as he recovered. Close follow-ups by the
physician mitigated several nursing errors in this case. Upon the patient’s discharge from the
CTC, the provider documented an impressively detailed discharge summary.
In case 14, medical staff admitted the patient to CMF’s hospice unit with end-stage renal
disease, and he refused dialysis treatment. The hospice physician documented a complete
and well-thought-out plan of care in the admission H&P. Throughout the patient’s hospice
course, the provider demonstrated compassionate care with an appropriate emphasis on
controlling the patient’s symptoms and maintaining dignity at the end of life.
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Correctional Treatment Center Nursing Performance
CCHCS policy requires that CTC nurses perform a patient systems assessment (review of all body
systems) during each shift. During the onsite visit, CMF management explained that this was also
the requirement in the hospice unit. For OHU patients, the OHU nurses were only required to
document all clinical interactions and changes in level of care. The OIG clinicians found that, prior
to July 2015, the CTC nurses did not document a systems assessment each watch. When the CTC
nurses did document them, they were generally inadequate assessments. Nursing staff often did not
initiate, update, or scan into the eUHR patient care plans. When providers discharged patients from
the CTC, the nurses failed to complete an RN discharge summary and provide evidence that they
gave discharge instructions to the patient. Poor or missing nursing documentation was a serious
concern throughout the review. The nurses failed to consistently document vital signs and complete
the required fields in the admission assessment and nursing care record forms. The majority of
records reviewed had illegible handwriting (notes and signatures). For these reasons, the OIG
clinicians considered the CTC nursing performance substandard.
Failure to Perform Systems Assessment Each Watch
The CTC RN did not perform an assessment each watch in cases 12, 13, 73, 75, 77, and 78.
Failure to Perform Adequate Assessment
In case 11, the patient was found lying on the floor. The RN did not completely assess the
status of the patient, including his sensory function. The RN did not check for any signs of
head or neck injury prior to moving the patient from the floor to the bed to determine if the
patient required a neck collar or other immobilization device. When the patient reported
chest pain, the RN did not utilize the nursing protocol for chest pain. In addition, the RN
delayed calling the provider for 30 minutes. The RN did not document the exact location of
the chest pain, did not inspect the patient’s chest for any injury from fall, and did not
observe the patient for any breathing difficulty. The RN failed to assess the pain level after
administration of nitroglycerin and to reassess the patient’s neurological status and vital
signs for the remainder of the shift.
In case 74, medical staff placed the patient in clinical restraints. After the restraints were
placed, the RN failed to assess each restraint to ensure adequate circulation, sensation, and
motion to each extremity, and failed to assess the patient’s body alignment and respiratory
status. Additionally, the CTC nurses did not assess the patient hourly or document the
patient’s physical or mental condition.
In case 77, the patient was dizzy and fell to the floor. The RN did not assess the patient from
head to toe for any injury or check for any changes in mental status. The RN did not
continue to monitor the patient’s vital signs and condition.
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Inadequate RN assessments were identified multiple times in some of the cases above and in cases
12, 25, 73, and 75.
Failure to Initiate and Update Patient Care Plan
In case 25, the CTC nurse did not initiate patient care plans to address the patient’s poor
nutrition and urinary problems.
In case 74, there was no evidence that the CTC nurse initiated any patient care plans when
the patient was admitted to the CTC. Further, after the patient had a seizure, the patient care
plan was not initiated or updated to address the patient’s seizure. There was also no patient
care plan for the patient’s self-injurious behavior and application of clinical restraints.
Inadequate Nursing Documentation
In cases 11, 12, 21, and 78, the RN did not complete RN discharge summaries or provide
discharge instructions, education, and follow-up care to the patients upon their discharge
from the CTC.
In case 9, the patient had been placed on oral fluid restriction. The CTC nurse did not
document or monitor the amount of the patient’s oral fluid intake, resulting in the patient
exceeding the limit ordered by the provider. Cloned documentation was identified from a
previous note in this case. The RN documented the presence of a peripherally inserted
central catheter (PICC) line and monitoring for signs of infection even though the PICC line
had already been removed more than two weeks prior.
In case 74, the patient was placed in clinical restraints. During the first two days, the CTC
nurses directly observing the patient did not properly document if the patient was in the
restraints during 15-minute checks or if the restraints were removed or discontinued. The
nurses did not document observation of the proper placement of the restraints, the patient’s
skin integrity, circulation, or sensation, or the patient’s behavior.
In cases 9, 14, 15, 25, 73, 75, and 77, there was incomplete documentation on the Admission
Assessment, Nursing Care Record, and Vital Signs Flow Sheet
.
Illegible handwriting was identified in cases 9, 11, 12, 14, 21, 25, 75, and 76.
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Outpatient Housing Unit Nursing Performance
Nursing performance in the OHU was adequate. The OIG clinicians identified one case (case 81) in
which nursing did not perform an adequate assessment on the patient.
In case 81, the patient completed six cycles of chemotherapy and a provider admitted him to
the OHU for further care. There were several nursing encounters in which the OHU nurses
did not assess the patient and document the clinical interaction or care provided.
o The provider ordered an antibiotic eye ointment. There was no clinical interaction
documented that the nurse assessed the patient for eye swelling.
o The patient refused his offsite appointment and reported that he was sick and throwing
up. The nurse did not assess the patient.
o The patient had rectal lesions. The RN did not assess the patient’s wound or document
the clinical interaction and care provided during wound treatment.
There were also several encounters in case 81 when nurses did not adequately assess the
patient:
o The patient complained of headache, cough, and a clogged nose. The RN did not assess
the patient’s lungs for any abnormal sounds, examine his throat for redness or irritation,
or check for swollen lymph nodes.
o The patient complained of intermittent nausea, swollen hands and legs, and foot pain,
and he was urinating less and stopping at midstream. The nurse did not assess the
patient’s hands and legs for good sensation, range of motion, or presence of pulses, nor
obtain a history and assess the patient for possible urinary retention. The nurse also did
not notify the provider of the patient’s condition, particularly with the presence of a
fever, which could indicate an infection. When the provider saw the patient two days
later, the patient had early cellulitis (an infection of the skin and subcutaneous tissues).
o The patient reported that his arm was swollen for a week and getting worse. The RN did
not adequately assess the patient for this condition.
The OIG clinicians identified other cases where there was incomplete OHU nursing assessment:
In case 79, the patient complained of leg pain. The RN did not assess the patient’s legs for
color, warmth, tenderness, degree of swelling, or the presence of a pulse.
In case 80, the patient complained of blurry vision and pain in both eyes. The RN did not
obtain adequate history, such as sensation of any foreign body in the eyes, chemical
exposure, and pain level.
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Cases 78, 79, 81, and 83 displayed illegible OHU nursing signatures.
Hospice Unit Nursing Performance
There were only a few minor nursing deficiencies in the hospice unit. Most of these were
incomplete documentation on Daily Flow Sheets and Nursing Care Record forms. The OIG
clinicians rated hospice nursing performance generally good.
Compliance Testing Results
The institution received an adequate score of 76.5 percent in the Specialized Medical Housing
indicator, which focused on the institution’s CTC, OHU, and hospice unit. The institution scored in
the proficient range in the following test area:
For all 20 patients sampled, nursing staff timely completed an initial assessment on the day a
provider admitted the patient to the CTC, OHU, or hospice (MIT 13.001).
The institution scored in the adequate range in the following two test areas:
Providers evaluated 16 of 19 sampled patients within 24 hours of admission to the CTC and
OHU (84 percent). Three patients did not receive a provider visit within 24 hours of
admittance to the OHU; two patients received their provider visits three and five days late.
For a third patient, the provider did not document the time of the post-admission evaluation.
As a result, there was insufficient evidence to conclude that the evaluation occurred timely
(MIT 13.002).
The OIG examined providers’ progress notes to verify that they completed subjective,
objective, assessment, plan, and education (SOAPE) notes at required seven-day intervals
for CTC patients and 14-day intervals for OHU and hospice patients. Information found in
the eUHR demonstrated that the providers completed timely SOAPE notes for 15 of the 19
sampled patients (79 percent). A provider missed one required seven-day interval for a
patient in the CTC by two days. Providers missed three OHU patients’ required 14-day
interval visits by one day each (MIT 13.004).
CMF scored in the inadequate range on the following two tests:
Providers ensured that an H&P exam was completed within 72 hours of CTC or OHU
admission for only 10 of 19 patients (53 percent). Nine patients did not have a properly
completed H&P exam. Of these nine, six patients had an H&P completed at an outside
hospital, but none was completed within five days of admittance to the CTC or OHU, as
required by CCHCS policy. The other three patients never had an H&P exam at all
(MIT 13.003).
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While all three of CMF’s specialized medical housing units had properly functioning call
buttons, the institution’s OHU was not performing and documenting evidence of conducting
daily tests of the system. As a result, CMF scored 67 percent for its ability to maintain a
properly working call button system. However, knowledgeable staff at all three housing
units stated that urgent or emergent access to cells was timely at two minutes or less, and
management did not identify any concerns related to this reported response time
(MIT 13.101).
Recommendations
No specific recommendations.
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SPECIALTY SERVICES
This indicator focuses on specialist care from the time a request for
Case Review Rating:
services or physician’s order for specialist care is completed to the
Adequate
time of receipt of related recommendations from specialists. This Compliance Score:
indicator also evaluates the providers’ timely review of specialist Inadequate
records and documentation reflecting the patients’ care plans, (65.0%)
including course of care when specialist recommendations were not
Overall Rating:
ordered, and whether the results of specialists’ reports are
Adequate
communicated to the patients. For specialty services denied by the
institution, the OIG determines whether the denials are timely and
appropriate, and whether the inmate-patient is updated on the plan of care.
In this indicator, the OIG’s case review and compliance review processes yielded different results,
with the case review giving an adequate rating and the compliance review resulting in an
inadequate score. The OIG’s internal review process considered those factors that led to both results
and ultimately rated this indicator adequate. The key factor warranting the higher overall rating was
that the case review found a high quality of provided specialty services and that CMF had a unique
specialty tracking process, which compensated for the lack of eUHR compliance evidence, which
would normally indicate a timely review.
Case Review Results
The OIG clinicians reviewed 198 events related to Specialty Services, including 104 specialty
consultations and procedures and 65 nursing encounters. Of the 92 deficiencies in this category, 44
related to specialty report handling and 46 to nursing services. Despite the large number of
deficiencies in this category, only 8 of the 92 deficiencies were significant.
Access to Specialty Services
CMF performed well with access to specialty services. Out of 104 specialty consultations and
procedures, there were only two deficiencies in this area. CMF performed equally well providing
access for both routine and urgent specialty referrals.
One concern was the availability of wheelchair transportation. In case 41, the patient missed
his offsite specialty appointment because the institution did not have a wheelchair
transportation van available. While this deficiency only occurred once during the case
reviews, it was notable because CMF had a large number of patients who utilized
wheelchairs.
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Office of the Inspector General State of California
Nursing Performance
Patients returning from offsite specialty appointments were seen in the TTA. There were only two
cases identified in which an RN did not see the patient upon his return from a specialty appointment
(cases 18 and 22).
TTA nurses often did not perform nursing assessments for patients returning from specialty
services, and often did not obtain orders for recommendations that the specialist suggested. These
deficiencies occurred in cases 7, 8, 10, 17, 18, 20, 22, 24, and 80, and could have resulted in
significant lapses in care. However, at the onsite inspection, CMF demonstrated an alternate
process, whereby the specialty department reviewed the specialty recommendations and obtained
appropriate orders directly from the PCP. This alternate process successfully mitigated the
post-specialty TTA nursing deficiencies identified in the case reviews.
Generally, the telemedicine nurse performed adequate nursing assessment and care during
appointments. There were only a few cases in which the telemedicine nurse did not address the
patient’s medical symptoms and refer to the provider appropriately:
In case 8, the patient was seen in the telemedicine clinic and his blood pressure was elevated
at 188/107, with an elevated heart rate of 110. The nurse did not check whether the patient
took his blood pressure medications or refer the patient to the provider.
In case 18, the telemedicine clinic saw the patient with a high blood pressure of 162/107.
The nurse did not address the patient’s blood pressure reading or recheck it before leaving
the telemedicine clinic.
Provider Performance
CMF providers performed proficiently concerning ordering specialty services. They made
appropriate referrals for specialty services. Most providers made diagnostic and consultative
requests with proper priority specified on the Physician Request for Services (CDCR Form 7243).
Health Information Management
There were frequent delays in the retrieval of specialty reports (cases 7, 13, 18, 38, 39, and 40).
CMF also failed to retrieve specialty reports altogether in cases 13, 18, 24, and 27. Delays in
retrieval or non-retrieval of specialty reports increased the risk of lapses in care.
Nearly all specialty reports at CMF were scanned into the eUHR without a provider’s initials or
date when it was reviewed. While some providers documented their review of the reports at the
following PCP appointment, others did not. Poor provider documentation likely explained some of
the low compliance scores in the compliance testing of this indicator. From a case review
perspective, CMF providers nearly always reviewed the specialty reports appropriately, which was
demonstrated by good clinical management, even when proper documentation was lacking. Poor
provider documentation also likely explained CMF’s poor compliance scores (discussed below) in
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Office of the Inspector General State of California
relaying information when the institution denies a request for specialty service or in discussing
alternative management for the denied service. While CMF providers showed marked room for
documentation improvement, the overall quality of specialty services was good.
The specialty department kept a tracking system to ensure that the PCP reviewed and processes all
specialty recommendations. Consequently, the deficiencies identified in the case review were likely
due to human oversight and had only minor effects on overall medical care.
Clinician Onsite Inspection
The telemedicine clinic was clean and adequate. The nurse kept an organized tracking and
scheduling system for all telemedicine appointments. There was no appointment backlog reported.
The nursing supervisor was working on training additional nurses to fill coverage behind the
telemedicine nurse. The specialty department developed a secondary process that tracked every
specialty service, retrieved the reports, reviewed them for recommendations, and emailed the
reports and recommendations to the PCP. While CMF staff scanned many of the specialty reports
into the medical record without provider review, this secondary process ensured that providers were
aware of specialty consultant reports and recommendations.
Compliance Testing Results
The institution received an inadequate compliance score of 65.0 percent in the Specialty Services
indicator, receiving low scores in the following specific test areas:
When CMF providers ordered high-priority specialty services for patients, the ordering
provider did not always receive and review the corresponding specialists’ reports within the
required time frame. CMF timely received and providers timely reviewed specialists’ reports
for only 7 of 15 patients sampled (47 percent); the reports for eight other patients were either
not received or not reviewed timely. Specifically, the institution received the specialist’s
report three days late for two patients, the provider reviewed the specialist’s report from one
to six days late for four patients, and providers never documented evidence of reviewing the
specialist’s report for two patients (MIT 14.002).
When patients are approved or scheduled for specialty service appointments at one
institution and then transfer to another institution, policy requires that the receiving
institution reschedule or provide the patient’s appointment within the required time frame.
Out of 20 sampled transfer-in patients who had previously approved specialty services, only
ten received their specialty services appointments timely (50 percent). Six patients received
their specialty appointments from one to 67 days late, and four patients did not receive an
appointment at all (MIT 14.005).
Among 18 patients sampled who had a specialty service denied by health care management,
only nine (50 percent) received timely notification of the denied service. Nine other patients
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Office of the Inspector General State of California
never received notification from a provider that the institution denied the specialty service
(MIT 14.007).
For patients who had a routine specialty service ordered, providers both timely received and
timely reviewed only 8 of the 15 corresponding specialists’ reports sampled (53 percent).
Timely provider reviews did not occur for seven sampled specialists reports, five reports
were reviewed from 4 to 56 days late, and two reports were never reviewed at all
(MIT 14.004).
The institution scored in the adequate range in the following test area:
The institution timely denied providers’ specialty service requests for 15 of 20 patients
sampled (75 percent). Five specialty services requests were denied from two to six days late
(MIT 14.006).
The institution scored in the proficient range in the following two areas:
CMF provided routine specialty service appointments to 14 of 15 patients tested within the
required time frame (93 percent). One patient received his specialty service 17 days late
(MIT 14.003).
High-priority specialty services appointments occurred within 14 calendar days of the
provider’s order for 13 of the 15 inmate-patients sampled (87 percent). One patient received
his specialty service six days late, and another, eight days late (MIT 14.001).
Recommendations
No specific recommendations.
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SECONDARY (ADMINISTRATIVE) QUALITY INDICATORS OF HEALTH CARE
The last two quality indicators (Internal Monitoring, Quality Improvement, and Administrative
Operations; and Job Performance, Training, Licensing, and Certifications) involve health care
administrative systems and processes. Testing in these areas applies only to the compliance
component of the process. Therefore, there is no case review assessment associated with either of
the two indicators. As part of the compliance component of the first of these two indicators, the OIG
did not score several questions. Instead, the OIG presented the findings for informational purposes
only. For example, the OIG described certain local processes in place at CMF.
To test both the scored and non-scored areas within these two secondary quality indicators, OIG
inspectors interviewed key institutional employees and reviewed documents during their onsite visit
to CMF in February 2016. They also reviewed documents obtained from the institution and from
CCHCS prior to the start of the inspection. Of these two secondary indicators, OIG compliance
inspectors rated both inadequate. The test questions used to assess compliance for each indicator are
detailed in Appendix A.
For comparative purposes, the CMF Executive Summary Table on page viii of this report shows the
case review and compliance ratings for each applicable indicator.
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INTERNAL MONITORING, QUALITY IMPROVEMENT, AND ADMINISTRATIVE OPERATIONS
This indicator focuses on the institution’s administrative health care
Case Review Rating:
oversight functions. The OIG evaluates whether the institution
Not Applicable
promptly processes inmate-patient medical appeals and addresses
Compliance Score:
all appealed issues. Inspectors also verify that the institution follows Inadequate
reporting requirements for adverse/sentinel events and inmate (53.7%)
deaths, and whether the institution is making progress toward its
Overall Rating:
Performance Improvement Work Plan initiatives. In addition, the
Inadequate
OIG verifies that the Emergency Medical Response Review
Committee (EMRRC) performs required reviews and that staff
perform required emergency response drills. Inspectors also assess whether the Quality
Management Committee (QMC) meets regularly and adequately addresses program performance.
For those institutions with licensed facilities, inspectors also verify that required committee
meetings are held.
Compliance Testing Results
The institution scored within the inadequate range in the Internal Monitoring, Quality
Improvement, and Administrative Operations indicator, with a compliance score of 53.7 percent.
CMF received a score of zero in the following four test areas:
The institution had not taken adequate steps to ensure the accuracy of its Dashboard data
reporting. Specifically, CMF’s Quality Management Committee meetings did not discuss
methodologies used to conduct periodic validation and testing of Dashboard data, and the
committee did not discuss methodologies used to train staff who collected Dashboard data
(MIT 15.004).
CMF’s 2015 Performance Improvement Work Plan (PIWP) did not include adequate
evidence demonstrating the institution’s improvement in achieving targeted performance
objectives for any of its 11 quality improvement initiatives. In general, the work plan
included insufficient progress information to demonstrate that, in each of its performance
objectives, the institution either improved or reached the targeted level (MIT 15.005).
The institution’s local governing body (LGB) only conducted three of four quarterly
meetings during the 12-month period ending December 2015. Of the three convened, the
meeting minutes did not provide a detailed narrative of the LGB’s general management and
planning of patient health care (MIT 15.006).
None of the 12 sampled incident packages Reviewed by the Emergency Medical Response
Review Committee (EMRRC) included required documentation. Specifically, none of the
packages included the use of the required Emergency Medical Response Review Event
Checklist Form (MIT 15.007).
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The institution scored in the adequate range on the following test:
Inspectors reviewed six recent months’ Quality Management Committee (QMC) meeting
minutes and confirmed that the QMC met monthly in all six months reviewed. However, the
QMC only adequately evaluated program performance or took action when the committee
identified improvement opportunities in five of the six months. More specifically, the
committee’s July 2015 meeting did not evaluate program performance. As a result, CMF
scored 83 percent on this test (MIT 15.003).
The institution scored in the proficient range with 100 percent scores on each of the following four
tests:
CMF processed inmate medical appeals timely for all 12 of the most recent months. In
addition, inspectors sampled ten second-level inmate medical appeals and found that all of
the appeal responses addressed the inmate’s initial complaint (MIT 15.001, 15.102).
Inspectors reviewed drill packages for three medical emergency response drills conducted in
the prior quarter, and the packages contained all required summary reports and related
documentation. In addition, the drills included participation by both health care and custody
staff (MIT 15.101).
Medical staff promptly submitted the Initial Inmate Death Report (CDCR Form 7229A) to
the CCHCS Death Review Unit for the ten applicable deaths that occurred at CMF in the
prior 12-month period (MIT 15.103).
Other Information Obtained from Non-Scored Areas
The OIG gathered non-scored data regarding the completion of death review reports and
found that CCHCS’s Death Review Committee did not timely complete its death review
summary for any of the ten deaths that occurred during the testing period. The CCHCS
Death Review Committee is required to complete a death review summary within 30 to 60
days of the death (depending on whether the death was expected or unexpected) and then
expeditiously notify the institution’s CEO of the review results, so that any needed
corrective action can be promptly pursued. For eight of the ten inmate deaths tested, the
committee completed its summary from 9 to 40 days late (39 to 93 days after the death) and
then notified the institution’s CEO of the review results from 2 to 13 days after that
(MIT 15.996).
Inspectors met with the institution’s chief executive officer (CEO) to inquire about CMF’s
protocols for tracking appeals. Management received from the appeals coordinator a weekly
update, which identified when appeals were due, and the QMC received a monthly appeals
update broken down by each appeals category (CMF used 22 different categories).
Management reviewed the reports during QMC meetings to identify and track problem
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Office of the Inspector General State of California
areas, and used the data to address specific issues that may require staff training
(MIT 15.997).
Non-scored data gathered regarding CMF’s practices for implementing local operating
procedures (LOPs) indicated that the institution had an effective process in place for
developing LOPs. The CEO stated the institution had an LOP committee that met on a
monthly basis and worked to adhere as closely as possible to statewide policies. Each
department supervisor was responsible for identifying and developing an LOP if it was
necessary, and supervisors consulted with subject matter experts as needed. The LOP
committee discussed each new LOP that department supervisors presented, and the
committee approved the LOP. At the time of the OIG’s inspection, CMF had implemented
all 49 applicable LOPs relating to the core topical areas recommended by the clinical experts
who helped develop the OIG’s medical inspection compliance program (MIT 15.998).
The OIG discusses the institution’s health care staffing resources in the About the Institution
section on page 2 of this report (MIT 15.999).
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
JOB PERFORMANCE, TRAINING, LICENSING, AND CERTIFICATIONS
In this indicator, the OIG examines whether the institution
Case Review Rating:
adequately manages its health care staffing resources by evaluating
Not Applicable
whether job performance reviews are completed as required;
Compliance Score:
specified staff possess current, valid credentials and professional
Inadequate
licenses or certifications; nursing staff receive new employee (69.9%)
orientation training and annual competency testing; and clinical and
Overall Rating:
custody staff have current medical emergency response
Inadequate
certifications.
Compliance Testing Results
The institution received an inadequate compliance score of 69.9 percent in the Job Performance
Training, Licensing, and Certifications indicator, scoring in the inadequate range on the following
three tests:
Inspectors examined records to determine if nursing supervisors completed the required
number of monthly performance reviews for subordinate nurses and discussed the results of
those reviews. The OIG sampled reviews completed for five subordinate nurses; all of them
had the required number of reviews completed by their supervisors. However, in each
instance, the nursing supervisor failed to address the positive, well-performed aspects of the
employee’s performance. CCHCS policy requires this task to be completed for each review
(MIT 16.101).
OIG inspectors examined provider, nursing, and custody staff records to determine if the
institution ensured that those staff members had current emergency response certifications.
CMF’s provider and nursing staff were all compliant, but custody staff did not always have
current certifications. Specifically, managerial custody officers above the rank of captain did
not have current certifications. Although the California Penal Code exempts those custody
managers who primarily perform managerial duties from medical emergency response
certification training, CCHCS policy does not allow for such an exemption. As a result, the
institution received a score of 67 percent in this inspection area (MIT 16.104).
When the institution hires new nursing staff, it is required to provide new employee
orientation within 30 days of their being hired. However, CMF did not timely provide new
employee orientation for six new nurses hired in the most recent 12 months. As a result, the
institution scored zero in this test area (MIT 16.107).
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While CMF scored low in the areas above, it received proficient scores in the following test areas:
All providers were current with their professional licenses, and nursing staff and the
pharmacist in charge were current with their professional licenses and certification
requirements (MIT 16.001, 16.105).
All ten nurses sampled were current on their clinical competency validations (MIT 16.102).
OIG inspectors found that 12 of 13 providers (92 percent) received timely clinical
performance evaluations. However, one provider (the chief physician and surgeon), who
periodically performed patient evaluations, did not receive a performance evaluation
(MIT 16.103).
The pharmacy and providers who prescribe controlled substances had current Drug
Enforcement Agency registrations (MIT 16.106).
Recommendations
No specific recommendations.
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Office of the Inspector General State of California
POPULATION-BASED METRICS
The compliance testing and the case reviews give an accurate assessment of how the institution’s
health care systems are functioning with regard to the patients with the highest risk and utilization.
This information is vital to assess the capacity of the institution to provide sustainable, adequate
care. However, one significant limitation of the case review methodology is that it does not give a
clear assessment of how the institution performs for the entire population. For better insight into this
performance, the OIG has turned to population-based metrics. For comparative purposes, the OIG
has selected several Healthcare Effectiveness Data and Information Set (HEDIS) measures for
disease management to gauge the institution’s effectiveness in outpatient health care, especially
chronic disease management.
The Healthcare Effectiveness Data and Information Set is a set of standardized performance
measures developed by the National Committee for Quality Assurance with input from over 300
organizations representing every sector of the nation’s health care industry. It is used by over
90 percent of the nation’s health plans as well as many leading employers and regulators. It was
designed to ensure that the public (including employers, the Centers for Medicare and Medicaid
Services, and researchers) has the information it needs to accurately compare the performance of
health care plans. Healthcare Effectiveness Data and Information Set data is often used to produce
health plan report cards, analyze quality improvement activities, and create performance
benchmarks.
Methodology
For population-based metrics, the OIG used a subset of HEDIS measures applicable to the CDCR
inmate-patient population. Selection of the measures was based on the availability, reliability, and
feasibility of the data required for performing the measurement. The OIG collected data utilizing
various information sources, including the eUHR, the Master Registry (maintained by CCHCS), as
well as a random sample of patient records analyzed and abstracted by trained personnel. Data
obtained from the CCHCS Master Registry and Diabetic Registry was not independently validated
by the OIG and is presumed to be accurate. For some measures, the OIG used the entire population
rather than statistically random samples. While the OIG is not a certified HEDIS compliance
auditor, the OIG uses similar methods to ensure that measures are comparable to those published by
other organizations.
Comparison of Population-Based Metrics
For the California Medical Facility, nine HEDIS measures were selected and are listed in the
following CMF Results Compared to State and National HEDIS Scores table. Multiple health plans
publish their HEDIS performance measures at the State and national levels. The OIG has provided
selected results for several health plans in both categories for comparative purposes.
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Office of the Inspector General State of California
Results of Population-Based Metric Comparison
Comprehensive Diabetes Care
For chronic care management, the OIG chose measures related to the management of diabetes.
Diabetes is the most complex common chronic disease requiring a high level of intervention on the
part of the health care system in order to produce optimal results. CMF performed well with its
management of diabetes in the available HEDIS measures when compared to other reporting
entities.
Statewide, CMF significantly outperformed Medi-Cal in all five diabetic measures. When compared
to Kaiser Permanente, CMF did better than or matched Kaiser North in four of the five diabetic
measures, but performed not as well in diabetic blood pressure control by 4 percentage points. CMF
only outperformed Kaiser South in three of the five diabetes measures, trailing in diabetic patient
blood pressure control and conducting dilated eye exams by 5 and 7 percentage points, respectively.
Nationally, CMF outperformed Medicaid, Medicare, and commercial health plans (based on data
obtained from health maintenance organizations) in all five diabetic measures. When compared to
the U.S. Department of Veterans Affairs (VA), CMF outperformed the VA in three of four
applicable diabetic measures (diabetic monitoring, diabetics under poor control, and blood pressure
control). However, CMF did not perform as well as the VA in conducting dilated eye exams,
trailing by 16 percentage points.
Immunizations
Comparative data for immunizations was only fully available for the VA and partially available for
Kaiser Permanente, Medicare, and commercial plans. With regard to administering influenza
vaccinations to younger adults, CMF outperformed all State and national health plans. For older
adults, CMF outperformed Medicare, but scored 2 percentage points lower than the VA. The OIG’s
comparative analysis found that CMF’s low scores were adversely affected by patient refusals, a
factor that prevented the institution from receiving full credit for providing a basic outpatient health
care service. Had the refusals not occurred, the institution would have received a 100 percent
compliance rate and the highest comparative score for the three immunization measures.
Finally, with regard to pneumococcal vaccinations, CMF scored better than Medicare by
14 percentage points, but more poorly than the VA by 9 percentage points. The OIG found that
CMF offered the immunization to 97 percent of patients sampled, and the institution would have
had the highest comparable score had patients not refused the vaccination.
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Office of the Inspector General State of California
Cancer Screening
With respect to colorectal cancer screening for older patients, CMF’s score of 52 percent was
significantly lower than the only other statewide comparative figures, which were 80 percent and
82 percent for Kaiser, Northern California and Southern California, respectively. Nationally, CMF
also performed worse than commercial plans, Medicare, and the VA. Again, patient refusals directly
impacted the institution’s performance in this cancer screening measure. Specifically, 45 percent of
CMF patients sampled refused the cancer screening. The cancer screening score for CMF would
have been significantly higher if not for the high refusal rate.
Summary
Overall, based on the institution’s comparative HEDIS results, CMF’s performance reflected an
adequate chronic care program with regard to comprehensive diabetes care and immunizations
compared to statewide and national health plans. However, the institution showed room for
improvement in providing colorectal cancer screenings, and could increase patient education to help
reduce patient refusals.
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Office of the Inspector General State of California
CMF Results Compared to State and National HEDIS Scores
California National
CMF HEDIS HEDIS HEDIS HEDIS
Clinical Measures
Medi- Kaiser Kaiser HEDIS Com- HEDIS VA
Cycle 4 Cal (No. CA) (So.CA) Medicaid mercial Medicare Average
Results1 20142 20153 20153 20154 20154 20154 20145
Comprehensive Diabetes Care
HbA1c Testing (Monitoring) 100% 83% 95% 94% 86% 91% 93% 99%
Poor HbA1c Control (>9.0%)6,7 18% 44% 18% 24% 44% 31% 25% 19%
HbA1c Control (<8.0%)6 68% 47% 70% 62% 47% 58% 65% -
Blood Pressure Control (<140/90)6 80% 60% 84% 85% 62% 65% 65% 78%
Eye Exams 74% 51% 69% 81% 54% 56% 69% 90%
Immunizations
Influenza Shots - Adults (18–64) 76% - 54% 55% - 50% - 58%
Influenza Shots - Adults (65+) 74% - - - - - 72% 76%
Immunizations: Pneumococcal 84% - - - - - 70% 93%
Cancer Screening
Colorectal Cancer Screening 52% - 80% 82% - 64% 67% 82%
1. Unless otherwise stated, data was collected in February 2016 by reviewing medical records from a sample of CMF’s population of
applicable inmate-patients. These random statistical sample sizes were based on a 95 percent confidence level with a 15 percent
maximum margin of error.
2. HEDIS Medi-Cal data was obtained from the California Department of Health Care Services 2014 HEDIS Aggregate Report for the
Medi-Cal Managed Care Program.
3. Data was obtained from Kaiser Permanente November 2015 reports for the Northern and Southern California regions.
4. National HEDIS data for Medicaid, commercial, and Medicare was obtained from the 2015 State of Health Care Quality Report,
available on the NCQA website: www.ncqa.org. The results for commercial were based on data received from various health
maintenance organizations.
5. The Department of Veterans Affairs (VA) data was obtained from the VA’s website www.va.gov. For the Immunizations:
Pneumococcal measure only, the data was obtained from the VHA Facility Quality and Safety Report-Fiscal Year 2012.
6. For this indicator, the entire applicable CMF population was tested.
7. For this measure only, a lower score is better. For Kaiser, the OIG derived the Poor HbA1c Control indicator using the reported data
for the <9.0% HbA1c control indicator.
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Office of the Inspector General State of California
APPENDIX A — COMPLIANCE TEST RESULTS
California Medical Facility
Range of Summary Scores: 53.70% - 78.36%
Indicator Compliance Score (Yes %)
Access to Care 78.36%
Diagnostic Services 76.30%
Emergency Services Not Applicable
Health Information Management (Medical Records) 61.70%
Health Care Environment 72.50%
Inter- and Intra-System Transfers 72.83%
Pharmacy and Medication Management 68.81%
Prenatal and Post-Delivery Services Not Applicable
Preventive Services 65.42%
Quality of Nursing Performance Not Applicable
Quality of Provider Performance Not Applicable
Reception Center Arrivals Not Applicable
Specialized Medical Housing (OHU, CTC, SNF, Hospice) 76.49%
Specialty Services 65.00%
Internal Monitoring, Quality Improvement, and Administrative Operations 53.70%
Job Performance, Training, Licensing, and Certifications 69.87%
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Access to Care
Number Yes No No Yes % N/A
1.001 Chronic care follow-up appointments: Was the inmate-patient’s most 31 9 40 77.50% 0
recent chronic care visit within the health care guideline’s maximum
allowable interval or within the ordered time frame, whichever is
shorter?
1.002 For endorsed inmate-patients received from another CDCR 25 4 29 86.21% 1
institution: If the nurse referred the inmate-patient to a provider during
the initial health screening, was the inmate-patient seen within the
required time frame?
1.003 Clinical appointments: Did a registered nurse review the 29 1 30 96.67% 0
inmate-patient’s request for service the same day it was received?
1.004 Clinical appointments: Did the registered nurse complete a 13 16 29 44.83% 1
face-to-face visit within one business day after the CDCR Form 7362
was reviewed?
1.005 Clinical appointments: If the registered nurse determined a referral to 24 0 24 100.00% 6
a primary care provider was necessary, was the inmate-patient seen
within the maximum allowable time or the ordered time frame,
whichever is the shorter?
1.006 Sick call follow-up appointments: If the primary care provider 7 3 10 70.00% 20
ordered a follow-up sick call appointment, did it take place within the
time frame specified?
1.007 Upon the inmate-patient’s discharge from the community hospital: 18 12 30 60.00% 0
Did the inmate-patient receive a follow-up appointment within the
required time frame?
1.008 Specialty service follow-up appointments: Do specialty service 21 9 30 70.00% 0
primary care physician follow-up visits occur within required time
frames?
1.101 Clinical appointments: Do inmate-patients have a standardized 6 0 6 100.00% 0
process to obtain and submit health care services request forms?
Overall percentage: 78.36%
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Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Diagnostic Services
Number Yes No No Yes % N/A
2.001 Radiology: Was the radiology service provided within the time frame 10 0 10 100.00% 0
specified in the provider’s order?
2.002 Radiology: Did the primary care provider review and initial the 8 2 10 80.00% 0
diagnostic report within specified time frames?
2.003 Radiology: Did the primary care provider communicate the results of 9 1 10 90.00% 0
the diagnostic study to the inmate-patient within specified time frames?
2.004 Laboratory: Was the laboratory service provided within the time 10 0 10 100.00% 0
frame specified in the provider’s order?
2.005 Laboratory: Did the primary care provider review and initial the 8 2 10 80.00% 0
diagnostic report within specified time frames?
2.006 Laboratory: Did the primary care provider communicate the results of 9 1 10 90.00% 0
the diagnostic study to the inmate-patient within specified time frames?
2.007 Pathology: Did the institution receive the final diagnostic report within 8 2 10 80.00% 0
the required time frames?
2.008 Pathology: Did the primary care provider review and initial the 2 7 9 22.22% 1
diagnostic report within specified time frames?
2.009 Pathology: Did the primary care provider communicate the results of 4 5 9 44.44% 1
the diagnostic study to the inmate-patient within specified time frames?
Overall percentage: 76.30%
Emergency Services
Scored Answers
Assesses reaction times and responses to emergency situations. The OIG RN
clinicians will use detailed information obtained from the institution’s incident Not Applicable
packages to perform focused case reviews.
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Scored Answers
Health Information Management Yes
Reference +
(Medical Records)
Number Yes No No Yes % N/A
4.001 Are non-dictated progress notes, initial health screening forms, and 16 4 20 80.00% 0
health care service request forms scanned into the eUHR within three
calendar days of the inmate-patient encounter date?
4.002 Are dictated / transcribed documents scanned into the eUHR within five
Not Applicable
calendar days of the inmate-patient encounter date?
4.003 Are specialty documents scanned into the eUHR within the required 19 1 20 95.00% 0
time frame?
4.004 Are community hospital discharge documents scanned into the eUHR 16 4 20 80.00% 0
within three calendar days of the inmate-patient date of hospital
discharge?
4.005 Are medication administration records (MARs) scanned into the eUHR 15 5 20 75.00% 0
within the required time frames?
4.006 During the eUHR review, did the OIG find that documents were 0 12 12 0.00% 0
correctly labeled and included in the correct inmate-patient’s file?
4.007 Did clinical staff legibly sign health care records, when required? 23 9 32 71.88% 0
4.008 For inmate-patients discharged from a community hospital: Did the 9 21 30 30.00% 0
preliminary hospital discharge report include key elements and did a
PCP review the report within three calendar days of discharge?
Overall percentage: 61.70%
California Medical Facility, Cycle 4 Medical Inspection Page 83
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Health Care Environment
Number Yes No No Yes % N/A
5.101 Infection Control: Are clinical health care areas appropriately 13 1 14 92.86% 0
disinfected, cleaned and sanitary?
5.102 Infection control: Do clinical health care areas ensure that reusable 12 0 12 100.00% 2
invasive and non-invasive medical equipment is properly sterilized or
disinfected as warranted?
5.103 Infection Control: Do clinical health care areas contain operable sinks 14 0 14 100.00% 0
and sufficient quantities of hygiene supplies?
5.104 Infection control: Does clinical health care staff adhere to universal 1 8 9 11.11% 5
hand hygiene precautions?
5.105 Infection control: Do clinical health care areas control exposure to 13 1 14 92.86% 0
blood-borne pathogens and contaminated waste?
5.106 Warehouse, Conex and other non-clinic storage areas: Does the 1 0 1 100.00% 0
medical supply management process adequately support the needs of
the medical health care program?
5.107 Clinical areas: Does each clinic follow adequate protocols for 13 1 14 92.86% 0
managing and storing bulk medical supplies?
5.108 Clinical areas: Do clinic common areas and exam rooms have 1 13 14 7.14% 0
essential core medical equipment and supplies?
5.109 Clinical areas: Do clinic common areas have an adequate environment 7 2 9 77.78% 5
conducive to providing medical services?
5.110 Clinical areas: Do clinic exam rooms have an adequate environment 6 8 14 42.86% 0
conducive to providing medical services?
5.111 Emergency response bags: Are TTA and clinic emergency medical 4 1 5 80.00% 9
response bags inspected daily and inventoried monthly, and do they
contain essential items?
5.999 For Information Purposes Only: Does the institution’s health care
management believe that all clinical areas have physical plant Information Only
infrastructures sufficient to provide adequate health care services?
Overall percentage: 72.50%
California Medical Facility, Cycle 4 Medical Inspection Page 84
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Inter- and Intra-System Transfers
Number Yes No No Yes % N/A
6.001 For endorsed inmate-patients received from another CDCR 30 0 30 100.00% 0
institution or COCF: Did nursing staff complete the initial health
screening and answer all screening questions on the same day the
inmate-patient arrived at the institution?
6.002 For endorsed inmate-patients received from another CDCR 29 1 30 96.67% 0
institution or COCF: When required, did the RN complete the
assessment and disposition section of the health screening form; refer
the inmate-patient to the TTA, if TB signs and symptoms were present;
and sign and date the form on the same day staff completed the health
screening?
6.003 For endorsed inmate-patients received from another CDCR 10 6 16 62.50% 14
institution or COCF: If the inmate-patient had an existing medication
order upon arrival, were medications administered or delivered without
interruption?
6.004 For inmate-patients transferred out of the facility: Were scheduled 11 9 20 55.00% 0
specialty service appointments identified on the Health Care Transfer
Information Form 7371?
6.101 For inmate-patients transferred out of the facility: Do medication 2 2 4 50.00% 2
transfer packages include required medications along with the
corresponding Medical Administration Record (MAR) and Medication
Reconciliation?
Overall percentage: 72.83%
California Medical Facility, Cycle 4 Medical Inspection Page 85
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Pharmacy and Medication Management
Number Yes No No Yes % N/A
7.001 Did the inmate-patient receive all chronic care medications within the 18 18 36 50.00% 4
required time frames or did the institution follow departmental policy
for refusals or no-shows?
7.002 Did health care staff administer or deliver new order prescription 32 8 40 80.00% 0
medications to the inmate-patient within the required time frames?
7.003 Upon the inmate-patient’s discharge from a community hospital: 23 7 30 76.67% 0
Were all medications ordered by the institution’s primary care provider
administered or delivered to the inmate-patient within one calendar day
of return?
7.004 For inmate-patients received from a county jail: Were all
medications ordered by the institution’s reception center provider
Not Applicable
administered or delivered to the inmate-patient within the required time
frames?
7.005 Upon the inmate-patient’s transfer from one housing unit to 26 4 30 86.67% 0
another: Were medications continued without interruption?
7.006 For inmate-patients en route who lay over at the institution: If the 8 2 10 80.00% 0
temporarily housed inmate-patient had an existing medication order,
were medications administered or delivered without interruption?
7.101 All clinical and medication line storage areas for narcotic 3 10 13 23.08% 8
medications: Does the institution employ strong medication security
controls over narcotic medications assigned to its clinical areas?
7.102 All clinical and medication line storage areas for non-narcotic 5 11 16 31.25% 5
medications: Does the institution properly store non-narcotic
medications that do not require refrigeration in assigned clinical areas?
7.103 All clinical and medication line storage areas for non-narcotic 1 10 11 9.09% 10
medications: Does the institution properly store non-narcotic
medications that require refrigeration in assigned clinical areas?
7.104 Medication preparation and administration areas: Do nursing staff 4 3 7 57.14% 0
employ and follow hand hygiene contamination control protocols
during medication preparation and medication administration
processes?
7.105 Medication preparation and administration areas: Does the 7 0 7 100.00% 0
institution employ appropriate administrative controls and protocols
when preparing medications for inmate-patients?
7.106 Medication preparation and administration areas: Does the 4 3 7 57.14% 0
institution employ appropriate administrative controls and protocols
when distributing medications to inmate-patients?
7.107 Pharmacy: Does the institution employ and follow general security, 2 0 2 100.00% 0
organization, and cleanliness management protocols in its main and
satellite pharmacies?
California Medical Facility, Cycle 4 Medical Inspection Page 86
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Pharmacy and Medication Management
Number Yes No No Yes % N/A
7.108 Pharmacy: Does the institution’s pharmacy properly store 1 1 2 50.00% 0
non-refrigerated medications?
7.109 Pharmacy: Does the institution’s pharmacy properly store refrigerated 2 0 2 100.00% 0
or frozen medications?
7.110 Pharmacy: Does the institution’s pharmacy properly account for 1 0 1 100.00% 1
narcotic medications?
7.111 Pharmacy: Does the institution follow key medication error reporting 30 0 30 100.00% 0
protocols?
7.998 For Information Purposes Only: During eUHR compliance testing
and case reviews, did the OIG find that medication errors were Information Only
properly identified and reported by the institution?
7.999 For Information Purposes Only: Do inmate-patients in isolation
housing units have immediate access to their KOP prescribed rescue Information Only
inhalers and nitroglycerin medications?
Overall percentage: 68.81%
Prenatal and Post-Delivery Services
Scored Answers
This indicator is not applicable to this institution. Not Applicable
California Medical Facility, Cycle 4 Medical Inspection Page 87
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Preventive Services
Number Yes No No Yes % N/A
9.001 Inmate-patients prescribed TB medications: Did the institution 12 6 18 66.67% 0
administer the medication to the inmate-patient as prescribed?
9.002 Inmate-patients prescribed TB medications: Did the institution 1 16 17 5.88% 1
monitor the inmate-patient monthly for the most recent three months he
or she was on the medication?
9.003 Annual TB Screening: Was the inmate-patient screened for TB within 16 14 30 53.33% 0
the last year?
9.004 Were all inmate-patients offered an influenza vaccination for the most 28 2 30 93.33% 0
recent influenza season?
9.005 All inmate-patients from the age of 50 through the age of 75: Was 26 4 30 86.67% 0
the inmate-patient offered colorectal cancer screening?
9.006 Female inmate-patients from the age of 50 through the age of 74:
Was the inmate-patient offered a mammogram in compliance with Not Applicable
policy?
9.007 Female inmate-patients from the age of 21 through the age of 65:
Not Applicable
Was the inmate-patient offered a pap smear in compliance with policy?
9.008 Are required immunizations being offered for chronic care 26 4 30 86.67% 10
inmate-patients?
9.009 Are inmate-patients at the highest risk of coccidioidomycosis (valley
Not Applicable
fever) infection transferred out of the facility in a timely manner?
Overall percentage: 65.42%
California Medical Facility, Cycle 4 Medical Inspection Page 88
Office of the Inspector General State of California
Quality of Nursing Performance
Scored Answers
The quality of nursing performance will be assessed during case reviews, conducted
by OIG clinicians, and is not applicable for the compliance portion of the medical
inspection. The methodologies OIG clinicians use to evaluate the quality of nursing Not Applicable
performance are presented in a separate inspection document entitled OIG MIU
Retrospective Case Review Methodology.
Quality of Provider Performance
Scored Answers
The quality of provider performance will be assessed during case reviews,
conducted by OIG clinicians, and is not applicable for the compliance portion of the
medical inspection. The methodologies OIG clinicians use to evaluate the quality of Not Applicable
provider performance are presented in a separate inspection document entitled OIG
MIU Retrospective Case Review Methodology.
Reception Center Arrivals
Scored Answers
This indicator is not applicable to this institution. Not Applicable
California Medical Facility, Cycle 4 Medical Inspection Page 89
Office of the Inspector General State of California
Scored Answers
Specialized Medical Housing Yes
Reference +
(OHU, CTC, SNF, Hospice)
Number Yes No No Yes % N/A
13.001 For all higher-level care facilities: Did the registered nurse complete 20 0 20 100.00% 0
an initial assessment of the inmate-patient on the day of admission, or
within eight hours of admission to CMF’s hospice?
13.002 For OHU, CTC, & SNF only: Did the primary care provider for OHU 16 3 19 84.21% 1
or attending physician for a CTC & SNF evaluate the inmate-patient
within 24 hours of admission?
13.003 For OHU, CTC, & SNF only: Was a written history and physical 10 9 19 52.63% 1
examination completed within 72 hours of admission?
13.004 For all higher-level care facilities: Did the primary care provider 15 4 19 78.95% 1
complete the Subjective, Objective, Assessment, Plan, and Education
(SOAPE) notes on the inmate-patient at the minimum intervals
required for the type of facility where the inmate-patient was treated?
13.101 For OHU and CTC Only: Do inpatient areas either have properly 2 1 3 66.67% 0
working call systems in its OHU & CTC or are 30-minute patient
welfare checks performed; and do medical staff have reasonably
unimpeded access to enter inmate-patient’s cells?
Overall percentage: 76.49%
California Medical Facility, Cycle 4 Medical Inspection Page 90
Office of the Inspector General State of California
Scored Answers
Yes
Reference +
Specialty Services
Number Yes No No Yes % N/A
14.001 Did the inmate-patient receive the high-priority specialty service within 13 2 15 86.67% 0
14 calendar days of the PCP order?
14.002 Did the PCP review the high-priority specialty service consultant report 7 8 15 46.67% 0
within the required time frame?
14.003 Did the inmate-patient receive the routine specialty service within 90 14 1 15 93.33% 0
calendar days of the PCP order?
14.004 Did the PCP review the routine specialty service consultant report 8 7 15 53.33% 0
within the required time frame?
14.005 For endorsed inmate-patients received from another CDCR 10 10 20 50.00% 0
institution: If the inmate-patient was approved for a specialty services
appointment at the sending institution, was the appointment scheduled
at the receiving institution within the required time frames?
14.006 Did the institution deny the primary care provider request for specialty 15 5 20 75.00% 0
services within required time frames?
14.007 Following the denial of a request for specialty services, was the 9 9 18 50.00% 2
inmate-patient informed of the denial within the required time frame?
Overall percentage: 65.00%
California Medical Facility, Cycle 4 Medical Inspection Page 91
Office of the Inspector General State of California
Scored Answers
Internal Monitoring, Quality Improvement, and Yes
Reference +
Administrative Operations
Number Yes No No Yes % N/A
15.001 Did the institution promptly process inmate medical appeals during the 12 0 12 100.00% 0
most recent 12 months?
15.002 Does the institution follow adverse/sentinel event reporting
Not Applicable
requirements?
15.003 Did the institution Quality Management Committee (QMC) meet at 5 1 6 83.33% 0
least monthly to evaluate program performance, and did the QMC take
action when improvement opportunities were identified?
15.004 Did the institution’s Quality Management Committee (QMC) or other 0 1 1 0.00% 0
forum take steps to ensure the accuracy of its Dashboard data
reporting?
15.005 For each initiative in the Performance Improvement Work Plan 0 11 11 0.00% 1
(PIWP), has the institution performance improved or reached the
targeted performance objective(s)?
15.006 For institutions with licensed care facilities: Does the Local 0 4 4 0.00% 0
Governing Body (LGB), or its equivalent, meet quarterly and exercise
its overall responsibilities for the quality management of patient health
care?
15.007 Does the Emergency Medical Response Review Committee perform 0 12 12 0.00% 0
timely incident package reviews that include the use of required review
documents?
15.101 Did the institution complete a medical emergency response drill for 3 0 3 100.00% 0
each watch and include participation of health care and custody staff
during the most recent full quarter?
15.102 Did the institution’s second level medical appeal response address all 10 0 10 100.00% 0
of the inmate-patient’s appealed issues?
15.103 Did the institution’s medical staff review and submit the initial inmate 10 0 10 100.00% 0
death report to the Death Review Unit in a timely manner?
15.996 For Information Purposes Only: Did the CCHCS Death Review
Committee submit its inmate death review summary to the institution Information Only
timely?
15.997 For Information Purposes Only: Identify the institution’s protocols
Information Only
for tracking medical appeals.
15.998 For Information Purposes Only: Identify the institution’s protocols
Information Only
for implementing health care local operating procedures.
15.999 For Information Purposes Only: Identify the institution’s health care
Information Only
staffing resources.
Overall percentage: 53.70%
California Medical Facility, Cycle 4 Medical Inspection Page 92
Office of the Inspector General State of California
Scored Answers
Job Performance, Training, Licensing, and Yes
Reference +
Certifications
Number Yes No No Yes % N/A
16.001 Do all providers maintain a current medical license? 17 0 17 100.00% 0
16.101 Does the institution’s Supervising Registered Nurse conduct periodic 0 5 5 0.00% 0
reviews of nursing staff?
16.102 Are nursing staff who administer medications current on their clinical 10 0 10 100.00% 0
competency validation?
16.103 Are structured clinical performance appraisals completed timely? 12 1 13 92.31% 0
16.104 Are staff current with required medical emergency response 2 1 3 66.67% 0
certifications?
16.105 Are nursing staff and the pharmacist in charge current with their 5 0 5 100.00% 1
professional licenses and certifications?
16.106 Do the institution’s pharmacy and authorized providers who prescribe 2 0 2 100.00% 0
controlled substances maintain current Drug Enforcement Agency
(DEA) registrations?
16.107 Are nursing staff current with required new employee orientation? 0 1 1 0.00% 0
Overall percentage: 69.87%
California Medical Facility, Cycle 4 Medical Inspection Page 93
Office of the Inspector General State of California
APPENDIX B — CLINICAL DATA
Table B-1: CMF Sample Sets
Sample Set Total
Anticoagulation 3
CTC/OHU 11
Death Review/Sentinel Events 5
Diabetes 3
Emergency Services – CPR 5
Emergency Services – Non-CPR 5
High Risk 5
Hospitalization 5
Intra-System Transfers In 3
Intra-System Transfers Out 3
RN Sick Call 30
Specialty Services 4
82
California Medical Facility, Cycle 4 Medical Inspection Page 94
Office of the Inspector General State of California
Table B-2: CMF Chronic Care Diagnoses
Diagnosis Total
Anemia 9
Anticoagulation 4
Arthritis/Degenerative Joint Disease 12
Asthma 11
COPD 24
Cancer 12
Cardiovascular Disease 19
Chronic Kidney Disease 4
Chronic Pain 27
Cirrhosis/End-Stage Liver Disease 3
Coccidioidomycosis 1
DVT/PE 3
Deep Venous Thrombosis/Pulmonary Embolism 2
Diabetes 28
Gastroesophageal Reflux Disease 20
HIV 3
Hepatitis C 34
Hyperlipidemia 29
Hypertension 58
Mental Health 17
Migraine Headaches 1
Rheumatological Disease 1
Seizure Disorder 8
Sickle Cell Anemia 1
Sleep Apnea 4
Thyroid Disease 9
344
California Medical Facility, Cycle 4 Medical Inspection Page 95
Office of the Inspector General State of California
Table B-3: CMF Event - Program
Program Total
Diagnostic Services 151
Emergency Care 89
Hospitalization 43
Intra-System Transfers In 6
Intra-System Transfers Out 5
Not Specified 1
Outpatient Care 437
Specialized Medical Housing 353
Specialty Services 198
1,283
Table B-4: CMF Case Review Sample Summary
Total
MD Reviews Detailed 30
MD Reviews Focused 0
RN Reviews Detailed 19
RN Reviews Focused 51
Total Reviews 100
Total Unique Cases 82
Overlapping Reviews (MD & RN) 18
California Medical Facility, Cycle 4 Medical Inspection Page 96
Office of the Inspector General State of California
APPENDIX C — COMPLIANCE SAMPLING METHODOLOGY
California Medical Facility
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Access to Care
MIT 1.001 Chronic care patients Master Registry Chronic care conditions (at least one condition per
inmate-patient—any risk level)
(40) Randomize
MIT 1.002 Nursing Referrals OIG Q: 6.001 See Intra-system Transfers
(30)
MITs 1.003-006 Nursing sick call MedSATS Clinic (each clinic tested)
(5 per clinic) Appointment date (2–9 months)
30 Randomize
MIT 1.007 Returns from OIG Q: 4.008 See Health Information Management (Medical
community hospital Records) (returns from community hospital)
(30)
MIT 1.008 Specialty services OIG Q: 14.001 & See Specialty Services
follow-up 14.003
(30)
MIT 1.101 Availability of health OIG onsite Randomly select one housing unit from each yard
care services request review
forms
(6)
Diagnostic Services
MITs 2.001–003 Radiology Radiology Logs Appointment date (90 days–9 months)
Randomize
(10) Abnormal
MITs 2.004–006 Laboratory Quest Appt. date (90 days–9 months)
Order name (CBC or CMPs only)
Randomize
(10) Abnormal
MITs 2.007–009 Pathology InterQual Appt. date (90 days–9 months)
Service (pathology related)
(10) Randomize
California Medical Facility, Cycle 4 Medical Inspection Page 97
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Health Information Management (Medical Records)
MIT 4.001 Timely scanning OIG Qs: 1.001, Non-dictated documents
(20) 1.002, & 1.004 1st 10 IPs MIT 1.001, 1st 5 IPs MITs 1.002, 1.004
MIT 4.002 OIG Q: 1.001 Dictated documents
(6) First 20 IPs selected
MIT 4.003 OIG Qs: 14.002 Specialty documents
(20) & 14.004 First 10 IPs for each question
MIT 4.004 OIG Q: 4.008 Community hospital discharge documents
(20) First 20 IPs selected
MIT 4.005 OIG Q: 7.001 MARs
(20) First 20 IPs selected
MIT 4.006 Documents for Any misfiled or mislabeled document identified
(12) any tested inmate during OIG compliance review (12 or more = No)
MIT 4.007 Legible signatures & OIG Qs: 4.008, First 8 IPs sampled
review 6.001, 6.002, One source document per IP
7.001, 12.001,
(32) 12.002 & 14.002
MIT 4.008 Returns from Inpatient claims Date (2–8 months)
community hospital data Most recent 6 months provided (within date range)
Rx count
Discharge date
Randomize (each month individually)
First 5 inmate-patients from each of the 6 months
(if not 5 in a month, supplement from another, as
(30)
needed)
Health Care Environment
MIT 5.101-111 Clinical areas OIG inspector Identify and inspect all onsite clinical areas.
(14) onsite review
Inter- and Intra-System Transfers
MIT 6.001-003 Intra-system transfers SOMS Arrival date (3–9 months)
Arrived from (another CDCR facility)
Rx count
(30)
Randomize
MIT 6.004 Specialty services MedSATS Date of transfer (3–9 months)
send-outs Randomize
(20)
MIT 6.101 Transfers out OIG inspector R&R IP transfers with medication
(4) onsite review
California Medical Facility, Cycle 4 Medical Inspection Page 98
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Pharmacy and Medication Management
MIT 7.001 Chronic care OIG Q: 1.001 See Access to Care
medication At least one condition per inmate-patient—any risk
level
(40) Randomize
MIT 7.002 New Medication Master Registry Rx count
Orders Randomize
(40) Ensure no duplication of IPs tested in MIT 7.001
MIT 7.003 Returns from OIG Q: 4.008 See Health Information Management (Medical
Community Hospital Records) (returns from community hospital)
(30)
MIT 7.004 RC arrivals – OIG Q: 12.001 See Reception Center Arrivals
medication orders
N/A at this institution
MIT 7.005 Intra-facility moves 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)
(30)
Randomize
MIT 7.006 En Route SOMS Date of transfer (2–8 months)
Sending institution (another CDCR facility)
Randomize
(10) NA/DOT meds
MITs 7.101-103 Medication storage OIG inspector Identify and inspect clinical & med line areas that
areas onsite review store medications
(varies by test)
MITs 7.104–106 Medication OIG inspector Identify and inspect onsite clinical areas that
Preparation and onsite review prepare and administer medications
Administration Areas
(7)
MITs 7.107-110 Pharmacy OIG inspector Identify & inspect all onsite pharmacies
(2) onsite review
MIT 7.111 Medication error Monthly All monthly statistic reports with Level 4 or higher
reporting medication error Select a total of 5 months
(30) reports
MIT 7.999 Isolation unit KOP Onsite active KOP rescue inhalers & nitroglycerin medications
medications medication for IPs housed in isolation units
(3) listing
Prenatal and Post-Delivery Services
MIT 8.001-007 Recent Deliveries OB Roster Delivery date (2–12 months)
N/A at this institution Most recent deliveries (within date range)
Pregnant Arrivals OB Roster Arrival date (2–12 months)
N/A at this institution Earliest arrivals (within date range)
California Medical Facility, Cycle 4 Medical Inspection Page 99
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Preventive Services
MITs 9.001–002 TB medications Maxor Dispense date (past 9 months)
Time period on TB meds (3 months or 12 weeks)
(18) Randomize
MIT 9.003 TB Code 22, annual SOMS Arrival date (at least 1 year prior to inspection)
TST TB Code (22)
(15) Randomize
TB Code 34, annual SOMS Arrival date (at least 1 year prior to inspection)
screening TB Code (34)
(15) Randomize
MIT 9.004 Influenza SOMS Arrival date (at least 1 year prior to inspection)
vaccinations Randomize
(30) Filter out IPs tested in MIT 9.008
MIT 9.005 Colorectal cancer SOMS Arrival date (at least 1 year prior to inspection)
screening Date of birth (51 or older)
(30) Randomize
MIT 9.006 Mammogram SOMS Arrival date (at least 2 yrs prior to inspection)
Date of birth (age 52–74)
N/A at this institution Randomize
MIT 9.007 Pap smear SOMS Arrival date (at least three yrs prior to inspection)
Date of birth (age 24–53)
N/A at this institution Randomize
MIT 9.008 Chronic care OIG Q: 1.001 Chronic care conditions (at least 1 condition per
vaccinations IP—any risk level)
Randomize
(30) Condition must require vaccination(s)
MIT 9.009 Valley fever Cocci transfer Reports from past 2–8 months
(number will vary) status report Institution
Ineligibility date (60 days prior to inspection date)
N/A at this institution
All
California Medical Facility, Cycle 4 Medical Inspection Page 100
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Reception Center Arrivals
MITs 12.001–008 RC SOMS Arrival date (2–8 months)
Arrived from (county jail, return from parole, etc.)
N/A at this institution Randomize
Specialized Medical Housing
MITs 13.001–004 CTC, OHU, Hospice CADDIS Admit date (1–6 months)
Type of stay (no MH beds)
Length of stay (minimum of 5 days)
(20)
Randomize
MIT 13.101 Call buttons OIG inspector Review by location
CTC (all) onsite review
Specialty Services Access
MITs 14.001–002 High-priority MedSATS Approval date (3–9 months)
(15) Randomize
MITs 14.003–004 Routine MedSATS Approval date (3–9 months)
(15) Remove optometry, physical therapy or podiatry
Randomize
MIT 14.005 Specialty services MedSATS Arrived from (other CDCR institution)
arrivals Date of transfer (3–9 months)
(20) Randomize
MIT 14.006-007 Denials InterQual Review date (3–9 months)
(19) Randomize
IUMC/MAR Meeting date (9 months)
Meeting Minutes Denial upheld
(1) Randomize
California Medical Facility, Cycle 4 Medical Inspection Page 101
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator patients) Data Source Filters
Internal Monitoring, Quality Improvement, & Administrative Operations
MIT 15.001 Medical appeals Monthly medical Medical appeals (12 months)
(all) appeals reports
MIT 15.002 Adverse/sentinel Adverse/sentinel Adverse/sentinel events (2–8 months)
events events report
(0)
MITs 15.003–004 QMC Meetings Quality Meeting minutes (12 months)
Management
Committee
(6) meeting minutes
MIT 15.005 Performance Institution PIWP PIWP with updates (12 months)
improvement work Medical initiatives
plans (PIWP)
(11)
MIT 15.006 LGB LGB meeting Quarterly meeting minutes (12 months)
(4) minutes
MIT 15.007 EMRRC EMRRC meeting Monthly meeting minutes (6 months)
(12) minutes
MIT 15.101 Medical emergency Onsite summary Most recent full quarter
response drills reports & Each watch
documentation
(3) for ER drills
MIT 15.102 2nd level medical Onsite list of Medical appeals denied (6 months)
appeals appeals/closed
(10) appeals files
MIT 15.103 Death Reports Institution-list of Most recent 10 deaths
deaths in prior Initial death reports
(5) 12 months
MIT 15.996 Death Review OIG summary Between 35 business days & 12 months prior
Committee log - deaths CCHCS death reviews
(10)
MIT 15.998 Local operating Institution LOPs All LOPs
procedures (LOPs)
(all)
California Medical Facility, Cycle 4 Medical Inspection Page 102
Office of the Inspector General State of California
Sample Category
Quality (number of
Indicator samples) Data Source Filters
Job Performance, Training, Licensing, and Certifications
MIT 16.001 Provider licenses Current provider Review all
listing (at start of
(10) inspection)
MIT 16.101 RN Review Onsite RNs who worked in clinic or emergency setting
Evaluations supervisor six or more days in sampled month
periodic RN Randomize
(5) reviews
MIT 16.102 Nursing Staff Onsite nursing On duty one or more years
Validations education files Nurse administers medications
(10) Randomize
MIT 16.103 Provider Annual OIG Q:16.001 All required performance evaluation documents
Evaluation Packets
(all)
MIT 16.104 Medical Emergency Onsite All staff
Response certification o Providers (ACLS)
Certifications tracking logs o Nursing (BLS/CPR)
(all) o Custody (CPR/BLS)
MIT 16.105 Nursing staff and Onsite tracking All required licenses and certifications
Pharmacist-in-charge system, logs, or
Professional employee files
Licenses and
Certifications
(all)
MIT 16.106 Pharmacy and Onsite listing of All DEA registrations
Providers’ Drug provider DEA
Enforcement Agency registration #s &
(DEA) Registrations pharmacy
registration
(all) document
MIT 16.107 Nursing Staff New Nursing staff New employees (hired within last 12 months)
Employee training logs
Orientations
(all)
California Medical Facility, Cycle 4 Medical Inspection Page 103
Office of the Inspector General State of California
C C
ALIFORNIA ORRECTIONAL
H C S ’
EALTH ARE ERVICES
R
ESPONSE
California Medical Facility, Cycle 4 Medical Inspection Page 104
Office of the Inspector General State of California